BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO DIRECT TESTIMONY AND EXHIBITS OF CHRISTOPHER E. PINK TABLE OF CONTENTS

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1 BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO IN THE MATTER OF THE APPLICATION OF TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE BURLINGTON LAMAR KV TRANSMISSION LINE PROJECT AND FOR SPECIFIC FINDINGS WITH RESPECT TO MAGNETIC FIELDS AND AUDIBLE NOISE ) ) ) ) PROCEEDING NO. ) ) ) ) DIRECT TESTIMONY AND EXHIBITS OF CHRISTOPHER E. PINK TABLE OF CONTENTS Section Page I. INTRODUCTION AND QUALIFICATIONS... II. PURPOSE OF TESTIMONY... III. TRI-STATE'S EXISTING TRANSMISSION SYSTEM IN THE PROJECT AREA... IV. PROJECT PURPOSE AND NEED... V. ALTERNATIVES ANALYSIS... VI. PROPOSED PROJECT... VII. PROJECT COORDINATION... 0_

2 I. INTRODUCTION AND QUALIFICATIONS Q: PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. A: My name is Christopher E. Pink. My business address is 10 West th Avenue, Westminster, Colorado 0. Q: BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY? A: I am employed by Tri-State Generation and Transmission Association, Inc. ( Tri- State ) as Manager, Technical Services/Bulk System Planning. Q: ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS DOCKET? A: I am testifying on behalf of Tri-State. Q: HAVE YOU PREPARED A STATEMENT OF YOUR EXPERIENCE AND QUALIFICATIONS? A: Yes. A statement of my experience and qualifications is attached to my testimony as Exhibit No. CEP-1. Q: PLEASE DESCRIBE BRIEFLY YOUR BACKGROUND AND EXPERIENCE IN THE ELECTRIC UTILITY INDUSTRY. A: I have over years of experience in the electric utility industry. In my present position, I am responsible for planning, coordinating, directing, and providing engineering support for the development of Tri-State s transmission network utilizing my knowledge of bulk power systems. Prior to joining Tri-State, I worked as a system engineer at a distribution cooperative, a research engineer at a national lab, and an electrical engineer at a consulting firm. I have undergraduate and master s degrees in engineering from the Colorado School of Mines. I am a registered Professional Engineer in the State of Colorado. 0_

3 II. PURPOSE OF TESTIMONY Q: WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? A: My testimony discusses the purpose and need for the Burlington Lamar Transmission Line Project (the Project ). Specifically, I will discuss the needs related to load serving, reliability, and constraints on planned renewables that give rise to the Project. I will also discuss the system studies that have been performed which confirm and support the need for the Project. I will also introduce Tri-State's other witnesses whose testimony supports the issuance of a Certificate of Public Convenience and Necessity ( CPCN ) for the Project as described in Tri-State s Application. Q. IS TRI-STATE PRESENTING TESTIMONY FROM OTHER WITNESSES IN SUPPORT OF ITS CPCN APPLICATION? A. Yes. In addition to my own testimony, Tri-State is sponsoring the direct testimony of the following witnesses in support of its Application: - Grant D. Lehman, Tri-State's Senior Manager, Transmission Engineering and Construction, will describe the details of the proposed transmission line design, the Project schedule, and estimated cost; - Karl W. Myers, Tri-State's Manager of Transmission Siting and Environmental Planning, will describe the land use, right-of-way, siting, and permitting issues associated with the Project; and - Dr. Robert Pearson, a consulting engineer, will address issues related to magnetic fields and audible noise. 0_

4 III. Together, my testimony and the testimony of these witnesses provide a comprehensive explanation of the Project and its underlying purpose and need. TRI-STATE'S EXISTING TRANSMISSION SYSTEM IN THE PROJECT AREA Q: PLEASE PROVIDE A BRIEF DESCRIPTION OF THE PROJECT. A: The Project is a new single-circuit, kv transmission line interconnecting Tri- State s existing Burlington and Lamar substations. The new transmission line will be approximately 0-1 miles long and will be constructed on wood H-frame structures. Project facilities are shown in electric one-line diagram format in Exhibit No. CEP-. Q: PLEASE DESCRIBE THE LOCATION OF THE PROJECT. A: The Project will be located in Kit Carson, Cheyenne, Kiowa, and Prowers counties and will cross areas served by Tri-State Member Systems K.C. Electric Association and Southeast Colorado Power Association. A map of the Project Area is included as Exhibit G to the CPCN Application. Q: PLEASE DESCRIBE THE EXISTING TRANSMISSION AND GENERATION SYSTEMS IN THE LAMAR AREA. A: The transmission network in the Lamar area consists of two systems: 1) a kv load serving network; and ) the Boone - Lamar kv line. The kv network is owned and operated by Black Hills/Colorado Electric Utility Company, L.P. and Tri-State. It serves all the load centers between Boone and Lamar, including Rocky Ford, Las Animas, Vilas, Lamar, Holly, and La Junta, among others. Transmission assessments have shown that the kv network 0_

5 will be unable to serve all the Lamar area loads after a loss of the Boone Lamar kv line. The Boone - Lamar kv line serves no distribution systems directly. Its primary purpose is to transfer bulk power into and out of the area. Tri-State imports power from Boone kv to Lamar kv to serve Tri-State s kv loads in the area. Public Service Company of Colorado ( PSCo ) utilizes the kv line to transfer their Lamar area generation to their Front Range loads. PSCo has MW of generation connected at Lamar kv, including the Lamar DC Tie (± MW), Colorado Green East and West Wind ( MW), and Twin Butte Wind ( MW). The underlying kv system is insufficient to transfer this much power; thus, a scheme is in place to automatically trip all Lamar area generation for an outage of the Boone Lamar kv line. Loss of the Boone Lamar kv element is the most severe single contingency in the area. Q: PLEASE DESCRIBE THE EXISTING TRANSMISSION AND GENERATION SYSTEMS IN THE BURLINGTON AREA. A: Like Lamar, the Burlington area transmission system presently consists of two systems: 1) an underlying kv load serving network; and ) a single kv line. There are several owners of the various kv load serving networks, including Western Area Power Administration, PSCo, Tri-State, and K.C. Electric Association Inc. These networks serve the majority of the eastern Colorado load centers, including Yuma, Wray, Idalia, and Burlington, among others. 0_

6 1 The kv line connects Burlington, via Landsman Creek, to the Big Sandy Lincoln Midway kv system. A second line, called Burlington Wray kv, is presently under development and expected to be in service by. It will connect Burlington to the Wray North Yuma kv system to the North. A sizable amount of conventional and renewable generation is connected and is planned to be connected at or near Burlington. The Burlington system is generation rich and transmission constrained. The most significant issue is its ability to safely export power following an outage of the Burlington Big Sandy Lincoln Midway kv system. During periods of high generation, significant overloads on the underlying kv network occur following kv outages. This condition is exacerbated during low-load, highwind conditions. To ensure kv overloads do not occur, the Burlington area 1 generation is restricted through operating procedures and agreements. This situation presently restricts any new renewable generation in the Burlington area. The future Burlington Wray kv project significantly relieves these restrictions. It does not, however, provide sufficient relief to accommodate all planned future generation. For example, Tri-State has plans for a 10 MW network resource, named Carousel Wind, to be connected at Burlington kv in 1. Lacking a significant transmission project, the output of Carousel Wind will be limited during light load conditions to protect against kv outages, much like today s existing Burlington area generation. 0_

7 In summary, even with the new Burlington - Wray kv line, the Burlington area transmission system still needs another outlet for planned generation. Q: PLEASE DESCRIBE TRI-STATE S RELATIONSHIP TO ITS MEMBER SYSTEMS AND ITS LOAD SERVING AND RELIABILITY OBLIGATIONS. A: Tri-State is a regional, wholesale electric power supplier owned by the electric cooperatives and public power districts (the Member Systems ) that it serves in Colorado, New Mexico, Nebraska, and Wyoming. Tri-State is obligated to provide reliable, efficient, cost-based, wholesale power to these Member Systems, who in turn provide retail electric service to their end-use member- consumers. Tri-State, as a regional transmission provider, also has the IV. obligation to provide reliable transmission service to its other network customers, such as Public Service Company of New Mexico, the Municipal Energy Agency of Nebraska, Arkansas River Power Authority, and PSCo, and to comply with all North American Electric Reliability Corporation ( NERC ) and Western Electricity Coordinating Council ( WECC ) transmission reliability standards. PROJECT PURPOSE AND NEED Q: WHAT IS THE PURPOSE OF THE PROPOSED PROJECT? A: The purpose of the Project is to alleviate existing and reasonably anticipated future transmission system constraints and reliability issues in a manner that aligns with elements of larger, strategic transmission initiatives in eastern Colorado. Q: ARE THERE SPECIFIC NEEDS THAT ARE ADDRESSED BY THE PROJECT? 0_

8 A: Yes, several reliability issues must be addressed in the eastern and southeastern Colorado transmission systems that are mitigated by the Project: 1) Unacceptable voltages and voltage deviations in the Lamar area following a Boone Lamar kv line outage; ) Transmission constraints in the Lamar area; and ) Transmission constraints in the Burlington area. Q: ARE THERE OTHER BENEFITS OF THE PROJECT? A: Yes. The Project provides increased operational flexibility for maintenance outages, better transmission system performance following multiple contingencies, reduced regional losses, and more stable voltages across a wide range of system conditions. The Project also increases transmission capacity in regions with a high potential for new wind resources. This benefits stakeholders developing such projects, supports public policy goals (e.g., SB1-), and possibly increases competition, thereby providing Tri-State a more diverse portfolio of generation resources from which to choose. Another benefit is that a new Burlington Lamar transmission element aligns with other major, strategic transmission projects in the region. Constructing the Project is an important first step to ultimately meet some of the objectives of these larger transmission projects. Q: DESCRIBE HOW THE PROJECT ALIGNS WITH OTHER STRATEGIC TRANSMISSION INITIATIVES IN EASTERN COLORADO? 0_

9 A: There are two major transmission initiatives in eastern Colorado that include new infrastructure between the Lamar and Burlington areas. One is the Lamar Front Range Project. It includes new transmission lines interconnecting Lamar, Burlington, Big Sandy, Missile Site, Story, Pawnee, and Vilas. It is described as a multi-faceted transmission project designed to enhance the high-voltage transmission network in eastern Colorado. More details for the Lamar Front Range project are included in the Lamar Front Range Transmission Project Feasibility Study Report attached as Exhibit No. CEP-. Another is the High Plains Express initiative. Its goals are to significantly strengthen the eastern portion of the Western grid. Larger than the Lamar Front Range Project, it also includes transmission ties between Wray, Burlington, Lamar, and Vilas, among others. More details for the High Plains Express project are included in the High Plains Express Transmission Project Feasibility Study Report attached as Exhibit No. CEP-. While the Burlington Lamar Project does not by itself accomplish all of the objectives of the Lamar Front Range or High Plains Express projects, it is an important first step to ultimately meet some of the objectives of those initiatives. Q: WHAT STUDIES HAVE BEEN CONDUCTED THAT HAVE IDENTIFIED AND CONFIRMED OR OTHERWISE SUPPORTED THE NEED FOR THE PROJECT? A: There have been many, including: 1) Tri-State s various transmission performance assessments; ) the Lamar Front Range Project study (Exhibit 0_

10 No. CEP-); ) the High Plains Express Project study (Exhibit No. CEP-); and ) recent generator interconnection studies for Tri-State wind resources to be connected at Burlington. While each study addressed slightly different needs, they all confirm and support improvements that include interconnecting the Burlington and Lamar transmission systems. The following exhibits are relevant studies that describe the need or benefits of transmission system improvements between Burlington and Lamar: 1) Exhibit No. CEP-: Lamar Front Range Transmission Project Feasibility Study Report. This study describes a major transmission project in eastern Colorado that includes a transmission connection between Burlington and Lamar, among other elements. ) Exhibit No. CEP-: High Plains Express Transmission Project 1 Feasibility Study Report. This study describes another strategic transmission project in eastern Colorado that includes a transmission connection between Burlington and Lamar, among other elements. ) Exhibit No. CEP-: Tri-State Transmission Planning Assessment (Per TPL-001a, TPL-00a, TPL-00a, and TPL-00). This study identified, among other things, unacceptable voltages and voltage deviations in the Lamar area following a Boone Lamar kv outage. ) Exhibit No. CEP-: Burlington Lamar / kv Impact and 1 Post TPL Assessment Study. A follow up to the TPL assessment, this study compared alternatives and ensured the adequacy of a new 0_

11 Burlington Lamar kv line in solving the Lamar area performance issues. ) Exhibit No. CEP-: Interconnection System Impact Re-Study Final Report April, 1. This study identified transmission system constraints around Burlington following the installation of a new 10 MW wind resource during light load, high wind conditions (1 light autumn). It concluded that a new Burlington Lamar kv line would relieve the identified constraints. ) Exhibit No. CEP-: Supplemental Study to the Burlington Lamar / kv Impact and 1 Post TPL Assessment Study. A new transmission line between Burlington and Lamar will improve the transmission capacity in both areas. This study analyzed potential new generation injection levels after installation of a single Burlington Lamar kv line. ) Exhibit No. CEP-: Burlington Lamar kv Losses Evaluation. A new transmission line in the area will reduce the system s overall impedance, which will reduce losses and thus increase overall system efficiency. This study enumerates the potential impact of the Project on system losses and determines if an upgraded project is economically justifiable based on reduced losses. ) Exhibit No. CEP-: Interconnection System Impact Study Final Report Generator Interconnection Request No. TI-1-01 (POI Lamar Substation). This study identified reliability issues around Lamar both 0_

12 prior to and following the installation of a new 0 MW wind resource at Lamar. A dynamic stability sensitivity case was run, and it concluded that with a Burlington Lamar kv element modeled, all simulated contingencies resulted in acceptable system performance. V. ALTERNATIVES ANALYSIS Q: BEFORE WE DISCUSS THE PROPOSED PROJECT, DID TRI-STATE CONSIDER ANY NON-TRANSMISSION ALTERNATIVES TO MEET THE IDENTIFIED NEEDS? A: Yes. Tri-State considered at a high level whether the identified needs could be met through a generation solution or a solution involving energy efficiency or demand side management ( EE/DSM ) measures. Tri-State also considered whether it was feasible to take no action at all. Q: WHAT CONCLUSIONS DID TRI-STATE REACH WITH REGARD TO WHETHER A GENERATION ALTERNATIVE COULD SATISFY THE IDENTIFIED NEEDS? A: Since two of the needs being addressed by the Project are to relieve transmission constraints imposed on existing and planned generation, it was determined early on that additional generation would not be a viable solution. Q: WHAT CONCLUSIONS DID TRI-STATE REACH WITH REGARD TO WHETHER AN EE/DSM ALTERNATIVE COULD SATISFY THE IDENTIFIED NEEDS? A: Being generation rich, the transmission constraints in the Burlington and Lamar areas are exacerbated by reduced local loads. With less power consumed 0_

13 locally, more power is exported over the limited transmission networks. EE/DSM alternatives would reduce loads and therefore, would not mitigate the transmission constraint issues. Q: IS IT FEASIBLE FOR TRI-STATE TO TAKE NO ACTION WITH REGARD TO THE IDENTIFIED NEEDS? A: No. Tri-State, WECC, and NERC transmission performance criteria require levels of system performance that will not be met if no action is taken. Q: WHAT CONCLUSION DID TRI-STATE REACH WITH REGARD TO THE APPROPRIATE MEANS TO ADDRESS THE IDENTIFIED NEEDS IN EASTERN COLORADO? A: Consistent with the various studies previously identified, Tri-State determined that the most appropriate means to address the present and future needs in eastern Colorado is through transmission system improvements between Burlington and Lamar. Q: PLEASE DESCRIBE TRI-STATE S GENERAL ASSUMPTIONS AND METHODOLOGY. A: As discussed earlier, Tri-State utilized many different studies, covering a range of alternatives, to determine the best solution. The final decision was based on a broad spectrum of potential future scenarios. The Tri-State Transmission Planning Assessment (Exhibit No. CEP-), for example, utilized five base case assumptions spanning nine years under heavy and light, winter and summer scenarios. Likewise, the Burlington Lamar / kv Impact and 1 Post 0_ 1

14 TPL Assessment Study (Exhibit No. CEP-), focused on 1 heavy summer and light autumn cases. Other studies similarly included diverse assumptions, which are outlined in their respective reports. The various analyses identified an assortment of issues, but all pointed to alternatives involving a new transmission line between Burlington and Lamar. The methodologies employed power flow analyses under system intact, single contingency, and in some cases, multiple outage conditions. System performance was judged against Tri-State s planning criteria and applicable NERC and WECC reliability criteria. Q: PLEASE DESCRIBE THE GENERAL TRANSMISSION ALTERNATIVES THAT WERE CONSIDERED. A: The alternatives considered varied from study to study. Having determined that a transmission solution was most appropriate, Tri-State primarily based its decision on the consideration of two studies and their corresponding alternatives. The first study was the Burlington Lamar / kv Impact and 1 Post TPL Assessment Study (Exhibit No. CEP-). The study focused on mitigating reliability and transmission constraint issues in and around the Lamar area. It analyzed the following three alternatives: 1) A 0-1 mile transmission line between the Burlington and Lamar substations. One option of this alternative considered construction of a new single-circuit transmission line on steel lattice structures capable of operating at kv but operated initially at kv. A second option 0_ 1

15 considered construction of a single-circuit kv transmission line on wood H-frame structures. ) A single-circuit kv transmission line on wood H-frame structures extending approximately miles between the Lamar and Lincoln substations. ) A single-circuit kv transmission line on wood H-frame structures extending approximately 1 miles between the Lamar and Midway substations. The second study was the Interconnection System Impact Re-Study Final Report April, 1 (Exhibit No. CEP-). This study assessed impacts and mitigation of specific transmission constraints for Tri-State s planned 10 MW network wind resource in the Burlington area. The study considered three approaches to eliminate kv overloads that the additional generation caused: 1) Reduce the project generation size; ) Increase the ratings of the overloaded lines by upgrading them; and ) Construct a new transmission line into the project area. In addition to the primary studies, Tri-State also considered the results of the Lamar Front Range Study (Exhibit No. CEP-) and High Plains Express Study (Exhibit No. CEP-). While the range of their alternatives went beyond the scope of Tri-State s specific requirements, the Lamar Front Range and High Plains Express conclusions were considered when evaluating how Tri-State s needs fit in a larger context. 0_ 1

16 Q: PLEASE SUMMARIZE THE RESULTS OF TRI-STATE S BURLINGTON LAMAR / KV IMPACT AND 1 POST TPL ASSESSMENT STUDY (EXHIBIT NO. CEP-). A: This study confirmed the load serving, reliability, and generation delivery concerns associated with an outage of the Boone Lamar kv transmission line. The analysis determined that all three alternatives studied, including both options associated with the Burlington - Lamar alternative, mitigated the concerns around Lamar. The analysis also showed negligible performance differences between constructing the Burlington Lamar transmission alternative for either kv or kv operation. Q: PLEASE SUMMARIZE THE RESULTS OF TRI-STATE S INTERCONNECTION SYSTEM IMPACT RE-STUDY FINAL REPORT APRIL, 1 (EXHIBIT NO. CEP-). A: Overloads on the kv load serving network around Burlington were identified with the generation facility at full output following various kv line outages. Proposed mitigation included reduction in generation output, rebuilding existing kv lines, or construction of a new transmission line to the Burlington area. The Burlington Lamar kv line was modeled and the results demonstrated that it mitigates the identified kv overloads. Q: PLEASE SUMMARIZE THE RESULTS OF TRI-STATE S INTERCONNECTION SYSTEM IMPACT STUDY FINAL REPORT GENERATOR INTERCONNECTION REQUEST NO. TI-1-01 (POI LAMAR SUBSTATION). (EXHIBIT NO. CEP-). 0_

17 A: Loss of the Boone - Lamar kv line (with cross-trip scheme) failed to converge in the model. A dynamic stability sensitivity case was run modeling the planned Burlington - Lamar kv line. A solution was obtained for loss of the Boone - Lamar kv line (no cross trip), and the study results confirmed that all simulated contingencies were compliant with the NERC/WECC criteria. Q: PLEASE SYNTHESIZE THE RESULTS OF TRI-STATE S BURLINGTON LAMAR / KV IMPACT AND 1 POST TPL ASSESSMENT STUDY (EXHIBIT NO. CEP-), INTERCONNECTION SYSTEM IMPACT RE-STUDY FINAL REPORT APRIL, 1 (EXHIBIT NO. CEP-), AND INTERCONNECTION SYSTEM IMPACT STUDY FINAL REPORT GENERATOR INTERCONNECTION REQUEST NO. TI-1-01 (POI LAMAR SUBSTATION) (EXHIBIT NO. CEP-). A: Each study was performed independently and evaluated alternatives unique to their focus. The Burlington Lamar / kv Impact and 1 Post TPL Assessment Study concentrated on resolving problems caused by an outage of the Boone Lamar kv line. The study found three kv alternatives that mitigate the reliability issues in the Lamar region: Lincoln Lamar kv, Midway - Lamar kv, or Burlington Lamar kv. It concluded that a new Burlington Lamar kv element was preferred and would greatly improve the transmission system in eastern Colorado. The Interconnection System Impact Re-study Final Report April, 1 identified constraints on a new 10 MW wind farm near Burlington. The study 0_ 1

18 recommended three possible approaches to mitigate the constraints: 1) a new Burlington - Lamar kv line; ) significant rebuilds to other kv lines; or ) curtailing the wind farm output. The last being the least desirable approach, obviously. The Interconnection System Impact Study Final Report Generator Interconnection Request No. TI-1-01 (POI Lamar Substation) found that the system model failed to converge for a loss of the Boone Lamar kv line, even before the proposed generation project was included. A new Burlington Lamar kv element was modeled in dynamic simulations and proper transmission system performance was achieved both with and without the additional generation. New transmission facilities are large and expensive endeavors. Preferably, they meet several needs and address multiple issues. In the case of the proposed Project, three independent studies demonstrated that this single transmission line would significantly improve two relatively independent transmission systems an ideal outcome for any transmission project. Q: PLEASE SUMMARIZE THE RELEVANT RESULTS OF THE LAMAR FRONT RANGE TRANSMISSION PROJECT FEASIBILITY STUDY REPORT (EXHIBIT NO. CEP-) AND THE HIGH PLAINS EXPRESS TRANSMISSION PROJECT FEASIBILITY STUDY REPORT (EXHIBIT NO. CEP-). A: Both studies describe major conceptual transmission projects in eastern Colorado. They each include a transmission circuit between Burlington and Lamar, as part of a larger transmission project. The studies contemplate 0_ 1

19 generation injection, import and export capability, and access to energy resource zones, among other things. For purposes of this testimony, the salient point is that a high voltage path from Story to Wray to Burlington to Lamar was deemed necessary by these studies. Q: GIVEN THAT BOTH BURLINGTON TRANSMISSION OPTIONS PERFORMED WELL RELATIVE TO THE IDENTIFIED PROJECT NEEDS IN THE BURLINGTON LAMAR / kv IMPACT AND 1 POST TPL ASSESSMENT STUDY (EXHIBIT NO. CEP-), HOW DID TRI-STATE SELECT A PREFERRED PROJECT AMONG THESE ALTERNATIVES? A: Tri-State first considered rough, plus-or-minus 0%, cost estimates for each alternative for comparative purposes. These estimates are set forth below and in Table 1 of Exhibit No. CEP-. I note that these cost estimates differ from the actual engineering level cost estimates as provided in Grant Lehman s testimony. Planning studies require relative ranking, so instead of creating detailed costs for each alternative, plus or minus 0% costs allow relative ranking while avoiding the expense of developing detailed facility estimates. Conductor Alternative Description (ACSR) 1 ($000) 1 Burlington Lamar kv Lattice Steel (0 miles) (operate at kv without Burlington / kv transformer) -,000 1A Burlington Lamar kv Wood H-Frame (0 miles) 1,000 Lamar-Lincoln kv Wood H-Frame ( miles),000 Lamar-Midway kv Wood H-Frame (1 miles),000 Tri-State next considered its presently identified needs as well as the reasonably anticipated transmission system needs in the Project area. Based on costs and transmission system needs, Tri-State determined that Alternative 1A was the 0_ 1

20 most appropriate, and as no other parties expressed interest in an expansion of the project, Alternative 1A was deemed the preferred alternative. Q: YOU MENTIONED THE REASONABLY ANTICIPATED TRANSMISSION SYSTEM NEEDS IN THE PROJECT AREA. DID TRI-STATE CONSIDER ANY ALTERNATIVES TO THE PROPOSED PROJECT THAT MIGHT ACCOMMODATE FUTURE TRANSMISSION SYSTEM NEEDS IN THE PROJECT AREA? A: Yes. Tri-State recognizes that other stakeholders may have immediate and longer-term needs in the Project area, so Tri-State reached out in public forums, planning forums, and by solicitation letter that was published in the CCPG venue and was picked up by industry media. None of the responses to the solicitation letter identified any need for increasing the capacity of the Project. Tri-State considered the possibility of constructing the Burlington Lamar transmission line to be capable of kv operation, but operating it initially at kv. Tri-State determined that the relative cost of such construction more than twice the estimated cost of the Project as per Exhibit No. CEP- could not be justified based on Tri-State s present and reasonably anticipated needs. Furthermore, since the transmission systems at either end only include kv infrastructure, the benefits of kv construction cannot be realized without multiple surrounding transmission system improvements that may or may not occur. Tri-State also considered the possibility of installing the proposed singlecircuit kv transmission line on double-circuit structures with the other side of the structure left vacant to accommodate potential future generation. 0_

21 Nevertheless, it was found that the additional cost of such structures would be more than double the original costs. This is an increase that Tri-State cannot justify based on its own needs and without financial participation in the Project by other stakeholders. I discuss Tri-State s efforts and outreach to solicit participation in the Project by other stakeholders in Section VII, below, of my testimony. Q: DID TRI-STATE STUDY THE CAPABILITIES OF THE PROPOSED PROJECT WITH RESPECT TO ACCOMMODATING EXISTING AND FUTURE GENERATION IN THE AREA? A: Yes. Tri-State performed a supplemental study to its post TPL Assessment called Supplemental Study to the Burlington Lamar / kv Impact and 1 Post TPL Assessment Study (Exhibit No. CEP-). This study analyzed potential new generation injection levels after installation of a single-circuit Burlington Lamar kv line. Based on evaluations of varying generation injection levels at Lamar, Tri-State s studies found that the system could accommodate approximately MW of combined generation at the Burlington and Lamar kv buses. The studies also demonstrated that with the new Burlington Lamar kv line, between and MW of generation could remain connected at Lamar following a loss of the Boone Lamar kv transmission line. This is a significant improvement since at present, all generation at Lamar is tripped for the same outage. The exact amount of new generation that could be installed following the Project depends on the manner in which the existing generation portfolio is managed 0_ 1

22 and future load levels. Nevertheless, the Project is certain to provide some level of opportunity for increased renewable generation in the region. Exhibit No. CEP- provides more details. Q: DID TRI-STATE STUDY THE IMPACT OF THE PROPOSED PROJECT ON REGIONAL LOSSES AND CONSIDER ALTERNATIVES THAT COULD FURTHER REDUCE LOSSES IN THE AREA? A: Yes. Tri-State performed the Burlington Lamar kv Losses Evaluation study (Exhibit No. CEP-) to quantify the proposed Project s benefit to regional transmission system losses and to consider alternatives that could potentially reduce losses further. The study found that with the proposed Project installed, area losses would be reduced by 0. MW to MW depending on seasonal loading and generation dispatch conditions. The study also determined that losses could be further reduced by 0. MW if bundled, rather than single, ACSR conductors were used. Unfortunately, 0. MW is a very small improvement considering the bundled-conductor s significantly higher construction costs. All the regional transmission stakeholders, including Tri- State, will benefit from the reduced system losses that single ACSR construction would provide. While bundled-conductor construction could provide even more benefits, given the marginal amount of those benefits, the significant costs, and the absence of participation by other stakeholders in this regard, it was concluded by inspection that the benefits do not justify the additional costs in the context of this Project. Tri-State cannot justify bundled-conductor construction in light of Tri-State s needs. 0_

23 VI. PROPOSED PROJECT Q: PLEASE DESCRIBE THE TRANSMISSION SYSTEM IMPROVEMENTS THAT WILL BE CONSTRUCTED AS PART OF ALTERNATIVE 1A. A: The Project will include a new, single-circuit kv transmission line extending approximately 0-1 miles between the Burlington and Lamar substations. The Project will also entail the installation of certain new equipment in each of the existing substations, which may require their expansion. Further, as discussed in the testimonies of Mr. Lehman and Mr. Myers, a singlecircuit, kv transmission line is typically constructed on a right-of-way 10 feet wide. While Tri-State believes that the Project as proposed will meet its needs into the reasonably foreseeable future, Tri-State is exploring the costs and feasibility of acquiring additional rights-of-way that may facilitate the construction of a second Burlington Lamar transmission circuit should that be necessary in the future. Tri-State intends to pay particular attention during the siting and permitting process to any locations where right-of-way bottlenecks might impair the ability to construct future transmission system improvements between Burlington and Lamar. 1 VII. PROJECT COORDINATION 1 1 Q: DID TRI-STATE SOLICIT INTEREST FROM OTHER TRANSMISSION STAKEHOLDERS FOR PARTICIPATION IN THE PROJECT? A: Yes. On April, 1, Tri-State sent a letter to various transmission owners and operators and to independent transmission companies soliciting their interest in expanding the capacity of the Project. A copy of Tri-State s solicitation letter is 0_

24 attached as Exhibit No. CEP- to my testimony. Tri-State informed the recipients that it was considering a new kv transmission line between the existing Burlington and Lamar substations, and solicited interest from parties who may be interested in expanding the capacity of the Project to accommodate additional needs and purposes. Two stakeholders expressed interest in building the Project for Tri-State; however, no stakeholders expressed an interest in participating to expand the capacity of the Project. Q: DID TRI-STATE COORDINATE THE PROJECT WITH OTHER TRANSMISSION OWNERS, OPERATORS, AND STAKEHOLDERS? A: Yes, this Project has been discussed and coordinated in numerous venues. The need for a new transmission element between Burlington and Lamar has been discussed either explicitly or in the context of the larger Lamar Front Range project in each of Tri-State s public FERC 0 and CO PUC Rule stakeholder outreach meetings since October, including: October 1, ; December, ; January 1, 1; April, 1; August, 1; and November, 1. Further, this Project was either specifically mentioned, or on the list of projects open for discussion at all Colorado Coordinated Planning Group meetings during that time. It has been included in each of Tri-State s list of projects in the WestConnect year reports since. Lastly, it has been posted on Tri- State s webpage of projects since. Stakeholders have had the opportunity to or comment through the webpage directly with Tri-State staff with any concerns, questions, or recommendations. 0_

25 Q: WAS THE PROJECT INCLUDED IN TRI-STATE S 1 TEN-YEAR TRANSMISSION PLAN? A: Yes. I would note, however, that the Burlington Lamar transmission project included in the 1 Ten-Year Plan contemplated construction of a kv transmission line that would be operated initially at kv. For the reasons discussed above, Tri-State has determined that the identified needs can be met appropriately through construction of a single-circuit kv transmission line. Q: WAS THE PROJECT INCLUDED IN TRI-STATE S TEN-YEAR TRANSMISSION PLAN? A: Yes, as an element in the larger Lamar Front Range Transmission Project. In Decision No. R-, the Commission found that Tri-State s Ten-Year Transmission Plan, as part of the Joint Ten-Year Plan coordinated with PSCo and Black Hills Energy, complied with Rule and was adequate for purposes of that rule. Q: IS THE PROJECT CONSISTENT WITH THE COORDINATED TRANSMISSION PLANNING GOALS OF COMMISSION RULE? A: Yes. The Project was developed through an open, transparent, and coordinated process that considered the needs and plans of other transmission owners, operators, and stakeholders, so as to evaluate the possibility of a joint project that could meet the needs of other transmission providers and stakeholders. In developing the Project, Tri-State also actively solicited the input of other transmission system stakeholders and ensured they had a meaningful opportunity to participate in and provide input to the development of the Project. 0_

26 The Project does not negatively impact the system of any other transmission provider or the overall transmission system in the near-term or within the longterm transmission planning horizon. The Project does not duplicate the existing or planned facilities of any other transmission provider. As discussed in greater detail in Tri-State s February 1, 1 Rule filing, the Project, as part of Tri- State s coordinated ten-year transmission plan, contributes to the efficient utilization of the transmission system on a best-cost basis, meets all applicable regulatory criteria, complies with or supports compliance with all legal and regulatory requirements, including Tri-State s renewable electricity standard obligations and resource adequacy requirements, and is consistent with applicable transmission planning requirements under Federal Energy Regulatory Commission Order 0. Q: HOW DOES THE PROJECT COMPLEMENT TRI-STATE S LONGER RANGE PLANS IN EASTERN COLORADO? A: In addition to the near-term load serving, reliability, and generation benefits I have discussed, the Project also complements Tri-State s long-range plans for improvements to the bulk electric system in eastern Colorado. While Tri-State s anticipated resource needs do not justify a project the size of Lamar Front Range, staged elements of the Lamar Front Range project do accommodate more reasonably anticipated resource injection needs. Tri-State has studied various scenarios in eastern Colorado, including increased Lamar injection levels from 0 MW to 0 MW. In each of these scenarios, a new kv transmission element between Burlington and Lamar was a critical first piece 0_

27 of any final build-out. Other elements could include increased transmission between Lamar and Comanche and Burlington and Big Sandy. In summary, the Burlington Lamar kv line aligns with, and is the appropriate first step for most reasonable transmission build-out scenarios for eastern Colorado. Q: WAS THE PROJECT INCLUDED IN TRI-STATE S 1 RULE FILING? A: As a component of the larger Lamar Front Range Project, yes, it was, but as a separate, stand-alone project, it was not individually identified. As discussed previously, the Burlington Lamar transmission line was originally proposed as part of the larger Lamar Front Range Project. The Lamar Front Range Project was included in Tri-State s Rule filing, and in Decision No. C-0, the Commission determined that a CPCN was required for that project. The Lamar Front Range Project was included as an Ongoing Project in Tri-State s 1 Rule filing. Consistent with the Commission s previous Decision and the Commission s CPCN rules, Tri-State is applying for a CPCN for the Burlington Lamar kv Transmission Line Project as a stand-alone project. Q: DOES THIS CONCLUDE YOUR DIRECT TESTIMONY? A: Yes. 0_