IN THE MA7TER OF THE APPLCIATION OF 1

Transcription

1 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATER OF THE APPLCIATION OF 1 ENTERGY ARKANSAS, INC. FOR A 1 CERTIFICATE OF PULIC CONVENIENCE AND ) NECESSITY TO CONSTRUCT, OWN AND 1 OPERATE A 11 KVTRANSMISSION LINE AND ) ASSOCIATED FACILITIES, IN CARROLL 1 COUNTY, ARKANSAS ) DOCKET NO U PREPARED TESTIMONY OF CIARK D. COTTEN SENIOR ELECTRICAL ENGINEER ON BEHALF OF THE GENERAL STAFF OF THE ARKANSAS PUBLIC SERVICE COMMISSION JANUARY,010

2 DOCKET NO. 0-1 IO-U 1 1. QUALIFICATIONS Q. Please state your name, employment and business address. A. 4 My name is Clark D. Cotten. I am the Senior Electrical Engineer for the General Staff (Staff) of the Arkansas Public Sewice Commission (APSC or Commission) in its Telecommunications and Quality of Service Section at 4000 Center Street, Little Rock, Arkansas. Q. Please state your qualifications and background. A. I earned a Bachelor of Science degree in Electrical Engineering from the University of Arkansas in 'l, and 1 have been a registered Professional 10 Engineer in Arkansas since 1. Before joining Staff in November 1, I was employed by Arkansas Power and Light Company {now Entergy Arkansas, Inc.) or Entergy Services, Inc. for twenty-two years. I have attended the National Association of Regulatory Utility Commissioners' two-week Annual Regulatory Studies program at Michigan State University and 1 have submitted testimony before the Commission addressing applications for Certificates of Public Convenience and Necessity (CCN), Certificates of Environmental Cornpati bility and Public Need (CECPN) for both electric transmission facilities and power generation facilities, the treatment of transmission facilities in rate unbundling -1-

3 DOCKET NO dockets, the acquisition of electric generating facilities, power factor issues, and miscellaneous tariff filings. II. PURPOSE 4 Q. What is the purpose of Entergy Arkansas, Inc.'s filing in this Docket? A. On October, 00, Entergy Arkansas, Inc. (EA[ or the Company) filed an Application for a Certificate of Public Convenience and Necessity (CCN) as required by Ark. Code Ann et seq., to construct and operate a new 11 kilovolt (kv) transmission switching station and a connecting A1 kv transmission line segment and related transmission facilities in Carroll County, 10 Arkansas. The transmission switching station, to be called the Grandview I Switching Station, will establish a new transmission interconnection between EA1 and the Southwest Power Administration (SPA) and will be constructed on the SPA'S existing transmission line connecting the hydroelectric facilities of Table Rock Darn and Beaver Dam. The new connecting transmission line segment will extend approximately miles from the proposed Grandview Switching Station to connect to EAl's existing transmission facilities at Arkansas Electric Cooperative Corporation's (AECC) Osage Creek metering point and substation located near Berryville, Arkansas. --

4 DOCKET NO This transmission line does not constitute a major utility facility as defined in Ark. Code Ann. -1-0()(A). Therefore, this Application is filed pursuant to Ark. Code Ann et seq., and Rules.01 and.04 of the Commission s 4 Rules of Practice and Procedure (RPP). In support of this Application, the Company filed the Direct Testimonies of Greg A. Borne, Michael D. Doyle, Charles W. Long, William R. Frizzell, and the Direct and SuppIementaI Testimonies of Dr. Gary E. Tucker. Q. What is the purpose of your Prepared Testimony? IO 11 A. The purpose of my testimony is to present my evaluation and recommendations regarding the need for, and the design and construction of, the proposed switching station and transmission line facilities. I will also present my evaluation of the factors to be considered in determining the reasonableness of the proposed transmission line route and my recommendation regarding whether the proposed facilities are in the public interest CCN EVALUATION 1 Q. What is the basis for your evaluation of the request for a CCN? 1 1 A. My evaluation of the request for a CCN is based on state law, previous Commission Orders, the Commission s RPP and Special Rules - kcfric, the --

5 DOCKET NO. 0- I 40-U 1 Company s Application, and my evaluation of site information provided for he proposed facilities. Q. Have you visited the site of the proposed facilities? 4 A. Yes. On December 1, 00, two representatives of EA1 and I examined the three optional routes for the transmission line and switching station. I also have reviewed aerial photographs of the Company s routing proposals. Need For The Facility Q. Please describe the Company s need for the proposed facility. A. IO I1 4 1 EA1 witness Long states that the Osage Creek Substation, owned and operated by AECC, is presently served by two 11 kv transmission line segments. These segments originate at the Eureka Springs and Harrison East substations. Should an event occur requiring the Eureka Springs - Osage Creek 11 kv line segment to be removed from senrice during times of peak loads, overloading may OCCUF on the EA1 11 kv Harrison East - Osage Creek transmission line, and low voltages in the Osage Creek, Green Forest, Berryville, and Harrison areas may occur requiring local load shedding to avoid facility damage. Direct Testimony of Charles W. Long, pp I1 (October,00). -4-

6 DOCKET NO I 0-U I 4 IO -ll I1 witness friuell, principal planning engineer for AECC, states that AECC has established three delivery points on EAl's Eureka Springs - Harrison East 11 kv transmission line located at Osage Creek, Green Forest, and Harrison South which serves approximately 0 megawatts (MW) of load. The Osage Creek delivery point is a 111 kv transmission substation which serves approximately 4 mites of kv transmission lines and I distribution substations.* Witness Frizzell also states that AECC has worked with 41 for many years to study and develop a plan for relieving the potential overloads and low voltages in the Eureka Springs to Harrison area and he condudes that the additional transmission source into the Osage Creek substation will greatly improve the ability to serve the entire area sewed by the Harrison East - Eureka Springs transmission line, will relieve the overloads under contingency conditions, and will support the voltage in the area. 1 Q. EAl's transmission plans are subject to review and oversight by its Independent Coordinator of Transmission (ICT). Has the ICT accepted the proposed facilities into its overall transmission plan for EAI? 1 1 I A. Yes. EA1 witness Long states that the ICT's Base Plan consists of a set of transmission improvements deemed necessary by the ICT as a result of the ICT's independent analysis. The proposed Grandview Switching Station -.. * Direct Testimony of William R. Frkelt, p. 4 (October,00). Frizzell Direct, pp

7 DOCKET NO U PREPARED TESTIMONY OF CIARK D. COTTEN 1 Osage Creek transmission facilities have been incorporated into the ICT Base In ferc on n e c ti0 n A qreem en t 4 Q. Is the Company negotiating an interconnection agreement with SPA? A. EA1 witness Doyle states that the Company and SPA are finalizing a contract specifying the general facilities and property requirements, as well as any environmental requirements, for an interconnection to be constructed in the vicinity of the Grandview Community in Carroll County, Arkansas The interconnection agreement between the Company and SPA will identify control and ownership of facilities within the switching station, as well as the transfer of ownership and operational responsibility of the facilities. A copy of the executed interconnection agreement will be filed upon completion as EA1 Application Exhibit E? Proposed FaciJify And Alternatives Q. Please describe the facility under consideration. Long Direct, pp. - IO. Direct Testimony of Michael D. Doyle, pp. - (October, 00). --

8 DOCKET NO U 1 4 A. The proposed transmission line will be approximately miles of a 11 kv, threephase, shielded, single circuit transmission line supported by single pole, steel structures on an 0 foot wide right of way. Dead-end structures will be a three pole structure. The kcmil [thousand circular mil] ACSR [aluminum conductor steel reinforced] will be supported on the poles in a braced post design. The proposed Grandview switching station will be constructed on a three acre site and will consist of a 4-element ring bus that indudes one spare transmission line position. Q. Please describe the proposed transmission line routes A. The Company presented three alternate locations for the placement of the switching station and routing of the transmission line. 1 j 1 Option A is approximately 4.4 miles in length and exits the existing Osage Creek substation to the west and runs northwest crossing both Osage Creek and the Kings River west of the US. Highway bridge crossing the Kings River. The line route then turns north and crosses US. Highway and joins an existing kv distribution cooperative owned transmission line right of way and parallels this right of way on the west side until it intersects with the existing SPA transmission line. This route would require an estimated poles for single and pole --

9 DOCKET NO. 0-1 IO-U PREPARED TESTIMONY OF CLARK D. COITEN I structures, include major angles, extensive right of way clearing, and cost approximatdy $1.1 million. 4 A0 I1 Option B is approximately.0 miles in length and exits the existing Osage Creek substation to the east, crosses U.S. Highway and continues on the same right of way and on the same pole line structures with the existing EA1 Osage Creek - Berryville transmission line, which also parallels two existing distribution cooperative kv transmission lines. Near the existing fifteenth structure, the proposed line turns approximately 4 degrees northeast, crosses Arkansas Highway passing to the east of the large horseshoe bend of the Kings River and crossing Clabber Creek to a point where the proposed route turns north and joins the existing SPA transmission line. This route would require an estimated 4 poles for single and pole structures, include major angles, moderate right of way clearing, with an estimated total project cost of $.4 million I 0 Option C is approximately. miles in length and is identical to Option B for the first. miles also crossing Clabber Creek. Option C continues the northeast direction of Option B an additional d.1 miles crossing Waxweed Run and then turning north until it intersects the existing SPA transmission line. This route would require an estimated poles for single and three pole structures, include major angles, moderate right of way clearing, with an estimated project cost of $. million. --

10 DOCKET NO. 0-1 IO-U 1 Q. Which of the optional routes is EAl s preferred route? A. 4 EA1 has selected Option C as its preferred route as it is estimated to provide the lowest construction cost and minimize any adverse environmental effects of the three options proposed by the Company. Q. Please describe the right-of-way required for this project. A. Where new right of way is required, the Company is proposing to obtain an 0 foot wide easement. a Q. Please describe the existing land use along the Company s proposed routes. IO A. 11 I The land along all routes is sparsely populated with most land either wooded or used for hay production and light cattle production. For Option B and Option C the land use is almost identical since they share a majority of the same route. Option A has the most forested land and a higher Concentration of residential development. The land around the existing Osage Creek substation and along US. Highway has significant commercial development. --

11 DOCKET NO. 0-1 IO-U *1 Q. Are any residences or businesses located near the proposed routes? A. Yes. Table I is based on the Supplemental Testimony of witness Tucker who provided a tabulation of the number of structures incrementally for varying 4 distances from the centerline of each of the proposed transmission line routes Table 1 Structures Within 00 Ft. of Centerline of Transmission Line Route Options Option Route A Residential Other Unknown Total Total Within Ft Ft Ft Ft Ft 00 Ft I 0 Option Route B Residential 0 Other 0 Unknown 0 Total Ft Total I * Within Ft Ft Ft Ft 00 Ft I1 41 Supplemental Testimony of Dr. Gary E. Tucker, p. 4 (January,010). -10-

12 DOCKET NO U PREPARED TESTIMONY OF CLARK D. COlTEN 1 Q. What is the estimated schedule for construction? A. 4 Witness Borne states that the present schedule is for the Company to complete final suweys of the transmission line structure sites and the switching station layout in the first quarter of 010 fojlowed by site preparation work. All right of way clearing, site access development, site grading, will be completed by the third quarter of 010. Transmission line construction will begin in the late second quarter of 010 and be completed by the first quarter of Switching station construction will begin in the second quarter of 010 and be completed by the second quarter of 011. The expected in-service date is June 1, 01 IO Evaluation Of Factors For The Proposed Facility 1 +I Q. What factorq did you consider in your evaluation of the proposed facility? A. Order No. in Docket No and Order No. in Docket No identified seven factors that should be considered in the siting of transmission facilities and by the Commission in determining whether the route or location Direct Testimony of Greg A. Borne, p. (October, 00)

13 DOCKET NO. 0-1 IO-U PREPARED TESTIMONY OF CLARK D. COTEN I chosen by the utility is reasonable. Those seven factors are: 4 a io 1. Cost of the Facilities,. Health and Safety,. Engineering and Technical Concerns, 4. EcologicallEnvironmental Disruptions,. Disruptions to Existing Manmade Property Uses,. Disruptions to Planned Manmade Property Uses, and. Aesthetic Displeasure. Q. What is the estimated cost of the proposed facilities and how will they be financed??i A. EA1 estimates the total cost of the project will vary depending on the final route approved. Table represents the estimated cost of the three proposed options. Table Total Project Estimated Cost Option B Option C (EAI's preferred route) $,4 $, In order to construct the project, EA1 will initially pay for construction from available funds of various sources, including retained earnings, debt, and capital securities. Witness Borne states that any sale of securities, which may be --

14 DOCKET NO. 0-1 IO-U PREPARED TESTIMONY OF CLARK D. COTFEN 1 required, wiil be at some later date and will be in amounts and under terms to be approved by the Commission.' Q. How will the health and safety concerns be satisfied? 4 A. Construction standards established in the Commission's Special Rules - Hecfn'c, Rules.01 and.0, which designate the current issue of the National Hectric Safety Code and the National Electrical Code as standards, will be followed. In addition, construction methods and activities in the field will also meet USa Department of Labor Occupational Safety and Health Organization requirements. Q. 10 Are there any engineering or technical concerns associated with this project? I1 A. 4 The construction of this transmission line and switching station does not present any engineering or technical concerns that are not routinely encountered in typical transmission line construction projects. Q. Please summarize the types of ecologicallenvironmental disruptions that will be caused by this project. 1 A. 1 Witness Borne states that construction, operation, and maintenance of the transmission line and switching station should generate minimal overall adverse a Borne Direct, p. 1 --

15 DOCKET NO. 0-1 IO-U PREPARED TESTIMONY OF CIARK D. COTTEN environmental impact to the natural and cultural resources environment of the area. However, as with any construction project, some adverse impacts will occur. Some impacts are unavoidable and are likely to occur with construction and operation of any transmission line that crosses forests and light pasture such as found in the project area. Some of these impacts are short term and temporary, while others are permanent and will last for the life of the projectg IO 11 +I Witness Tucker states in his Preliminary Alternatives Assessmentqo that Option A has a high potential for numerous adverse environmental factors; the high potential for karst topography that could support the federally listed gray bat in combination with a high potential for the presence of cultural resources issues could result in adverse impacts to both schedule and budget. Option B and Option C are probably equivalent or near equivalent in the sense that they have a minimal number of adverse environmental factors; either option would be a much better choice than Option A. In his testimony, witness Tucker added that Option Route C is adjacent to and parallels the Kings River for a lesser distance than Option Route B, thereby minimizing the potential of a direct impact to the watershed. " Some Direct, pp. -. lo Tucker Direct, Exhibit GET-, p. of 1. " Tucker Direct, p

16 DOCKET NO. 0-1 IO-U PREPARED TESTIMONY OF CLARK D. COlTEN 1 Q. Wilt this construction disrupt existing manmade property uses? 4 A. Witness Borne states that the proposed facilities will no adversely impact any private or single-family residences, or interfere with any state or federal national park lands. Q. Does the proposed construction disrupt planned property uses? 10 A. Witness Borne states that there were no other major planned property uses found for the tracts of land along the optional routes except for minimal pasture land supporting light cattle farming with some timber production capability. However, there is some potential that the proposed facilities may impact certain platted lands or lands that may be platted in the future for home site andlor small 11 farm development. He further states that the Company will work with any impacted land owners to minimize effects of the proposed facilities where it is practical, economically feasible, and not adverse to the operation or reliability of the electric systems of EAI, AECC, and the SPA. Q. Were the aesthetics of the project considered? 1 -I A. Yes. The Company's decision to use modular steel structures was driven in part by the reduced right of way width that these structures require, minimizing the ' Borne Direct, p.. l Borne Direct, p.. -1s-

17 DOCKET NO. 0-1 IO-U 1 aesthetic displeasure of the in~tallation.'~ Q. Please describe the site of the proposed switching station associated with each of the optional transmission line routes A. Access to and the elevation variation of the terrain for the acre site required for the switching station varies widely between the three optional sites. The switching station site associated with Option A is wooded and undeveloped and would require extensive clearing and the construction of an access road of approximately 1000 feet in length. In addition, the elevation variance at this site is 0 feet requiring the most expense of all the sites for earth removal and land leveling. There are no residential structures within 00 feet of this site. I1 Option B would also require the construction of an access road of approximately A000 feet in length. The elevation variance at this location is feet and little to no cjearing would be required. There are no residential structures within 00 feet of this site. Option C is located a short distance to a developed roadway and requires no 1 clearing, The elevation variance is feet and will require the least site 1 1 preparation and land leveling compared to the other optional sites. There is one residential structure within 00 feet of this site. l4 Borne Direct, p.. -1-

18 DOCKET NO U I 4 Witness Tucker in his Preliminary Alternatives Assessment provides a table listing the environmental issues associated with each of the switching station sites.l This table shows that the probable environmental issues associated with either Option B or Option C are essentially the same and are less than Option A. Q. Based on your evaluation of these factors, what is your finding? 10 A. Based on my evaluation of EAl s Application, the transmission line and switching station to provide for a new interconnection with the SPA to provide for additional transmission capacity and enhanced transmission reliability to the transmission facilities between Eureka Springs and Harrison East are reasonable and are in the public interest. Option A is the least desirable as it has the greatest potential I? for adverse environmental impact and is estimated to cost the most. Option B and Option C on an environmental basis ate relatively the same with Option C providing possibly less impact to the Kings River since it is separated farther from A4 it than Option B. Option C is estimated to cost the least. Considering the 1 1 aesthetics of the three routes to existing residential structures, Option B has the Ieast residential structures within 00 feet of the proposed facilities with seven followed by Option C with 10, and Option A with. l Tucker Direct, Exhibit GET-, p., Table I. -1-

19 DOCKET NO. 0-1 IO-U 1 IV. NOTICE REQUIREMENTS Q. Has notice of this Application and proceeding been served on a11 parties as required by the Commission's RPP Rule.0.(b)() and.0.(c)? 4 A. Yes. EA1 identified owners of tracts of land that could be affected by the a IO 11 proposed construction by either site access or visual sight of the transmission line andlor switching station. AI Application Exhibit F, filed on October, 00, is the Certification of Proof of Sewice to these landowners. A representative copy of the letter is included in the Direct Testimony of EA1 witness Borne as Exhibit GAB-. On November 0, 00, EA1 provided proof of notice that a public notice was published in the Carol/ County News, a newspaper in Berryville, Arkansas, having substantial circulation in the area under consideration by filing the same with the Secretary of the Commission in this Docket. The proof of notice also certified that copies of EAl's Application, Direct Testimony and Exhibits were placed in the BerryvilIe Public Library. 1 -I 1 On January, 010, the Company filed a Certification of Proof of Notice that a copy of Order No. was sent to each landowner by first class mail, and included the mailing list and a representative copy of the form letter, of notification of the procedural schedule. -1-

20 DOCKET NO U PREPARED TESTIMONY OF CIARK D. COTTEN 1 Q. What other activities has the Company participated in to provide additional information to concerned individuals in the area of the proposed construction? 4 A. IO The Company sponsored a public open house to provide information regarding the proposed switching station and transmission line on the evening of September,00, at the Berryville Community Center. Through letters by firstclass mail, the Company invited all landowners of record within a reasonable distance of each routing option to the open house. The Company also ran a newspaper notice advising the public of the open house. The open house was attended by 41 individuals. I1 Q. Have public comments been received in this Docket? A. d Yes. Written public comments have been received from landowners in the form of a petition and voicing opposition to the use of Option B and Option C. The Arkansas Department of Environmental Quality has supplied comments that for environmental reasons, it supports Route C. -1-

21 DOCKET NO. 0-1 IO-U 1 V. FINDINGS AND RECOMMENDATIONS Q. Are the facilities proposed in the Application needed by EA1 to provide reliable service? 4 A. Yes. The proposed facilities are needed to provide adequate transmission service and reliability. Q. Are the facilities proposed to be constructed reasonable? A. Yes, based on the information provided, the proposed facilities are reasonable. Q. Is the Company s selection of Option C as its preferred route and location reasonable? IO A. 11 The selection of Option C as EAl s preferred route is reasonable since it is estimated to provide the lowest construction cost and minimize any adverse environmental effects of the three options presented by EAI. Q. Have the seven factors identified in previous Commission orders been satisfied? A. 1 1 Based on the information provided in EAl s Application and testimony, it appears that the seven factors have been adequately addressed in planning the proposed facilities. -0-

22 DOCKET NO. 0-1 IO-U 1 Q. Have the notice provisions of Rule.0.(b)() and.0.(c) of the Commission's RPP been met? A. Yes. 4 Q. What are your recommendations regarding the Application for a CCN? A. Based upon my evaluation of the Application and other information, the proposed facilities are in the public interest. On the condition that EA1 obtain a fully executed Interconnection Agreement with the SPA and file it in this Docket as EA1 Application Exhibit E, I recommend that the Commission grant EA1 a CCN to construct the Grandview Switching Station and transmission line along Option C. IO Q. Do you have any other recommendations? 1 A. Yes. I recommend that EA1 be directed to comply with Rule.01(b) and.01(c) of this Commission's RPP by filing he required completion or delay of construction reports in Docket No U. I also recommend that the Commission specify in its order that nothing in this proceeding be construed as a finding of value for rate making purposes. 1 Q. Does this conclude your testimony? j A. Yes. -1 -

23 CERTIFICATE OF SERVICE I, Susan D'Auteuil, hereby certify that a copy of the foregoing Testimony has been served on all parties of record by electronic delivery or first class mail (postage prepaid) on January,010.