20170705Vail Direct - Redacted.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NO.PAC-E-17-07
OF ROCKY MOUNTAIN POWER FOR A )
CERTIFICATE OF PUBLIC )DIRECT TESTIMONY OF
CONVENIENCE AND NECESSITY AND )RICK A.VAIL
BINDING RATEMAKING TREATMENT )REDACTED
FOR NEW WIND AND TRANSMISSION )FACILITIES )
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ROCKY MOUNTAIN POWER
CASE NO.PAC-E-17-07
June 2017
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l Q.Please state your name,business address,and present position with PacifiCorp.
2 A.My name is Rick A.Vail.My business address is 825 NE Multnomah,Suite 1600,
3 Portland,Oregon 97232.My present position is Vice President of Transmission.I am
4 responsible for transmission system planning,customer generator interconnection
5 requests and transmission service requests,regional transmission initiatives,asset
6 management,capital budgeting for transmission,and administration of the Company's
7 Open Access Transmission Tariff ("OATT").I am testifying on behalf of Rocky
8 Mountain Power ("Company").
9 QUALIFICATIONS
10 Q.Please describe your educational backgroundand professional experience.
11 A.I have a Bachelor of Science Degree with Honors in Electrical Engineeringwith a focus
12 in electric power systems from Portland State University.I have been employed at the
13 Company since 2001,and have had a range of management responsibility within the
14 asset management group,including capital planning,maintenance policy,maintenance
15 planning,and investment planning.I served as director of asset management from 2007
16 to 2012.I became Vice President of Transmission in December 2012.
17 PURPOSE AND SUMMARY OF TESTIMONY
18 Q.What is the purpose of your testimony?
19 A.My testimony supports the Company's Application for Certificates of Public
20 Convenience and Necessity ("CPCNs")for the construction or acquisition of four wind
21 facilities in Wyoming ("Wind Projects")totaling approximately 860 megawatts
22 ("MW")and the construction of new transmission facilities that are necessary to relieve
23 existing congestion and enable interconnectionof the proposed Wind Projects into the
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l Company's transmission system.Specifically,my testimony describes the purpose for
2 and customer benefits resulting from the construction of the "Transmission Projects":
3 "Aeolus-to-Bridger/Anticline Line"
4 A 140-mile,500 kilovolt ("kV")transmission line ("Aeolus-to-Anticlineline"),
5 which includes construction of the new Aeolus (500/230 kV)and Anticline
6 (500/345 kV)substations;
7 A five-mile,345 kV transmission line that will extend from the proposed
8 Anticline substation to the Jim Bridger substation,along with associated
9 interconnection facilities at the Jim Bridger substation to accommodate the
10 interconnectionof the 345 kV line from the proposed Anticline substation;
11 A voltagecontrol device at the existing Latham substation.
12 "230 kV Network Upgrades"
13 A new 16-mile 230kV transmission line parallel to an existing 230 kV line from
14 Shirley Basin substation to the proposed Aeolus substation,including
15 modifications to the Shirley Basin substation to accommodate the new line;
16 The reconstruction of four miles of an existing 230 kV transmission line
17 between the proposed Aeolus substation and the Freezeout substation,including
18 modifications of the Freezeout substation to accommodate the new line;and
19 The reconstruction of 14 miles of an existing 230 kV transmission line between
20 the Freezeout substation and the Standpipe substation,including modifications
21 to the Freezeout and Standpipe substations to accommodate the transmission
22 lines.
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1 The reconstructed sections are proposed to be in a parallel alignment to the
2 existing 230 kV transmission line.The 230 kV Network Upgrades are needed to
3 support interconnectionof the Wind Projects,which are described in the testimony of
4 Company witness Mr.Chad A.Teply.
5 My testimony and exhibits provide the information required by Rule 112 of the
6 Idaho Public Utilities Commission's ("Commission")Rules of Procedure ("RP"),
7 related to applications for CPCNs for the Transmission Projects.
8 Q.Please summarize your testimony.
9 A.The Transmission Projects support the Company's short-and long-term energy
10 demands and will strengthen the overall reliability of the existing transmission system.
11 While the Aeolus-to-Bridger/Anticline Line has long been recognized as an integral
12 component of the Company's long-term transmission planning,its construction and
13 that of the other components of the Transmission Projects has not been economic until
14 now.Renewal of the federal wind production tax credits ("PTC")has created a time-
15 limited opportunity for the Company to acquire significant cost-effective,zero-fuel-
16 cost wind resources,generating PTCs that provide cost savings necessary to construct
17 the Transmission Projects.
18 To achieve the full customer benefits of the PTCs,however,the Company
19 must develop the Wind Projects with the Transmission Projects and bring them into
20 service by December 31,2020.The Wind Projects are not economic without the
21 Transmission Projects,which are needed to relieve existing congestion and to
22 interconnect new PTC-eligible wind facilities in high-wind areas of Wyoming.The
23 Transmission Projects are not economic without incremental cost-effective wind
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l facilities producing zero-fuel-cost energy and PTCs.
2 Congestion on the current transmission system in eastern Wyoming limits the
3 ability to deliver energy from eastern Wyoming to the Jim Bridger energy hub.The
4 Aeolus-to-Bridger/Anticline Line will relieve this congestion and increase the
5 transmission capacity across Wyoming by 750 MW.The Transmission Projects will
6 allow the Company to interconnect up to approximately 1,270 MW of wind resources,
7 including the 860 MW of Wind Projects that are the subject of this Application,and
8 create substantial benefits for Idaho customers and customers throughout the
9 Company's service area.Construction of the Transmission Projects will also enable the
10 Company to more efficientlyutilize existing generation resources in Wyoming to serve
11 loads in Idaho,Wyoming,Utah and the Pacific Northwest.The Transmission Projects
12 also better position the Company to interconnect and integrate future resources in
13 southeastern Wyoming and more efficientlyserve expected customer load.
14 In addition to increasing the transmission capacity out of southeastern
15 Wyoming,the Transmission Projects will also provide critical voltage support to the
16 Wyoming transmission network and enhance the overall reliability of the transmission
17 system by adding incremental new transmission capacity westbound between the
18 Company's existing thermal and renewable facilities,the proposed Wind Projects in
19 eastern Wyoming,and other sources of energy in northern Utah.Additional
20 transmission paths will mitigate the impact of outages on the existing system.The
21 Transmission Projects will also enhance the Company's ability to comply with
22 mandated North American Electric Reliability Corporation ("NERC")and Western
23 Electricity Coordinating Council ("WECC")reliabilityand performance standards.
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1 The Aeolus-to-Bridger/Anticline Line is also an important component of the
2 Company's Energy Gateway Transmission Expansion Project ("Energy Gateway")and
3 has long been recognized as a key transmission segment in the region's long-term
4 transmission planning.By acting on this time-limited opportunity to develop the
5 Transmission Projects and the associated Wind Projects,the Company can provide
6 substantial customer benefits.
7 GENERAL DESCRIPTION OF THE TRANSMISSION PROJECTS
8 Q.Please describe the Aeolus-to-Anticline line.
9 A.The proposed Aeolus-to-Anticline line is a single-circuit 500 kV line that will begin at
10 the proposed Aeolus substation,which will be located approximately 11 miles
11 northwest of Medicine Bow,Wyoming.From the Aeolus substation,the transmission
12 line will run west across the Medicine Bow River past the Hanna Draw.The line willO13thencontinuesouthwesterlytoWalcottJunctionandthenwestacrossthePlatteRiver
14 and south of Sinclair and Rawlins,where it will then largely follow an existing 230 kV
15 transmission line to the proposed Anticline substation.
16 From the proposed Anticline substation,the Company will construct a 345 kV
17 transmission line that will extend north for approximately five miles and terminate into
18 an expansion of the existing Jim Bridger generating plant substation.
19 The Aeolus-to-Anticline line will be located in Sweetwater and Carbon
20 Counties and will primarilycross open rangeland.Approximately 49 percent of the land
21 crossed is federally owned,seven percent state owned,and nearly 44 percent privately
22 owned.
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l Attached as Exhibit No.4 is a map showing the proposed route for the Aeolus-
2 to-Anticline line,along with the other facilities included in the Transmission Projects.
3 Q.What types of towers and conductors will be used to construct the Aeolus-to-
4 Anticline line?
5 A.The Aeolus-to-Anticline line segment will be constructed using approximately 522
6 lattice steel towers with heights about 115 to 160 feet.The steel towers will have a
7 "flat"configuration with each phase being parallel to each other in a horizontal
8 arrangement.Attached to my testimony as Exhibit No.5 is a sample drawing of
9 proposed 500 kV tower designs.
10 The conductor for the Aeolus-to-Anticline line will be triple bundled 1272
ll kemil 45/7 Aluminum Conductor Steel Reinforced ("ACSR")"Bittern"per phase.
12 Each conductor in the phase bundle will have a diameter of 1.345 inches,with three
13 phases,comprised of three conductors each,for a total of nine conductors in the circuit.
14 The 345 kV Anticline-to-Jim Bridger line segment will use 25 to 30 of either of
15 the following types of structures:(1)tubular steel H-frames;or (2)poles with heights
16 from about 110 to 150 feet.Attached to my testimony as Exhibit No.6 is a sample
17 drawing of proposed 345 kV tower designs.The conductor for this segment will also
18 be triple bundled 1272 kemil 45/7 ACSR Bittern per phase.The steel poles will have
19 two arms on one side,with one arm on the other side to carry one phase per arm.
20 In addition,each of the transmission line segments will also carry two overhead
21 ground wires.One of the wires will be galvanized steel while the other will be Optical
22 Ground Wire ("OPGW")to facilitate communications.Each wire will have a diameter
23 of approximately 0.5 inches.
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l Q.Please describe the proposed new Aeolus substation.
2 A.The new Aeolus 500/230 kV substation will be located approximately 11 miles
3 northwest of Medicine Bow,Wyoming,and will be sited on a Company-owned parcel
4 of land (Township 24 North,Range 80 West,Section 35)and occupy approximately
5 100 acres.The substation will include security fencing and an improved access road
6 from U.S.Highway 30.The substation will be constructed using conventional air
7 insulated bus and equipment and connect to existing Shirley Basin and Freezeout
8 substations via the connection of an existing 230 kV transmission line into the new
9 Aeolus site (discussed in more detail below).Attached to my testimony as Exhibit No.
10 7 are the preliminary Aeolus substation one-line diagram and general arrangement
11 drawings.
12 Construction of the Aeolus substation will require the following:
13 Construction of a 230 kV yard,including all work to support the
14 installation of 230 kV breaker bays for termination of the existing
15 Freezeout-to-ShirleyBasin 230 kV transmission line and to support the
16 low side of the 500/230 kV transformer;
17 Installation of a 230 kV shunt reactor;
18 Completion of all site development,civil work,bus work,protection
19 and controls,security and communications,and construction of a
20 control building;
21 Construction of a 500 kV yard including all work to support the
22 termination of one 500 kV transmission line to Anticline substation,
23 including two 500 kV breaker bays to support termination of the 500 kV
24 line and connection to the high side of a 500/230 kV transformer;
25 Installation of three single phase 500/230 kV transformer units with one
26 additional spare unit;
27 Installation of one 500 kV shunt capacitor,three single phase line
28 reactors and one 500 kV neutral reactor;
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1 Construction of a replacement access bridge over the Medicine Bow
2 River and associated upgrades to an existing unpaved county road from
3 U.S.Highway 30 to the substation location.The bridge will be
4 constructed to Wyoming Department of Transportation HS-20
5 ("Highway Semi-trailer")specifications.Upon completion,the bridge
6 will become the property and responsibility of Carbon County;
7 Completion of all site development,civil work,bus work,protection
8 and controls,security,communications,and construction of a control
9 building including site emergency power;and
10 Implementation of a new generation tripping remedial action scheme,
11 which would trip generation in the Foote Creek/Aeolusarea in the event
12 the Aeolus-to-Jim Bridger lines (or transformers)trip during high
13 transfers on the Aeolus West transmission path.Initial technical studies
14 indicate tripping up to approximately 660 MW of generation at the
15 following wind farms during high-transferconditions:
16 Foote Creek:108 MW
17 Carbon County 1 (Q706):250 MW
18 High Plains/McFadden Ridge 1:245 MW
19 Seven Mile I and II:53 MW.
20 Specific remedial action scheme arming levels for lower flow
21 conditions will need to be determined via follow-on technical studies.
22 In addition,the Aeolus substation will be designed to facilitate future expansion of
23 the site for additional resources.
24 Q.Please describe the proposed new Anticline substation.
25 A.The new Anticline 500/345 kV substation will be located approximately three miles
26 northeast of Point of Rocks,Wyoming and will be sited on a Company-owned parcel
27 of land (T20N,Rl00W,Sec.13)and occupy approximately 140 acres.The new
28 substation will include security fencing and an improved access road and will be
29 constructed using conventional air insulated bus and equipment.The Anticline
30 substation will connect to the existing Jim Bridger generating plant substation via a
31 new 345 kV transmission line (discussed above)and can be expanded to accommodate
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l future 500 kV transmission lines.Attached to my testimony as Exhibit No.8 are the
2 preliminary Anticline substation one-line diagram and general arrangement drawings.
3 Construction of the Anticline substation will require the following:
4 Construction of the new 500 kV substation yard including all work to
5 support the termination of one 500 kV transmission line to the Aeolus
6 substation;
7 Construction of two 500 kV breaker bays to support termination of the
8 500 kV line and connection to the high side of a 500/345 kV
9 transformer;
10 Installation of three single phase 500/345 kV transformer units with one
11 additional spare unit;
12 Installation of one 500 kV shunt capacitor,three single phase line
13 reactors and one 500 kV neutral reactor;
14 Construction of a 345 kV yard which includes a ring bus and 345 kV
15 breakers to facilitate 345 kV line termination to Jim Bridger and future
16 installation of phase shifting transformers;and
17 Completion of all site development,civil work,bus work,protection
18 and controls,security and communications,and construction of a
19 control building including site emergency power.
20 Q.Please describe the modifications to the Jim Bridger generating plant substation
21 that will be necessary to interconnect the new Anticline substation to the Jim
22 Bridger generating plantsubstation.
23 A.The new Anticline substation will interconnect to the Jim Bridger substation via a new,
24 five-mile,345 kV transmission line (discussed above).The Jim Bridger substation is
25 located west of,and immediately adjacent to,the Jim Bridger power plant.To
26 accommodate the interconnection of the Anticline substation,the Jim Bridger
27 substation will be expanded to include an additional transmission line termination bay.
28 Attached to my testimony as Confidential Exhibit No.9 are the preliminary Jim Bridger
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l substation one-line diagram and general arrangement drawings related to the
2 construction at the Jim Bridger substation,which will include the following:
3 Expanding the existing 345 kV substation yard to add one new 345 kV
4 line termination bay to the existing yard;
5 Relocating the existing shunt capacitor to facilitate connection of a new
6 line termination bay to the existing 345 kV bus;
7 Completion of all site development,civil work,bus work,protection
8 and controls,security and communications;
9 Modification to the Jim Bridger remedial action scheme will be needed
10 due to the re-dispatch of Jim Bridger generation necessary to
11 accommodate new wind generation in eastern Wyoming,while
12 maintaining the 2,400 MW rating on the Bridger West transmission
13 path;and
14 Modification of existing protection and control systems within the
15 existing 345 kV yard to enable safe operation of the expanded facility.
16 In addition,the existing Latham substation,located approximately four miles
17 south of Interstate Exit 187,adjacent to Wyoming Highway 789,will be expanded to
18 include a voltage control device.The type and design of the device will be defined
19 pending completionof future technical studies.The Company plans to install the device
20 within the constraints of the currently-leased property boundaries.Attached to my
21 testimony as Confidential Exhibit No.10 are the existing Latham substation one-line
22 diagram and general arrangement drawings.The substations will be modified once final
23 design details of the voltage control device are determined.
24 Q.Please describe the 230 kV transmission line from the Shirley Basin substation to
25 the Standpipe substation.
26 A.The proposed 230 kV transmission line projects will begin at the Company's existing
27 Shirley Basin substation,located approximately 1.5 miles east of the south junctionof
28 state highways 77 and 487.A new 230 kV line will parallel an existing 230 kV
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l transmission line running southwesterly along the western side of the Freezeout
2 Mountains and will connect into the Aeolus substation.South of Aeolus substation to
3 Standpipe substation,via the Freezeout substation,the 230 kV project is a
4 reconstruction of the existing 230 kV line.The line continues south out of the Aeolus
5 substation across the Medicine Bow River and connects into the Company's existing
6 Freezeout substation located between the Pine and South Pine Draws.The 230 kV line
7 then continues in a southwesterly direction to the Company's existing Standpipe
8 substation,which is located approximatelytwo-and-one-halfmiles southeast of Hanna,
9 Wyoming.
10 All of the 230 kV segments are located in Carbon County and the new line will
11 cross areas of mountainous terrain reaching elevations of approximately 7,500 feet.
O 12 Attachedto my testimony as Confidential Exhibit No.11 are the existing Shirley Basin,
13 Freezeout and Standpipe substations one-line diagrams and general arrangement
14 drawings.These substations may be modified to accommodate the 230 kV transmission
15 line project.Final drawings will be provided when they become available.
16 Q.What types of towers and conductors will be used for the 230 kV transmission
17 line?
18 A.The single circuit 230 kV transmission line will be rebuilt using either wood or steel
19 H-frame structures with heights ranging from 90 to 120 feet.Attachedto my testimony
20 as Exhibit No.12 is a sample drawing of proposed 230 kV tower designs.The
21 conductor for the section north of the Aeolus substation to the Shirley Basin substation
22 will be double bundled 1575 kemil ACSR/TW "Potomac"per phase.The conductor for
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l the section south of the Aeolus substation will be double bundled 1272 kemil 45/7
2 ACSR Bittern per phase.
3 Q.Please describe the estimated total cost of the Transmission Projects.
4 A.The Aeolus-to-Bridger/Anticline Line is estimated to cost ,as
5 summarized in Confidential Table 1 below:
Confidential Table 1
6 The entire cost of the Aeolus-to-Bridger/Anticline Line will be paid by theO7Companywithoutcontributionfromanythird-party customer projects.
8 The 230 kV Network Upgrades are estimated to cost -as
9 summarized in Confidential Table 2 below:
Confidential Table 2
10 The Company expects that the costs of the 230 kV Network Upgrades will be
11 re-assessed and assigned to the wind resource facilities selected via the Company's
12 2017R request for proposals ("RFP")process under their respective interconnection
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l agreements.The 230 kV Network Upgrades and are necessary to support the
2 interconnectionof up to 1,270 MW of new or repowered wind generation in eastern
3 Wyoming.
4 Q.When does the Company expect to complete the construction of the Transmission
5 Projects?
6 A.The Transmission Projects are being developed together with the Wind Projects,which
7 will generate zero-fuel-cost energy and PTCs that make the codependent projects
8 economic.To obtain the full benefits of the PTCs,the Transmission Projects and the
9 Wind Projects must be in service no later than December 31,2020.
10 Q.Why must the Company receive a CPCN now for a project that is not scheduled
ll for completion until December 2020?
12 A.The Company does not currentlyhave all of the necessary rights-of-way to construct
13 the Transmission Projects.To achieve an in-service date before the end of 2020,the
14 Company must acquire the necessary rights-of-way by March 31,2019.The Company
15 must obtain a CPCN from the Commission under the schedule it has proposed in the
16 Application to meet this schedule.A delay in approval of the CPCN jeopardizes the
17 December 31,2020 deadline and risks the loss of PTC benefits-which will mean that
18 neither the Transmission Projects nor the Wind Projects will move forward.A project
19 critical path schedule is attached to my testimony as Exhibit No.13.
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l BENEFITS OF THE TRANSMISSION PROJECTS
2 Q.How will the Transmission Projects benefit customers and improve system
3 performance?
4 A.The Transmission Projects will:(1)relieve congestion and increase transmission
5 capacity across Wyoming,allowing interconnection of new generation resources and
6 greater flexibilityin managing existing resources;(2)provide critical voltage support
7 to the transmission system;(3)improve system reliability;and (4)reduce energy and
8 capacity losses.Because the cost of the Transmission Projects are substantially offset
9 by the generation of zero-fuel-cost energy and PTCs from the Wind Projects,customers
10 receive substantial benefits as quantified by Mr.Link.
ll Q.How will the Transmission Projects increase transmission capacity in
12 southeastern Wyoming?
13 A.Currently,the Company's transmission system in southeastern Wyoming is operating
14 at capacity,which limits transfer of existing resources from eastern Wyoming.Also,
15 due to limited fault current in the southeastern portion of the transmission system,
16 which indicates a weak grid,interconnectionof additionalresources in this prime wind
17 region is precluded to maintain grid stability.The Transmission Projects will not only
18 increase the transfer capability from east to west by 750 MW,but will also improve the
19 fault current providing "stiffness"to the grid.This will allow additional wind facilities
20 in and around the proposed Aeolus substation,which is not possible today.
21 When the Transmission Projects are complete,the Company estimates that it
22 can interconnect up to approximately 1,270 MW of additional wind facilities east of
23 the Bridger/Anticline substation.The assumed level of new wind resources is higher
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l than the assumed incremental transfer capability of the transmission facilities because
2 wind resources do not generate at their full capability in all hours of the year.At times
3 when wind resources in southeastern Wyoming are operating near full output,other
4 resources in the area can be re-dispatched to accommodate PTC-producing wind
5 generation.Installingmore variable resources in an area relative to total transmission
6 capacity allows for more ef5cient use of the transmission system and the ability to use
7 the most cost-effective resources to meet customer demand.
8 The increased capacity also provides improved access to existing generation
9 resources,and increased opportunities to move incremental energy from Wyoming to
10 offset higher-priced generation in the PacifiCorp system or other energy imbalance
11 market participants'systems,as noted by Mr.Link.
12 Q.Is the increased capacity from the Transmission Projects consistent with the
13 Company's obligation to provide transmission service under its OATT?
14 A.Yes.The Company's OATT,approved by the Federal Energy Regulatory Commission
15 ("FERC"),details the Company's requirements and obligationsto provide transmission
16 service.Section 28.2 defines the Company's responsibilities,which include the
17 requirement to "plan,construct,operate and maintain the system in accordance with
18 good utility practice."Section 28.3 states the requirement for the Company to provide
19 "firm service over the system so that designated resources can be delivered to
20 designated loads."The Company is required to provide adequate and non-
21 discriminatory service to all network customers.Although the Transmission Projects
22 are not specifically mandated by the Company's obligations under its OATT,the
23 Transmission Projects will allow the Company to more efficiently meet current and
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l forecasted customer energy demand by relieving the existing transmission congestion
2 in southeastern Wyoming.
3 Q.Will the up-front transmission costs of the Transmission Projects be recovered in
4 PacifiCorp's transmission rates?
5 A.Yes,the Transmission Projects are considered network transmission assets under
6 PacifiCorp's OATT and provide a number of benefits to the transmission grid,as
7 discussed earlier in my testimony.Because the Transmission Projects are integrated
8 into PacifiCorp's transmission network and provide benefits to that network,such as
9 congestion relief,increased transmission capacity and improved system reliability,
10 FERC precedent for ratemaking supports rolling the costs of these assets into
11 PacifiCorp's transmission rates.
12 Q.How will the costs of the Transmission Projects flow into PacifxCorp's
13 transmission rates,and who will pay these rates?
14 A.All transmission rates charged to wholesale transmission customers must be approved
15 by FERC.PacifiCorp's transmission rate structure is a FERC-approved formula that
16 has been in place since 2012.A formula rate is a method of calculating a rate,but is not
17 the rate itself;the actual transmission rate that is charged to wholesale transmission
18 customers is produced annually by updatingFERC-approved inputs to the formula rate.
19 Formula rates rely on annual updates using inputs from the detailed,publiclyavailable,
20 and audited FERC Form No.1,along with other Company data.The annual update
21 process includes transmission capital additions such as the Transmission Projects.
22 PacifiCorp's merchant function is the largest transmission customer of
23 PacifiCorp's transmission system,but there are third-party transmission customers as
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l well.While all transmission customers pay OATT transmission rates,third-party
2 transmission customers generate revenue credits that offset the cost of PacifiCorp's
3 transmission revenue requirement in retail rates,as discussed in Mr.Link's testimony.
4 Q.What are the benefits resulting from the critical voltage support that will be
5 provided by the Transmission Projects?
6 A.Under certain operating conditions,voltage control issues have limited the ability to
7 add additional resources,particularlywind facilities,in southeastern Wyoming.The
8 Transmission Projects will solve the voltage control issues and allow up to 1270 MW
9 of additional wind generation to be interconnected into the transmission system.
10 Q.How will the Transmission Projects improve system reliability?
11 A.The transmission grid can be affected in its entirety by what happens on an individual
12 transmission line or path.For example,the transmission system between eastern and
13 central Wyoming is comprised of several individual transmission lines or line
14 segments.Attached to my testimony as Exhibit No.14 is a diagram of the existing
15 Wyoming transmission system.A single outage on any of the individual lines or line
16 segments due to storm,fire,or other interference can and does cause significant
17 reductions in transmission capacity and can negatively impact the Company's ability
18 to serve customers.Line outages require the Company to significantly curtail
19 generation resources to stabilize system voltages and require less efficient re-dispatch
20 of system resources to meet network load requirements.
21 In the event of a line outage,the redundancy provided by the Transmission
22 Projects will allow the Company to continue to meet native load service obligations
23 and continue to meet other contractual obligations to third parties.Strengthening this
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1 path and increasing system redundancy with the new Transmission Projects will benefit
2 all customers by reducing the risk of outages and inefficient dispatch resulting from
3 those outages.
4 In addition,the Transmission Projects will improve the Company's ability to
5 perform required maintenance without significant operational impacts to the system,
6 and will reduce impacts to customers during planned and forced system outages.
7 Transmission line and substation maintenance windows are currentlylimited because
8 the system is highly utilized.By relieving congestion and providing additional
9 transmission paths,the Transmission Projects will allow greater flexibility for the
10 Company.
11 Q.Can you provide an example where the Transmission Projects will mitigate the
12 impact of an outage on the 230 kV transmission system?
13 A.Yes.The following are examples of potential outages that will be mitigated by the
14 Transmission Projects:
15 For an outage of the Latham-to-Point of Rocks 230 kV line,the Project
16 eliminates the overload on the Dave Johnston to Amasa 230 kV line;
17 For an outage of the Mustang-to-Spence 230 kV line,the Project
18 eliminates the overload on 230 kV lines west of Platte;
19 For an outage of the Riverton-to-Wyopo 230 kV line,the Project
20 eliminates overloads on 230 kV lines west of Platte;
21 For an outage of the Dave Johnston-to-Amasa 230 kV line,the Project
22 eliminates the overload on the 230 kV lines west of Platte;and
23 For an outage of the Platte-to-Standpipe 230 kV line,the Project
24 eliminates the need to trip approximately 130 MW of generation at
25 Foote Creek.
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l Q.Will the Transmission Projects also enhance the Company's ability to meet the
2 reliabilitystandards applicable to its transmission system?
3 A.Yes.Although the Company currently meets or exceeds the applicable reliability
4 standards and criteria,the addition of the Transmission Projects will allow the
5 Company to more efficientlymeet or exceed those standards and criteria.
6 Q.Please describe the applicable reliabilitystandards.
7 A.The Company plans,designs,and operates its transmission system to meet or exceed
8 NERC Standards for Bulk Electric Systems ("BES")and WECC Regional standards
9 and criteria.The NERC standards are set forth in 18 CFR Part 40 (Mandatory
10 Reliability Standards for Bulk-Power Systems).The WECC standards and criteria are
11 deemed necessary for the Western Interconnectionto meet or exceed NERC standards.
12 The Company must currently comply with more than 100 approved NERC standards.
13 These standards dictate the minimum levels of transmission system reliability,
14 redundancy,and performance required for transmission facilities.
15 The most relevant standard here is NERC's Transmission Planning
16 Performance Requirements set forth in NERC TPL-001-4,which establishes
17 transmission system planning performance requirements intended to ensure that the
18 BES will operate reliably over a broad spectrum of system conditions and followinga
19 wide range of probablecontingencies.
20 Q.How do NERC's and WECC's standards and criteria influence the need for the
21 Transmission Projects?
22 A.The mandatory standards,particularly,NERC's TPL-001-4 standard,require the
23 Company to have a forward-looking transmission plan to reliably serve current and
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l anticipated customer demands under all expected operating conditions,including
2 normal system operations (all system elements in service)and during system
3 contingencies (where elements of the transmission system are out of service),both
4 planned or otherwise.
5 The Company performs annual reliability assessments to determine whether its
6 transmission system complies with minimum mandatory system performance
7 standards,which require that during loss of any single transmission system element
8 ("N-1 single contingencies")that firm service is maintained,no system overloads exist,
9 and there is no loss of customer demand.
10 The Aeolus-to-Anticline line is sub-segment D.2 of Gateway West,which,as
11 part of Energy Gateway,has been included in the Company's annual TPL-00l-4
12 assessment as part of its short-and long-term plans to dependably meet NERC and
13 WECC reliability requirements.The Transmission Projects'new transmission
14 segments are particularly effective in increasing system reliability under the various
15 multiplecontingency categories of the TPL-001-4 standard.
16 Q.Can you explain the TPL-001-4 standard?
17 A.Yes.The NERC Standard TPL-001-4 requires the Company to plan for a scenario with
18 outages of multiple transmission elements.The Company must plan how it will adjust
19 the transmission system after the first outage and then respond to the second outage
20 (this type of scenario is referred to as an N-1-1 condition).The Aeolus-to-Anticline line
21 will significantly help under these types of N-1-1 conditions.For example,without the
22 Aeolus-to-Anticline line,the N-1-1 outage of Riverton to Wyopo 230 kV line followed
23 with an outage of Spence to Mustang 230 kV line would require curtailment of the
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1 TOT 4A path by approximately 500 MW.But with the addition of the Aeolus-to-
2 Anticline line,this curtailment would not be required.The study was performed with
3 TOT 4A flows at 1,030 MW in the original case.The addition of the Aeolus-to-
4 Anticline line prevents thermal overload on the 230 kV transmission system west of
5 Platte.
6 Q.What are the WECC path rating studies?
7 A.The WECC path rating studies follow a three-phase process established by the Planning
8 Coordination Committee ("PCC")that utilizes peer review study groups,made up of
9 the project sponsor and other interested WECC members,to establish a path rating for
10 a given transmission path or set of transmission paths,which may exhibit simultaneous
11 interactions with each other.Path rating studies utilize a transmission model of the
12 Western Interconnectionand will take multiple months to evaluate the performance of
13 the new transmission facilities and to demonstrate that the proposed transmission
14 project will have no negative impacts on previously established transmission path
15 ratings.The path ratings that are established following this process represent the
16 "Maximum Path Transfer Capability"of a transmission path.
17 Once projects complete the second phase of the path rating studies,they are
18 granted an "Accepted"rating and placed in Phase 3 (construction phase)status.After
19 the Accepted status is granted,other projects currentlygoing through the WECC path
20 rating process must recognize the project in their studies and cannot negatively impact
21 the path rating for the project.
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l Q.Has the Aeolus-to-Anticline line been included in WECC path rating studies?
2 A.Yes.The Aeolus-to-Anticline line has undergone WECC's Three Phase Ratings
3 Process,and has been approved by WECC for Phase 3 Construction Phase status as
4 part of the overall Energy Gateway project.The Aeolus West transmission path and
5 three other Gateway West transmission paths (TOT 4A,Bridger/Anticline West,and
6 Path C)have completed the Three Phase Rating Process and were granted Phase 3
7 status on January 5,2011.This WECC approval is necessary because it allows the
8 Company to interconnect the Aeolus-to-Anticline line to the wider transmission system
9 in the area and to reliably operate the project at its approved ratings.This line will
10 strengthen the Company's transmission capacity and flexibility,especially when
11 complemented with other Energy Gateway projects,specifically Anticline-to-Populus,
12 Aeolus-to-Clover and Oquirrh-to-Terminal.The Aeolus-to-Anticline line is regarded as
13 a necessary interconnection point to support the long-term transmission expansion
14 planning established in the WECC Region plans and in the most recent Northern Tier
15 Transmission Group sub-regional plan.The construction of this project,as an integral
16 component of the larger Energy Gateway project,provides options to access additional
17 resources.
18 Q What are the impacts to the system and the Company if the Transmission Projects
19 are not completed?
20 A.If the projects are not completed,the existing congestion will remain and the
21 Company's ability to deliver resources to load will remain constrained.Because the
22 Company currently meets all applicablesystem reliabilityand performance criteria,the
23 Transmission Projects are not strictly required to satisfy those standards.Rather,the
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l Transmission Projects have long been identified as an important addition to Wyoming's
2 transmission system,and the zero-fuel-cost energy and PTCs generated by the
3 incremental wind resources provide a time-limited opportunity to build the projects
4 now and deliver significant savings to customers over the projects'life.
5 Q.How will the Transmission Projects reduce energy and capacity losses?
6 A.Reduced energy and capacity losses on the transmission system have the potential to
7 provide significant cost savings over time.Generally,the addition of a new
8 transmission path in parallel with existing lines,like the Transmission Projects,will
9 reduce the energy and capacity losses by reducing the impedance of the transmission
10 system.Reduced line losses mean more efficient delivery of energy and capacity at
11 reduced costs.
12 Q.Did the Company consider alternatives to the Transmission Projects?
13 A.Yes.While long-term alternatives to constructing a new transmission line are limited,
14 the Company did consider other approaches,but none were as cost-effective.As
15 described more fully in the testimony of Mr.Link,the Transmission Projects and Wind
16 Projects were included in the Company's 2017 Integrated Resource Plan,where they
17 were analyzed in comparison to alternatives.The resource portfolios that included the
18 Transmission Projects and Wind Projects were consistently least cost,least risk.
19 Q.Has the Company considered any other alternatives to the Transmission Projects?
20 The Company also considered the ability to obtain additionaltransmission capacity by
21 upgrading the existing transmission system or implementing alternative transmission
22 technologies.Since 2013 the Company has completed several important projects to
23 enhance the transmission system in southeast Wyoming,including the dynamic line
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l rating of the Miners (Standpipe)-Platte 230 kV line (2013),Southern Wyoming Voltage
2 Control Scheme,which coordinated wind generation reactive output to stabilize local
3 area voltages (2015),and construction of the Standpipe substation and (60 MVAr)
4 synchronous condenser for voltage control (2016).These projects allowed the
5 Company to delay the Transmission Projects until 2020,but are not a long-term
6 substitute for the Transmission Projects.
7 REQUIREMENTSOF RP 112
8 Q.Please summarize how the Company's Application meets the requirements for a
9 CPCN application.
10 A.RP 112 describes what must be included in an application for a CPCN.I have
11 incorporated exhibits to my testimony that include the required information for the
12 Transmission Projects.
13 Q.What is required by RP 112(1)?
14 A.This section of the rule requires a statement or prepared testimony and exhibits
15 explaining why the Transmission Projects are in the public convenience and necessity.
16 The Company's testimony and exhibits as a whole address this requirement.
17 Q.Have you provided the description of the Transmission Projects required by RP
18 112(2)?
19 A.Yes.In addition to the description included in the introductory sections of my
20 testimony,Exhibits Nos.5,6,7,8,12 and Confidential Exhibits Nos.9,10 and 11
21 provide engineering specifications,drawings,and other pertinenttechnical information
22 for the Transmission Projects.
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l Q.Have you provided a map of the Transmission Projects required by RP 112(3)?
2 A.Yes.The Transmission Projects will be sited entirely in Wyoming's Carbon and
3 Sweetwater counties and the terrain is primarily open rangeland.The map attached as
4 Exhibit No.4 describes the proposed route for the transmission lines and the proposed
5 locations for the associated substations.Cadastral surveying (which is a field survey
6 that establishes or re-establishes legal property boundaries)for all transmission lines
7 and associated access roads is in progress,so metes and bounds descriptions are not
8 available at this time.The Company will provide the results of the surveys once they
9 are complete.The attached Confidential Exhibit No.15 provides the Transmission
10 Projects'sections on federal lands and the Transmission Projects'sections on private
11 and state lands.
12 Q.Have you also prepared a geological report of the proposed sites of the
13 Transmission Projects?
14 A.Yes.As part of the federal permitting process for the Energy Gateway project,the
15 Company conducted a two-year geotechnical exploration and geologic hazards
16 assessment.For the Aeolus-to-Bridger/Anticline Line,the geotechnical exploration
17 program consisted of advancing 44 borings,collection of soil samples for laboratory
18 testing,lab testing and determination of soil properties,and reporting for use in the
19 foundation design.The Company intends to advance an additional 44 borings to further
20 inform the foundation design.During the same period,the Company conducted
21 surficial geology and geologic hazard reconnaissance.Recommendations regarding
22 noted geologic hazards were published in reports for all segments of the Aeolus-to-
23 Bridger/Anticline Line.The geological reports are included in Exhibit No.16.The
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l work is also generally applicable to the balance of the Transmission Projects and will
2 be validated as such.
3 The geotechnical engineering studies concluded that all tower sites were
4 suitable for drilled pier foundations as planned,as long as the recommended values for
5 soil engineering properties are used in the design and consideration is given to potential
6 excavationdifficulties during construction.
7 A geotechnical study consistent in scope and technical approach to that
8 described above and as contained within Exhibit No.16 will be performed for the
9 230 kV Network Upgrades.
10 Shallow groundwater is not likely to pose a significant constraint on the
11 Transmission Projects,but could complicate foundation drilling and construction.
12 Areas where annual or seasonal groundwater depths are less than 10 feet below the
13 ground surface are considered high risk.Geologichazard reconnaissance confirms high
14 ground water in only few isolated locations.
15 Operating mineral deposits are provided in Exhibit No.17 and a topographical
16 map showing the substation locations and right-ofway overlay is included in Exhibit
17 No.18.
18 Q.RP112(4)requires information on how the Transmission Projects will be financed.
19 Where is that information in the Company's Application?
20 A.The testimony of Cindy Crane explains how the Company intends to fund the
21 investment in the Transmission Projects.
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l Q.RP 112(4)also requires information on construction timelines.Can you provide
2 these timelines and additional information on the status of the Transmission
3 Projects?
4 A.Yes.To meet the December 2020 deadline,the Company expects to execute contracts
5 for the upgrades to access roads and the bridge to the Aeolus substation site by
6 September 2017 and construction on those components is expected to begin in May
7 2018 for completion by November 2018.
8 The Company expects to provide a limited notice-to-proceed for the Aeolus-to-
9 Anticline line and 230 kV transmission lines by the end of 2018,so the Company can
10 acquire the necessary rights-of-way by March 31,2019.The final notice-to-proceed for
11 the transmission facilities is expected to be issued by April 1,2019,so construction can
12 begin.
13 The Company expects the transmission facilities to become commercially
14 operationalby October 31,2020.
15 A project critical-path schedule is attached to my testimony as Exhibit No.13.
16 Q.Has the Company entered into a binding contract for design and construction of
17 the Transmission Projects?
18 A.No.The Company has engaged the services of an owner's engineer to provide
19 engineering and design services for the Transmission Projects scope of work.The final
20 designs will be performed by the engineer,procurement and construction ("EPC")
21 contractor(s)selected via competitive market solicitation.
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l Q.Are there additional technical studies that are necessary before the Transmission
2 Projects are completed?
3 A.Yes.While many technical studies have been completed to date,a number of technical
4 studies will need to be performed to assure that the completed projects will meet all
5 national standards for engineering,reliability and system operations,specifically:
6 Substation and Line Design Studies;
7 Static VAr Compensator Design Studies;
8 Jim Bridger -Subsynchronous Resonance ("SSR")Analysis Studies
9 and SSR Mitigation Analysis;
10 Dynamic Voltage Control Analysis;
11 Remedial Action Scheme (Bridger/Aeolus)Studies;
12 FAC-013-2 Assessment of Transfer Capability for the Near-Term
13 Transmission Planning Horizon Studies;and
14 System Operating Limit Studies.
15 These technical studies will be completed in phases as required to support the
16 design during the engineering phase of the Transmission Projects.All studies will be
17 completed by late 2018.Near-term planning and operationalstudies will be completed
18 in the middle of 2020,in preparation for the Transmission Projects being placed in
19 service by October 31,2020.
20 Q.Please describe how the Company plans to address environmental issue associated
21 with the Transmission Projects.
22 A.The Company has conducted a thoroughassessment of the impacts of the Transmission
23 Projects on the surrounding environment and resources.Much of this assessment
24 occurred as part of the permitting process required by National Environmental Policy
25 Act ("NEPA")because portions of the Transmission Projects will be sited on federal
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l land.For the 230 kV line section between Aeolus and Standpipe substations,the route
2 was analyzed for impacts as an alternative under the Gateway South project.The
3 Company and Bureau of Land Management ("BLM")are currentlyevaluating any
4 requirements necessary to complete the impacts assessment.
5 In addition to requirements developed via the NEPA process,the Company will
6 also ensure compliance with the Company Avian Protection Plan and other Company
7 Standards.
8 Q.Please describe the NEPA process.
9 A.In December 2008,the Company filed a right-of-waypermit application with the BLM
10 and the U.S.Forest Service,which triggered the need for BLM to prepare an
11 Environmental Impact Statement ("EIS")in accordance with the requirements of
12 NEPA.The draft EIS was released for public comment on July 29,2011,and the Final
13 EIS was published on April 26,2013.The Record of Decision was released on
14 November 14,2013.
15 The BLM used the followingcriteria to select the authorized route:
16 Allow for reasonable construction costs associated with the preferred
17 route;
18 Route on public land where practical;
19 Avoid cultural and natural resource areas;
20 Avoid sensitive species habitat,including bald eagle nests and big game
21 winter range;
22 Follow existing corridors or linear structures;
23 Avoid Visual Resource Management Class II areas;
24 Avoid designated areas such as National Monuments,Wilderness Study
25 Areas,National Landscape Conservation System areas and State and
26 local parks;and
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O 1 Avoid BLM-identified preliminary priority sage-grouse habitat and
2 Wyoming core habitat areas.
3 The assessment that supported BLM's EIS analyzed the impact of construction,
4 ongoing operation and maintenance,and decommissioning and reclamation of the
5 Aeolus-to-Bridger/Anticline Line.The assessment considered the cumulative effects of
6 the proposed Transmission Projects,together with past,present,and reasonably
7 foreseeable future actions,and addressed the following:
8 Cultural resources,such as prehistoric or historic archaeological sites,
9 districts,buildings,historic trails,roads,and landscapes;
10 Vegetation communities,including the potential impact of invasive
11 plant species due to the construction process;
12 Wetlands and riparian areas;
13 Wildlife and fish,including big game,small mammals,reptiles,
14 amphibians,migratory birds and raptors;
15 Special status species,including those listed under the federal
16 Endangered Species Act ("ESA"),those proposed for federal listing as
17 well as candidates under the ESA,BLM,or Forest Service Sensitive
18 species,Forest Service Management Indicator Species,and State
19 Heritage Program plant species of concern;
20 Soils,include clearing,grubbing,and grading along the rights-ofway
21 and at additional temporary workspaces;trenching;backfilling;
22 excavating;and construction of permanent structures,such as
23 transmission line structures,access and service roads,co-generation
24 sites,and substations;
25 Paleontologicalresources;
26 Water resources;
27 Agriculturalresources;
28 Air quality;and
29 Noise.
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l Based on that analysis,the BLM and cooperating agencies concluded that for
2 many resources,the effects of the Transmission Projects,coupled with the effects of
3 other known projects,will not be substantial.To the extent that resources may be
4 impacted,the Company has proposed reasonable mitigation efforts to minimize the
5 impact.
6 Q.What impact assessment studies have been performed?
7 A.The studies related to the impact assessment are included in BLM's Record and
8 Decision.The studies are voluminous and can be found at followingwebsites:
9 The Final EIS:
10 https://eplannine.blm.gov/epl-front-
11 office/eplanning/docset view.do?projectId=65164&currentPaceld=92763&do
12 cumentId=78833
13 The Final EIS Appendices:
14 httos://eplanning.blm.cov/epl-front-
15 office/eplannine/docset view.do?projectId=65164&currentPageld=92763&do
16 cumentId=78834
17 The mitigation plans are also included in the above links,and identified in the
18 attached Exhibit No.19.
19 Q.Please describe the Company's plan of development related to the Transmission
20 Projects.
21 A.Once the Transmission Projects are in service,they will not directly produce any
22 emissions into the environment.The Company is preparing the plan of development,
23 which will govern the construction phase of the Aeolus-to-Bridger/Anticline Line and
24 must be approved by BLM.This plan will include specific requirements to ensure full
25 compliance with all applicableregulations and requirements of the right-of-waypermit
26 granted by BLM for siting the Aeolus-to-Bridger/Anticline Line on federal lands.The
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l plan of development will also include best practices for all aspects of environmental
2 protection.The Company anticipates that,at a minimum,the plan of development for
3 the construction phase will account for fugitive dust control,storm water pollution
4 prevention,spill containment and counter measures,plant/wildlife restrictions,and
5 ground disturbance reclamation.The Company anticipates that the protection measures
6 it will use for the Transmission Projects as shown in Exhibit No.20 will be similar to
7 those implemented on the Company's Mona-to-Oquirrh and Sigurd-to-Red Butte
8 transmission projects,adjusted to meet the specifics of this project as necessary.
9 Once the Transmission Projects are in service,the Company will install three
10 primary devices to protect air,water,chemical,biological,and thermal qualities:
11 Construction of retention basins at the substation sites to control storm
12 water runoff,to manage erosion control and waterflows across adjacent
13 properties as well as at the substation sites;
14 Storm water control along the transmission line access routes will be
15 managed using ditches at the verge ofnew access roads along with water
16 control and diversion techniques,such as the use of water bars;and
17 At the substation sites,an oil containment plan will be incorporated into
18 the final design such that,in the event of a leak,the contents of any oil-
19 filled equipment would be contained within the substation site and not
20 leach into the underlying soils.
21 Q.Please describe the effectiveness of the three protective devices you describe above
22 and the operational conditions for which the Company designed and tested the
23 devices.
24 A.The devices all represent proven technology employed at numerous substation and
25 other facilities across the United States.Water-retention designs will comply with all
26 relevant codes as well as the Clean Water Act requirements where applicable.The
O 27 Company has successfully employed all of these techniques on recent transmission
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l projects including Populus-to-Terminal,Mona-to-Oquirrh,and Sigurd-to-Red Butte
2 transmission projects.
3 Q.Please describe any potential safety hazards related to the Transmission Projects.
4 A.The Company requires a high standard of safety performance and planning by all of its
5 employees and contractors.During the construction phase,the primary safety hazards
6 will vary somewhat by stage of the project,but will generally relate to:
7 Heavy equipment operations;
8 Open excavations;
9 Slips,trips and falls;
10 Crane operations;
11 Working at height;
12 Working around energized facilities;and
13 Climatic conditions.
14 The Company will require all personnel working on the Transmission Projects
15 to perform safety training specific to the Transmission Projects.The safety plan will
16 require appropriate safety markings,barriers and other restriction devices to prevent
17 worker or public access to potentially unsafe conditions.
18 During operations,the main safety hazard will be the energized facilities.Tower
19 structures are designed to provide electrical clearances to the ground and structures and
20 prevent climbing without specialist equipment,so that the public cannot reach the
21 conductor.
22 All substation energized facilities are constructed so that the high-voltage
23 equipment is placed with sufficient clearances from the site security fence to prevent
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l accidental contact with the energized equipment.All substations will include security
2 fencing,controlled access devices,security monitoring to limit and manage personnel
3 gaining access to the site.
4 Q.Please describe the status of satisfying local,state,tribal,or federal governmental
5 agency requirements.
6 A.The Company has obtained a federal right-of-waypermit from the BLM,which covers
7 approximately half of the 140 mile-length of the Aeolus-to-Anticline line.The right-
8 of-waygrant was authorized concurrently with the release of the Record of Decision,
9 discussed above.The BLM's decision provides the authorizations,with stipulations,
10 necessary for the Company to begin construction on federally administered lands.
11 Stipulationsin the right-of-waygrant require additional environmental surveys
12 to be completed in order to clear construction areas before receiving the notice to
13 proceed to construct on public land.The Company is currently conducting surveys for
14 cultural,paleontological,biological and potential wetland resources that will need to
15 be protected and,if adversely impacted,mitigated.The BLM and the U.S.Corp of
16 Engineers will issue final notices to proceed after receipt and approval of survey
17 reports,pre-construction notifications,and payment of any required mitigation funds
18 determined.
19 In addition,the right-of-way grant includes the requirement to comply with
20 several additional federal agency required permits and approvals,which the Company
21 is currentlyin the process of completing,including Section 106 Consultation under the
22 National Historic Preservation Act,Section 404 Clean Water Act Permit,and Resource
23 Protection Plans required by the BLM.
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l The Company is in the process of securing all relevant federal,state,and local
2 permits for the 230 kV section between the Aeolus substation and the Standpipe
3 substation.The Company anticipates that this section will be subject to the same or
4 similar conditions included in the Record of Decision,released November 12,2013.
5 Q.What is the current status of the necessary permits from local government
6 entities?
7 A.The Company has or will receive the required consents,franchises,and permits from
8 all the local governmental entities havingjurisdiction over the proposed route for the
9 Transmission Projects.These will include an application to the Wyoming Department
10 of Environmental Quality and the Wyoming Industrial Siting Council for the issuance
11 of a permit.The Company will also obtain a conditional use permit from Carbon
12 County and a construction permit from Sweetwater County.
13 In addition to the conditional use permit,the Company is in the process of
14 obtaining the required consents and permits from the State of Wyoming,subject to
15 completion of the fmal design of the transmission line alignment.Additionally,the
16 Company will obtain any permits and approvals required from state agencies for actual
17 construction and operation of the Transmission Projects in the ordinary course of
18 development.These required consents and permits may include,but may not be limited
19 to,stream alteration permits from the Wyoming Game and Fish Department,highway
20 encroachment permits from the Wyoming Department of Transportation,storm water
21 permits from the Wyoming Department of Environmental Quality Water Quality
22 Division,right-of-waygrants from the Wyoming State Trust Lands Administration,and
23 approvals from the State Historic Preservation Office of Wyoming.
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l Based on the current routing plan,these are the only permits,franchises,and
2 consents required for the Transmission Projects.Should a routing change resulting from
3 the environmental approval process require any additional local consents,franchises,
4 or permits,the Company will immediately seek such approval and inform the
5 Commission..
6 Exhibit No.21 provides additionaldetails on the required permits.
7 Q.Please describe the sage grouse habitat in the vicinity of the Transmission Projects.
8 A.As part of the NEPA process,the Company's assessment specifically addressed the
9 potential impact of the Aeolus-to-Bridger/Anticline Line on sage grouse habitat.The
10 studies related to sage grouse are included in the Final EIS issued by BLM.In addition,
11 the mitigation plan associated with sage grouse is described in Exhibit No.19.
12 The Company is also in the process of developing a Greater Sage Grouse
13 Avoidance,Minimization,and Mitigation Plan to demonstrate compliance with BLM
14 and state policies designed to minimize impacts to sage grouse and their habitat,and
15 support the position that a listing as threatened or endangered under the ESA is not
16 needed.
17 Q.Under RP 112(5),has the Company provided cost estimates for the Transmission
18 Projects?
19 A.Yes.The estimated total cost for the Transmission Projects is .The
20 individual cost components of this estimate are set forth in Confidential Tables 1-2
21 above.
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l Q.RP 112(5)also requires information on the Transmission Projects'effect on the
2 Company's revenue requirement.Please explain where that information is located
3 in the Company's Application.
4 A.Mr.Larsen and Mr.Link sponsor the Company's revenue requirement analysis related
5 to the Transmission Projects.
6 RECOMMENDATION AND CONCLUSIONS
7 Q.Please summarize your recommendation to the Commission.
8 A.I recommend that the Commission approve the Company's Application.The
9 Transmission Projects will provide substantial benefits to its customers and are prudent
10 and in the public interest.Based on this conclusion,I recommend that the Commission
11 grant the Company CPCNs for the Transmission Projects.
12 Q.Does this conclude your direct testimony?
13 A.Yes.
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