Nogales Transmission, L.L.C. and Nogales Frontier Operations, L.L.C., Docket No. EL Second Supplement to Petition for Declaratory Order

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1 Eversheds Sutherland (US) LLP 700 Sixth reet,, Suite 700 ashington, DC D: F: eversheds-sutherland.com June 30, 2017 Via Electronic Filing Hon. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First.,.E. ashington, DC Re: ogales Transmission, L.L.C. and ogales Frontier Operations, L.L.C., Docket o. EL Second Supplement to Petition for Declaratory Order Dear Ms. Bose: ogales Transmission, L.L.C. ( ogales Transmission ) and ogales Frontier Operations, L.L.C. ( ogales Operations ) (collectively Applicants ) hereby provide this second supplement to their December 21, 2016 Petition for Declaratory Order ( Petition ) to reflect a recent electrical reconfiguration of the Project s interconnection with the US Electric, Inc. ( USE ) grid. This reconfiguration is not material to the relief requested in the Petition, but Applicants are providing this information to ensure the accuracy of the technical information contained in the Petition. I. Purpose of the Reconfiguration The purpose of the electrical reconfiguration is to make the Project more costeffective. Specifically, a detailed engineering analysis conducted by USE as part of the Project interconnection study determined that USE would avoid approximately $11 million in costs if the Project connected to its transmission system from the Gateway Substation rather than, as originally proposed, USE s Valencia Substation. That engineering analysis determined that the Valencia Substation could not accommodate an additional circuit, and connecting the Project there would require a complete rebuild of the Valencia Substation on a larger footprint. The cost for this rebuild would be approximately $15 million. In contrast, terminating the existing USE transmission line at the Gateway Substation would require additional facilities that would cost approximately $4 million but would avoid the need for a rebuild of the Valencia Substation. II. Description of the Reconfiguration Conceptually, the new configuration connects the Project to the USE system at the planned Gateway Substation rather than, as originally proposed, at the existing Valencia Eversheds Sutherland (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit

2 Hon. Kimberly D. Bose June 30, 2017 Page 2 Substation. That connection will be accomplished by severing the existing USE Vail-to- Valencia 138-kV transmission line and connecting it to one circuit of a new, approximately 3-mile long, overhead double-circuit 138-kV line, to be constructed and owned by USE. This circuit will originate at an existing pole 1,900 feet west of the existing Valencia Substation and terminate at the new Gateway Substation, thereby converting the existing Vail-to-Valencia transmission line to a new Vail to Gateway transmission line. The second circuit will originate at the Gateway Substation and proceed in an easterly direction, utilizing the other side of the new double-circuit 138-kV line, to a pole 1,900 feet west of the existing Valencia Substation, where it will connect with the existing portion of the USE 138-kV transmission line that travels east to the Valencia Substation. This circuit will constitute the new Gateway to Valencia transmission line. The reconfiguration is shown on the map included as Attachment 1. The reconfiguration does not change the proposed Project route or right-of-way requirements, and as compared to the original configuration would have equal or better reliability. III. Conclusion The updated electrical configuration contained in this Second Supplement is provided to ensure the continued accuracy of the technical information provided in the Application. Please contact us should you have any additional questions or need additional information. Respectfully submitted, /s/ Daniel E. Frank James M. Bushee Daniel E. Frank Counsel for ogales Transmission, L.L.C. and ogales Frontier Operations, L.L.C.

3 Attachment 1 Map of Project Reconfiguration

4 Dr Ave Jose Gallego Dr MariposaRanch Frank Reed Paul Bond Dr Shell Loop Mariposa Mastick ay VALECIA SUBSTATIO Ln Smokey E Cll Sonora OPTIO 3 MAY, 2017 OGALES ITERCOECTIO!( PROPOSED GATEAY SUBSTATIO AB 189 Bell Manor Dr Industrial Park Dr Grand Ave! Phoenix! Tucson PATH: \\MSPE-GIS-FILE\GISPROJ\HUT\244842\MAP_DOCS\DRAFT\DOE\OPTIO3_11X17L.MXD - USER: STUOHEY - DATE: 5/31/2017 Target Range Freeport Mariposa Mariposa Cam la Quinta de Mariposa lapaloma Vista Dr Linda Industrial Park Cll Canada Quinta Cimarron Canada Target Range Target Range U n i t e d S t a t e s M e x i c o 19 estern Ave Macnab Dr Anthony Dr alnut oon Crawford Curtis est International Hughes Elm Kelsey Ave estern Pl Dr Highland Plum Oak Terrace Ave Grand Ave Loma Quarry estern Ave Hwy Blvd Arroyo Tucson-ogales elson Ave Cam del Pajarito Smelter Sonoita Ave Grand Court ;=19 Plz E Court E East Anza Dr Sage Ellis Sol EscaladaDr Martinez 2nd Burk 2nd Kolver E Beck 1st First Kino Potrero Ave E Hudgins Grand Ave Morley Ave 3rd E Adams E International Tucson-ogales Hwy Hohokam Dr Tyler Perkins E Edward Perkins Ave Bankerd Ave E Grant!( Origination Point Substation Site 230 kv Route Alternative 138 kv Double Circuit Route Alternative Existing UniSource Energy Services Vail to Valencia 138 kv Access Road International Border Interstate / US / ate Highway Other Road Coronado ational Forest OTES: 1.. TARGET RAGE RD IS A PUBLIC ROAD AD CA BE SURVEYED. 2. EXISTIG EASEMETS CA BE SURVEYED BY RIGHT OF EASEMET. O 0 Miles 0.5

5 Certificate of Service I hereby certify that I have this day served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated at ashington, DC this 30th day of June, /s/ Daniel E. Frank Daniel E. Frank