Control Number: 49603 1 II II 1 - TransmissionHub.com · 2020. 2. 21. · RAMYA RAMASWAMY INFRASTRUCTURE DIVISION PUBLIC UTILITY COMMISSION OF TEXAS February 19, 2020 0000001 . SOAH

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Item Number: 166

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SOAH DOCKET NO. 473-20-04172" PUC DOCKET NO. 49603

APPLICATION OF UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSVILLE - GUM SPRING)

BEFORE THE STATE OFFICE OF

ADMINISTRATIVE HEARINGS

DIRECT TESTIMONY OF

RAMYA RAMASWAMY

INFRASTRUCTURE DIVISION

PUBLIC UTILITY COMMISSION OF TEXAS

February 19, 2020

0000001

SOAH Docket No. 473-20-0417 PUC Docket No. 49603 Page 1

TABLE OF CONTENTS

I. STATEMENT OF QUALIFICATIONS 3

II. SCOPE OF TESTIMONY 3

III. CONCLUSIONS AND RECOMMENDATIONS 8

IV. PROJECT JUSTIFICATION 12

A. DESCRIPTION OF THE PROJECT 12

B. TEXAS COASTAL MANAGEMENT PROGRAM 13

C. NEED FOR THE PROJECT 14

D. PROJECT ALTERNATIVES 15

V. ROUTING 15

A. STAFF RECOMMENDATION 15

B. COMMUNITY VALUES 16

C. RECREATIONAL AND PARK AREAS 17

D. HISTORICAL VALUES 18

E. AESTHETIC VALUES 19

F. ENVIRONMENTAL INTEGRITY 19

G. ENGINEERING CONSTRAINTS 22

H. COSTS 22

I. MODERATION OF IMPACT ON THE AFFECTED

COMMUNITY AND LANDOWNERS 25

J. RIGHT-OF-WAY 26

1. USE AND PARALLELING OF EXISTING, COMPATIBLE RIGHT-OF-WAY (INCLUDING

APPARENT PROPERTY BOUNDARIES) 27

DIRECT TESTIMONY OF RAMYA RAMASWAMY February 19, 2020 0000002


2. PARALLELING OF NATURAL OR CULTURAL 28 FEATURES

K. PRUDENT AVOIDANCE 28

VI. CONCLUSION 30

ATTACHMENTS

RR-1 Qualifications of Ramya Ramaswamy

RR-2 Letter from Texas Parks and Wildlife Department dated September 11, 2019

RR-3 Upshur Rural Electric Cooperative Corporation's Response to BMWB's 1st RFI

RR-4 Upshur Rural Electric Cooperative Corporation's Response to Christopher Tucker's First Set of Requests for Information

RR-5 Upshur Rural Electric Cooperative Corporation's Response to Intervenors Cherry Ridge Ranch LLC and 4-Sight Operating LTD.'s l' RFI



1 I. STATEMENT OF QUALIFICATIONS

2 Q. Please state your name, occupation and business address.

3 A. My name is Ramya Ramaswamy. I am employed by the Public Utility Commission of

4

Texas (Commission) as an Engineer within the Infrastructure Division. My business

5

address is 1701 North Congress Avenue, Austin, Texas 78701.

6 Q. Please briefly outline your educational and professional background.

7 A. I have a Master of Science in Mechanical Engineering. I completed my degree in May

8

of 2003 and have been employed at the Commission since May 2019. A more detailed

9

resume is provided in Exhibit RR-1.

10 Q. Are you a registered professional engineer?

11 A. No.

12 Q. Have you previously testified as an expert before the Commission?

13 A. No.

14

15 II. SCOPE OF TESTIMONY

16 Q. What is the purpose of your testimony in this proceeding?

17 A. The purpose of my testimony is to present Commission Staff' s recommendations

18

concerning the application of Upshur Rural Electric Cooperative Corporation

19

(URECC) to amend its Certificate of Convenience and Necessity (CCN) to construct a

20

new 138-kilovolt (kV) electric transmission line. The transmission line will connect the

21

existing Hallsville Substation to the proposed Gum Springs Substation in Harrison

22

County, Texas (Proposed Project). The Proposed Project will be roughly 4.8 to 5.9

23

miles long, depending on the route selected.

24 Q. What is the scope of your testimony?



1 A. The scope of my testimony is to provide Commission Staff's recommendation

2 regarding the need for the project and regarding selection of routes from among the

3 alternative routes presented by URECC.

4 Q. What are the statutory requirements that a utility must meet to amend its CCN

5 to construct a new transmission line?

6 A. Section 37.056(a) of the Public Utility Regulatory Act (PURA)' states that the

7 Commission may approve an application for a CCN only if the Commission finds that

8 the CCN is necessary for the service, accommodation, convenience, or safety of the

9 public. Further, PURA provides that the Commission shall approve, deny, or modify a

10 request for a CCN after considering the factors specified in PURA § 37.056(c), which

11 are as follows:

12 (1) the adequacy of existing service;

13 (2) the need for additional service;

14 (3) the effect of granting the certificate on the recipient of the certificate and

15 any electric utility serving the proximate area; and

16 (4) other factors, such as:

17 (A) community values;

18 (B) recreational and park areas;

19 (C) historical and aesthetic values;

20 (D) environmental integrity;

21 (E) the probable improvement of service or lowering of cost to

22 consumers in the area if the certificate is granted; and

23 (F) to the extent applicable, the effect of granting the certificate on

1 Public Utility Regulatory Act, Tex. Util. Code Ann. §§ 11.001-66.016 (PURA).



1 the ability of this state to meet the goal established by PURA

2 § 39.904(a).

3 Q. Do the Commission's rules provide any instruction regarding routing criteria?

4 A. Yes. 16 Texas Administrative Code (TAC) § 25.101(b)(3)(B) requires that an

5 application for a new transmission line address the criteria in PURA § 37.056(c), and

6 that upon considering those criteria, engineering constraints and costs, the line shall be

7 routed to the extent reasonable to moderate the impact on the affected community and

8 landowners, unless grid reliability and security dictate otherwise. The following factors

9 shall be considered in the selection of URECC's alternative routes:

10 (i) whether the routes parallel or utilize existing compatible rights-of-way

11 for electric facilities, including the use of vacant positions on existing

12 multiple-circuit transmission lines;

13 (ii) whether the routes parallel or utilize existing compatible rights-of-way,

14 including roads, highways, railroads, or telephone utility rights-of-way;

15 (iii) whether the routes parallel property lines or other natural or cultural

16 features; and

17 (iv) whether the routes conform with the policy of prudent avoidance.

18 Q. What issues identified by the Commission must be addressed in this docket?

19 A. In the Order of Referral and Preliminary Order issued on October 01, 2019, the

20 Commission identified the following issues that must be addressed:

21 1. Is URECC's application to amend its CCN adequate? Does the application

22 contain an adequate number of reasonably differentiated alternative routes to

23 conduct a proper evaluation? In answering this question, consideration must be

24 given to the number of proposed alternatives, the locations of the proposed

DIRECT TESTIMONY OF RAMYA RAMASWAMY February 19,2020 0000006


1 transmission line, and any associated proposed facilities that influence the

2 location of the line. Consideration may also be given to the facts and

3 circumstances specific to the geographic area under consideration, and to any

4 analysis and reasoned justification presented for a limited number of alternative

5 routes. A limited number of alternative routes is not in itself a sufficient basis

6 for finding an application inadequate when the facts and circumstances or a

7 reasoned justification demonstrates a reasonable basis for presenting a limited

8 number of alternatives. If an adequate number of routes is not presented in the

9 application, the ALJ must allow URECC to amend the application and to

10 provide proper notice to affected landowners; if URECC chooses not to amend

11 the application, the ALJ may dismiss the case without prejudice.

12 2. Are the proposed facilities necessary for the service, accommodation,

13 convenience, or safety of the public within the meaning of PURA § 37.056(a)

14 taking into account the factors set out in PURA § 37.056(c)? In addition,

15 a) How does the proposed facility support the reliability and adequacy of

16 the interconnected transmission system?

17 b) Does the proposed facility facilitate robust wholesale competition?

18 c) What recommendation, if any, has an independent organization, as

19 defined in PURA § 39.151, made regarding the proposed facility?

20 d) Is the proposed facility needed to interconnect a new transmission

21 service customer?

22 3. Is the transmission project the better option to meet this need when compared

23 to employing distribution facilities? If URECC is not subject to the unbundling

24 requirements of PURA § 39.051, is the project the better option to meet the



1 need when compared to a combination of distributed generation and energy

2 efficiency?

3 4. Which proposed transmission line route is the best alternative weighing the

4 factors set forth in PURA § 37.056(c) and 16 TAC § 25.101(b)(3)(B)?

5 5. Are there alternative routes or facilities configurations that would have a less

6 negative impact on landowners? What would be the incremental cost of those

7 routes?

8 6. If alternative routes or facility configurations are considered due to individual

9 landowner preference:

10 a) Have the affected landowners made adequate contributions to offset any

11 additional costs associated with the accommodations?

12 (b) Have the accommodations to landowners diminished the electric

13 efficiency of the line or reliability?

14 7. On or after September 1, 2009, did the Texas Parks and Wildlife Department

15 provide any recommendations or informational comments regarding this

16 application in accordance with Section 12.0011(b) of the Texas Parks and

I 7 Wildlife Code? If so, please address the following issues:

18 a) What modifications, if any, should be made to the Proposed Project as

19 a result of any recommendations or comments?

20 b) What conditions or limitations, if any, should be included in the final

21 order in this docket as a result of any recommendations or comments?

22 c) What other disposition, if any, should be made of any recommendations

23 or comments?



1 d) If any recommendation or comment should not be incorporated in this

2 project or the final order, or should not be acted upon, or is otherwise

3 inappropriate or incorrect in light of the specific facts and circumstances

4 presented by this application or the law applicable to contested cases,

5 please explain why that is the case.

6 8. Are the circumstances for this line such that the seven-year limit discussed in

7 section III of this Order should be changed?

8 Q. Which issues in this proceeding have you addressed in your testimony?

9 A. I have addressed the issues from the Order of Referral and Preliminary Order and the

10 requirements of PURA § 37.056 and 16 TAC § 25.101.

11 Q. What have you relied upon or considered to reach your conclusions and make

12 your recommendation?

13 A. I have relied upon my review and analysis of the data contained in URECC's

14 application and the application's accompanying attachments, including the

1 5 Environmental Assessment (EA)2 prepared by Power Engineers. I have also relied upon

16 my review of the direct testimonies and statements of position filed in this proceeding

17 by or on behalf of URECC and the intervenors, responses to requests for information,

18 and the letter from the Texas Parks and Wildlife Department (TPWD) to Ms. Karen

19 Hubbard, dated September 11, 2019.3

20

2 1 III. CONCLUSIONS AND RECOMMENDATIONS

2 Upshur Rural Electric Cooperative Corporation's Application to Amend its Certificate of Convenience and Necessity for a Proposed 138 kV Transmission Line in Harrison County, Texas (Application) at Attachment 1

3 Attachment RR-2.



1 Q. Based on your evaluation of URECC's application and other relevant material,

2 what conclusions have you reached regarding the application and the Proposed

3 Project?

4 1. I conclude that the application is adequate and that URECC's proposed routes

5 are adequate in number and geographic diversity.

6 2. I conclude that the application complies with the notice requirements in 16 TAC

7 § 22.52(a).

8 3. I conclude that, taking into account the factors set out in PURA § 37.056(c), the

9 Proposed Project is necessary for the service, accommodation, convenience and

10 safety of the public.

11 4. I conclude that the Proposed Project is the best option to meet the need when

12 compared with other alternatives.

13 5. I conclude that Route 13 is the best route when weighing, as a whole, the factors

14 set forth in PURA § 37.056(c)(4) and in 16 TAC § 25.101(b)(3)(B).

15 6. I conclude that TPWD provided mitigation measures regarding the application,

16 and that the recommened measures provided on Pages 10 through 12 of my

17 testimony, as well as mitigation measures mentioned in the environmental

18 concerns on pages 19 through 21 of my testimony, are sufficient to address

19 TPWD's mitigation recommendations. I also conclude that URECC has the

20 resources and procedures in place in order to accommodate the mitigation

21 recommendations.

22 Q. What recommendation do you have regarding URECC's application?

23 A. I recommend that the Commission approve URECC's application to amend their CCN

24 in order to construct a new 138-kV electric transmission line in Harrison County,



1 Texas.

2 I also recommend that the Commission order URECC to construct the Proposed Project

3 on Route 13 (Segments C, F, J1, AS, T2, Z1, Z3, AE1, AE2, AH, AP). I further

4 recommend that the Commission include in its order approving URECC's application

5 the following paragraphs in order to mitigate the impact of the Proposed Project:

6 I . URECC shall conduct surveys, if not already completed, to identify pipelines

7 that could be affccted by the transmission lines and coordinate with pipeline

8 owners in modeling and analyzing potential hazards because of alternating-

9 current interference affecting pipelines being paralleled.

10 2. If URECC encounters any archeological artifacts or other cultural resources

11 during project construction, work must cease immediately in the vicinity of the

12 artifact or resource, and the discovery must be reported to the Texas Historical

13 Commission. In that situation URECC must take action as directed by the Texas

14 Historical Commission.

15 3. URECC must follow the procedures to protect raptors and migratory birds as

16 outlined in the following publications: Reducing Avian Collisions with Power

17 Lines: The State of the Art in 2012, Edison Electric Institute and Avian Power

18 Line Interaction Committee, Washington, D.C. 2012; Suggested Practices for

19 Avian Protection on Power Lines: The State of the Art in 2006, Edison Electric

20 Institute, Avian Power Line Interaction Committee, and the California Energy

21 Commission, Washington, D.C. and Sacramento, CA 2006; and Avian

22 Protection Plan Guidelines, Avian Power Line Interaction Committee and

23 United States Fish and Wildlife Service, April 2005. URECC must take

24 precautions to avoid disturbing occupied nests and take steps to minimize the



1 burden of construction on migratory birds during the nesting season of the

2 migratory bird species identified in the area of construction.

3 4. URECC must exercise extreme care to avoid affecting non-targeted vegetation

4 or animal life when using chemical herbicides to control vegetation within

5 rights-of-way. URECC must ensure that the use of chemical herbicides to

6 control vegetation within the rights-of-way complies with rules and guidelines

7 established in the Federal Insecticide Fungicide and Rodenticide Act and with

8 Texas Department of Agriculture regulations.

9 5. URECC must minimize the amount of flora and fauna disturbed during

I 0 construction of the transmission lines, except to the extent necessary to establish

11 appropriate right-of-way (ROW) clearance for the transmission lines. In

12 addition, URECC must revegetate, using native species and must consider

13 landowner preferences and wildlife needs in doing so. Furthermore, to the

14 maximum extent practical, URECC must avoid adverse environmental

15 influence on sensitive plant and animal species and their habitats, as identified

16 by the Texas Parks and Wildlife Department and the United States Fish and

I 7 Wildlife Service.

18 6. URECC must implement erosion control measures as appropriate. Erosion

I 9 control measures may include inspection of the ROW before and during

20 construction to identify erosion areas and implement special precautions as

21 determined necessary. URECC must return each affected landowner's property

22 to its original contours and grades unless otherwise agreed to by the landowner

23 or the landowner's representative. URECC is not required to restore the original

24 contours and grades where a different contour or grade is necessary to ensure



1 the safety or stability of the project's structures or the safe operation and

2 maintenance of the lines.

3 7. URECC must use best management practices to minimize the potential impacts

4 to migratory birds and threatened or endangered species.

5 8. URECC must cooperate with directly affected landowners to implement minor

6 deviations from the approved route to minimize the burden of the transmission

7 lines. Any minor deviations from the approved route must only directly affect

8 landowners who were sent notice of the transmission line in accordance with

9 16 TAC § 22.52(a)(3) and landowners that have agreed to the minor deviation.

10 9. URECC must report the transmission line approved by the Commission on its

11 monthly construction progress reports before the start of construction to reflect

12 the final estimated cost and schedule in accordance with 16 TAC § 25.83(b). In

13 addition, URECC must provide final construction costs, with any necessary

14 explanation for cost variance, after completion of construction when all costs

15 have been identified.

16 Q. Does your recommended route differ from the route that URECC believes best

17 addresses the requirements of PURA and the Commission's rules?

18 A. Yes. URECC believes Route 8 best addresses the requirements of PURA and the

19 Commission's rules. Route 13 is similar to Route 8, which is recommended by the

20 Applicant; however, it utilizes links J1 and AS instead of links I and Tl.

21

22 IV. PROJECT JUSTIFICATION

23 A. DESCRIPTION OF THE PROJECT

24 Q. Please describe the Proposed Project.



I A. The Proposed Project consists of the design and construction of a new 138-kV single

2 circuit transmission line to be constructed on concrete or steel monopole structures.

3 The project will originate from the existing Hallsville Substation located just east of

4 the intersection of County Road 3428 and Fort Crawford Drive in Hallsville, Texas.

5 The new transmission line will terminate at the proposed Gum Springs Substation to

6 be located approximately one-half mile northwest of the intersection of Whitehurst

7 Drive and Coleman Road. All the facilities subject to this application are located in

8 Harrison County.

9 Q. Does URECC's application contain a number of alternative routes sufficient to

10 conduct a proper evaluation?

11 A. Yes. URECC's application identified 13 proposed alternative routes (Route 1 -13).

12 Q. Were any additional routes suggested by intervenors?

13 A. Subsequent to the filing of the application 13 additional routes were proposed by the

14 intervenors. URECC provided EA and cost data for all the addional routes proposed

15 from Hallsville Substation to Gum Springs Substation as discussed further in my

16 testimony.

17 Q. Is the Proposed Project located within the incorporated boundaries of any

18 municipality?

19 A. A small portion of Segments B and C are located within the western boundary of the

20 City of Hallsville, traversing across the city boundary for approximately 50 and 500

21 feet respectively.4 Route 2, Route 3 and Routes 5 — 13, as well as Route 4.2, Route 9.1,

22 Route 9.2, Route 14, and Route 14.1 all utilize Segments B or C.

23

4 Application at Page 5, Question 10.



1 B. TEXAS COASTAL MANAGEMENT PROGRAM

2 Q. Does any part of this project lie within the Texas Coastal Management Program

3 (TCMP) boundary?

4 A. No. The Proposed Project is not located, either in whole or in part, within the TCMP

5 boundary.5

6

7 C. NEED FOR THE PROJECT

8 Q. Could you briefly summarize the need for the project?

9 A. Yes. URECC serves its members through a radial 138-kV transmission line that begins

10 at its Diana Metering Point. There are nine substations served by the Diana Metering

11 Point, providing a total of 118 megawatts (MW) to cooperative members during peak

12 loading conditions. 6 This Proposed Project is the first step in mitigating future loading

13 constraints on the existing transmission network by providing a looped service between

14 URECC's Diana Metering Point and the Gum Springs Substation, allowing the Diana

15 Auto Station, the Noonday Substation, and the Hallsville Substation to have redundant

16 138-kV transmission service in the case of an outage event on any other line segment.

17 Additionally, this construction is targeted to improve reliability to the nearly 18,000

18 meters that are connected to the radially served Diana Metering Point.

19 A recent storm damaged a structure between the Diana Auto Station and the Noonday

20 Substation illustrated why the looped facilities in this Proposed Project could help

21 provide more reliable service. This storm caused a breaker at Diana Metering Point to

22 open, which affected all nine substations served by the Diana Metering Point. The




SOAI-1 Docket No. 473-20-0417 PUC Docket No. 49603 Page 15

1 transmission line contemplated in this Proposed Project would have isolated the fault

2 between the Diana Metering Point and the Noonday Substation, then restored power

3 from the Gum Springs Substation connection on the southern end of the proposed loop,

4 significantly reducing the outage time for the members who are served by the Noonday

5 and Hallsville Substations.

6 Q. Has an independent organization, as defined in PURA § 39.151, determined that

7 there is a need for the Proposed Project?

8 A. No.

9 Q. Are the proposed facilities necessary for the service, accommodation, convenience,

10 or safety of the public within the meaning of PURA § 37.056(a)?

11 A. Yes. In my opinion, based on the data and load projections provided by URECC, it is

12 evident that this project is necessary and is the best way to address the reliability issues

13 resulting from the load growth on the substations currently served by the Disna

14 Metering Point.

15

16 D. PROJECT ALTERNATIVES

17 Q. Did URECC consider distribution alternatives to the Proposed Project?

18 A. Yes. URECC considered distribution alternatives, upgrading voltages, bundling of

19 conductors, adding transformers and distributed generation as prospective solutions.

20 Q. What was the conclusion URECC reached as a result of that study?

21 A. Distribution alternatives do not address the specific reliability concerns and do not

22 provide closed loop transmission facilities to the existing radially served substations.

23 Similarly, upgrading voltage, bundling of conductors, adding transformers or

24 distributed generation do not address the issue at hand.



1 Q. Do you agree that the Proposed Project is the best option when compared to other

2

alternatives?

3 A. Yes.

4

5 V. ROUTING

6 A. STAFF RECOMMENDATION

7 Q. What routes do you recommend upon considering all factors, including the factors

8

in PURA § 37.056(c) and 16 TAC § 25.101(b)(3)(B)?

9 A. Based on my analysis of all the factors that the Commission must consider under PURA

10

§ 37.056 and 16 TAC § 25.101, I recommend that Route 13 be approved for the

II

Proposed Project. The basis for my recommendation is discussed in more detail in the

12

remainder of my testimony.

13 Q. Which route did URECC select as the route that it believes best addresses the

14

requirements of PURA and the Commission's rules?

15 A. URECC selected Route 8, as the route that it believes best addresses the requirements

16

of PURA and the Commission's rules.7

17

18 B. COMMUNITY VALUES

19 Q. Has URECC sought input from the local community regarding community

20

values?

21 A. Yes. URECC held public meeting as required by 16 TAC § 22.52(a)(4). The public

22

meeting was held on October 26, 2017 from 4:30 PM to 7:30 PM at Hallsville High

23

School in Hallsville, Texas. At the public meeting, questionnaires were provided for




1 all the attendees. Manned information stations were set up to provide information to

2 the attendees. URECC provided written notice of the Proposed Project to county and

3 municipal officials as required by 16 TAC 22.52(a)(2) and to directly affected

4 landowners as required by 16 TAC 22.52(a)(3). I conclude that the Applicant provided

5 adequate means by which members of the community could express concerns.

6 Q. Did members of the community who attended the public meeting express concerns

7 about the Proposed Project?

8 A. URECC mailed 300 open house invitation letters to landowners. A total of 15

9 individuals attended the meeting according to the sign-in sheet provided at the meeting.

10 One questionnaire was submitted at the meeting and 30 questionnaire responses were

11 received by mail after the open meeting.8 Table 2-1 in the EA summarizes general

12 response information from the questionnaires.

13 Q. In your opinion, would construction of the Proposed Project on Route 13 mitigate

14 the concerns expressed by members of the community at the open houses?

15 A. In my opinion, Route 13 would mitigate some of the concerns expressed by members

16 of the community at the open house. Route 13 utilizes existing transmission or

17 distribution line ROW for 2.5 miles along the segments C, F, J1, AP, and AS, which is

18 52% along its length. Route 13 has 32 habitable structures within 300 feet of its

19 centerline, 11 more than the route with the least (Route 4.1) and 31 fewer than the route

20 with the most (Route 9). I will specifically address recreational and park areas,

21 historical values, aesthetic values, environmental integrity, engineering constraints,

22 costs, moderation of impact on the affected community and landowners, and ROW later

23 in my testimony.




1 Q. Are property values and the impact on future/potential development factors

2 considered by the Commission in a CCN proceeding under PURA § 37.056(c)(4)

3 or in 16 TAC §25.101(b)(3)(B)?

4 A. No. PURA and the Commission's rules do not list these two issues as factors that are

5 to be considered by the Commission in a CCN proceeding. However, these rules do

6 require consideration of using or paralleling existing ROW, which may minimize

7 concerns about these impacts.

8 Q. Are there any routes that did not receive specific opposition from intervenors?

9 A. No.

10

11 C. RECREATIONAL AND PARK AREAS

12 Q. Are any parks or recreational areas located within 1,000 feet of the centerline of

13 any of the alternative routes?

14 A. There are no parks or recreational areas located within 1,000 feet of the centerline of

15 any of the proposed alternative routes listed in the route data provided by Power

16 Engineers.9

17

18 D. HISTORICAL VALUES

19 Q. Are there possible impacts from the Proposed Project on archeological and

20 historical values, including known cultural resources crossed by any of the

21 proposed alternative routes or that are located within 1,000 feet of the centerline

22 of any of the alternative routes?

9 Application at Page 20, Question 26, EA Attachment 13.



1 A. There is one recorded archeological site and one cemetery located within 1,000 feet of

2 the proposed alternative routes. 10 The archeological site boundary is approximately

3 136 feet from the centerlines of alternative Route 3, Route 8, Route 10, Route 12, and

4 Route 13. The cemetery boundary is approximately 107 feet from the centerlines of

5 alternative Routes Route 3, Route 8, Route 10, Route 12 and Route 13.

6 The length of the proposed alternative routes that cross high archeological or historical

7 potential ranges from 4.6 miles for Route 10.2 to 2.7 miles for Route 9. Route 13

8 crosses only 3.3 miles of areas of high archeological potential. Therefore, I conclude

9 that Route 13 is acceptable from a historical values perspective.

10 If any further archeological or cultural resources are found during construction of the

11 proposed transmission line, URECC should immediately cease work in the vicinity of

12 the archeological or cultural resources, and immediately notify the Texas Historical

13 Commission.

14

15 E. AESTHETIC VALUES

16 Q. In your opinion, which of the proposed routes would result in a negative impact

17 on aesthetic values, and which portions of the study area will be affected?

18 A. In my opinion, all of the proposed alternative routes would result in a negative impact

19 on aesthetic values, some routes more than others, depending on the visibility from

20 homes and public roadways. Temporary effects would include views of the actual

21 transmission line construction (e.g. assembly and erection of the structures) and of any

22 clearing of ROW. Permanent effects would involve the visibility of the structures and

23 the lines. I therefore conclude that aesthetic values would be impacted throughout the




1 study area, and that these temporary and permanent negative aesthetic effects will occur

2 on any proposed alternative routes approved by the Commission.

3

4 F. ENVIRONMENTAL INTEGRITY

5 Q. Please provide a general description of the area traversed by the proposed

6 alternative routes.

7 A. The study area is located within the Interior Coastal Plains sub-province of the Gulf

8 Coastal Plains Physiographic Region of Texas and is characterized by young deltaic

9 sands, silts and clays, creating nearly flat grasslands. I I Elevations in the study area

10 range from approximately 285 feet to 475 feet above mean sea level.

11 Q. Based on your review, in your opinion, will the Proposed Project present a

12 significant negative impact to environmental integrity?

13 A. No. Transmission lines do not often create many long-term impacts on soils. Most of

14 those impacts will be during initial construction, and when appropriate mitigation

15 measures are implemented during the construction phase, Power Engineers does not

16 anticipate that those impacts will be significant. 12 Impacts on vegetation would be the

17 result of clearing and maintaining the ROW. The highest risk of soil erosion and

18 compaction is primarily associated with the construction phase of the project. Areas

I 9 with vegetation rernoved would have the highest potential for soil erosion and the

20 movement of heavy equipment down the cleared ROW creates the greatest potential

21 for soil erosion and compaction.I 3 The Proposed Project is expected to cause only short-

11 Environmental Assessment 3.1.

12 Environmental Assessment at 4.2, Page 85.

13 Environmental Assessment at 4.2, Page 85.



1 term effects to water, soil, and ecological resources during the initial construction

2 phase.

3 Q. In your opinion, how would construction of the Proposed Project on Route 13

4 compare from an environmental perspective to construction on the other routes?

5 A. Route 13 is ranked as the shortest route. Further, Route 13 maximizes the utilization of

6 existing transmission and distribution line ROW, minimizes fragmentation of intact

7 lands, and thereby has the least adverse impact to natural resources among the

8 alternative routes.

9 Q. What route did TPWD recommend?

10 A. TPWD also recommends Route 13.14 TWPD's recommendation was based on the fact

11 that Route 13 is the shortest route (4.8 miles), that Route 13 utilizes the greatest amount

12 of existing transmission and distribution line ROW (2.5 miles), and that Route 13

13 parallels existing transmission line ROW and other existing compatible ROW.

14 Furthermore TPWD noted that Route 13 has the second-longest length through

15 pastureland/rangeland, which represents approximately 51% of its length and thus

16 reduces the need to clear woodland habitats (2.4 miles). Route 13 also has the shortest

17 length of route through upland bottomland/riparian woodlands (0.1 miles), has the

18 third-shortest length of route through upland forest (2.1 miles) and has the third-least

19 number of stream crossings.15

20 Q. Did TPWD recommend avoiding any routes or segments proposed by URECC?

21 A. TPWD recommends choosing a route that avoids utilizing either Segments J2 or

14 Attachment RR-2 (TPWD Letter) at Page 4

15 Id.


1

2

3


Segment Y due to the large amounts of streams, riparian, and forested wetland

resources along these segments. 16 Segments J2 and Y are utilized by the proposed

Routes 9, 10, 11, 12, and 9.2.

4 Q. Do you conclude that Route 13 is acceptable from an environmental and land use

5

perspective?

6 A. Yes.

7

8 G. ENGINEERING CONSTRAINTS

9 Q. Are there any possible engineering constraints associated with this project?

10 A. There are no specific engineering constraints that are not present in a usual transmission

11

line project. In my opinion, all of the possible constraints can be adequately addressed

12

by using design and construction practices and techniques that are usual and customary

13

in the electric utility industry.

14 Q. Are there any special circumstances in this Project that would warrant an

15

extension beyond the seven-year limit for the energization of the lines?

16 A. No, URECC has not described any special circumstances that would merit an extension

17

of this limit for this project.

18

19 H. COSTS

20 Q. What are URECC's estimated cost of constructing the Proposed Project on each

21

of the proposed alternative routes?

22 A. Attachment 3 of the Application list URECC's estimated costs of constructing each

23

proposed route. The table below shows the total estimated cost for each of the routes

16 Id. at Pagc 5



1 from least expensive to the most expensive proposed alternative route:

2 Route Estimated Cost of the Route 13.1 $5,487,923 13 $5,522,438 8 $5,654,748

12 $5,736,983 9.1 $5,752,540 14 $5,867,591 9 $5,888,689 6 $5,888,848

10 $5,906,249 7 $5,919,031

11 $5,926,399 3 $5,933,468

9.2 $5,982,642 5.1 $5,982,642 5 $5,985,738

4.2 $6,028,662 4.3 $6,097,692 10.2 $6,109,197 10.1 $6,102,703 14.1 $6,212,743

2 $6,214,355 1 $6,396,780

1.1 $6,442,845 4.4 $6,672,946 4 $6,753,460

4.1 $6,834,018 3

4 As the table illustrates, Route 13 is the second least expensive proposed alternative

5 route.

6 Q. Could you briefly discuss the routes less expensive than Route 13 and why Route

7 13 is still preferred?

8 A. Yes. Route 13.1 has one more habitable structure than Route 13 and utilizes less

9 existing transmission or distribution line ROW than Route 13. Route 13 and 13.1 are

10 very similar. Route 13 is less than 1% more expensive than Route 13.1.

11 Q. What methodology has URECC adopted to estimate cost for this project?



1 A. URECC has utilized a flat cost per mile to estimate the cost of the proposed routes for

2 this project..

3 Q. Does using a project-wide cost per mile provide cost estimates that uniquely

4 differentiate the routes with regards to cost?

5 A. No. Deriving cost estimates in this manner makes cost a function of length and does

6 not account for the route-specific differences. While utilizing a flat cost per mile to

7 estimate route cost gives a general idea of what the actual cost might be, it does not

8 take into consideration the actual material cost incurred based on terrain, or the cost of

9 actual construction of the facilities that may differ between routes.

10 Q. What are the factors that could affect the relative cost of the routes provided by

1 1 URECC?

12 A. Route-specific high cost items like turning and angle structures for each particular route

13 could be a significant cost factor for the construction of the Proposed Project. URECC

14 has not provided any detailed analysis on their cost breakdown dependent on the

15 particular route or terrain. Those factors would necessarily affect the construction cost

16 per route actually chosen for this project. Tower structures, classified by the way in

17 which they support the line conductors, are classified as either tangent suspension,

18 angle suspension, tangent dead-end, or angle dead-end structures. Costs for these

19 structures can vary significantly by type, by material and by foundation structures used.

20 Q. How has URECC estimated the cost of constructing the Proposed Project?

21 A. URECC has estimated the cost per mile of construction to be $1,150,508.00 and has

22 worked backwards on the breakdown of cost components provided in Attachment 3

23 based solely on the length of each route. URECC has not provided any analysis on

24 which routes might traverse difficult terrains, which routes would require more or less



1 turning structures, which routes would require more expensive tower structures, or any

2 other analysis accounting for any route-specific differences in cost. The actual

3 construction cost could vary significantly from the estimate based on all the above

4 mentioned factors.

5 Q. In your opinion is the cost per mile number that is chosen by URECC

6 unreasonable?

7 A. No, but it is conservative.

8 Q. What are the factors that you are applying to determine that cost per mile chosen

9 by URECC is reasonable?

10 A. URECC is proposing 85 feet to 115 feet tall single tangent poles based on "standard

1 I design" commonly used by utilities.17 URECC is proposing 100 feet ROW for the

12 Proposed Project. Typical 138 kV transmission line costs can range from $1M per mile

13 to an extreme of over $5 million per mile depending on the terrain & grading, land cost

14 (pasture, crop or urban) and route-specific considerations proposed. Typical costs fall

15 between $1 rnillion to $2 million per mile. Considering the terrain, length of this

16 proposed route and single tangent pole construction proposed by URECC, I find the

17 cost per mile used by URECC for this project, and therefore the estimated general

18 project cost, reasonable.

19 Q. Are there any particular factors that favor Route 13 over other proposed routes

20 with respect to cost?

21 A. Route 13 is forward progressing and in my opinion, would utilize fewer turning

22 structures and right angle turns when compared to many of the alternate routes

23 proposed in this project. Further, Route 13 is a short transmission line and it utilizes




1 fewer sharp angle turns when compared to other proposed routes in this project. A route

2 with many high-angle turning structures would necessarily have a higher cost of

3 construction and materials. Route 13 has a minimal number of large angle turns and is

4 the shortest route proposed.

5

6 I. MODERATION OF IMPACT ON THE AFFECTED COMMUNITY AND

7 LANDOWNERS

8 Q. Do the Commission's rules address routing alternatives intended to moderate the

9 impact on landowners?

10 A. Yes. Under 16 TAC § 25.101(b)(3)(B), "the line shall be routed to the extent reasonable

11 to moderate the impact on the affected community and landowners unless grid

12 reliability and security dictate otherwise."

13 Q. Subsequent to filing its application, has URECC made or proposed any routing

14 adjustments to accommodate landowners?

15 A. Not to my knowledge.

16 Q. Subsequent to filing its application, have Intervenors made or proposed any

17 routing adjustments?

18 A. Yes. On November 6, 2019, Intervenors BMWB Coalition filed a Request for

19 Information (RFI) for URECC. BMWB Coalition proposed alternative Route 4.1,

20 Route 4.2, Route 4.3, Route 10.1, Route 10.2 and Route 13.1. In its response to BMWB

21 Coalition, URECC provided EA data for these routes on November 26, 201918. Also,

22 on January 8, 2020, Intervenor Christopher Tucker proposed Route 1.1, Route 4.4,

18 Attachment RR-3



1 Route 9.1, Route 9.2, Route 14 and Route 14.1 as additional routes. URECC provided

2 EA data for these routes on January 28, 202019. Earlier on January 17, 2020, Intervenors

3 Cherry Ridge Ranch, LLC and 4-Sight Operating Company Ltd. filed an RFI to

4 URECC proposing Modified Route 5.1 and requesting information on the said route.

5 URECC provided EA data for the Modified Route 5.1 on February 6, 202020.

6 Q. Has URECC proposed any specific means by which it will moderate the impact of

7 the Proposed Project on landowners or the affected community other than

8 adherence to the Commission's orders, the use of good utility practices,

9 acquisition of and adherence to the terms of all required permits, and what you

10 have discussed above?

11 A. Not to my knowledge.

12

13 J. RIGHT-OF-WAY

14 Q. Do the Commission's rules address routing along existing corridors?

15 A. Yes. The following factors are to be considered under 16 TAC § 25.101(b)(3)(B):

16 (i) whether the routes utilize existing compatible rights-of-way, including the use

17 of vacant positions on existing multiple-circuit transmission lines;

18 (ii) whether the routes parallel existing compatible rights-of-way;

19 (iii) whether the routes parallel property lines or other natural or cultural features;

20 and

21 (iv) whether the routes conform with the policy of prudent avoidance.

22

19 Attachment RR-4

20 Attachment RR-5



1 1. USE AND PARALLELING OF EXISTING, COMPATIBLE RIGHT-OF-WAY

2 (INCLUDING APPARENT PROPERTY BOUNDARIES)

3 Q. Describe how URECC proposes to use existing or, parallel, or compatible ROW

4 for the Proposed Project.

5 A. Each proposed alternative route parallels apparent property boundaries and parallels or

6 utilizes existing compatible ROW. The percentage of Route 13's length that parallels

7 or utilizes existing compatible ROW and apparent property boundaries is

8 approximately 52% of its length. The table below summarizes the overall length, the

9 length parallel to a compatible ROW or to a property boundary, and the total percentage

10 of parallel ROW used by the proposed alternative routes. 16 TAC § 25.101(b)(3)(B)

11 does not consider existing pipeline ROW as compatible ROW.

Route Length Length

Percentage

Length

Percentage Utilizing Parallel (Miles) Existing to Existing to

ROW (Miles) ROW (Miles) 13 4.8 2.5 52.24% 0 0%

13.1 4.8 2.2 46.46% 0 0% 8 4.9 2.0 39.77% 0 0% 12 5.0 2.3 46.50% 0 0% 9.1 5.0 0.5 9.45% 0 0% 9 5.1 1.1 22.28% 0.03 0.53% 6 5.1 0.6 11.98% 0 0% 10 5.1 1.8 34.50% 0.7 14.13% 14 5.1 0.5 9.22% 0 0% 7 5.1 0.6 12.24% 0 0%

9.2 5.2 0.5 8.94% 0 0% I 1 5.2 0.5 8.94% 0 0% 3 5.2 2.2 42.15% 0 0%

5.1 5.2 0.5 10% 0 0% 5 5.2 0.6 11.79% 0 0%

4.2 5.2 0.5 9.05% 0 0% 4.3 5.3 0.6 11.56% 0 0%



10.2 5.3 0.9 16.12% 0.5 10.10% 10.1 5.3 1.1 21.35% 0.5 10.08% 14.1 5.4 0.2 2.81% 0 0%

2 5.4 0.3 5.37% 0 0% 1 5.6 2.4 42.63% 0 0%

1.1 5.6 2.4 46.46% 0 0% 4.4 5.8 1.3 22.35% 0 0% 4 5.9 1.3 22.24% 0 0%

1

2

As the chart shows, Route 13 is the shortest route and has the highest percentage of

3

compatible ROW compared to the other proposed alternative routes.

4

5 2. PARALLELING OF NATURAL OR CULTURAL FEATURES

6 Q. Describe how URECC proposes to parallel natural or cultural features for the

7

Proposed Project.

8 A. None of the proposed alternative routes parallel natural or cultural features.

9

10 K. PRUDENT AVOIDANCE

11 Q. Define prudent avoidance.

12 A. Prudent avoidance is defined by 16 TAC § 25.101(a)(6) as follows: "The limiting of

13

exposures to electric and magnetic fields that can be avoided with reasonable

14

investments of money and effort."

15 Q. How can exposure to electric and magnetic fields be limited when routing

16

transmission lines?

17 A. Primarily by proposing alternative routes that would minimize, to the extent reasonable,

18

the number of habitable structures located in close proximity to the routes.

19 Q. How many habitable structures are located in close proximity to each of the

DIRECT TESTIMONY OF RAMYA RAMASWAMY Febtuary 19, 2020 0000030


1 proposed alternative routes?

2 A. The table below ranks the number of habitable structures that are within 300 feet of the

3 centerline of the proposed routes in this project.

Route Number of habitable structures 4.1 21 4.2 27 10.1 28 10.2 29

7 29 4.3 30 9.2 30 8 30 11 30 4.4 30 1.1 31 9.1 31 13 32 6 32

13.1 33 12 36 14 36

14.1 36 5.1 38 5 39 4 48 10 48 1 52 3 58 2 60 9 63

4

5 There are 32 habitable structures that are within 300 feet of the centerline of Route 13.

6 This makes Route 13 tied for 13th among all the proposed alternative routes.

7 Q. Could you briefly discuss the routes with fewer or equal numbers of habitable

8 structures and why Route 13 is still preferred?

9 A. Yes. Route 4.1, Route 4.2, Route 10.1, Route 10.2, Route 7, Route 4.3, Route 9.2, Route

10 8, Route 11, Route 4.4, Route 1.1 and Route 9.1 have fewer habitable structures. Route



1 4.1 has eleven fewer habitable structures than Route 13, but it is significantly longer

2 and is not forward progressing. Other than Route 8, all the other proposed alternate

3 routes are longer and have significant turns along their path and that could significantly

4 increase the final construction cost.

5 Q. Do you conclude that the URECC's proposed alternative routes have minimized,

6 to the extent reasonable, the number of habitable structures located in close

7 proximity to the routes?

8 A. Yes.

9

10 vI. CONCLUSION

11 Q. In your opinion, is any one of the proposed alternative routes better than all of the

12 other routes in all respects?

13 A. No.

14 Q. If no proposed alternative route is better than all of the others in all respects, why

15 have you recommended Route 13 instead of the other proposed alternative routes?

16 A. In summary, after analyzing all the factors that the Commission must consider under

17 PURA § 37.056 and 16 TAC § 25.101, I conclude that Route 13 best meets the criteria

18 of PURA and the Commission's rules because it:

19 • Is the shortest route (4.8 miles);

20 • Has the least number of angled turns and is reasonably expected to be cost

21 competitive;

22 • Utilizes the greatest amount of existing transmission or distribution line ROW

23 (2.5 miles);

24 • Has the second-longest length of route through pastureland/rangelands, which



1 represents approximately 51% of its length and thereby reduces the need to

2 clear woodland habitats (2.4 miles);

3 • Has the shortest length of route through upland bottomland/riparian woodlands

4 and the third shortest length through upland forest; and

5 • Is preferred by TPWD.

6 Overall, I consider Route 13 to have the most advantages and to be superior to the other

7 proposed alternative routes.

8 Q. In your opinion, if the Commission considered the criteria of PURA and the

9 Commission's rules in a way that favored any of the other proposed routes over

10 Route 13, do you believe those other proposed alternative routes are viable?

11 A. Yes.

12 Q. Does this conclude your testimony?

13 A. Yes.



ATTACHMENT RR-1

Qualifications of Ramya Ramaswamy

In May 2000 I received a Bachelor of Science in Mechanical Engineering from Bharathiyar

University in Coimbatore, Tamil Nadu, India. In December 2004 I earned my Master of Science

in Mechanical Engineering from Texas A&M University in College Station, Texas. My Master's

thesis focused on loss of bone density and mechanical strength of bones due to osteoporosis,

weightlessness in space and during prolonged bedrest.

Upon completion of my Masters, I worked for Thermo Fisher Scientific for over 12 years in the

Research and Development (R&D) division. My primary duties included designing analyzers for

coal, cement, nuclear and oil industry. I was responsible for identifying and analyzing design

issues, designing the analyzer, planning, sourcing materials & vendors that would best suit my

design. I was also tasked with identifying new national & international vendors to manufacture

various parts of the analyzers, assembling and testing the analyzer in-house and in the field to meet

customer and company standards and releasing it to manufacturing and the market. Additionally,

I provided engineering support to the field team, to the marketing and manufacturing teams with

regards to any technical issues related to the design, and assisted with the installation and

mechanical aspects of the analyzers.

Prior to accepting my current role at the Public Utility Commission, I worked as a Manufacturing

Engineer at Applied Materials and also as a Senior Consultant at a supply chain consulting firm. I

joined the Public Utility Commission in May 2019 as an Engineering Specialist in the

Infrastructure Division.



ATTACHMENT RR-2

The Letter from Texas Parks and Wildlife Department dated September 11, 2019

TEXAS PARKS &

WILDLYFE

September 11, 2019

"I ttl Li , • vt ! 6 1111 2

Ms. Karen Hubbard Puhlic t ltility Commission 10.0 Box 13326 Austin, TX 78711-3326

PUC Docket 49603 Upshur Rural Electric Cooperahve Corporation Proposed Hallsvtlle to Crum Springs 138-kilovolt l ransmission Line Ilarrison County

Lite's better outside:

ComnItss,OHers

Ralph H Num', Choum.n

Fort North

S Reed Mor,,n Vice-CNN rmon

Houston

Arch heave, AOttn, ,11 t Jdrkson

Dear Ms. Hubbard .

Car7fr P Smith L. etutise Director

Texas Parks and Wildlife Department (TPWD) has received and reviewed the Environmental Assessment and Alternative Route Analysis (FA) regarding the ahoy e-referenced proposed transmtssion line project 1 Pkv, D offers the following comments concerning this project.

Please be aware that a written response to a TPWD recommendation or informational comment received by a state governmental agency may he required by state law I or further guidance. see the Texas Parks and Wildlife (TPW) Code. Section 12 0011 For traeking purposes. please refer to TPWD project number 42218 in any return correspondence regarding this project

Project Description

pshur Rural Electric Cooperative Corporation (URFCCI is proposing to construct a new single-circuit l 18-kilovolt (kV) electric transmission line in llarrison County to connect the existing HallsvIlle Substation. located just cast of the intersection ol County Road 3428 and Fort Crawford Drive in Išallsville. Texas, to the proposed (ium Springs Substation to be located approximately onc-half nide northwest of the intersection of Whitehurst Drive and Coleman Road, lhe transmission ltne will be 4.8 to 5.9 miles in length and constructed on concrete or steel monoptile structures within a 100-foot wide right-of-way (ROW ),

t IRLCC retained POWLR Lngineers Mc (POW FRI to prepare the 1 A to support IRECCs application to amend a Certificate of Convenience and Necessity l( CN) for

this project

Previous Coordination

I PWD provided information and recommendations regarding the preliminary study area for this project to POW1 Irt on August 7, 201 7 1 his letter is included in Appendis A of the EA

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Ms. Karen llubbard Page 2 September 11. 2019

Recommendation: Please review the 1 OA 0 correspondence in Appendix A and consider thr recommendations provided. as they remain applicable to the project as proposed.

Proposed Route

URECC's Recommended Route

Using 50 primary alternative segments. L.RECC and POWF.R identified 13 primary alternative routes tbr evaluation in the EA, with each segment incorporated in at least one route lhe consensus opinion of the POWER evaluators was that alternative Route 8 was the route that best balanced land use. ecological. and cultural factors based on the following criteria

Route 8-

• Is the second shortest route. at 4.9 miles. • Is tied with Route 11 for the second fewest habitable structures (30) v ithin 100

feet; • I las the second fewest newly affected habitable structures within 300 feet (251. • Utilizes or parallels existing linear features (transmission distribution lines.

other existing compatible ROW. or apparent property lines or other natural or cultural features) for 92 percent of its length.

• ls tied-with six other routes for having the fewest pipeline crossings (3): • Does not eross any existing transmission lines. and • lias the fourth shortest lenoh of ROV) across areas of hich archeological

potential (3.6 miles)

And like each of the other altemative routes evaluated. Route 8

• Does not cross any parks recreational areas. • Does not cross through any cropland; • Does not cross land irrigated by traveling systems. • Does not cross any gravel pits. mines. or quarries; • Does not cross any interstate. U S . or state highways. • Does not cross any Farm-to-Market (FM) or Ranch-to-Market 1RM) roads. • ROW centerline is not loeated within 10.000 feet ot any private use airstrips. • ROW centerline is not located within 5,000 feet of any heliports; • ROW centerline is not located within 10.000 or 2.0.000 feet of any Federal

Aviation Administration registered airports: • Has no AM radio transminers within 10.000 feet of ROA centerhne. • I las no existing water wells within 200 Ret of the route centerline. • Is not within foreground visual zone of FM RM roads: • Has no length withm foreground visual zone of parks. recreaiional areas. • Crosses no known. occupied habitat of federally -listed endangered ur

threatened species. • Docs not cross any recorded historic or prehistoric sites. and


SOAH Docket No. 473-19-6766 PLJC Docket No. 49523 Page 36

Ms. Karen I lubbard Page 3 September I t. 2019

• Does not cross or within 1,000 feet of any National Register of Historic Places listed sites.

I YR FCC concluded after rev iewing the results of POWER- s e aluation and considering other factors. such as costs, that Route 8 best addresses the requirements of the Public Utility Regulatory Act and Public Utility Commission of Texas (Pl. C ) Substantive Rules. and that each of the alternative routes are feasible from an env ironmental land use and engineering perspective.

IPWD's Recommended Route

In addition to rev iew of (he EA and publicly-available GIS data. TPW D evaluated potential impacts to fish and wildlife resources and pubhc recreational properties using the follow ing criteria from Table 4-1 in the EA.

• Length of alternative route: • Length of route utilizing existing transmission or distribuuun line ROW . • Length of route parallel to existing electric transmission or distribution line

ROW: • I ength of route parallel to other existing compatible ROW highway. roads.

railway. etc.) - Excluding apparent property lines: • Length of route parallel to pipeline ROW : • Length of route across pasturerfangcIand. • Length of route across bottomland riparian woodlands. • Length of route across upland forest. • I.ength of route across National Wetland Inventory (NA I) mapped wetlands. • Length of route across open water Oakes, ponds. etc ). • Number of stream or river crossings: • Length of route parallel (within 100 feet) to streams or rivers. and • Length of route across mapped l 00-year floodplains.

The following eeological and land use criteria had values of zero for all routes and were not used by TIM D to compare routes. length of route across parks recreational areas. number of additional parksirecreational areas w ithin 1.000 feet of ROW centerline. length of routc across cropland or land irrigated by travelling s:vsterns: and length of route across known occupied habitat of federally-listed endangered or threatened species.

TPWD did not evaluate the length of ROW parallel to apparent property lines because the existence of propert) l ines does not always represent a linear disturbance or a break between contiguous tracts of habitat and cannot be used to assume existing habitat fragmentation

After careful evaluation of the 13 routes tiled with the CCN. TPWD selected Route 13 (Segments C-F-Il -AS-Z I -Z3-AEI -AE2-Al I-AP) as the route haying the least adverse impacts to fish and wildlife resources. The decision to recommend Route 13 was based prmarih on the following factors that Route 13.



Ms. Karen I lubbard Page 4 September 11, 2019

• ls the shortest route (4.8 miles) ( All routes' 4.8 to 5.9 miles). • Utilizes the greatest amount of existinc transmission or distribution line ROW

(2.5 miles) (All routes: 0.3 to 2.5 miles): • Follows parallel to existing transmission line ROW and other existing

compatible ROW (road.. highways. railways, etc.) combined. for approximately 57 percent of its length — Excluding apparent property boundaries (All routes: 14 to 72 percent):

• Has the second-longest length of route through pastureland. rangelands. which represents approximately 51 percent of its length. thus reducing the need to clear woodland habitats (2.4 miles) (All routes: 1.1 to 2.8 miles: 20 to 51 percent),

• Has thr shortest length of route through upland bottomland. riparian woodlands (0.1 mile) (All routes: 0 1 to 0.8 mile).

• Has the third-shortest length of route through upland forest (2.1 miles) (All routes 1.9 to 3.8 milest:

• Along with all routes except Route 10. has up to 0.1 mile of length across NWE mapped wetlands (0.1 mile) i All routes: 0 to Mt:

• Along with one other route. has the third-least number of streams crossings (91 (All routes: 7 to 19 stream crossings):

• Along with six other routes. has the second-shortest length of route parallel (‘Nithin JO0 feet) to streams 0.2 mile) (All routes: 0 to 0.8 mile.); and

• Along with five other routes. has the third-shortest length of route across mapped floodplains (0.2 mile} routes: 0 to 1.0 mile).

The EA indicates that the extent of fiekl investigation of the routes included reconnaissance surveys of the study area from public viewing points. The EA failed to provide sufficient information based on field surveys to determine which route would best minimize impacts to important. rare. and protected species. 't herefore. TPWD's routing recommendation is based solely on the natural resource information pro% ided m the CCN application and the EA. as well as publicly available intOrmation examined in a Geographic Information System (GIS).

Recommendation: Of the 13 routes evaluated in the EA. Route 13 appears to be the route that causes the least adverse impacts to natural resourc.es while also maintaining a shorter route length and ut ing existing transmission and distribution line ROW. TPWE) s primary recommendation to the PC( is to select a route that minimizes thr fragmentation of intact lands hecausr such a route should have the least adverse impacts to natural resources TPWD belieses the State's long-term interests are best semed when new utility lines and pipelines are sited where possible in or adjacent to existing utility corridors, roads. or rail lines instead of fragmenting intact lands_ Of the proposed routes. Route 13 would appear to be the preferred route,

Segments J2 and Y have the greatest number of strearn crosstngs and the largest amount of length parallel to streams and across riparian woodlands. NV. I forested wetlands. and mapped floodplains compared to the other segments. Routes utilizing 12 and Y



Ms. Karen Hubbard Page 5 September 11, 2019

include Routes 9.10, 11, and 12. Although the EA indicates that none of the alternative routes arc anticipated to have a significant impact on jurisdictional wetlands. a transmission line through forested wetlands would permanently alter the vegetation to a herbaceous state. and there are alternatives segments other than J2 that can minimize the project' s impacts to forested wetlands. Placing a transmission line along a stream with numerous crossings. such as along Segment Y. can impact stream-stabilizing vegetation and may affect long-term stream function Routes that have a lower number of stream crossings are available which can minimize impacts on streams resources.

Recommendation: TPWD recommends the PLC choose a route that avoids utilizing Segments .12 and Y (Routes 9, 10. II. and 121 due to the large amounts of stream, riparian. and forested wetland resources along these segments.

Federai Law

Afigratory Bird Treaty Act

The Migratory Bird Treaty Act (MBT.A) prohibits direct and affirmative purposeful actions that reduce migratory birds. their eggs. or their nests. by killing or capturing, to human control, except when specifically authorized by thc Department of thc Interior. This protection applies to most native bird species, including ground nesting species.

Secvion 4.4.2 of the EA states "If ROW clearing occurs during bird nesting season. potential impacts could occur within the ROW area related to potential take of bird eggs andior nestlings. Increases in noise and equipment activity levels during construction could also potentially disturb breeding or other activities of bird species nesting in areas adjacent to the ROW. URECC proposes to complete all ROW clearing and construction activities compliant with the M1.11 A to avoid or minimize these potential impacts.-

Recommendation: TPWD recommends any MC certificate preclude vegetation clearing activities during the general bird nesting season. March 15 through September 15. to avoid adverse impacts to birds. If clearing vegetation during the migratory bird nesting season is unavoidable. TPWD recommends URECC survey the proposed route for active nests (nests with eggs or young). TPWD recommends a minimum 150-foot butler of egetation remain around any nests that are observed prior to disturbance and occupied nests and buffer vegetation not be disturbed until the eggs have hatched and the young ha% e fledged.

Also. please note. Texas Parks and Wildlife (TPW ) Code Section 64.002. regarding protection of nongame birds. provides that no person may catch. kill. injure, pursue. or possess a bird that is not a game bird l'PW Code Section 64.003. regarding destroying nests or eggs. provides that. no person may destroy' or take the nests, eggs. or young and any wild game bird. wild bird, or wild fowl TPW Code Chapter 64 does not allow for incidental take and therefore is more restrictive than the MB I A.



Ms i:aren Hubbard Page 6 September 11. 2014

The project area is located ss ithin the Central Flysvay . a mayr bird migration corridor that leads to the resas coast and Central South America Artificial nighttime lighting can attract and disorient night-migrating birds. Rtrds circling the lights' glare can cause colliston with substation structures or exhaustion mortality The EA does not identifv the best management practices IRVIN) that %sill be implemented by l'RECC regarding substation lighting to minimize lighting impacts on birds

Recommendation: TPWD recommends L.RECC irnplernent con sery ation measures presented in the CSFW S .Vatiorm ide Standard Con.wrvcason Measure< for reducing impacts to birds and their habitats. to as °id segetation clearing dunng the bird nesting season, to survey for nests if clearing is done during the nesting season. and to implement lighting RMPs TPW D recommends designing thc substation to utilize the minimum arnount of night-time lighting needed for safety and securit). TPWD recommends utilizine dark-sky friendly lighting that is on only ss hen needed. dosvn-shielded_ as bright as needed and minimizes Nue light emissions Appropriate lighting technologies and BAIPs may be found at the International Dark-Sky Association ssebsite Additionally. l PWD recommends avoiding the removal of trees svhich contain colonial viaterbird rookeries through route adjustments.

State La»

Parks a4d t.:444,1e-Si•ction 68 015

Section 4 4 3 of the EA states "The construction of a transmission line dors not include activ ities associated o.ithcollecting. hooking. hunting. netting. shooting. or snaring by any means or des ice. and does not include an attempt to conduct such actis ities Therefore. "take of state-listed specrcs as defined in Section 1.01i 5 of the I exas Parks and W ildlife Code, is not anticipated by this Project

Recommendation: Please note that the definition of take is presided in Section 1 101151 of the Parks and Wildlife Code rather than 1 01( 5 as stated in the 1-A Also note that m addition to take as defined in Seetion i 101(5i. Section 68 015 of the Parks and Wildlife Code identifies other prohibited acts regarding state-listed fish or ssildlife Section 68 015 of the Parks and W ildlife Code prohibits capture, trap, take. or kill. or attempts to capture. trap. take or kill ot statelisted fish or o. ildlife: thus. Alai% rues associated v. ith the project that trap or loll a state-listed species rnay be in s iolation of state task. There is no pros ision tor the capture trap. take. or kill (incidental or otherssiso ot state-listed species 1- fm:) recommends POWER and URECC res icy. the ITU.) Guidetine% _for Protet iron of .Stutc•Listed Species. Y. hid% can be found on the 1PW D vsebsite

Section 3 4 4 of the EA regarding the state-listed threatened species indicates that the Bachman's sparrovs (Peucaea at's:malts). bald eagle (Mahe:ems feueocephallo). ssood stork (Alp:terra americana). alligator snapping tunic t Vacrocheivs tentoninckal. Ratinesque's big-eared bat Wan norhmus ra,mesquiii umber ranlesnake rotaius horridu.$). blackside darter t Peri ma maculatai. hluehead shiner i ffcronorups, hohh.“), creek chubsucker i Eninnnon paddiefish Poi( ()skin spathula)



Ms. Karen Ilubbard Page 7 September 11. 2019

Louisiana pigtoc (Pleurobema riddellri). sandbank pocketbook (Lampsdis satura). southern hickorynut Whovarta jacksoniana). Texas heelsplitter IPotamdus amphichaenus). and Texas pigtoe (Fuseonaia askew) may occur within the study area. if suitable habitat exists.

The EA generally identifies potential impacts to wildlife and state-listed species. but dismisses the impacts as temporary. minimal, and less than significant. The F.A does not identify construction BMPs that would be implemented to avoid or minimize potential irnpacts to terrestrial state-listed species other than implementing .Vational Bala Eagle Management Guidelines if a bald eagle roost or nest tree is encountered during further biological surveys and allowing terrestrial state-listed mammals and reptiles to leave the ROW. if encountered.

Recommendation: PAD recommends URECC commit to implementing the terrestrial state-listed species BMPs recommended in IP \VD- s scoping letter (dated August 7. 20171 for this project including. but not limited to. a survey of the approved route to determine the potential of the ROA' to support state-listed species or their habitat. utilizing a biological monitor to be present during clearing and construction activities to assist in detecting state-listed species in the ROW, educating contractors of the state-listed species that may occur in the project area. avoiding harassment or handling of timber rattlesnakes, avoiding wildlife entanglement by only using wildlife-friendly erosion control matting. preventing entraprnent of wildlife in trenches, reporting occurrences of state.-listed species and species of greatest conservation need (SGCN) to the Texas Natural Diversity Database. marking sensitive areas with flagging or fencing to ensure they are not destroyed by construction equipment. and establishing native vegetation and pollinator resources within the ROVv. .

If the presence of a biological monitor during construction is not feasible. state-listed threatened species observed during construction shouki he allowed to safely leave the site or be translocatcd b a permitted individual to a nearby arca with similar habitat that would not be disturbed during construction. TP \VD recommends that any translocations of reptiles be the minimum distance possible 00 greater than one mile. preferably within 100-200 yards from the initial encounter location. 1- or purposes of relocation. surveys. monitoring. and research. terrestrial state-listed species may only be handled by persons authorited through the 1PWD

Wildlt re Permits Office

Section 4.4 1 of the FA identities potential adverse impacts to aquatic resources associated with construction in or near streams including changes in water quality and available habitat caused by erosion. siltation. and sedimentation and physical aquatic habitat loss or alteration where riparian vegetation is remov ed and at temporary crossings required kir access roads Section 4 3 1 indicates that band-cutting within the ordinary high water marks may be impkrnented where reasonable and limited to the removal of woody vegetation exceeding ten feet in height As protection measures to avoid or minimize adverse impacts to aquatic species. Section 4 4.3 or the EA indicates that LRLCC would span surface waters and wetlands and would implement a storm water pollution prevention plan to the extent practicable

DIRECT TESTIMONY OF RAMYA RAMASWAMY Febmary 19, 2020 0000041


Ms. Karen Hubbard Page 8 September I I, 2019

Recommendation: To avoid or minimize potential adverse impacts to state-listed aquatic species. TPWD recommends implementing additional stream protection measures which include diverting construction traffic around ater resources via existing roads. and constructing stream crossings that do not obstruct flow, do not prohibit upstream/downstream migration of aquatic wildlife. and do nut tramp(e freshwater mussels. if present. during placement of permanent or temporary fills/culverts.

Recommendation: If the project will require work within strearns. the project may need to be coordinated with the TPWD Kills and Spills Team iKAS I') for appropriate authorintion and to ensure protection of all native aquatic wildlife, not just state-listed species. fPWD recommends as oiding placernent of temporary fills. culverts or structures into waters serving as suitable habitat for freshwater mussels, lf construction occurs during times when water is present in streams and dewatering, fill or trampling activities are ins olv ed. then I PWD recommends relocating potentially impacted native aquatic resources in conjunction with a Permit to Introduce Fisk Shellfish or Aquatic Plants inw Public Waters and an AR RP. The ARRP should be completed and approved by the department 30 day5 prior to activity within project waters and/or resource relocation and submitted with an application for a no-cost Permi( to Introduce Fish. ShelltiNh or Aquatic Planis into Public Waters ARRPs can be submitted to Adam Whisenant TPW D Region 2 KAST available at Adarn.Whisenannatpwti.textrigov and 903-566-

Species of Greatest Conservation !Seed

In addition to state- and federally-proteeted species, SCUN and natural plant communities are tracked in the TANDD, and 1PWI) actively promotes their conservation. TPWD considers it important to evaluate and. il necessary. rninirnin impacts to rare species and their habitat to reduce the likelihood of endangemient and preclude the need to list as threatened or endangered in the future

Section 3.4.4 of the EA identifies the SGCN that have potential to kNA.1.1r within the proiect area, however. the TPWD online application identifying rare. threatened, and endangered species by county, (RIEST) has undergone a significant update as of April 2019 and now includes 23 additional SGCN lOr Harrison County , as well as 10111c species removals from the county list

Reco of end a lion: In addition to threatened and endangered spec les, 1PW D recommends that pre-construction survey's of the approved route include surveys to determine whether SGCN or suitable habitat lOr SOCN would be impacted as a result of the proposed project and to avoid or nUnimiLe impacts to the extent

The presence of a biological monitor is recommended dunng construction to identify rare plants. vegetation communities, and w Mille and to assist contractors w ith avoiding inlpaets tO any of these natural resources.



Ms. Karen Hubbard Page 9 September 11, 2019

Comment: TPWD encourages the assesstnent of irnpacts to all species and communities identified in the texas Conservation Action Plan (ICAP), T.VviDD. and Harrison County RTEST list. Broad Issues such as habitat fragmentation, habitat loss. and open-space land conversion, vs hich constitutes a majority of impacts caused by transmission line construction. are implicated in the decline of many Texas SCiCN. Because lexas contains largely privately-oyvned lands. these lands arc essential to the conservation of sensitive natural resources like SGCN a. identified in the TCAP. Thoughtful consideration of the impacts and potential conservation measures that can be impleniented to rninimin those impacts are recommended during the conversion of private land for public utility development.

PW D appreciates the opportunity to rev icy: and comment on this EA Please contact Ms. Karen Hardin at (903)322-5001 or Karen Hardin a tpvy diexas wy if you have any questions. Thank you for your favorable consideration.

Sincerely.

John Silovsky Wildlife Div ision Deputy Director

KlEjn.-122.18438146l

cc: Ms. Theresa Undervyood. tli&ECC System Engineer, tundemood a ureck..‘orn Ms. Karen Hardin



ATTACHMENT RR-3

Upshur Rural Electric Cooperative Corporation's Response to BMWB's 1st RFI

SOAH DOCKET NO. 473-20-0417 PUC DOCKET NO. 49603

APPLICATION OF' UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION UNE IN HARRISON COUNTY (HALLSVILLE - GUM SPRINGS)

BEFORE THE STATE OFFICE

OE

ADMINISTRATIVE IIF.ARINGS

UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION RESPONSE TO BMWS COALITION'S

FIRST SET OF REQUF.STS FOR INFORMATION

Question No. 1-9 Please consider an alternate route, narned - Route 4.1" consisting of the following combination of links: A-N-0-P-R-U-AC-AD-A1-AL-AM-ANI-AN2-AQ.

Please pros ide URF:CCs best av ailable estimate of the route e%,aluation criteria for this altemat is e route in the sarne forrnat as Table 4-1. Env ironrnental Data for Route Evaluation. which is contained in Application Attachment 13. Env ironmental Assessment and Alternative Route Analysis.

b. Please provide 11R ECC ' s best av ail able cost estimate for this al ternati e route in the same forntat as the cost estimates provided in Application Attachment 3. Costs-Application Question l 3.

c. lf I R.LCC is not willing to construct its proposed transmission line on this alternative route, please explain in detail why not

Ronm_m:

a. Please see Exhibit BMWB 1-9 Environmental Data for the following additional alternative routes:

Route 4.1: A-N-O-P-R-1 .-AM-AN1-AN2-AQ Route 4.2: B-0-P-R-U-AC-AD-A1-AL-AM-ANI-AN2-AQ Route 4.3: C-E-G-P-R-1 l-AC-AD-M-AL-AM-AN1-AN2-AQ Route 10.1: C-F-J142-7143-AE1 -AF.2-AH-AP Route 10.2: C-1: -Jl-J 24143-A L 1 -AR-AN2-AQ Route 13.1: C-1—.11-AS-T2-Z1-73-AEl-AR-AN2-AQ

S0,111 Doc kel .'so 47 3-20-04'. PLC DoL ka So 49603 LRECe s Response to RMWR Cualinun 3, l Page 11 (J1 22



b Please see Exhibit BM B I -9 Estimated "transmission 1.ine Costs for the additional alternatne routes listed above.

e. CRECC is willing to construct as proposed transmission line on this alternative route

Preparer(s). Gar!, McClanahan and Mitchell 13!rnes Sponsor(s): Gar!, McClanahan and Brian Tomlinson

SO IR Docket ‘,.) i Ikk kei So 49603 L REX_ C Re3ptour to 8 1,1i48 oalmon's RFI Polo




APPLICATION OF UPSHUR RURAL ELECTRIC' COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NF.CESSITV FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY DIALLSVILLE - GUM SPRINGS)


OF


UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION RESPONSE TO BMWB COALITION'S

FIRST SET OF REQUESTS FOR INFORMATION

Ouestion No.1-10 Please consider an alternate route. named - Route 4 2- consisting of the following combination of links B-O-P-R-L -AC-AD-M-AL-AM-AN1-AN2-AQ

a Please pro% ide URECC' s best av ailable estimate of the route e% aluation cntena for this alternative route in the same format as Table 4-1 Environmental Data for Route Ev aluatiom which is contained in Application Attachment 13. hnvironrnental Assessment and Alternativ e Route Anal sts

b. Please provide LIRECC's best available cost estimate for this alternative route in the same format as the cost estimates prov ided in Application Attachment 3. Costs-Application Question 13.

c If URFCC is not willing to construct its proposed transmission line on this alternative route. please explain in detail whv not

tpj.L_4se:

a. Please refer to Exhibit BMWB 1-9 Env ironrnental Data pro. ided in response to BMWB Coalition RFI No. 1-9 for the following additional alternative routes:

Route 4 : A-N-O-P-R-1:-AC-AD-AJ-AL-AM-ANI-AN2-AQ Route 4 2: B-0- P- R- L-AC-AD-AJ-AL -AM -AN I -AN 2-AQ Route 4 I - C-F.-G-P-R-U-AC-AD-A1-AL-AM-AN I -AN2- AQ Route 10.1: C-12 41424, -Z3-AL1 -AE2-AH -AP Route 10 2 - C-4-11-.12-Z1-/.3-AF1-AR-AN2-AQ Route 13.1 C-F-.11-AS-T2-Z -13-AE1-AR-AN2-AQ

SOAH Docker Vo 4'1-20441". C D9cker 49603 IIREC(' '5 Response to 8t1iB'oaf oion RE( Pax. 13 (nr 22



h. Please refer to lAhibit BMW B 1-9 Estimated Transmission Line Costs provided in response to BMWB C'oahtion RI-I No. 1-9 for the additional alternathe routes listed abuse.

URECC is ssilhng to construct its proposed transmission line on this alternative route.

Preparer(s) Gar) McClanahan and Mitchell 13)rnes Sponsonsi. Gar) McClanahan and Brian Tomlinson

SO-111 Docket Vo 4 -3-20-0417 PUC Do.thet %-o 490 URECC Response to 84113B Coahuon's I" Rti Page 14 of 22



SOAH DOCKET NO. 473-20-0417 MC DOCKET NO. 49603

APPLICATION OF UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE. OE CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSVILLE - GUM SPRINGS)

BEFORE THE ST.ATE OFFICE.

OF

ADMINISTRATIVE: HEARINGS

UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION RESPONSE TO BMWS COALITION'S

FIRST SET OF REQUESTS FOR INFOKMATION

Oucstion No. 1-11 Please consider an alternate route. names - Route 4 3" consisting of the follovving combination of links: C-E-C-P-R-U-AC-AD-A,1- AI -AM-AN I -AN2-AQ.

a. Please provide URECC • s best available estimate of the route evaluation criteria for this alternative route in the sarne format as Table 4-1, Fn. ironmental Data for Route Evaluation, which is contained in Application Attachment 13. Env ironmental Assessment and Alternative Route Analysis

Please prov ide URECC's best available cost estimate for this alternative route in the same format as the cost estimates provided in Application Attachment 3. Costs-Application Question 13.

c. If URECC is not %sitting to construct its proposed transmission line on this alternative route please explain in detail why not.

Re_m_insE:

a. Please refer to Exhibit BMWB 1-9 Environmental Data pro% ided in response to BMWB Coalition RE1 No. 1-9 for the follovving additional alternativ e routes.

Route 4.1: A-N-O-P- RA, -AC-AD-AJ-AL-AM-ANI-AN2-AQ Route 4 2: B-O-P-R-U-AC-AD-AJ-AL-AM-AN -AN2-AQ Route 4.3 C-E-G-P-R-U-AC-AD-M-AL-AM-AN1-AN2-AQ Route 10.1: C4'414241 -13-AEI-AL2-All-AP Route 10.2. C-F-,11-72-Z113-AEI-AR-AN2-AQ Route I n C-F-1 I -AS- T2-71-7.3-AF I -AR- AN2-AQ

SOAH Docket Su 4'3-20-041". P1'(' Pucka ‘o 49603 (.10.(1:- .1Re.p,mse Cootaton s 1" liF1 l'axe 13 ul :2



b. Please a:ter to Exhibit BMWB 1-9 Fstimated Transmission Line Costs pro% ided in response to BMWB Coalition REI No 1-9 for the additional alterTlaWde MLitt's listed ahme

c CRECC is illing to construct its proposed transmission line on this alternative route

Preparetls). Gar) McClanahan and Mitchell Byrnes Sponsortst: (far) McClanahan and Brian lomlinson

SOAn Pudic( No I 3 )0.-041 - tet .10 -14,603 I,WF( Revhoew eAfit oattflun s 101 Page If. ed



SOAH DOCK.ET NO. 473-20-0417 PUC DOCKET NO. 49603

APPLICATION OF UPSHUR RURAL ELECTRIC COOPERAT IVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSVILLE - GUM SPRINGS)


OF


UPSHUR RURAL ELECTRIC COOPERATI V E CORPORATION RESPONSE TO BMWB COALITION'S


Question No. 1-12 Please consider an alternate route, names - Route 10 1" consisting of the following combination of links: C-F-JI-J2-1, I 43-ALl-AE2-AH-AP,

a Please pro% ide CRECC's best available estimate of the route evaluation enteria for this alternative route in the sarne format as I able 4-1. Environmental Data for Route Evaluation. which is contained in Application Attachment 13. Env ironrnental Assessment and Alternative Route Analysis

b. Please provide URECC's best available cost estimate for this alternative route in the sante format as the cost estimates prov ided in Application Attachment 3. Costs-Application Question 13

c. If URECC is not vvilling to construct its proposed transmission line on this alternative route. please evplain in detail why not

Resjonse

a. Please refer to Exhibit BMWB 1-9 Environmental Data prov ided in response to BMWB Coalition RFI No. 1-9 for the following additional alternative routes

Route 4.1. A-N-0-P-R-U-AC-AD-AJ-AI -AM-AN1-AN2-AQ Route 4.2: 13-0-P-R-1 LAC-AD-A.1-AL -AM-AN1-AN2- AQ Route 4.1 C-F.-6-P-R-U-AC-AD-AJ-Al -AM-AN I -AN2-AQ Route 10.1: c.}-41-12-Z -/3 -AL I -AL2-AH-AP Route 10 2: C-F-J1-12-7.1-73-AF -AR-AN2-AQ Route 13.1: C-F-.11 -AS- 12-Z1 -Z3-AE -AR-AN2-AQ

SO•Ilð Do,ket Ne, .1"j-2()-04/ C DUcka Nu POO L REt'C's Rehoonar zo BtlWBC'oularrar $ RH Page 1 - al 22



h. Please refer to l..xhibit BVIWB I -9 Estimated Transmission Line Costs pro% ided in response to BMW B Coalition RI-I No. I -9 for the additional alternative routes listed above

c. IIRECC is wilhng to construct its proposed transmission line on this alternati‘e route.

Preparens): Gar) McClanahan and Mitchell By riles Sponsor(s) Gar!. McClanahan and Brian Tomlinson

SOAP' f ()whet Au 4"3-21.1-041" PEA' kef ,No 4Y60.1 URE( C . 's Response go BMWR Codason 1" RFI Pak,' l EA/ 22



SOAH DOCKET NO. 473-20-0417 PUC DOCKET O. 49603

APPLICATION OF UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSVILLE - GUM SPRINGS)


OF


UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION RESPONSE TO BMWB COALITION'S

FIRM' SET OF REQUESTS FOR INFORMATION

Question No. 1-13 Please consider an alternate route. named "Route 10.2- consisting of the following combination of links. C-E-.11-J2-/1-/3-All-AR-AN2-AQ.

a. Please provide URI-CC's hest available estimate of the route tn. aluxion eritena for this alternative route in the same format as able 4-1. Env ironmental Data for Route Evaluation, which is contained in Application Attachment 13. Environmental Assessment and Alternative Route Anal)sis.

b. Please provide URECC's best available cost esurnate for this alternativ e route in the same format as the cost estimates prov ided in Application Attachment 3, Costs-Application Question 13

If URECC is not v. illing to constnict its proposed transmission line on this alternativ e route, please explain in detail why not.

Response

a. Please refer to Exhibit BMWB 1-9 Environmental Data provided in response to BMWB Coalition Rt.! No 1-9 for the following additional ahernative routes

Route 4,1: Route 4 2: B-0-P-R-1.1-AC-AD-AJ-A1.-AM-AN1-AN2-AQ Route 4 3: C-E-G-P-R-U-AC-AD-AJ-AL-AM-AN -AN2-AQ Route 10.1: C-F-.11-12-71-7.3-AE1 -AE2-AH-AP Route 10.2- C-1 -.11-12-/1-13-AE l -AR-AN2-AQ Route 13.1. C-F-J1-AS-12-71-7.3-AEI-AR-AN2-AQ

SUVI Docker Nu 47.1-20-041- , PIV-Docket Va 49(03 URECCr Rerponse to MA1158 c oahnon RI. I rage 19 44 22



h Please refer to If.xhibit BMWB 1-9 Estimated Transmission Line Costs prtnided in response to BMW1-1 Coalition Rh I No. 1-9 for the additional altemathe routes listed above.

URECC is willing to construct its proposed transmission line on dus alternati‘e route.

Preparer(s): McClanahan and Mitchell By rnes Sponsor(s): Gary McClanahan and Brian ^I omlinson

SOAH Docket Vo 4 - 3 20-041" Ducke •Vo 4003 s Response to BUWB coalition's 1" RP! Page 20 oy 22




APPLICATION OF UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSVILLE - GUM SPRINGS)

BEFORE THE STA rE OFFICE

OF


PSHUR RURAL ELF.CTRIC COOPERATIVE CORPORATION RESPONSE. TO BMWS COALITION'S


Ouestios No. 1-14 Please consider an alternate route, names -Route 13.1- consisttng of the following combination of links- C-F-J1-AS-T2-Z1-Z3-AE I -AR-AN2-AQ.

a. Please provide URECC's best available estimate of the route o al uation criteria for this alternative route in the sarne format as Table 4-1. Env ironmental Data for Route Evaluation, which is contained in Application Attachment 13. Env tronmental Assessment and Alternative Route Analysis.

b. Please provide URECC's best available cost estimate for this alternative route in the sarne format as the cost estimates provided in Application Attachment 3. Costs-Application Question 13.

If URECC is not willing to construct its proposed transmission line on this alternative route, please explain in detail why not.

Reia_mse:

a. Please refer to Exhibit BMWB 1-9 Environmental Data prov ided in response to BMWB Coalition REI Nu. 1-9 for the follovving additional alternative routes.

Route 4.1: A-N-O-P-R-U-AC-AD-AJ-AL-AM-AN l -AN2-AQ Route 4.2: B-0-P-R-U-AC-AD-AJ-AL-AM-ANI-AN2-AQ Route 4.3: C-E-O-P-R-U-AC-AD-A1-Al .-AM-AN1-AN2-AQ Route 10 1: C-E-J I -32-ZI-Z3-AE1-AF.2-AH-AP Route 10 2: C-f-.11 -12-71-Z3-AEI-AR-AN2-AQ Route 13.1: C-1:-.11-AS-12-Z1 -Z3-AEI-AR-AN2-At)

SO.411 Ducker No 4- 3-20-041- , PLC Doaet 45,603 L'RE(1- s Response in BMR Cf)ahtwn a I" Rici rage of


SOAFI Docket No. 473-19-6766 PUC Docket No. 49523 Page 54

Please refer to I .xhibit BM W13 1-9 Estimated Transmission Line Costs pro% tried in response to BMWB Coalition RI.1 No 1-9 for the additional alternatne routes listed above.

IRECC is willing to construct its proposed transmission line on this alternati‘e route.

Preparer(s): Gan. McClanahan and Mitchell Fš rnes Sponsons): Gary McClanahan and Brian Tornlinson

SOW! Docket At) 4- 3-204)417. rt,c Docket No 49603 1•1?Et' Responce to IAMB Coularon's 1" la 1 Page 22 22



ATTACHMENT RR-4

Upshur Rural Electric Cooperative Corporation's Response to Christopher Tucker's First Set of Requests for Information


APPLICATION OF UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE LN HARRISON COUNTY (HALLSVILLE - GUM SPRINGS)


OF

ADN1INISTRATIVE IIEARINGS

UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION'S RESPONSE TO CHRISTOPHER TUCKER'S


Tucker-Upsbur 1-25

Please consider an alternate route, named "Route 1.1- consisting of the following combination of segments: A-M-Al -A L-AM-A N1-AN2-AQ.

a. Please provide URECC's best available estimate of the route el. aluation criteria for this alternative route in the same format as table 4- 1. Env ironrnental Data for Route Evaluation, which ts contained in Application Attachment 13, Environmental Assessment and Alternative Route Analysis

b. Pkase provide URECC's best available cost estimate for this alternative route in the same format as the cost estimates provided in Application Attachment 3, Costs-Application Question 13.

c. If URECC is not willing to construct its proposed transmission line on thts alternative route, plrase explain in detail why not.

Response:

a Please see F.xhibit Tucker-Upshur 1-25 Environmental Data for the hillowing Addnional Alternative Routes•

Route 1.1. Route 4.4: Route 9.1: Route 9.2. Route 14 • Route 14 l•

A-M- Al-AL-AM- AN -AN2-AQ A-N-0-Q-AB-AC-AD-AK-AN1-A.N2-AQ B-0-P-R-1.1-AC-AD-AK-AN1-AN2-AQ B-O-P-R-V-W- Y-AE1-A E2-AH-AP B-O-Q-AB-AC-AD-AK-AN1-AN2-AQ B-O-Q-AA-A I-AL-AM-AN I -AN2 -AQ

b. Please see Exhibit Tucker-Upshur 1-25 Estimated Transmission Line Costs for the

SOAH Dotiet ,No 473-20-04r PUC Docket No 49603 CRECC s Responses to C Tucker's 1st Rfl

uRECC _00011



additional alternative routes hsted above. c. URECC is willing to construct its proposed transmission line on this ahernative

route

Preparer: Gra) Rackiey and Brian Torahnson Sponsor Gary McClanahan and Brian Tomlinson

awke No 41 , 20.041- , PLC Ducat! J 40603 CRECY' "t Resportie.s to C Tucker s 1st 10

ORECC 00034



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uRFCC_0003$



Exhibit Tneker-Upsbur RFI No. 1-25 Estimated Transmission Line CO319

&mats. Route 1.1

Alternate Alternate Route 9 I

Alternate R. te 9.1

....t.kmat, ‘$,, erg_itto_t Route 4 4 Roctle 14 Kral. 14.1

Illght-ot-ony and Load 5cC106113146 51.473 926 SI 511 744 SI 3214469 S t 373,283 51,346 179 51 426 107

Engineering and Detiga (1 'bitty) $694 103 5719,617 5620.359 5645,174 5632 767 5669 911

£66164ortai 6641 D6111111 Wont rod( $611.606 5674.377 5511 791 5605.063 Ss93.427 5628,114

rewarmed( o) Material find Ectolyment (ncludlog .tore.) 1125,152 5751 465 5647 114 5673,727 5660.7/1 3699.639

Cotatructioo of Venlig/6s (Utlltly) 6121 137 5I31 459 6115 051 5119.651 5117.35 5114.715

Coontrortion o( Fac4l(tle4 (Contract) S1,738,210 51,200 361 SI 152,031 51,614.117 SI 113.076 51.676,191

Other tall ewsts net tncloded In the abo3e canegorle.) S1.024,991 SI 061.605 5915.177 5951,784 3911 460 (932,391

tattooed Total li. ost 56,442.145 56,672.946 53,752 540 33 912 642 53.867 591 36,212.743

C4'4 Proceedlna Estimate 6360.021 21 5130 091 31 3500,078 77 5520 031 91 5513 010 35 5140.085 01

Connogracy S464,909 55 5431,511 46 5415,097 11 5431.701 72 5423,399 77 5.34,105 61

Mternahre Rowe Length (Rottotledl




APPLICATION OF UPSHUR RURAL F.LECTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIF,NCE AND NECESSITY FOR A I38-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSV1LLE - GUM SPRINGS)


OF

ADMIMSTRATIVF. HEARINGS

UPSHUR RURAL ELECTRIC COOPF.RATIVF. CORPORATION'S RESPONSE TO CHRISTOPHER TUCKER'S


Tucker-Upaltur 1-26

Please consider an alternate route, named "Route 4.4" consisting of thc following combination of segments: A-N-0-Q-AB-AC-AD-AK-AN1-AN2-AQ

a. Please provide URECC 's best available estimate of the route evaluation criteria for this alternauve route in the sarne format as Table 4- 1, Environmental Data for Route Evaluation, which is contained in Application Attachment 13. Environmental Assessment and Alternative Route Analysis.

h. Please provide URECC's best available cost esttmatc for this alternative route in the same format as the cost estimates provided in Application Attachment 3, Costs-Application Question 13

c. If URECC is not willing to construct its proposed transrnisston line on this alternative route, please explain in detail why not.

Response..

Please refer to URECC's rebponse to Tucker-Upshur RFT No 1-25

Preparer Gray Rackley and Brian I onilinson Sponsor Gary McClanahan and 13rian Tomhnson

Sa.111 thhiet No 4'3-20-0417 PUC Llocker o S9603 URECC 's Responses C Tucker J 151

URIC _00037


SOAH Docket No. 4'73-19-6766 PUC Docket No. 49523 Page 60


APPLICATION OF UPSFIL R RURAL ELECTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A I 3.11-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSVILLE - GUM SPRINGS)


OF




Tucker-Upabur 1-21

Please consider an alternate route, named - Route 9.1- consisting of the following combination of segments- B-O-P-R-U-AC-AD-AK-A N I -AN2-AQ

a. Please provide URECC"s best available estimate of the route evaluation cntena for this alternato.c route in the saint format as Table 4- I. Environmental Data for Route Evaluation, which is contained in Application Attachment 13. Environmental Assessment and Alternative Route Analysis Please provide URECC's best available cost estimate for this alternatise route in the same format as the cost estimates prosided m Application Attachment 3. Costs-Application Question 13 If URECC is not wilhng to construct its proposed transmission hne on this aiternabse route. please explain ir. detail why not_

Respoase:

Please refer to URECC's n.isponse to Tucker-Lpshur REI No. 1-25

Preparer: Gray Rackle, and Bruin Tomlinson Sponsor: Gary McClanahan and Brian Tomlinson

SO411 DoLkei 4 -3-20-041 - PI (' fkx*er o 49603 UREIc Responses la C Tucker s !r: RFI

uRE-cc_cou35




APPLICATION OF UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION T() AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSVILLE - GUM SPRINGS)


OF




Tneker-Upshur 1-28

Please consider an alternate route. narned "Route 9 2" consisting of thc following combination of segment.s: 13-0-P-R-V-W-Y-AEl-AE2-AP.

a. Please provide LRECC's bcst availabk estimate of the route evaluation criteria for this alternative route in thc same format as Tabk 4- 1, Environmental Data for Route Evaluation. which is contained in Application Attachment 13, Environmental Assessment and Alternative Route Analysis.

b. Please provide URECC's best available cost estimate for this alternative route in the same format as thc cost estimates provided in Application Attachment 3. Costs-Application Question 13.

c. If URECC is not willing to construct its proposed transmission line on this alternative route, please explain in detail i.vhy not

Response:

Please refer to I IRECC's response to Tucker-Upshur RH No, 1-25.

Preparer: Gray Rackley and Brian Tomlinson Sponsor. Gary McClanahan and Brian lomhnson

SO411 Docket No 41.1-20-041 7; ITC Docket No 49603 URECC's Responses to C. hider's 1st R1.1

1iRECC_00339



SOAH DOCKF.T NO. 473-20-0417 PUC DOCKET NO. 49603

APPLICATION OF UPSHUR RURAL ELECTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY (IIALLSVILLE - GUM SPRINGS)


OF




lucker-Upsbur 1-29

Please consider an alternate route, named "Route 14" consisting of the following combination of segments. B-O-Q-AB-AC-AD-AK-ANI-AN2-AQ

Please provide I IR EC("s hest available estimate of thc route evaluation critena for this alternative route in the same format as Table 4- 1, Environmental Data for Route Evaluation, which is contained in Application Attachment 13, Environmental Assessment arid Alternative Route Analysis.

b. Please provide URECC's best available cost estimate Ibr this alternative route tn the same format as the cost estimates provided in Application Attachment 3. Costs-Application Question 13.

e IfIJRECC is not willing to construct its proposed transmission I me on this alternative route, please explain in detail why not

Please refer to URECC's response to lueker-Bpshur tal No I -25

Preparer. Cita) Rackley and Bnan loinlinson Sponsor. Clary McClanahan and 13rian I umlinson

„ . 4"3 10 041, , PUC Docker No 49603

ResPOIL.C.f iuC hider

URECC 00040




APPLICATION OF UPSHUR RURAL ELF.CTRIC COOPERATIVE CORPORATION TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSVILLE -GUM SPRINGS)


OF


UPSHUR RURAL F.LECTRIC COOPERATIVE CORPORATION'S RESPONSE TO CHRISTOPHER TUCKEWS


Tucker-Umber 1-30

Please consider an alternate route. named "Rome 14 1" consisting of the following combination of segments B-40-Q-AA-A1-AL-AM- AN 1 -AN2-AG.

a. Please provide URECC's best available estimate of the route evaluation criteria for this alternativ e route in the same format as fable 4- 1. Environmental Data for Route Evaluation. which is contairved in Application Attachment 13. Environmental Assessment and Alternative Route Analysis

b. Please provide URECC's best available cost estimate for this alternative route in the same format as the cost estimates provided in Application Attachment 3. Costs-Application Qucstion 13 If URECC is not willing to construct its proposed transmission lme on this alternative route, please explain in detail why not.

Response:

Please refer to URECC's response to fucket-Upshur RFI No 1-25

Preparer Gray Rackley and Brian Tomlinson Sponsor Gary McClanahan and Brian 1 omlmson

SOAR Docket No 473-20-041', Docket Nu 06(13 URECC'3 Respormes Tucker's Jzt RFI

URECC_0.1041



ATTACHMENT RR-5

Upshur Rural Electric Cooperative Corporation's Response to Intervenors Cherry Ridge Ranch LLC and 4-Sight Operating LTD.'s 1s1 RFI

SOAH DOCKET NO. 473-20-0.117 Pl. C DOCKET NO. 49603

APPLICATION OF UPSIIUR RURAL ELECTRIC COOPERATIVE CORPORATION '10 ANIEND 11S CERTIFICATE OF CONVF.NIF,NCE AND NECESSITY FOR A 138-KV TRANSMISSION LINE IN HARRISON COUNTY (HALLSVILLF - Gt M SPRINGS)


OF


UPSHUR RURAL ELECTRIC COOPERATIVE CORPORA f ION RESPONSE TO INTERVENORS CHER.R1 RIDGE RANCH 11 AND 4-SIGH I

OPER.ATING LTD.'S FIRS F SET OF REOUF.STS FOR INFORMA FION

RFI No. 1-1. Please consider an alternate route. named - Modified Route 5 I," constructed trom the flails% ille substation to ()um Springs substation using Segments C. F, G. P, R. V, W, X. AD, AK. AN1, A \ 2 and ,NQ

Please provide 1 Ipshur Rural's best as adable estimates 01- route metrics for this alternative route in the same format as fable 4- l of Attachment I 3, Fris ironmental Assessment and Ahernative Route Anal!, sis. of the CC,s Application

Please provide t:pshur Rural's hest available cost estimate for this alternate route in the same forrnat as the cost estimates pros ided in Attachment 3 - Application Question 13. Alternative Route Cyst aluation, of the CCN Applieation

If tIpshur Rural is nut %Ming to construct its proposed transmission line on this alternate route, please explain in detail ssliv not

Response.

a Please refer to I xhibit Chem Ruige and 4 Sight R1-1 1- la h Please refer to I•xhthit Cherry Ridge and 4-Sight RI I Ko I - Its

LIR! ,CC is vs ill ing to construct its proposed transmission line on this alternattse route

Preparer Gary McClanahan and Brian I omlinson Sponsor 6:try McClanahan and Brian Tomlinson

Sir tr/ Iter 5 .1'.5 ,.20 041'. 1'1( Dot Ael Nu—P/6-0.1 I tic %pock. h. i Swert Rtdo X 4 Ahgtt is, /


SOAH Docket No. 473-19-6766 PDC Docket No. 49523 Page 65

EXHIBIT CHERRY RIDGE AND 4 SIGHT RFI 1-ls ENVIRONMENTAL DATA FOR ROUTE EVALUAT/ON cram

Lana We kale it ' LAN WM*. TA.* 5 i 2 Nuour a Ube -cum' -11, 300 NW 111 111 4.1* cananft

MIMI, d' qsPI Swd Memos mtnne leVed

I 1.60911 Y rauy er.7 entni . irsordesno go oordo..In lia

mop ce.3.1.1,4l1 Ild *mini eadpc ranwo, soo. oo *Omuta, me V*

5 Alrgai s' -ado molod to ace, lasing canaille C.71 NOW. CAM '4r.... OE

7 i nyon Snub pirelon t3 AFAINri wow. Ole :cy on, VLF* a Cr.J11,4 *Am! 2 .i A mil d two. war t. sceke

iy.toron cn 1..na Wass AMIN. esloV11 rola

1 06, et 1011,10,11 961.5. /MOO AeAc ve7un X2 WOirqNAFA UAW+,

1 1 Alp cIA3 mss '...*Aire

11 LorgI,PQA*A.CAS paraVilipeirt ,rcit.teC a usn eAsaA1 lAAANANI

13 twirl or UM aro 6 Vav oT,aila cue Tao** Solerni ellrq ePAA,AAF

ft t..rgm Ince Amu ;wept% nom, 21

15 041, c< ca.a.tvaillp

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11 "Linter el 1(11011111.1H1 J5 '1.pd4r oJS 4.71 and Stooli V.v., (S-1; ace.s.

11 Panebnr d (.1r I> 144i.11 ,F Al: or 9."0. *MaNg AM; ma] :ATIAless

15 vole v arnew,es 0,5d, 1 555 um cfrte 2A1A Awn/aNre

Z( .4**4 0,,,A7 .AA alins age, 1,31213 ilia Oft Mar Mralryri

:. Nonl.' cn VIP. arr SUMO 11 No 'DA wis.-e

72 n......ak .1.11dieed sive tn.o.......3 7J111*1 =to 221(13 a.4 11,30. IN.

72 9 en 41 FAA tipsioncl ArcAn 7..,..r5 . 401, 1C 3 ftsi To ,A.,* ...sr.

24 \nar, ,,on., ...d 4noodaial. Alod.A.Le tAwl rdtc '.s'cc.r, c,lsct wax k*/ ru ..or rox,,c

Ly.. ,-.3s CMr.ac franur*I rnacANaus Doom an alc 1 J.,111 adE 4 No v..18:-INVIT.

2fi 1*.riM 01ttas.np «in *all arm 202 rort .0 re lor xelerre

FtFA- Ile. 31 a 02 Vu. vAtior 113 lee al Tne mode artanws

AOSAINGI lb r^ *ups v.a ow keeq-Axid nes At rimilla JS arol Soma 1pflulp

2. 01.11114 411r Cr ,01.19 affon rtresto.re 414,141 IWO Of VOW sans

74 inzec larv. * arm' 121110,09 v ora c' :a.542L1021117.11 re..

Eaforf

31 Lerçtr 7 acid au.. toanndanimanan ‘gladats 1 VFW CF rale Iva* 421art Woo 3 3 11

3 4, 1r.... FISCSUSF4/$1.110.21 alb wird:. sel.TC1

31 LnOçIr Y lat 1r1CS3 ARTA a;coode hot.* cl Wig*, ,e0s1CeltArcweil 7 snored owes

IS anon d .ana alas nix yam arla. tor '

N. Edo of cor ,oll,

•rsrld tn.. ay** (who lai *an ra w.a.a 7,eft

31 20 &a91r a vas annss Om , awca 14C oar IOXG6.".

Calm* lileaucee

.71 Ñocflppncc Alartht I l'AC / 3,17*.0 WS c'essi cy AA*

4C, pciror 8MANION* Aged cat . t7efolourc s1es wiln ' 3X 1•41 a/ raJle.rien

4 Nu WI cl NAlAnal an** AM Ms =Awl *, Auff

43 *4 mtAA of 4010:Aal %PAW 1001 5* , 7,1, 1 SO Is. cs mreCeI*1,*

A 1ANT d IAA* Kttei. IVA AVAACKSKAut slc,..* 3. 1.161,,4O

SINCLIT,11-1Ny Cticatal I,ncrnlcc rwarmate t visec c. News co *Fat, N, 4l5.w 1.1114/ ...Are cr..*reI A.: re me 14,141241t 14.4•11,41 .V''114,1114n1.1.441l1c14 P1 'NW 1.1411.1% 4aiT,1!.,11•Tg ccrnnc'.na s:Nr-Ars Oltsto r.T.C1-rek )41,11141,...A•As CARA* -VIM" .r.r§r1 Hmel and wt.* 140.1 et. POI.* or... at liaceiCe ce,cccn. aNc NO .1 Or Mar.. ',xi UV* ra flat cr Fr FAA NA 'AWN..., AN,

'MAAR F/AArces 3trtfOlat 41 "44421u4ri 1.41.11 .1•14, ..” N.•111.11241 146, 441 Fur,. ,A141 impans.- N 4a14,9 "IL* Nun escalei clacc4ail ..14ttC. ADM or crepel,

V.aq. oral owlet s.ara molt 'Waft W.* AA --Fr must NoNar 41 N. arp'scl nrtc casl.ccenn 11.4.44111.1 Wer,a1 a calf all swansa sea own or 4 4114.41111141.141 . 4.14 11' 9C1411

.11a3 OW Sum,. Scur CeAra U :1 4.1. X *tan. gm,. al :It S1,11 - r's* WAS 0 'CO.

1,45thltet Rale 51 CF GPR ADAK 0,517 AC,

0000-I



Exhibit Cherry Ridge and 4-Sight RF1 No. 1-1 b Estimated Transmission Line Costs

Altentate Route 5.1

Right-of-way and Land Acquisition SLY/3.288

Engineering and Design (Utility) S645. 1 74

Engineering and Design (Contract) S605.063

Procurement of Material and Equipment (including stores)

$673,727

Construction of Facilities (Utility) S )19.653

Construction of Facilities (Contract) 51.614.117

Other (all costs not included in the above categories)

S951.784

Estimated Total Cost S5,982.642

Breakdown of Other Costs:

CCN Proceeding Estimate S520.082

Contingency 5431.702

Alternative Route Length (Rounded) 5 2

00003


Documents

Control Number: 49603 1 II II 1 - TransmissionHub.com · 2020. 2. 21. · RAMYA RAMASWAMY INFRASTRUCTURE DIVISION PUBLIC UTILITY COMMISSION OF TEXAS February 19, 2020 0000001 . SOAH