Dominion" Application, Appendix, DEQ Supplement, Direct Testimony and Exhibits of Virginia Electric and Power Company. Application No.

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1 Dominion" Application, Appendix, DEQ Supplement, Direct Testimony and Exhibits of Virginia Electric and Power Company Before the State Corporation Commission of Virginia Poland Road 230 kv Double Circuit Transmission Line Loop and kv Poland Road Substation Application No. 270 Case No. PUE Filed: May 20, 2015 Volume I of 3

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3 COMMONWEALTH OF VIRGINIA BEFORE THE STATE CORPORATION COMMISSION APPLICATION OF VIRGINIA ELECTRIC AND POWER COMPANY FOR APPROVAL AND CERTIFICATION OF ELECTRIC FACILITIES Poland Road 230 kv Double Circuit Transmission Line Loop and kv Poland Road Substation Application No. 270 Case No. PUE Filed: May 20, 2015

4 COMMONWEALTH OF VIRGINIA BEFORE THE STATE CORPORATION COMMISSION Application of Virginia Electric and Power Company For approval and certification of electric transmission facilities under Va. Code and the Utility Facilities Act, Va. Code et seq. ) ) ) ) ) ) ) ) Case No. PUE APPLICATION OF VIRGINIA ELECTRIC AND POWER COMPANY FOR APPROVAL AND CERTIFICATION OF ELECTRIC FACILITIES FOR POLAND ROAD 230 kv DOUBLE CIRCUIT TRANSMISSION LINE LOOP AND kv POLAND ROAD SUBSTATION Virginia Electric and Power Company ("Dominion Virginia Power" or the "Company") respectfully shows as follows: 1. Dominion Virginia Power is a public service corporation organized under the laws of the Commonwealth of Virginia furnishing electric service to the public within its Virginia service territory. The Comphny also furnishes electric service to the public in portions of North Carolina. Dominion Virginia Power s electric system, consisting of facilities for generation, transmission and distribution of electric energy, is interconnected with the electric systems of neighboring utilities, and is a part of the interconnected network of electric systems serving the continental United States. By reason of its operation in two states and its interconnections with other utilities, the Company is engaged in interstate commerce. 2. In order to perform its legal duty to furnish adequate and reliable electric service, Dominion Virginia Power must, from time to time, replace and construct new

5 transmission facilities in its system. The electric facilities proposed in this application are necessary so that Dominion Virginia Power can provide service requested by a retail electric service customer (the "Customer") for a new data center campus in Loudoun County, Virginia and maintain reliable electric service to its customers in the area in accordance with mandatory North American Electric Reliability Corporation ("NERC") Reliability Standards for transmission facilities and the Company s planning criteria. 3. Accordingly, the Company proposes to construct in Loudoun County, Virginia a new kv Poland Road Substation and a new approximately 4.0-mile overhead 230 kv double circuit transmission line between a tap of existing 230 kv Loudoun-Brambleton Line #2094 ("Poland Road Junction") and the proposed Poland Road Substation ("Poland Road Loop") (the Poland Road Loop and Poland Road Substation, collectively, the "Project"). 4. The proposed new facilities must be in service by June of 2018 to serve the Customer s development located on approximately 47 acres in Loudoun County, Virginia. This in-service date reflects a coordinated adjustment to the Customer s original load ramp and campus build-out schedule to accommodate the permitting and construction schedule. The necessity for the proposed Project is described in more detail in Section I of the Appendix attached to this application. 5. The proposed Poland Road Loop will be constructed on new right-of-way using double circuit, single-shaft galvanized steel poles with three twin-bundled 795 ACSR 26/7 phase conductors with a summer transfer capability of 1225 MVA. The approximate size of the structures, the materials to be used to construct the Project, and the right-of-way clearing methods, corridor usage and maintenance procedures are described in Section II of

6 the Appendix. The proposed facilities will meet or exceed the standards of the National Electrical Safety Code in effect at the time of construction. 6. As noted above, the in-service date for the proposed facilities is June 2018, with an estimated 18 months for construction of the Project and a period of 12 months for engineering, material procurement, right-of-way acquisition and construction permitting. The estimated cost of the Project is approximately $54.5 million (2015 dollars), of which approximately $39.5 million is for transmission line construction, approximately $4.3 million is for transmission station work and $10.7 million is for distribution substation work. The proposed facilities will afford the best means of meeting the continuing need for reliable service while reasonably environmental and historic assets of the area. minimizing adverse impact on the scenic, The Project will be constructed on a new 100- foot transmission right-of-way but parallels Route 50 for substantially all of its length. The Company has identified a proposed route and two alternate routes for the Commission s consideration. The proposed transmission line route and two alternate routes are described in Section III of the Appendix. 8. Based on consultations with the Virginia Department of Environmental Quality ("DEQ"), the Company has developed a supplement ("DEQ Supplement") containing information designed to facilitate review and analysis of the proposed facilities by the DEQ and other relevant agencies. The DEQ Supplement is attached to this application, as is a Route Selection Report. 9. Dominion Virginia Power s experience, the advice of consultants and a review of published studies by experts in the field have disclosed no causal link to harmful health or

7 safety effects from electric and magnetic fields generated by the Company s existing or proposed facilities. For further discussion of this topic, see Section IV of the Appendix. 10. A list of federal, state and local agencies and officials that reasonably may be expected to have an interest in the proposed construction, and to which a copy of the application will be sent, is set forth in Section V of the Appendix. 11. In addition to the information provided in the Appendix, the DEQ Supplement and the Route Selection.Report, this application is supported by the prepared direct testimony of Company witnesses Mark R. Gill, Harrison S. Potter, Robert J. Shevenock II, Santosh Bhattarai and Benjamin A. Saunders filed with this application.

8 WHEREFORE, Dominion Virginia Power respectfully requests that the Commission: (a) direct that notice of this application be given as required by of the Code of Virginia; (b) approve pursuant to of the Code of Virginia the construction of the proposed 230 kv transmission facilities; and (c) grant a certificate of public convenience and necessity for the facilities under the Utility Facilities Act. VIRGINIA ELECTRIC AND POWER COMPANY B CI McAfee Counsel for Applicant Charlotte P. McAfee Dominion Resources Services, Inc. 120 Tredegar Street Richmond, Virginia (804) charlotte.p, mcafee@dom, com Vishwa B. Link Jennifer D. Valaika McGuireWoods LLP One James Center, 901 East Cary Street Richmond, Virginia (804) (804) vlink@mcguirewoods, corn jvalaika@mcguirewooods, tom Counsel for Applicant Virginia Electric and Power Company May 20, 2015

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10 COMMONWEALTH OF VIRGINIA BEFORE THE STATE CORPORATION COMMISSION APPLICATION OF VIRGINIA ELECTRIC AND POWER COMPANY FOR APPROVAL AND CERTIFICATION OF ELECTRIC FACILITIES Poland Road 230 kv Double Circuit Transmission Line Loop and kv Poland Road Substation Application No. 270 Appendix Containing Information in Response to "Guidelines of Minimum Requirements for Transmission Line Application" Case No. PUE Filed: May 20, 2015

11 TABLE OF CONTENTS I. Necessity for the Proposed Project... 1 II. Description of the Proposed Project III. Impact of Line on Scenic, Environmental and Historic Features IV. Health Aspects of EMF V. Notices... 90

12 I. NECESSITY FOR THE PROPOSED PROJECT Detail the engineering justifications for the proposed project (for example, provide narrative to support why the project is necessary to upgrade or replace an existing facility, to significantly increase system reliability, to connect a new generating station to the Company s system, etc.). Detail the later plans for the proposed project, if appropriate. Response: In order to provide service requested by a retail electric service customer (the "Customer") for a new data center campus in Loudoun County, Virginia; to maintain reliable ~ervice for the overall growth in the area; and to comply with mandatory North American Electric Reliability Corporation ("NERC") Reliability Standards by increasing transmission capacity; Virginia Electric and Power Company ("Dominion Virginia Power" or the "Company") proposes to construct in Loudoun County, Virginia a new kv Poland Road Substation and a new approximately 4.0-mile overhead 230 kv double circuit transmission line between a tap of existing 230 kv Loudoun- Brambleton Line #2094 ("Poland Road Junction") and the proposed Poland Road Substation ("Poland Road Loop") (the Poland Road Loop and Poland Road Substation, collectively, the "Project"). Attachments I.A.1 and I.A.2 are one-line diagrams of the area transmission system before and after construction of the Project. See Attachment II.A.2 for a map depicting the proposed Project, and Attachments I.E.1 and I.E.2 for depictions of the existing transmission system in the area and the addition of the Project. The Customer is developing a data center campus in Loudoun County, which has been identified as the East Gate Campus. This development is on approximately 47 acres and is located south of Washington Dulles International Airport ("Dulles Airport"), approximately 3.3 miles west of Route 28 along Route 50, and the Customer has requested retail electric service from Dominion Virginia Power. The total Customer load at East Gate Campus is projected to be approximately 152 MW, consisting of four buildings. The proposed new electric transmission facilities must be in service by June of 2018 to serve the Customer s new development. The proposed Poland Road Substation will be constructed initially with four 230 kv breakers in a ring arrangement, two 84 MVA, kv transformers, eight 34.5 kv distribution circuits, and other associated equipment. It will be designed to accommodate future growth in the area with a build-out of three 84 MVA, kv transformers, and eleven 34.5 kv distribution circuits. The load area served by the proposed Poland Road Substation will be referred to as the "Poland Road Load Area" for purposes of this Appendix.

13 The proposed Poland Road Loop will be constructed on new right-of-way from Poland Road Junction using double circuit, single-shaft galvanized steel poles with three twin-bundled 795 ACSR 26/7 phase conductors with a summer transfer capability of 1225 MVA. The Poland Road Loop will create two new 230 kv lines to be designated 230 kv Loudoun-Poland Road Line #2094 and 230 kv Brambleton-Poland Road Line #2183. The proposed route for the Poland Road Loop ("Proposed Route"), as well as Alternate Routes A (Northern Route) and B (Southern Route) comprised of alternative route segments for possible consideration by the Commission, are described in Section II.A.1 of this Appendix and in detail in the Route Selection Report included with this application. The double circuit Poland Road Loop was selected over a single circuit tap because the load at the Poland Road Substation, including the Customer s load ramp schedule, is projected to exceed 100 MW by April To accommodate the permitting and construction schedule, however, the Company has coordinated with the Customer to adjust the ramp schedule to reflect the proposed summer (commencing June 1) 2018 in-service date for the Project. Consequently, the Company anticipates that loading at the Poland Road Substation including the Customer s load, will reach or exceed 100 MW by August In order to comply with mandatory NERC Reliability Standards, the Company maintains NERC-compliant "Facility Connection Requirements," which include the Company s Transmission Planning Criteria. Section C.2.6 of the Company s Transmission Planning Criteria limit loading on a radial feed in excess of 100 MW without "an alternate transmission supply." The double circuit configuration of the Poland Road Loop satisfies this criterion. Federally-mandated NERC Reliability Standards constitute minimum criteria with which all public utilities must comply as components of the interstate electric transmission system. Moreover, the Energy Policy Act of 2005 mandates that electric utilities must follow these NERC Reliability Standards, and utilities could be fined up to $1 million a day per violation if found to be in noncompliance. NERC has been designated by the Federal Energy Regulatory Commission ("FERC") as the Electric Reliability Organization for the United States. Dominion Virginia Power is part of the Eastern Interconnection transmission grid, meaning it is interconnected, directly or indirectly, with all of the other transmission systems in the United States and Canada between the Rocky Mountains and the Atlantic coast, except Quebec and most of Texas. All of the transmission systems in the Eastern Interconnection are dependent on each other for support in moving bulk power through the transmission system and t The Company s Transmission Planning Criteria can be found in Exhibit A of the Company s Facility Connection Requirements document, which is available online at 2

14 for reliability support. Dominion Virginia Power s service to its customers is extremely reliant on a robust and reliable regional transmission system. Dominion Virginia Power also is part of the PJM Interconnection L.L.C. ("PJM") regional transmission organization (RTO) providing service to a large portion of the eastern United States. PJM is currently responsible for ensuring the reliability and coordinating the movement of electricity through all or parts of Delaware, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia and the District of Columbia. This service area has a population of about 60 million and on July 21,2011, set a record high of 158,450 MW for summer peak demand, of which Dominion Virginia Power s load portion was approximately 19,636 MW serving 2.4 million customers. On July 22, 2011 the Company set a record high of 20,061 MW for summer peak demand. On February 20, 2015, the Company set a winter and all-time record demand of 21,651 MW. Moreover, based on the 2015 PJM Load Forecast, the Dominion Zone is expected to be one of the fastest growing zones in PJM with an average growth rate of 1.7% over the next ten years compared to the PJM average of 1.0% over the same period. Dominion Virginia Power s transmission system is responsible for providing transmission service to the Company s retail customers and also to Appalachian Power Company (APCo), Old Dominion Electric Cooperative (ODEC), Northern Virginia Electric Cooperative ("NOVEC"), Central Virginia Electric Cooperative (CVEC), and Virginia Municipal Electric Association (VMEA) for redelivery to their retail customers in Virginia, as well as to North Carolina Electric Membership Corporation (NCEMC) and North Carolina Eastem Municipal Power Agency (NCEMPA) for redelivery to their customers in North Carolina. The Company needs to be able to maintain the overall, long-term reliability of its transmission system, as its customers require more power in the future. The estimated cost to construct the Project, which is proposed for completion by June 2018, is approximately $54.5 million (2015 dollars), of which approximately $39.5 million is for transmission line construction, approximately $4.3 million is for transmission station work and approximately $10.7 million is for distribution substation work.

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17 I. NECESSITY FOR THE PROPOSED PROJECT Describe the present system and detail how the proposed project will effectively satisfy present and future demand requirements. Provide pertinent load growth.data (at least five years of historical and ten years of projected loads where applicable). Provide all assumptions inherent within the projected data and why existing right-of-way cannot adequately serve the needs of the Company if that is the case. Indicate when the existing system is projected to be inadequate. If the existing system is, or will at some future time be inadequate in a contingency situation, describe this critical contingency. Detail what might cause such situation. Where appropriate, provide historical incidence of similar situations which would be avoided by the proposed construction. Response: As presented in Attachment I.E. 1, Dominion Virginia Power s existing utility system in the vicinity of the proposed Poland Road Substation includes two switching stations (Loudoun and Mosby) that exclusively network transmission lines and do not contain distribution transformers or distribution circuits to serve local loads. Also presented in Attachment I.E.1 are the five stations containing distribution-level voltages in the vicinity of the proposed Project (Brambleton, Dulles, Discovery, Sully, and Walney). These five stations are networked by lines from three overhead 230 kv transmission corridors. The Company s existing Brambleton Switching Station ("Brambleton Station") is 4.5 straight-line miles northwest from the Customer s East Gate Campus. Brambleton Station is located west of Dulles Airport at the intersection of the north/south Pleasant View-Loudoun corridor and the Brambleton-Shellhorn corridor. Brambleton Station contains nine 230 kv breakers arranged in breaker-and-a-half configuration, one 84 MVA kv transformer and three 34.5 kv distribution circuits. A planned expansion includes a second kv 84 MVA transformer and two additional distribution circuits. NOVEC s Brambleton Delivery Point ("DP"), located at and sourced from Brambleton Station, contains two 40 MVA kv transformers; four 34.5 kv distribution circuits; two 30 MVA kv transformers; and eight 12.5 kv distribution circuits. Two 500 kv lines and six overhead 230 kv lines currently terminate at Brambleton Station.2 Emanating from the north are 500 kv Brambleton- Goose Creek Line #558, 230 kv Brambleton-Pleasant View Line #201, and 230 kv Brambleton-Beaumeade Line #227. Leaving the station from the south are 500 kv Brambleton-Mosby Line #590, 230 kv Brambleton- Loudoun Line #2045, and 230 kv Brambleton-Loudoun Line #2094. Existing 2 An additional 500 kv line between Brambleton and Mosby Stations is pending before the Commission in Case No. PUE

18 230 kv Brambleton-Enterprise Line #2095 and Brambleton-BECO Line #2137 (Brambleton-Pacific by 2016) leave the station to the east. The other four substations in the vicinity (Dulles, Discovery, Sully, and Walney) are located in the overhead corridor that roughly parallels Route 28 (Sully Road) east of Dulles Airport and crosses Route 50 south of Dulles Airport. Dulles Substation is the northernmost station of the four and is the terminus for 230 kv Loudoun-Dulles Line #2008 and Dulles-Reston Line #2115. Dulles Substation also contains one 75 MVA and one 84 MVA kv transformer, six 34.5 kv distribution circuits, two 56 MVA kv transformers, and six 13.2 kv distribution circuits. Discovery Substation, approximately 1.8 miles south of Dulles Substation, is the terminus for 230 kv Sully-Discovery Line #2107 and Discovery-Reston Line #2043. Discovery Substation also contains two 33 MVA kv transformers servicing on-site customer load. Sully Substation is located south of Discovery Substation, approximately 1.2 miles east of the main Route 28 corridor. Sully Substation contains two 75 MVA kv transformers and six 34.5 kv distribution circuits. Walney Substation is approximately 2.5 straight-line miles southeast of the Customer s East Gate Campus. Walney Substation is the southernnmst station of the four in this corridor and contains two 75 MVA transformers and six 34.5 kv distribution circuits. A planned expansion of this substation includes a new kv 84 MVA transformer along with three 34.5 kv distribution circuits. The Company s distribution network to the Customer s site will consist of four 34.5 kv distribution circuits, two from the west (Brambleton distribution circuit ("DC") #616, #641) and two from the east (Walney DC #451, #667) on horizontally-arranged double circuit pole structures that tie at the property. Brambleton 34.5 kv DC #616 and future DC #641 run 1.5 miles south along the existing transmission right-of-way from the substation and 3.6 miles east along Route 50 to the Customer s East Gate Campus. The remaining Brambleton circuits are not available for either bridging or permanent service. Walney 34.5 kv DC #667 runs north 1.0 mile along the transmission right-ofway to Route 50 and then heads west 4.0 miles to the Customer s East Gate Campus. Future DC #451 runs 1.5 miles north along Stonecroft Boulevard and 2.2 miles west along Route 50 to the East Gate Campus. These four circuits represent the full extent of load that the Company s distribution network will be able to serve until the proposed Poland Road

19 Substation is energized. Each circuit is rated for 36 MVA (for a total of 144 MVA) with differing amounts of existing load currently served by each circuit. Due to the amount of load requested by the Customer and the line mileage from the Company s existing substations, prudent utility practice would prevent building additional distribution circuits to feed the Customer s load long-term. Neither of the Dominion Virginia Power stations containing distribution-level voltage that currently feed into the area where the Customer is constructing the East Gate Campus - Brambleton Station and Walney Substation - is suitable to be a long-term source of power to serve the Customer s projected loads as explained in detail below. All distribution alternatives to the proposed Project were therefore rejected.. Attachment I.B.1 shows historical and projected loads for the Poland Road Load Area without the load contribution associated with the Customer s East Gate Campus. Five years of historical and 10 years of projected loads are shown for the summer season. Summer loads are shown because the higher ambient temperatures cause customer loads in this area to be at their annual maximum, and the heat also reduces the thermal capacity of the distribution system components such as wire and transformers. Load growth was estimated at 1% each year. Attachment I.B.2 shows historical and projected loads for the four 34.5 kv distribution circuits (Walney DC #451 and #667, Brambleton DC #616 and #641) that will serve the Customer s East Gate Campus. As the area s customer load increases in tandem with the Customer s requested load ramp schedule, overloads are projected to occur in summer (commencing June.1) The Customer has requested service for 125 MVA3 by summer 2017, and with only MVA available on distribution circuits, the Company has worked with the Customer to adjust the original ramp schedule mentioned in Section I.A. Attachment I.B.3 shows historical and projected loads for the Poland Road Load Area with the Customer s adjusted ramp schedule. Normal and Contingency overloads on the area s distribution system are solved with this proposed Project. Initially, Poland Road Substation will primarily feed the Customer s load but will be available for future load growth in the surrounding area. Ultimately, 3 Apparent power, measured in megavolt amperes (MVA), is made up of real power (MW) and reactive power megavolt ampere reactive (MVAR). The power factor (pf) is the ratio of real power to apparent power. For loads with a high pf (approaching unity), real power will approach apparent power and the two can be used interchangeably. Load loss criteria specify real power (MW) units because that represents the real power that will be dropped; however, MVA is used to describe the equipment ratings to handle the apparent power, which includes the real and reactive load components.

20 the reliability for customers in the Poland Road Load Area can be enhanced for two distinct reasons. First, with additional capacity, the Company will have greater opportunity to switch load to other available circuits in the event of an outage on any given circuit, which can result in faster restoration times in the event of an outage. Second, by constructing new distribution circuits into the load area from the proposed Poland Road Substation, the length of certain circuits could be reduced, which improves the distribution system reliability. 9

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24 I. NECESSITY FOR THE PROPOSED PROJECT Co Describe the feasible alternatives, if any, for meeting the identified need without constructing the proposed project. Explain why these alternatives were rejected. Response: The Company considered and rejected electrical alternatives to the proposed Project, including the use of distribution facilities as well as existing and planned substations to serve the need for the Project. Distribution Alternatives: Distribution alternatives for serving the Customer s East Gate Campus are described in Section I.B. For the reasons stated, there is no feasible distribution alternative to the Project. Transmission Alternatives: Because the Customer load described in this application and the facilities proposed in Case No. PUE (Yardley Ridge 230 kv Loop and Yardley Ridge Switching Station ("Yardley Ridge Station"), collectively the "Yardley Ridge Project") are in physical proximity to each other and have coincident target dates, the following transmission alternatives have been developed and studied for both projects (collectively, "Projects"). The estimated costs of the Transmission Alternatives described in this section do not include the estimated $10.7 million distribution substation costs associated with the Project, as noted in the comparison table included as Attachment I.C.7. Transmission Alternative (I) Construct 230 kv Belmont Switching Station in the Line 2095/#2137 corridor and an overhead double circuit 230 kv line from Belmont Station to new Yardley Ridge Station and from Yardley Ridge Station to new Poland Road Substation. This alternative would involve construction of a new Belmont Switching Station ("Belmont Station") in the Line #2095/#2137 corridor, approximately 1.65 miles east of existing Brambleton Station. The new Belmont Station would be constructed with a six-breaker 230 kv ring bus to accommodate cutting and terminating Brambleton-Enterprise Line #2095 and Brambleton- Pacific #2137, to create Brambleton-Belmont Line #2095, Brambleton- Belmont Line #2137, Belmont-Pacific Line #9067,4 and Belmont-Enterprise Line #9068. Also from Belmont Station, a new approximately 0.5-mile overhead 230 kv double circuit transmission line would be constructed to Yardley Ridge Station and an additional approximately 3.2-mile overhead Line numbers in the #9000 series represent conceptual lines identified only for study of electrical alternatives to the Project. 13

25 kv double circuit transmission line would be constructed from Yardley Ridge Station to Poland Road Substation. This would create Belmont-Yardley Ridge Line #9069, Belmont-Poland Road Line #9070, and Yardley Ridge- Poland Road Line #9071. The Yardley Ridge Station would be constructed as described in the Yardley Ridge Project application and Poland Road Substation would be constructed as described in Section II.C of this Appendix. These new lines would be built in new right-of-way using double circuit, single-shaft galvanized steel poles with three twin-bundled 795 ACSR 26/7 phase conductors with a summer transfer capability of 1225 MVA. The cost of this alternative is estimated to be approximately $63.0 million. See Attachment I.C.1 for a one-line diagram of this alternative. Also, see Attachment I.C.7 for a table comparing th~ costs of the Transmission Alternatives to the Projects. In addition to a higher cost than the combined costs of the proposed Project and Yardley Ridge Project, this transmission alternative was not selected because it would cause reliability violations by increasing the loading to more than the 300 MW threshold for allowable load loss on the 230 kv line network connected to Belmont Station, Yardley Ridge Station, and Poland Road Substation, creating a NERC Category C (N-1-1) criteria violation for a tower event. In order to resolve the violation associated with the 300 MW tower event, a double circuit line would be continued approximately 3.1 miles beyond Poland Road Substation to the Line #265/#2008 corridor and a new South Dulles Switching Station ("South Dulles Station"), effectively constructing Transmission Alternative (2) described below. Further, the line between Yardley Ridge Station and Poland Road Substation would involve obtaining easements from the Metropolitan Washington Airports Authority ("MWAA") that the Company expects would require a federal review under the National Environmental Policy Act ("NEPA"), which could further delay energization of the Poland Road Substation. Transmission Alternative (2) Construct 230 kv Belmont Station in the Line #2095/#2137 corridor and 230 kv South Dulles Station in the Line #265/#2008 corridor. Also, construct an overhead double circuit 230 kv line from Belmont to new Yardley Ridge Station, from Yardley to new Poland Road Substation, and from Poland to South Dulles Station. In addition to constructing the Belmont, Yardley Ridge, and Poland Road facilities and lines as described for Transmission Alternative (1), this alternative would involve construction of the South Dulles Station in the Line #265/#2008 corridor, approximately 1.25 miles northeast of the Company s Walney SubStation. The new South Dulles Station would be constructed with a six-breaker 230 kv ring bus to accommodate cutting and terminating 230 kv Clifton-Sully Line #265 and Loudoun-Dulles Line #2008, which would create 230 kv Clifton-South Dulles Line #265,230 kv Loudoun-South Dulles Line #2008, 230 kv South DullesoDulles Line #9079, and 230 kv South 14

26 Dulles-Sully Line #9080. Also from South Dulles Station, a new approximately 3.1-mile overhead 230 kv double circuit transmission line would be constructed to Poland Road Substation. One of the new lines from South Dulles Station would tie into Line #9071 from Yardley Ridge Station to create a Yardley Ridge-South Dulles line while the other new line would terminate at Poland Road Substation to create South Dulles-Poland Road Line #9072. The Yardley Ridge Station and Poland Road Substation would be constructed as described for Transmission Alternative (1). These new lines would be built in new right-of-way using double circuit, single-shaft galvanized steel poles with three twin-bundled 795 ACSR 26/7 phase conductors with a summer transfer capability of 1225 MVA. The cost of this alternative is estimated to be approximately $115.8 million. See Attachment I.C.2 for a one-line diagram of this alternative. Also, see Attachment I.C.7 for a table comparing the costs of the Transmission Alternatives to the Projects. In addition to its cost being higher than the combined costs of the proposed Project and Yardley Ridge Project, this alternative was not selected because Lines #2095 and #2137 are projected to load to approximately 150% of their 1047 MVA rating for an N-l-1 event in 2023, involving the loss of either one of these lines and 230 kv Pleasant View-Beaumeade Line #274. To resolve this violation, a rating in excess of 4000 Amps would be required which is not feasible for a double circuit 230 kv facility, thereby requiring that a third line be constructed between Brambleton Station and Belmont Station. However, the available space at Brambleton Station will not accommodate another row of 230 kv breakers to terminate an additional 230 kv line. Further, both the South Dulles Station and the line between Yardley Ridge Station and Poland Road Substation would involve obtaining easements from MWAA that the Company expects would require a federal review under NEPA, which could further delay energization of the Poland Road Substation and Yardley Ridge Station. Transmission Alternative (3) Construct 230 kv South Dulles Station in the Line #265/#2008 corridor and an overhead double circuit 230 kv line from South Dulles Station to Poland Road Substation. Also, construct an overhead double circuit 230 kv line from the Line #2095/#2137 corridor to the new Yardley Ridge Station. This altemative would involve construction of the South Dulles Station in the Line #265/#2008 corridor, approximately 1.25 miles northeast of the Company s Walney Substation. The new South Dulles Station would be constructed with a six-breaker 230 kv ring bus to accommodate cutting and terminating Clifton-Sully Line #265 and Loudoun-Dulles Line #2008, which would create Clifton-South Dulles Line #265, Loudoun-South Dulles Line #2008, South Dulles-Dulles Line #9079, and South Dulles-Sully Line #9080. Also from South Dulles Station, a new approximately 3.1-mile overhead 230 kv double circuit transmission line would be constructed to Poland Road Substation. Both of the new lines from South Dulles Station would terminate 15

27 at Poland Road Substation, creating South Dulles-Poland Road Line #9071 and #9072. In the Line #2095/#2137 corridor, existing 230 kv Brambleton- Pacific Line #2137 would be cut and extended to Yardley Ridge Station as the Yardley Ridge Loop. This would create Brambleton-Yardley Ridge Line #2137 and Yardley Ridge-Pacific Line #9067. The Yardley Ridge Station and Poland Road Substation would be constructed as described for Transmission Alternative (1). These new lines would be built in new right-of-way using double circuit, single-shaft galvanized steel poles with three twin-bundled 795 ACSR 26/7 phase conductors with a summer transfer capability of 1225 MVA. The cost of this alternative is estimated to be approximately $61.4 million. See Attachment I.C.3 for a one-line diagram of this alternative. Also, see Attachment I.C.7 for a table comparing the costs of the Transmission Alternatives to the Projects. This alternative was not selected due to its cost being higher than the combined costs of the proposed Project and Yardley Ridge Project. Further, as mentioned in the previous alternative discussion, the South Dulles Station would involve obtaining an easement from MWAA that the Company expects would require a federal review under NEPA, that could delay energization of the Poland Road Substation. Additionally, implementing this alternative without the South Dulles Station would cause undesirable reliability consequences by increasing to more than the 300 MW threshold for allowable load loss on the 230 kv line network connected to Loudoun Station and Reston Substation, creating a NERC Category C (N-l-l) criteria violation for a tower event. As described in Section I.B, Dulles Substation is sourced by Loudoun-Dulles Line #2008 and Dulles-Reston Line #2115. Line #2008 and Line #2115 do not have another network source between Loudoun Station and Reston Substation, including at Dulles Substation, which means that any load tapped from these lines is subject to being dropped for the loss of source at Loudoun and Reston Substations. In addition to the load from the four Dulles distribution transformers, other load sourced from these lines already includes Reston TX#1, Walney TX#1, and NOVEC s Cub Run DP. Additionally, future Walney TX#4 will be sourced from these lines. As the combined load on Line #2008 and Line #2115 continues to grow toward 300 MW, it is anticipated that a switching station will eventually be needed to network Line #2008 and Clifton-Sully Line #265 somewhere in the corridor between Walney and Dulles Substations. Two locations for a possible switching station have been preliminarily identified along this corridor, in the vicinity of Route 50. The first location, north of Route 50, on MWAA property, would provide access to both Line #2008 and Line #265 while accommodating line terminals for the proposed Poland Road Loop. Unfortunately, it is anticipated that this site could not be acquired and constructed in time to meet the needs identified in the Yardley Ridge Project. The second location, south of Route 50, would also provide access to both Line #2008 and Line #265; however, the lines for the Poland Road Loop leaving the site would have to utilize the existing transmission corridor to the north, which is encumbered with 16

28 overhead distribution circuits and an underground gas transmission line that would be difficult to expand due to surrounding commercial growth. Transmission Alternative (4) Construct 230 kv South Dulles Station in the Line #265/#2008 corridor. Also, construct an overhead double circuit 230 kv line from South Dulles to new Poland Road Substation, from Poland Road to new Yardley Ridge Station, and from Yardley to the Line #2095/#2137 corridor. This alternative is essentially the same as Transmission Alternative (2) discussed above, except without construction of the Belmont Station. This alternative would involve construction of the South Dulles Station in the Line #265/#2008 corridor with a six-breaker 230 kv ring bus to accommodate cutting and terminating Clifton-Sully Line #265 and Loudoun-Dulles Line #2008, which would create Clifton-South Dulles Line #265, Loudoun-South Dulles Line #2008, South Dulles-Dulles Line #9079, and South Dulles-Sully Line #9080. Also from South Dulles Station, a new approximately 3.1-mile overhead 230 kv double circuit transmission line would be constructed to Poland Road Substation, continue approximately 3.2 miles from Poland Road Substation to Yardley Ridge Station, and another approximately 0.5 mile from Yardley Ridge Station to the Line #2095/#2137 corridor where Line #2137 would be cut and tied into the new double circuit construction. The following lines would be created: South Dulles-Yardley Ridge Line #9071, South Dulles-Poland Road Line #9072, Poland Road-Yardley Ridge Line #9070, Brambleton-Yardley Ridge Line #2137, and Poland Road-Pacific Line #9070. The Yardley Ridge Station.and Poland Road Substation would be constructed as described for Transmission Alternative (1). These new lines would be built in new right-of-way using double circuit, singlershaft galvanized steel poles with three twin-bundled 795 ACSR 26/7 phase conductors with a summer transfer capability of 1225 MVA. The cost of this alternative is estimated to be approximately $87.4 million. See Attachment I.C.4 for a one-line diagram of this alternative. Also, see Attachment I.C.7 for a table comparing the costs of the Transmission Alternatives to the Projects. This altemative was not selected due to its cost being higher than the combined costs of the proposed Project and Yardley Ridge Project. Further, as mentioned in the previous alternative discussion, both the South Dulles Station and the line between Yardley Ridge Station and Poland Road Substation would involve obtaining easements from MWAA that the Company expects would require a federal review under NEPA, which could delay energization of the Poland Road Substation. 17

29 Transmission Alternative (5) Construct an overhead double circuit 230 kv line from the Line #2045/#2094 corridor to the new Poland Road Substation and an overhead double circuit 230 kv line from the Line #2095/#2137 corridor to the new Yardley Ridge Station. Also, construct an overhead double circuit 230 kv line between Yardley Ridge Station and Poland Road Substation. This alternative is essentially the same as the proposed Project and the Yardley Ridge Project in combination, except with the additional overhead double circuit 230 kv line between Yardley Ridge Station and Poland Road Substation. This additional overhead double circuit 230 kv line would extend south from Yardley Ridge Station approximately 1.5 miles to the intersection with the Poland Road Loop, in the vicinity of Loudoun County Parkway (Route 606) and Route 50. The following lines would be created by this alternative: Loudoun-Poland Road Line #2094, Poland Road-Pacific Line #9067, Brambleton-Yardley Ridge Line #9071 and #2137. The Yardley Ridge Station and Poland Road Substation would be constructed as described previously. These new lines would be built in new right-of-way using double circuit, single-shaft galvanized steel poles with three twin-bundled 795 ACSR 24/7 phase conductors with a summer transfer capability of 1225 MVA. The cost of this alternative is estimated to be approximately $67.0 million. See Attachment I.C.5 for a one-line diagram of this alternative. Also, see Attachment I.C.7 for a table comparing the costs of the Transmission Alternatives to the Projects. This alternative was not selected due to its cost being higher than the combined costs of the proposed Project and Yardley Ridge Project. Further, as mentioned in the previous alternative discussion, the line between Yardley Ridge Station and Poland Road Substation would involve obtaining an easement from MWAA that the Company expects would require a federal review under NEPA, which could further delay energization of the Poland Road Substation and Yardley Ridge Station. Transmission Alternative (6) Construct an overhead double circuit 230 kv line from the Line #2045/#2094 corridor to the new Poland Road Substation and an overhead double circuit 230 kv line from the Line #2095/#2137 corridor to the new Yardley Ridge Station. Also, construct an overhead double circuit 230 kv line between Yardley Ridge Station and Poland Road Substation. This alternative is essentially the same as Transmission Alternative (5) except that the transmission lines for the Poland Road Loop are transposed such that the following lines would be created by this alternative: Loudoun-Yardley Ridge Line #2094, Poland Road-Pacific Line #9067, Brambleton-Poland Road Line #9071, and Brambleton-Yardley Ridge Line #2137. The Yardley Ridge Station and Poland Road Substation would be constructed as described for Transmission Alternative (1). These new lines would be built in new right-of- 18

30 way using double circuit, single-shaft galvanized steel poles with three twinbundled 795 ACSR 26/7 phase conductors with a summer transfer capability of 1225 MVA. The cost of this alternative is estimated to be approximately $67.0 million. See Attachment I.C.6 for a one-line diagram of this alternative. Also, see Attachment I.C.7 for a table comparing the costs of the Transmission Alternatives to the Projects. This altemative was not selected due to its cost being higher than the combined costs of the proposed Project and Yardley Ridge Project. Further, as mentioned in the discussion of Transmission Altemative (5), the line between Yardley Ridge Station and Poland Road Substation would involve obtaining an easement from MWAA that the Company expects would require a federal review under NEPA, which could further delay energization of the Poland Road Substation and Yardley Ridge Station. Underground Alternative In addition to the six Transmission Alternatives described above, the Company also considered an underground alternative to the Project, which would require construction of a transition and switching station with two reactors adjacent to the overhead lined corridor where the 230 kv overhead line will be tapped. The high-level cost estimate for an electrically equivalent underground alternative, excluding the distribution work required at the proposed Poland Road Substation, is approximately $133 million and was rejected because an overhead route exists and the cost of the underground alternative is slightly more than three times greater than the cost of the Project. 19

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37 26

38 NECESSITY FOR THE PROPOSED PROJECT D. Describe any lines or facilities which will be removed, replaced, or taken out of service upon completion of the proposed project. Response: Not applicable. 27

39 I. NECESSITY FOR THE PROPOSED PROJECT Provide a system map of suitable scale showing the location and voltage of the Company s transmission lines, substations, generating facilities, etc., which would affect or be affected by the new transmission line and are relevant to the necessity for the proposed line. Clearly, label on this map all points referenced in the necessity statement. Response: See Attachment I.E.1 for a system map of the existing transmission system facilities and Attachment I.E.2 for a system map with the addition of the Project facilities. These maps show the general locations and are not intended to show the actual location of facilities. 28

40 Existing Transmission System Attachment I.E ~//~// 115kV Transmission Line 230kV Transmission Line 500kV Transmission Line 203 A Dominion Switching/Substation ~-~ Delivery Point W~POOL GREENWAY ENTERPRISE STERLING. PARK BRAMBLEToN DP BRAMBLEToN ~ / SHELLHORN RUNAWAY DP NEW ROAD DULLES 2043 o "~ ARCOLA DP FAIRFAX 2107,OUDOUN 115, & 500KV MOSBY _ / WALNEY SULLY DP 2030 BULL

41 Transmission System with Proposed Projects Attachment I.E.2 PLEASANT 115kV Transmission Line 230kV Transmission Line 500kV Transmission Line Yardley Ridge Route Poland Road Route A Dominion Switching/Substation ---~ Delivery Point 2Ol ASHBURN "274 "\\ GREENWAY, ~ 2081 STERLING ENTERPRISE BRAMBLEToN DP 2045,-- ~ NEW ROAD " ~,OUDOUN 115, 30, & 500KV ARCOLA DPi / /// SHELLHORN 227._ - ---, RUNAWAYDP MOSBY 156 E 2094 ~~ DULLES POLAND ROAD FAIRFAX 2033 RE: 2043 DISCOVERk ~2107~ SULLY 20O EATHARPIN DP

42 NECESSITY FOR THE PROPOSED PROJECT F. Provide the desired in-service date of the proposed project and the estimated construction time. Response: The in-service date for the proposed Project is June The estimated construction time for the Project is 18 months. A period of 12 months will be needed for engineering, material procurement, and construction permitting. 31

43 I. NECESSITY FOR THE PROPOSED PROJECT G. Provide the estimated cost of the project. Response: The estimated cost of the Project is approximately $54.5 million, which is comprised of $39.5 million for transmission line work, $4.3 million for transmission station work and $10.7 million for distribution substation work. The transmission line construction costs for Alternate Routes A and B are estimated to be $43.4 million and $36.9 million, respectively. All costs are based on 2015 dollars. 32

44 I. NECESSITY FOR THE PROPOSED PROJECT In addition to all other information required by these guidelines, applications for approval to construct facilities and transmission lines interconnecting a Non Utility Generator (NUG) and a utility shall include the following information. The full name of the NUG as it appears in its contract with the utility and the dates of the initial contract and any amendments; A description of the arrangements for financing the facilities, including information on the allocation of costs between the utility and the NUG: o a. For Qualifying Facilities (QFs) certificated by Federal Energy Regulatory Commission (FERC) order, provide the QF or docket number, the dates of all certification or recertification orders, and the citation to FERC Reports, if available; For self-certificated QFs, provide a copy of the notice filed with the FERC; o So In addition to the information required in 3a or 3b, provide the project number and project name used by the FERC in licensing hydroelectric projects, also provide the dates of all orders and citations to FERC Reports, if available; and If the name provided in 1 above differs from the name provided in 3 above, give a full explanation. Response: Not applicable. 33

45 I. NECESSITY FOR THE PROPOSED PROJECT Describe the new and existing generating sources, distribution circuits or load centers planned to be served by all new substations, switching stations and other ground facilities associated with the proposed project. Response: No new or existing generating facilities are associated with the Project. For a description of distribution circuits and load centers to be served by the Project, see Sections I.A and I.B. 34

46 II. DESCRIPTION OF THE PROPOSED PROJECT A. Right-of-way (ROW) 1. Provide the length of the proposed alternatives; corridor and viable Response: Proposed Route (Parallel Route) The Proposed Route is for a new 230 kv double circuit transmission line that commences at a tap-point along the 230 kv Loudoun-Brambleton Line #2094,. approximately 800 feet south of Route 50, and extends for approximately 4.0 miles primarily paralleling Route 50 before terminating at the proposed Poland Road Substation (also referred to as the "Parallel Route"). The Proposed Route angles to the north from the tap-point for 1,200 feet to parallel Route 50 on the south side of the roadway. The Proposed Route continues parallel to the south side of Route 50 for approximately 1.9 miles, crossing to the north side of Route 50, east of the intersection with Loudoun County Parkway/Old Ox Road. The Proposed Route continues east parallel to the south side of South Perimeter Road (MWAA property boundary), crossing Vance Road before turning southeast parallel to the east side of Vance Road for approximately 920 feet. At this point, the Proposed Route turns east parallel to the north side of Route 50 for approximately 1.0 mile. At this point, the Proposed Route angles to the northeast, away from Route 50, to avoid development immediately adjacent to the roadway (approximately 0.2 mile). On the east side of the development, the Proposed Route angles sharply to the south, crossing Route 50 and entering the proposed Poland Road Substation property (530 feet). Alternate Route A (Northern Route) Alternate Route A is for a new 230 kv double circuit transmission line that commences at a tap-point along the 230 kv Loudoun-Brambleton Line #2094, approximately 1,500 feet north of Route 50, and extends for approximately 4.5 miles before terminating at the proposed Poland Road Substation (also referred to as the "Northern Route"). Alternate Route A commences at the northern tap point along the Loudoun- Brambleton 230 kv transmission line, approximately 1,500 feet north of Route 50, at the intersection of Racefield Lane. Alternative Route A parallels Racefield Lane for approximately 2,000 feet from the tap-point, before turning sharply to the southeast to follow parcel boundaries for 0.8 mile. Alternate Route A then continues east parallel to property boundaries for approximately 1,050 feet. At this point, Alternate Route A turns sharply to the south to parallel Amethyst Lane and property boundaries for 1,200 feet, then turns 35

47 sharply to the east to parallel the north side of Route 50. Altemate Route A parallels Route 50 for approximately 0.8 mile before crossing over Route 50 and then paralleling the south side of Route 50 for approximately 700 feet. Alternate Route A then turns northeast for approximately 350 feet and crosses over Route 50. At this point, Alternate Route A turns east parallel to the north side of Route 50 for approximately 1,700 feet. From this point, Alternate Route A turns east for approximately 1,900 feet and crossing Vance Road. At this point, Alternate Route A turns southeast to parallel the south side of the quarry property line for approximately 1,270 feet. Alternate Route A then turns south for approximately 520 feet before turning southeast to parallel the north side of Route 50 for approximately 2,525 feet. At this point, Alternate Route A angles to the northeast, away from Route 50, to avoid development immediately adjacent to the roadway (approximately 0.2 mile). On the east side of the development, Alternate Route A angles sharply to the south, crossing Route 50 and entering the proposed Poland Road Substation (530 feet). Altemate Route B (Southern Route) Alternate Route B is for a new 230 kv double circuit transmission line that commences at the same southern tap-point along the 230 kv Loudoun- Brambleton Line #2094 as the Parallel Route, approximately 800 feet south of Route 50, and extends for approximately 3.8 miles before terminating at the proposed Poland Road Substation (also referred to as the "Southern Route"). Altemate Route B commences at a tap-point along the Loudoun - Brambleton 230 kv transmission line, approximately 800 feet south of Route 50. Alternate Route B angles to the north from the tap-point for 1,200 feet to parallel Route 50 on the south side of the roadway. Alternate Route B continues parallel to the south side of Route 50 for approximately 3.5 miles and enters the proposed Poland Road Substation. Alternate Route B is identical to the Proposed Route until it crosses Loudoun County Parkway. 36

48 II. DESCRIPTION OF THE PROPOSED PROJECT A. Right-of-way (ROW) o Provide a map of suitable scale showing the route of the proposed line and its relation to: the facilities of other public utilities which could influence the route selection, highways, streets, parks and recreational areas, scenic and historic areas, schools, convalescent centers, hospitals, airports and other notable structures close to the proposed project. Indicate the existing facilities which the line is proposed to follow, such as existing ROW, railroad tracks, etc.; Response: A map of the Proposed Route and Alternate Routes A and B is provided in Attachment II.A.2. 37

49

50 II. DESCRIPTION OF THE PROPOSED PROJECT A. Right-of-way (ROW) 3. Provide a drawing(s) of the ROW cross section showing typical transmission line structure placements referenced to the edge of the right-of-way. This drawing should include: a. ROW width for each cross section drawing; b. Lateral distance between the conductors and edge of ROW; and c. Existing utility facilities on the ROW. Response: See Attachment II.A.3.a. 39

51 ATTACHMENT ll.a.3.e POLAND ROAO TAP PROPOSED 231BKV CIRCUIT (LINE =2183) PROPOSED 231~KV CIRCUIT (LINE "20q4) 37-0" PROPOSED R/W PROPOSED R/W FEET 100 FEET FEET ~I PROPOSED CONFIGURATION TYPICAL RIGHT OF WAY LOOKING TOWARD POLAND ROAD SUBSTATION u w (~ Z TYPE OF STRUCTURE= FOUNDATION = APPROXIMATE AVERAGE HEIGHT= WIDTH AT CROSSARH= WIDTH AT BASE= APPROX. AVERAGE SPAN. LENGTH= CONDUCTOR TYPE= RIGHT OF WAY WIDTH= APPROXIMATE LENGTH OF LINE = 4O STEEL POLE CONCRETE III~ FEET 26 FEET 4 FEET 531ll FEET ALUMINUM II~l~ FEET 4.1~1 MILES

52 II. DESCRIPTION OF THE PROPOSED PROJECT A. Right-of-way (ROW) o Detail what portions of the ROW are subject to existing easements and over what portions easements will be needed. Response: The Proposed Route (Parallel Route), Alternate Route A (Northern Route) and Alternate Route B (Southern Route) are located entirely within Loudoun County, Virginia. The Project will be constructed on a new 100-foot right-ofway. New electric transmission easements will be needed for the entirety of all three route alternatives (Proposed Route, Alternate Route A or Alternate Route B). During the construction phase of the proposed Project, Dominion Virginia Power s distribution will not be able to de-energize the current and planned overhead facilities for transmission construction without sustained outages to the Customer or the Company s existing customers. As shown in Attachment I.B.3, the four 34.5 kv distribution circuits will not have sufficient capacity to pick up additional load for non-outage switching. For this reason, installing the transmission line adjacent to the existing distribution infrastructure would pose significant safety concerns along with potential road blocks to the successful completion of the Project. 41

53 II. DESCRIPTION OF THE PROPOSED PROJECT A. Right-of-way (ROW) 5. Detail the proposed ROW clearing methods to be used and the ROW restoration and maintenance practices planned for the proposed project; Response: The right-of-way will be 100 feet wide. Clearing of the right-of-way will be required to allow construction activities and eventual transmission line operation consistent with NERC compliance requirements applicable to the new 230 kv facilities. Additionally, trees located outside the planned right-ofway that are tall enough to potentially impact the transmission facilities, commonly referred to as danger trees, may also need to be cut. Danger trees will be cut to be no more than three inches above ground level, limbed, and will remain where felled. Debris that is adjacent to homes will be disposed of by chipping or removal. In other areas, debris may be mulched or chipped as practicable. Clearing will be accomplished by hand in wetland areas and within 100 feet of streams. Care will be taken not to leave debris in streams or wetland areas. Matting may be used for heavy equipment in these areas. Erosion control devices will be used on an ongoing basis during all clearing and construction activities. Erosion control will be maintained, and temporary stabilization for all soil disturbing activities will be used until the right-of-way has been restored. Upon completion of the Project, the Company will restore the right-of-way utilizing site rehabilitation procedures outlined in the Company s General Erosion and Sedimentation Control Specifications for the Construction and Maintenance of Electric Transmission Lines that is approved yearly by the Virginia Department of Conservation and Recreation. Time of year and weather conditions may affect when permanent stabilization takes place. This right-of-way will continue to be maintained on a regular cycle to prevent interruptions to electric service and provide ready access to the right-of-way in order to patrol and make emergency repairs. Periodic maintenance to control woody growth will consist of hand cutting, machine mowing and herbicide application. 42

54 II. DESCRIPTION OF THE PROPOSED PROJECT A. Right-of-way (ROW) 6. Indicate the permitted uses of the ROW; Response: Any non-transmission use will be permitted that: is in accordance with the terms of the easement agreement for the right-ofway; is consistent with the safe maintenance and operation of the transmission lines; will not restrict future line design flexibility; and will not permanently interfere with future construction. Typical permitted uses, with conditions, of the rights-of-way include: 1) Agriculture 2) Nurseries 3) Bicycle trails 4) Parking lots 5) Other utility facilities 6) Recreational areas 7) Roadways 8) Fences with gates 43

55 II. DESCRIPTION OF THE PROPOSED PROJECT Right-of-way (ROW) Q Describe the Company s route selection procedures. Detail alternative routes considered. Describe the Company s efforts in considering these alternatives. Detail why the proposed route was selected and other alternatives were rejected. Response: The Company s route selection procedure for new transmission lines begins with identification of the project "origin" and "termination" points provided by the Company s Transmission Planning department and then the creation of a study area for the project. The point of origin for this Project can occur by tapping an existing 230 kv line in the vicinity of the Customer s East Gate Campus (i.e., Loudoun-Brambleton Line #2094). The termination point is the proposed Poland Road Substation near the Customer s East Gate Campus. The objective was to identify reasonable and feasible route segments that would provide power to the proposed substation, while reasonably avoiding or minimizing impacts to both the human and natural environment. Using this as a guideline, the Company engaged Bums & McDonnell Engineering Company, Inc. ("Bums & McDonnell") to assist in the routing study and requested that it develop a study area for the Project. With the assistance of Bums & McDonnell, the Company identified and considered preliminary route segments. The study team then revised the route segment network, eliminating, adding and revising route segments based on information obtained from agency contacts, local officials, and the public to create a final route segment network for evaluation. As part this process, Bums & McDonnell quantified the ~potential impacts to the scenic assets, historic districts, and environment of the area concerned. Route segments were combined to create complete routes between the tappoint(s) and the proposed Poland Road Substation. Data for the combinations of route segments creating routes between the Project start and end points were summed to quantify the total resources potentially affected by complete routes. Quantitative data, public input, and engineering criteria were used to screen the route segments to a manageable number of reasonable and feasible routes for further evaluation. Social and environmental data for the selected routes were evaluated to select a Proposed Route for the new 230 kv transmission line. Bums & McDonnell then used a statistical z-score analysis as a tool to screen the route alternatives and identify a set of routes warranting further investigation and comparison. The Company s final selection of the Proposed Route was based on fewer impacts to current and future residential and business development than 44

56 Alternate Routes A and B, the full utilization of an existing transportation right-of-way, and as determined through the z-score analysis ranking. The Proposed Route (Parallel Route) has significant multiple advantages over Alternate Route A (Northern Route). By paralleling Route 50 as much as possible, the Proposed Route avoids or lessens the impact to current and future development on the north side of Route 50. The Proposed Route has fewer residences within 150 and 500 feet, as well as 50% fewer heavy angle structures and forest clearings. Alternate Route A has greater residential impacts with four additional single family dwellings and 33 more units within multi-family buildings located within 500 feet compared to the Propos.ed Rout~. Also, the Proposed Route is significantly shorter than Alternate Route A by 0.57 mile or 13% of the total length of Alternate Route A. The Proposed Route, while similar to Alternate Route B (Southern Route), has two significant advantages over Alternate Route B. First, the Proposed Route is less impactful to current and future residential development because it is located on the north side of Route 50, east of the Route 606 and Route 50 intersection. Alternate Route B stays on the south side of Route 50 and passes within 500 feet of a large condominium complex and would have a greater impact on future residential and commercial development south of Route 50 due to its closer proximity. Also, the Proposed Route is less impactful to existing businesses. The Proposed.Route has no businesses within the proposed right-of-way while Alternate Route B has eight businesses within the proposed right-of-way. A complete description of the route evaluation and selection process is provided in the Route Selection Report included with this application. 45

57 II. DESCRIPTION OF THE PROPOSED PROJECT A. Right-of-way (ROW) So Indicate how the construction of this transmission line complies with "Guidelines for the Protection of Natural, Historic, Scenic, and Recreational Values in the Design and Location of Rights-of- Way and Transmission Facilities" adopted by the Federal Power Commission in Order No. 414 issued November 27, 1970, and now applied by the Federal Energy Regulatory Commission. These guidelines may be found in Volume 44 of the Federal Power Commission Reports, page 1,491, or Volume 35 of the Federal Register, page 18,585 (December 8, 1970). Copies of the Guidelines may also be obtained from the Office of Public Information, Federal Energy Regulatory Commission, Washington, D.C For reference purposes a copy of the guidelines is included. Response: The FERC guidelines are a tool routinely used by the Company in routing its transmission line projects. The Company utilized FERC Guideline #1 (existing rights-of-way should be given priority when adding additional facilities) by locating the Proposed and Alternate Routes A and B along existing road right-of-way (Route 50) to the extent possible. For a discussion of the existing distribution line right-of-way along Route 50, see Section II.A.4. Consistent with FERC Guideline #2 (where practical, rights-of-way should avoid sites listed in the National Register of Historic Places ("NRHP")), no NRHP sites or landmarks are crossed by the Proposed Route or Alternate Routes. FERC Guideline #4 encourages early contact with land managed by Government agencies, State agencies, or private organizations. The Company has communicated with a number of local, State and Federal agencies prior to filing this application (see Section III.B and the DEQ Supplement). The Company follows FERC construction methods on a site specific basis for typical construction projects (Guidelines #8, 10, 11, 15, 16, 18, and 22). The Company also utilizes FERC guidelines in the clearing of rights-of-way, constructing facilities and maintaining rights-of-way after construction. Moreover, secondary uses of rights-of-way that are consistent with the safe maintenance and operation of facilities are permitted. 46

58 II. DESCRIPTION OF THE PROPOSED PROJECT A. Right-of-way (ROW) o a. Detail counties and localities through which the line will pass. If any portion of the line will be located outside of the applicant s certificated service area: (1) advise of each electric utility affected; (2) whether any affected electric utility objects to such construction and (3) the length of line(s) proposed to be located in the service area of an electric utility other than the applicant; b. Provide three (3) copies of the Virginia Department of Transportation "General Highway Map" of each county and city through which the line will pass. On the maps show the proposed line and all previously approved and certificated facilities of the applicant. Also where the line will be located outside of the applicant s certificated service area; show the boundaries between the applicant and each affected electric utility. On each map showing the line outside of the applicant s certificated service area, have the appropriate individual of the affected electric utility sign if his/her company is not opposed to the proposed construction. Response: ao Of the approximately 4.0 miles of the Proposed Route s length, approximately 0.5 mile is located within the NOVEC service territory and 3.5 miles are located within the Company s service territory. For the 4.5- and 3.8-mile length of the Alternate Routes A (Northern Route) and B (Southern Route), 0.6 and 0.5 mile, respectively, are located in NOVEC s service territory, with the remainder located in the Company s service territory. bo Three copies of the Virginia Department of Transportation "General Highway Map" of Loudoun County are marked as required and have been submitted to the Commission s Division of Energy Regulation. These maps reflect Virginia Department of Transportation and other road data obtained from Navteq and County data, and include signatures from NOVEC signifying it is not opposed to this Project. A reduced copy of that map is contained in Attachment II.A.9.b. 47

59 II. DESCRIPTION OF THE PROPOSED PROJECT Line Design and Operational Features Detail number of circuits and their design voltage and transfer capabilities. Response: The Project will include looping existing 230 kv Line #2094 in and out of the proposed Poland Road Substation. The Loudoun-Brambleton Line #2094 will be split at Poland Road Junction, resulting in a Loudoun-Poland Road Line #2094 and a Brambleton-Poland Road Line #2183, both with a transfer capability of 1047 MVA in the existing line segments. The proposed new line segments to Poland Road Substation included in the Project will have a transfer capability of 1225 MVA. 48

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61 II. DESCRIPTION OF THE PROPOSED PROJECT B. Line Design and Operational Features 2. Detail number, size(s), type(s), and typical configurations of conductors; Response: The two proposed 230 kv circuits between Poland Road Junction and Poland Road Substation will each have three twin-bundled 795 ACSR 26/7 phase conductors arranged vertically with one fiber optic shield wire. 5O

62 II. DESCRIPTION OF THE PROPOSED PROJECT B. Line Design and Operational Features 3. With regard to the proposed supporting structures over each portion of the ROW provide: ao f. g. h. i. j. types of structures; length of ROW with each type of structure; material for typical structure (steel, oxidizing steel, etc.); foundation material; width at cross arms of typical structure; width at base of typical structures; typical span length; approximate average heights of structures; a schematic drawing of each typical structure; and minimum conductor-to-ground clearance under maximum operating conditions Response: (Attachment II.A.3.a) a. Structure type -- Steel Pole bo f. g. h. i. j. ROW length --approximately 4.01 miles Structure material -- Galvanized Steel Foundation material -- Concrete Cros~ arm width of typical structure feet Base width of typical structure -- 3 feet Average span length feet Approximate average structure height feet Typical structure -- see Attachment II.A.3.a Minimum clearance over ground feet 51

63 II. DESCRIPTION OF THE PROPOSED PROJECT B. Line Design and Operational Features o Describe why the proposed structure type(s) was selected for this line. Response: The proposed structure will allow the installation of two circuits in the proposed right-of-way. The single shaft steel pole will also minimize the footprint of the structure. 52

64 II. DESCRIPTION OF THE PROPOSED PROJECT C. Describe and furnish plan drawings of all new substations, switching stations, and other ground facilities associated with the proposed project. Response: The Project requires the construction of new Poland Road Substation, which is proposed to be constructed with four 230 kv circuit breakers in a ring bus configuration, two 230 kv line terminals, two kv, 84 MVA transformers, eight 34.5 kv circuits and other associated equipment. Two 230 kv backbone structures and three shielding structures with shield wires will be installed. The ultimate substation arrangement will consist of three kv, 84 MVA transformers and up to eleven 34.5 kv circuits. Additionally, a new control enclosure will be installed to accommodate the communications and protective relay cabinets for the initial and future equipment. The proposed Poland Road Substation will cut the 230 kv Brambleton- Loudoun Line #2094 and be located approximately 4.0 miles from existing Line #2094, approximately 0.3 mile east of Route 742 (Poland Road) on the south side of Route 50. The Company is in the process of acquiring this property. The one-line and general arrangement for the proposed Poland Road Substation are provided as Attachment II.C.1 and Attachment II.C.2, respectively. 53

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67 III. IMPACT OF LINE ON SCENIC, ENVIRONMENTAL AND HISTORIC FEATURES A. Describe the character of the area which will be traversed by this line, including, land use, wetlands, etc. Provide the number of dwellings within 500 feet of the line for each route considered. Response: The study area is in an urban setting and is primarily comprised of heavy residential and commercial development, including a portion of the Dulles International Airport. Loudoun County has undergone significant growth over the past 10 years. The study area includes a combination of urban residential, commercial, industrial development and public lands, as well as the Dulles International Airport. The various land uses in the study area include urban and residential areas, recreation areas and transportation and utility uses. For a more detailed description of the study area, see Section 3.0 of the Route Selection Report. The Proposed Route and Alternate Routes A and B cross through several different zoning districts identified by the Loudoun County Zoning Ordinance ("Zoning Ordinance"), as shown in Table III.A. 1 immediately below. Table III.A.1: Zoning Length Percentage of Commercial Light Industry (CLI) % Mineral Resource - Heavy Industry (MRHI) Planned Development-Commercial Center (PDCC(RC)) Planned Development-General Industrial (PDGI) Planned Development Housing (PDH4) Planned Development-Industrial Park (PDIP) Planned Development, Office Park (PDOP) % 17.2% 7.4% 5.1% 5.6% 7.2% ~i... ~... ~ 5 i= Commercial Light Industry (CLI) Mineral Resource - Heavy Industry (MRHI) % 3.3% Planned Development-Commercial Center (PDCC(RC)) % Planned Development-General Industrial (PDGI) % Planned Development Housing (PDH4) % Planned Development-Industrial Park (PDIP) % 56

68 Planned Development, Office Park (PDOP) 0.4 8~0% Townhouse/Multi-family Residential(R16) % Multi-family Residential District (R24) % Commercial Ligti~ hidustry (CLI) Planned Development-Commercial Center (PDCC(RC)) Planned Development Housing (PDH4) Planned Development-Industrial Park (PDIP) Planned Development, Office Park (PDOP) % % % % % Overlay Districts and other areas of importance that intersect the Proposed Route include the Airport Noise Impact Overlay District, Airport Impact Overlay LDN60 1-mile buffer, and the Quarry Notification Overlay District. See Attachment III.A. 1 for a visual depictionof the zoning break down. Table III.A.2 shows the acreage of probable wetland occurrence within the rights-of-way for the Project s Proposed and Alternate Routes. Table III.A.2 Acreage of Probable Wetland Occurrence within the Proposed and Alternate Routes ROW Wetland Type (Acres)a Probability Total Acres Forested Open Scrub/Shrub Emergent Water High Medium/High Medium Medium/Lowb N/A N/A N/A N/A Low/Uplands b e N/A N/A N/A N/A Total , , High Medium/High Medium Medium/Lowb N/A N/A N/A N/A 57

69 Low/Uplands b c N/A N/A N/A N/A Alternate Route B Total High Medium/High Medium Medium/Lowb 9.22 N/A N/A N/A N/A Low/Uplands b c N/A N/A N/A N/A Total (a) PFO = palustrine forested, PSS = palustrine scrub-shrub, PEM = palustrine emergent, PUB = palustrine unconsolidated bottom (b) The Medium/Low and Low probabilities did not include data with wetland types. (c) The low probability category was calculated by subtracting hydric soils, Interpreted Wetlands, and NWI data from the ROW area. Impacts to wetlands during the construction of the Project will be avoided and minimized to the extent practicable. Where access is required across a wetland, timber mats will be utilized to reduce compaction and rutting. The majority of impacts to wetlands will be temporary and limited to the construction period. The overhead transmission line will span the wetlands, and the spacing of the structures will generally allow for the footings to be installed in upland areas. Although not anticipated, if excavation for a structure is necessary in a wetland, excess spoil will not be disposed of in adjacent wetland areas. Operation impacts along the transmission line will be similar to those for an existing line and will be limited to periodic maintenance clearing of the right-of-way. There are eight single family dwellings and 30 units within three multi-family buildings located within 500 feet of the Proposed Route (Parallel Route). There are 12 single family dwellings and 63 units within seven multi-family buildings located within 500 feet of Alternate Route A (Northern Route). There are 29 single family dwellings and 30 units Within three multi-family buildings located within 500 feet of the Alternate Route B (Southern Route). See Attachment IH.A.2 for a map showing the location of the buildings within 500 feet of the right-of-way. 58

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72 III. IMPACT OF LINE ON SCENIC, ENVIRONMENTAL AND HISTORIC FEATURES Advise of any public meetings the Company has had with neighborhood associations andofficials of local, state or federal governments who would have an interest or responsibility with respect to affected area of areas. Response: Beginning in August 2014, Dominion Virginia Power began to meet or speak with a number of local, state, and federal officials to inform them of this Project in Virginia, including: On August 8, 2014, Company representatives met with Loudoun County officials to introduce the Project, including Assistant County Administrator Charles Yudd, Shevaun Hochstetler, Assistant to Supervisor Janet Clarke and Monica Filyaw, Assistant to Supervisor Matt Letoumeau. Subsequently, Company representatives met with a variety of Loudoun County officials on numerous occasions through the second half of 2014 and the spring of 2015 to discuss the Project, provide updates as to the progress of the routing study and any other developments in planning. Officials the Company met with included Chairman York, Supervisor Clarke, Supervisor Letoumeau, County planning and zoning staff, Director of Economic Development Buddy Rizer, Assistant County Administrator Yudd, and aids to Supervisors Clarke and Letourneau. In September 2014, the Company submitted information requests to a variety of state and federal environmental agencies concerning the Project. Additionally, on April 14, 2015, Dominion Virginia Power held a stakeholder "Immersion Day." This event is a public engagement tool piloted for this Project. The purpose was to gather a small, representative sample of members in the community to initiate communications and learn from one another in a focused and constructive way. The end purpose was to gain a deeper understanding of the community leading into the Company s broader communications efforts with the public. Approximately 21 people participated in the event held at the Gum Spring Library in Stone Ridge, Virginia. Dominion Virginia Power held a public information open house at the Little River Elementary _School in South Riding, Virginia, on April 29, Approximately 50 people attended. Letters were sent to approximately 750 area property owners, including owners of property within 1,000 feet of the proposed centerline for the route options being considered. The mailing included a project fact sheet with a map and details regarding the Project. 61

73 On April 22, 2015, the Company sponsored an advertisement for the open house in local weekly newspapers Chantilly Connection and the Loudoun Times Mirror. See Attachment III.B.1 for the open house mailing to property owners with the Project fact sheet enclosed and Attachment III.B.2 for the newspaper advertisement. Also, in accordance with Va. Code D, a letter dated May 12, 2015 (contained as Attachment III.B.3) was sent to Loudoun County Administrator, Mr. Tim Hemstreet, advising of the Company s intention to file this application and inviting the County to consult with the Company about the Project. Additional information is provided to the public through an internet website dedicated to the Project: The website includes route maps, an explanation of need, a description of the Project and its benefits, information on the Commission review process, structure diagrams and answers to frequently asked questions. The letter and the factsheet advised readers to visit and enter the search word "Poland Rd" for more information regarding the Project.

74 Attachment III.B.1 Dominion April 17, 2015 RE: Project Announcement: Dominion Virginia Power Plans to Add New Electric Transmission Facilities Dear Neighbor, Dominion is planning a new electric transmission project in your area, which includes new 230 kilovolt (kv) transmission line and substation facilities. You are receiving this notification because one of the routes currently being evaluated is on or near your property. Why is this project needed? The successful economic development efforts of Loudoun County have resulted in electrical loads that are projected to exceed the capabilities of the electric infrastructure currently in place in your community. The forecasted increase in electric demand over the next few years will eventually strain and outgrow the local distribution system. Since we know the predicted growth in energy demand we must take steps now to meet that demand and to alleviate any potential reliability issues from occurring while still meeting the immediate needs of the business and population expansion taking place. This project will support the area s thriving business community and growing population while maintaining overall reliability. What is the project? A new 230kV double circuit transmission line will be constructed, paralleling existing transportation corridors where possible and appropriate, and will require the acquisition of new right of way. The proposed line will extend from a current transmission line in the area to a new Dominion substation facility to be located along Route 50 east of Poland Road. Please refer to the enclosed map for additional information. How do we determine routes? We are required to serve the community with safe and reliable power while minimizing the cost to ratepayers. Our state regulator, the Virginia State Corporation Commission (SCC), requires us to submit our application with an exhaustive routing study that looks at all options available. The SCC requires us to present the route that meets the need electrically, while balancing impacts and cost to ratepayers, with potential alternatives to compare against. We do our best to solve electrical issues and increased energy demands in the least impacfful way, always treading lightly when new right of way is needed as part of the solution. When developing a solution, we first review our existing facilities for available options, but in some cases creating new right of way is the only way to meet the demand, as is the case here. When preparing the application to be filed with the SCC, Dominion typically considers many alternatives including underground. However, overhead transmission lines have proven to be the best choice for providing safe, reliable and economical energy to our customers, therefore the SCC expects us to first review an overhead option if one exists. Page 1. of 2 63

75 We are committed to reasonably minimizing the impact on communities, historic areas, and the environment by working with local residents and public officials in the study area to identify constraints and opportunities for locating new facilities. Any feedback we receive will be considered and will help us prepare a stronger and more thorough application for the SCC to review. The ultimate route is determined by the SCC, whether it s one that Dominion included in its study or one that the SCC develops and evaluates on its own. What is the SCC review process? The SCC is responsible for determining the need, route and environmental impact of transmission lines in Virginia. Review of an application usually takes between one to two years and includes multiple ways for the public and interested parties to participate. Our submission is really the starting point of the process. Once we file, documents related to the case are made available to the public on the SCC Docket Search section of the SCC web site, in the "Search Cases" section. In addition, interested parties may also comment directly to the SCC. To learn more about this project and speak with our electric transmission experts, you are invited to attend our Open House where you will also have the opportunity to provide us with your thoughts on the project. Please be assured that community involvement is an important part of our project planning and development. We hope you can join us. Event Details Wednesday, April 29, 2015 from 5:00 to 8:00 p.m. Little River Elementary School, Hyland Hills Street South Riding, Virginia In the meantime, please refer to the enclosed fact sheet for additional information or visit our website, keywords: Poland Rd. You may also contact us by sending an to powerline@dom.com or calling , Monday through Friday, 7:00 a.m. to 5:00 p.m. I hope to see you at the Open House. Sincerely, Greg Mathe Manager, Electric Transmission Communications Enclosures Page :2 of 2 64

76 Poland Rd 230kV Transmission and Substation Project Dominion Virginia Power is planning to add facilities to meet the growing demand for electricity in Loudoun County. The successful economic development efforts of Loudoun County have resulted in electrical loads that are projected to exceed the capabilities of the electric infrastructure currently in place in the Dulles area. The forecasted power demand increase over the next few years will eventually strain and outgrow the system. To address this, Dominion is planning a new electric transmission project in this area. This is a necessary project to support the area s thriving business community while maintaining overall reliability. Overview: A new 230kV double circuit transmission line, approximately four miles long, will need to be constructed requiring new right of way 100 feet wide near the Route 50 corridor to a Dominion substation located east of Poland Road on Route 50. Benefits: Maintains federal and company standards while addressing the rapid commercial/high tech sector growth in a prudent and safe manner Provides needed electrical capacity to maintain overall reliability for the community Supports continued economic development in the area Preliminary Schedule Early Spring 2015 Community Outreach; letters, newspaper ads and public open house - Finalize proposed route options after community engagement Mid 2015 Late 2016 Spring 2018 Submit application to the Virginia State Corporation Commission for consideration Begin preliminary construction work -forestry, right of way clearing, etc (pending necessary approvals) Energize line and substation 65

77 230kV Poland Rd Transmission and Substation Project Propo ed Pob, nd Ro.~d SubCt=tion Exi:ting 600 kv Tran-.mi*-~-ion Line Exi:ting 230 kv Tr~n:mi::ion Line Propo:ed Route Option Propo~-ed Route Option Proposed Poland Road Substation For more information, please visit our website at keyword: Poland Rd Contact our dedicated transmission team by sending an to or call , Monday through Friday, 7 a.m to 5 p.m. Dominion

78 Att~tchment III.B.2 ~Dominion" INFORHATIONAL OPEN HOUSE POLAND RD 2$OKV TRANSHISSION AND SUBSTATION PROJECT Dominion is seeking input on a new electric transmission project to serve Loudoun County Dominion Virginia Power is committed to providing safe and reliable service to customers, especially as the community s demand for power grows. New economic development In the area has outgrown the electrical Infrastructure currently in place becoming necessary for Dominion to add facilities that transport and deliver power to local homes and businesses. PROJ ECT: Dominion is evaluating options for new 230 kilovolt transmission line and substation facilities in the Dulles Community. OPEN HOUSE Wednesday, April 29, 2015 S:OO p.m. - 8:00 p.m. Little River Elementary School Hyland Hills Street South Riding, Virginia WHY: To maintain reliable electric service for the area as the business community continues to grow and require more electricity. YOUR INVOLVEHENT: The project must be filed with the Virginia State Corporation Commission for approval. But before submitting the application, we want to share our plans and hear your views on the project. Your involvement and input is important to us. Stop by our open house event to learn more about what this project will mean for you and your community. We welcome your ideas. For more information regarding the Poland Rd project, please visit our website at keywords: Poland Rd. Or call t4onday - Friday, 7:00 a.m. - 5:00 p.m. For routine business or reporting an outage, please call DOFI-HELP ( ).

79 Attachment III.B.3 Dominion Virginia Power 701 E. Cary St.. Richmond, VA Mailing Address: P.O. Box Richmond, VA dora.corn Dominion May 12,2015 Loudoun County Government Building Attention: Mr. Tim Hemstreet, County Administrator 1 Harrison Street, S.E. Leesburg, Virginia 201_75 RE: Dominion Virginia Power s Proposed Poland Road 230 kv Double Circuit Transmission Line Loop and kv Poland Road Substation - Loudoun County, Virginia Dear Mr. Hemstreet: Loudoun County continues to experience rapid growth in electrical demand, particularly by the commercial/high-tech sector. The County s attraction to the business community has resulted in the need to build new transmission line and substation facilities located in the Dulles community. Dominion proposes to build a new substation and approximately 4 miles of new overhead transmission lines that tap off of an existing line. There are two alternative routes under consideration at this time; these alternatives as currently shown are depicted on the enclosed map. This map was the one presented at our open house held April 29th, 2015, where we were able to meet individuals with interest in the Project and listen to feedback regarding the routes. Pursuant to Virginia State Code , Dominion met with various county officials and representatives on multiple occasions to present the Project, hear and understand the preferences of the County, and to advise Loudoun County of the Company s intention to file an application for this Project with the Virginia State Corporation Commission in May of this year. Dominion respectfully invites Loudoun County to share any interests related to our proposal. Dominion is committed to continuing dialogue on this project; we will keep you informed by providing the County copies of the SCC application. You may also see project details by visiting keyword, "Poland". You may contact me at (804) or by at benjamin,_q._~jl~l~.~r_~!z!.!. Sincerely, Ben Saunders Sr. Siting and Permitting Specialist 68

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81 III. IMPACT OF LINE ON SCENIC, ENVIRONMENTAL AND HISTORIC FEATURES Co Detail the nature, location, and ownership of all buildings which would have to be demolished or relocated if the project is built as proposed. Response: The Company is aware of one house, three greenhouses, and one outbuilding that are located within the proposed right-of-way for the Proposed Route (Parallel Route) that will need to be demolished or relocated as part of this Project. Alternate Route A (Northern Route) would also have one business and one outbuilding that would be at least partially located within the proposed rightof-way. Alternate Route B (Southern Route) would have seven businesses, one house, one outbuilding, and two abandoned homes that would be located within the proposed right-of-way. 7O

82 III. IMPACT OF LINE ON SCENIC, ENVIRONMENTAL AND HISTORIC FEATURES Do What existing physical facilities will the line parallel, if any, such as existing transmission lines, railroad tracks, highways, pipelines, etc.? Describe the current use and physical appearance and characteristics of the existing right-of-way that would be paralleled. How long has the right-of-way been in use? Response: There are a limited number of existing facilities available for parallel in the Project study area. No transmission line, gas pipeline, or railroad rights-ofway crossing the study area provide an opportunity for the Project to parallel such facilities. The available existing facilities in the study area include roadways, and the Project parallels Route 50, which is a highly traveled road in Loudoun County with significant commercial, industrial, and residential uses along its right-of-way and within the study area. Thus, the Proposed Route (Parallel Route) makes use of one of the only available linear features by paralleling Route 50 for the majority of its length, or approximately 3.3 miles. Alternate Route A (Northern Route) al~o parallels Route 50, but to a lesser extent than the Proposed Route (approximately 1.9 miles). Alternate Route B (Southern Route) also parallels Route 50 for almost the entire length of the route (approximately 3.5 miles). 71

83 III. IMPACT OF LINE ON SCENIC, ENVIRONMENTAL AND HISTORIC FEATURES Eo Has the Company investigated land use plans in the areas of the proposed route? How would the building of the proposed line effect future land use of the areas affected? Has the Company determined from the governing bodies of each county, city and town in which the proposed facilities will be located whether those bodies have designated the important farmlands within their jurisdictions, as required by Virginia Code Section ? e If so, and if any portion of the proposed facilities will be located on any such important farmland, please: Include maps and other evidence showing the nature and extent of the impact on such farmlands. bo Describe what alternatives exist to locating the proposed facilities on the affected farmlands, and why those alternatives are not suitable. Describe the applicant s proposals to minimize the impact of the facilities on the affected farmland. Response: The Company has investigated the land use plans and the General Plan for Loudoun County and the impact of the Proposed Route. The Proposed Route bisects the Suburban Policy Area. The Loudoun County General Plan discusses the Route 50 Corridor Plan, which makes recommendations on how to "create an attractive gateway to Loudoun County." Land use along Route 50 within the study area is planned for business, hybrid or industrial uses. The General Plan also describes specific policies, including landscaping, economic development, and transportation policies. A letter provided by.the Loudoun County Department of Planning and Zoning is included as Attachment III.E. 1. There are large rezoned areas on both sides of Route 50, with residential, commercial and industrial developments proposed or under construction. The Company attempted to minimize the effect of the proposed Project on future land use by utilizing existing linear features and the edge of parcel and development boundaries as much as possible. To that end, the Proposed Route (Parallel Route) parallels one of the only linear features in the study area, Route 50, for 3.3 miles. Further, the Proposed Route avoids skirting the boundaries between parcels that are currently under construction or proposed for development. By utilizing Route 50 as much as possible, the Company was able to decrease the impact to each development, as opposed to routing the line through the middle of future development. Alternate Route A 72

84 (Northem Route) parallels Route 50 for approximately 1.5 miles; however, it bisects individual ongoing and future developments on the north side of Route 50 where the Company was unable to utilize existing linear features. Alternate Route B (Southern Route) parallels Route 50 for 3.5 miles and avoids bisecting proposed and ongoing construction. 1. The Proposed Route and Altemate Routes do not cross any such farm lands. 2. Not applicable. 73

85 Attachment III.E.1 Loudoun County, Virginia Department of Planning and Zoning 1 Harrison Street, S.E., 3~ Floor, P.O. Box 7000, Leesburg, VA Telephone (703) Fax (703) dpz@loudoun.gov October 23, 2014 Mr. Ben Saunders Senior Siting and Permitting Specialist Dominion Virginia Power PO Box Richmond, VA Re: Poland Road 230-kV Transmission Project Project Number Dear Mr. Saunders, The Loudoun County Department of Planning and Zoning has received your correspondence dated September 26, 2014 requesting our comments and concerns regarding siting transmission lines in the Arcola area. Your correspondence requests information including property or resources that represent constraints or conflicts. The County does have several concerns about this project given the proximity of the "Potential Alternative Routes" to existing and proposed development of varying types and the overall land use plan for the area. We believe that land use conflicts and compatibility issues are most likely to result from incompatibility with existing and proposed residential development as well as the Village of Arcola. However, we would require additional information about the project to provide you with a comprehensive and detailed response. We note that you are requesting information about the "study area" but the information you provided does delineate a specific study area. Accordingly, we are providing general information in the vicinity of "Potential Alternative Routes" depicted in the map you provided. Given the size of this area which totals approximately 15 square miles and the general nature of your request, we are proving an overview of existing development, proposed development, and land uses plans. With additional information and clarification of the project, we can provide you with more detailed information. We are also unclear about the goals and requirements of this project, its current status, and the specific locations power needs to be conveyed to and from. Overall, given the extensive network of alternative routes depicted in the map you provided, the lack of information provided to describe how these routes were identified, and the extensive resources and development existing in this area, we recommend that you contact us to further discuss potential land use conflicts and compatibility of the proposed project. Project Understanding Based on our understanding, your letter and mapping appears to provide two alternative scenarios. The first scenario would result in a proposed 230-kV line tapping =Dominions existing Greenway - Brambleton 230-kV transmission line" and connecting it to the proposed Yardly Ridge NOVEC Substation with a north-south alignment. From the Yardley Ridge NOVEC substation, the transmission line would continue to run in a general north-south alignment to Dominion s proposed Poland Road Substation. 74

86 The second scenario would tap the existing Loudoun - Brambieton 230kV transmission line located to the west and would require an east-west alignment to serve the proposed Poland Road Substation. This scenario would still require the Greenway-Brambleton 230-kV line to be tapped but the line will terminate at the proposed Yardley Ridge NOVEC Substation and there will be no direct connection between Yardley Ridge and Poland Road. While the information provided does not specify, we are assuming that the Greenway - Brambleton transmission line is the existing line currently running east-west along the general alignment of the Broad Run and that the Loudoun-Brambleton transmission line runs north-south from Leesburg to Prince William County. We remain unclear, however about the locations of the proposed Poland Road and Yardley Ridge Substations and whether there have been formal applications for these facilities. Please confirm that our project understanding is correct and provide additional information to describe the potential routes and how they were identified. Please also more specifically describe the proposed substation locations, how they were identified, and whether there is any opportunity to relocate these substations. Existing Conditions The area north of Route 50 consists of areas of undeveloped land and several existing businesses and residential developments. The businesses are primarily focused around Gum Spring Road and Azalea Lane. Major existing residential subdivisions include Evergreen Meadows along Evergreen Mills Road and Hiddenwood Lane, Briarfield Estates along Cameron Parish Road, Winsbury along Gum Spring Road, and Arcola Center located at Route 50 and Hutchinson Farm Drive. The Tradewinds Industrial Park is also located north of Route 50 along Tradewinds Drive. While only a few of the lots in the industrial park are currently developed, more businesses are expected to come online in the future. In addition, construction is currently underway to develop a hospital at the intersection Gum Spring Road and Route 50 and to construct a major retail development in the vicinity of Loudoun County Parkway and Route 50. The area east of Loudoun County Parkway on the north side of Route 50 is occupied primarily by industrial development and the Luck Stone Quarry. In general the south side of Route 50 is more fully developed than the north side, Existing development includes several residential subdivisions and non-residential uses. Major Subdivisions include Stone Ridge, Avonlea, South Riding and East Gate. These subdivisions generally include both residential and non-residential components. Several smaller individual commercial and industrial businesses also exist along Route 50. Approved Development Figure 1 provides a map showing some of the projects with approved, but not yet built development in the vicinity of the altemative reutes you identified. These projects represent a significant amount of development that may present compatibility issues with the proposed transmission lines. The projects shown in the map represent over 4,000 approved but not yet built residential units, approximately 2 million square feet of unbuilt office space, and approximately 2 million square feet of unbuilt retail space. In addition these projects will provide a range of new roads, parks, cultural facilities, and community amenities. Planned Land Use Loudoun County approved a Comprehensive Plan Amendment on October 17, 2006 specifically dealing with the Route 50 Corridor (The Route 50 Corridor Plan). The County s Revised General Plan seeks to establish Route 50 as an attractive gateway into the County. The gateway is intended to recognize heritage and cultural resources, promote economic development and tourism, and provide for transportation and infrastructure improvements that are tailored to the unique needs of the area. In

87 general, the Route 50 corridor is planned for Business or Industrial Communities per Revised General Plan policies specific to the Route 50 Corridor. Figure2 provides a Planned Land Use Map for areas surrounding the alternative routes. Other specific aspects of the Route 50 Corridor Plan include provision for destination retail uses, revitalization of the Village of Arcola including provisions for new residential development, establishment of a Village Perimeter Transition Area to protect the Village of Arcola from larger scale development, policies for pedestrian-friendly design, encouraging tourism related business. Summary As noted above, Loudoun County has concerns about potential conflicts associated with the Poland Road 230-kV Transmission Project. As =it currently appears, you do not have a specific plan or preferred alternative identified for this project. As such, we recommend that you avoid scheduling any public meetings or workshops until details of the project are :more clearly defined. We also recommend that you contact us to discuss the project need and alternatives so that we can provide further guidance regarding potential conflicts and compatibility issues. We also note that other individuals and departments within Loudoun County have received similar correspondence from you. Therefore, in an effort to prepare a coordinated and consolidated response, the Department of Planning and Zoning is responding on behalf of the following individuals/organizations: A. Mr. Mike Seigfried, Director, Loudoun County Department of Building and Development B. Mr. Buddy Rizer, Director, Loudoun County Department of Economic Development If you have any questions regarding the comments in this letter or if you wish to further discuss these issues, please contact Richard Klusek, Senior Planner, at or richard.klusek@loudoun.gov. Sincerely, FAICP Director ~ CC: Tim Hemstreet, County Administrator (via ) Scott York, Chairman-at-Large, Loudoun County Board of Supervisors (via ) Matthew Letourneau, Dulles District, Loudoun County Board of Supervisors (via ) Janet Clarke, Blue Ridge District, Loudoun County Board of Supervisors (via ) Charles Yudd, Deputy County Administrator (via ) John Merrithew, AICP, Assistant Director, Loudoun County Department of Planning and Zoning (via ) Cindy Keegan, AICP, Program Manager, Community Planning (via ) Richard Klusek, AICP, Senior Planner, Community Planning (via ) Buddy Rizer, Director, Department of Economic Development (via ) Mike Seigfried, Director, Building and Development (via )

88

89

90 III. IMPACT OF LINE ON SCENIC, ENVIRONMENTAL AND HISTORIC FEATURES Identify the following that lie within or adjacent to the proposed right-ofway: 1. Any district, site, building, structure, or other object included in the National Register of Historic Places maintained by the U.S. Secretary of the Interior; 2. Any historic landmark, site, building, structure, district or. object included in the Virginia Landmarks Register maintained by the Virginia Board of Historic Resources; 3. Any historic district designated by the governing body of any city or county; 4. Any state archaeological site or zone designated by the Director of the Virginia Department of Historic Resources, or his predecessor, and any site designated by a local archaeological commission, or similar body; 5. Any underwater historic property designated by the Virginia Department of Historic Resources, or predecessor agency or board; 6. Any National Natural Landmark designated by the U.S. Secretary of the Interior; 7. Any area or feature included in the Virginia Registry of Natural Areas maintained by the Virginia Department of Conservation and Recreation; 8. Any area accepted by the Director of the Virginia Department of Conservation and Recreation for the Virginia Natural Area Preserves System; ~9. Any conservation easement qualifying under Sections to of the Code of Virginia, or prior provision of law; 10. Any state scenic river; 11. Any federal state, or local park, forest, game or wildlife preserve, recreational area, or similar facility; Features, sites, and the like listed in I through 10 above need not be identified again. 79

91 Response: None. None. None. None. None. None. None. None. None. None. None.

92 IMPACT OF.LINE ON SCENIC, ENVI. RONMENTAL AND HISTORIC FEATURES Go List any airports where the proposed route would place a structure or conductor within the glide path of the airport. Advise of contacts and results of contacts made with appropriate officials regarding the effect on the airport s operations. Response: The Federal Aviation Administration ("FAA") is responsible for overseeing air transportation in the United States. The FAA manages air traffic in the United States and evaluates physical objects that may affect the safety of aeronautical operations through an obstruction evaluation. The prime objective of the FAA in conducting an obstruction evaluation is to ensure the safety of air navigation and the efficient utilization of navigable airspace by aircraft. Dominion Virginia Power reviewed the FAA s website ( sp) to identify airports within 10 miles of the Project. In order to evaluate whether the proposed Project would require providing notification to the FAA, the Company completed the FAA s online Notice Criteria Tool. Based on the results of this review, the Project will exceed Notice Criteria and notification to the FAA is required. Bums & McDonnell completed an airspace restriction analysis which is included as Attachment 2.N.4 to the DEQ Supplement. Neither the Proposed Route nor Alternative Routes A and B are anticipated to have any significant impact on the operations of Dulles Airport, including the existing runways and the proposed new fifth runway. Additionally, the approach and departure surfaces for Dulles Airport are not anticipated to significantly limit the heights of the structures along any of the routes described in this application. While every effort is made to anticipate all potential airspace issues associated with this Project, the results of the studies conducted by the FAA Will ultimately be considered definitive. 81

93 III. IMPACT OF LINE ON SCENIC, ENVIRONMENTAL AND HISTORIC FEATURES no Advise of any scenic byways that are in close proximity to or will be crossed by the proposed transmission line and describe what steps will be taken to mitigate any visual impacts on such byways. Describe typical mitigation techniques for other highway s crossings. Response: The Commonwealth Transportation Board is authorized to designate any highway as a scenic byway or as a Virginia byway. This designation shall be made in cooperation with the Director of the Virginia Department of Conservation and Recreation ("DCR"). A "Virginia Byway" is defined as a road, designated as such by the Commonwealth Transportation Board, having relatively high aesthetic or cultural value, leading to or within areas of historical, natural, or recreational significance. A "scenic highway" is defined as a road designated as such by the Commonwealth Transportation Board, within a protected scenic corridor located, designed and constructed so as to preserve and enhance the natural beauty and cultural value of the countryside. According to the Virginia Department of Transportation ("VDOT") website, and in consultation with DCR, the Proposed Route and Alternate Routes are not proximate to and do not cross any Virginia Byways. Along road crossings, existing vegetation that will not conflict with the safe electrical clearances of the conductors will be retained to soften the view of the right-of-way from the traveling public. 82

94 IV. HEALTH ASPECTS OF EMF State the calculated maximum electric and magnetic field (EMF) levels that are expected to occur at the edge of the right-of-way. If the new transmission line is to be constructed on an existing electric transmission line right-of-way, provide the present EMF levels as well as the maximum levels calculated at the edge of right-of-way after the new line is operational. Response: Public exposure to magnetic fields is best estimated by field levels from power lines calculated at annual average loading. For any day of the year, the EMF levels associated with average conditions provide the best estimate of potential exposure. Maximum (peak) values are less relevant as they may occur for only a few minutes or hours each year. This section describes the levels of EMF associated with the proposed 230 kv transmission lines. EMF levels are provided for the future (2018) annual average and maximum (peak) loading conditions. Proposed Project - Projected average loading in 2018 EMF levels were calculated for the proposed Project at the projected average load condition (244.4 amps for Line #2094 and 67 amps for Line #2183) and at an operating voltage of kv when supported on the proposed Project structures - see Attachment II.A.3.a. These field levels were calculated at mid-span where the conductors are closest to the ground and the conductors are at a projected average load operating temperature and at a clearance to ground of 25.7 feet for Line #2094 and 25.7 feet for Line #2183. EMF levels at the edge of the rights-of-way for the proposed Project at projected average loading: Northern Edge Southern Edge Electric Field Magnetic Field Electric Field Magnetic Field (kv/m) (mg) (kv/m) (mg) Attachment II.A.3.a

95 Proposed Project - Peak loading in 2018 EMF levels were calculated for the proposed Project at the projected peak load condition (407.3 amps for Line #2094 and amps for Line #2183) and at an operating voltage of kv when supported on the proposed Project structures - see Attachment II.A.3.a. These field levels were calculated at mid-span where the conductors are closest to the ground and the conductors are at a projected peak load operating temperature and at a clearance to ground of 25.7 feet for Line #2094 and 25.7 feet for Line #2183. EMF levels at the edge of the rights-of-way for the proposed Project at projected peak loading: Northern Edae Southern Edge Electric Field Magnetic Field Electric Field Magnetic Field (kv/m) (mg) (kv/m) (mg) Attachment II.A.3.a

96 IV. HEALTH ASPECTS OF EMF Bo If Company is of the opinion that no significant health effects will result from the construction and operation of the line, describe in detail the reasons for that opinion and provide references or citations to supporting documentation. Response: The foundation of the Company s opinion is the conclusions of expert panels formed by national and international scientific agencies; each of these panels has evaluated the scientific research related to health and power-frequency EMF and provided conclusions that form the basis of guidance to governments and industries. The Company regularly monitors the recommendations of these expert panels to guide their approach to EMF. Major reviews on this topic, in order of their most recent publication, include those published by the European.Health Risk Assessment Network on Electromagnetic Fields Exposure (EFHRAN),5 the International Commission on Non-Ionizing Radiation Protection (ICNIRP), the Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR), the World Health Organization (WHO), and the International Committee on Elect~oma~gnetic Safety (ICES) (EFHRAN, 2010; ICNIRP, 2003, 2010; SCENIHR 2007, 2009; WHO, 2007; ICES, 2002). Research on this topic varies widely in its approach. Some studies evaluate the effects of high EMF exposures not typically found in our day-to-day lives, while others evaluate the effects of common EMF exposures. The studies evaluate long-term effects (e.g., cancer, neurodegenerative diseases, and reproductive effects) and short-term biological responses. This research includes hundreds of epidemiology studies of people in their natural environment and laboratory studies of animals (in vivo) and isolated cells and tissues (in vitro). Standard scientific procedures are used by the expert panels to identify, review and summarize this large and diverse research area. The general scientific consensus of the health agencies reviewing this research is that at levels associated with the operation of the proposed transmission lines, or other common sources of EMF in our environment, the research does not support the conclusion that EMF causes any long-term, adverse health effects. Thus, based on the conclusions of scientific reviews and the levels of EMF associated with the Projects, the Company has determined that no adverse health effects will result from the operation of the proposed transmission lines. 5 EFHRAN is funded by the European Commission s Executive Agency for Health and Consumers. 85

97 IV. HEALTH ASPECTS OF EMF Co Describe any research studies the Company is aware of that meet the following criteria: Became available for considerat, ion since the completion of the Virginia Department of Health s most recent review of studies on EMF and its subsequent report to the Virginia General Assembly in compliance with 1985 Senate Joint Resolution No. 126; o Include findings regarding EMF that have not previously been reported and/or provide substantial additional insight into previous findings; and 3. Have been subjected to peer review. Response: The Virginia Department of Health s most recent review of studies on EMF was completed in 2000; many peer-reviewed research studies have become available since that time and were reviewed by the scientific organizations discussed above. The WHO recently conducted one of the most comprehensive and detailed reviews, which summarized peer-reviewed research published through early 2006 (WHO, 2007). Research published in the peer-reviewed literature subsequent to the WHO report has been reviewed by several scientific organizations, all of which support the conclusions of the WHO (2007) report, including: The Health Council of the Netherlands (HCN) reviewed new research in SCENIHR, a committee of the European Commission, published their most recent assessment in The Swedish Radiation Protection Authority (SSI) updates their review annually; their most recent review evaluated research through 2007 (SSI, 2008). EFHRAN published the mo.st recent review in.february These reviews can be consulted for commentary on recent studies. In addition, other recent peer-reviewed studies (e.g., Chung et al., 2010; Coble et al., 2009; Kheifets et al., 2010a, 2010b; Kroll et al., 2010; McNamee et al., 2010) provide evidence that clarifies previous findings. Chung et al. (2010) found no difference in lymphoma rates between cancer-prone mice exposed long-term to strong magnetic fields and an unexposed control group. Mice were exposed 21 hours per day for 40 weeks to magnetic fields up to 5,000 mg, which is hundreds to thousands of times greater than routine residential exposures. This study is 86

98 consistent with previous in vivo studies that found no evidence that magnetic fields promote the development of lymphoma or leukemia in laboratory animals. Coble et al. (2009) conducted a case-control study in the U.S. of brain tumors (gliomas and meningiomas) in U.S. workers. This study was advanced because several different measures were used to assess individual exposure, and exposure duration was incorporated into lifetime magnetic-field exposure. No association was reported between any of the exposure metrics and brain tumors. This study s strengths are its large size and advanced exposure assessment. Kheifets et al. (2010a) conducted a pooled analysis of epidemiologic studies of childhood brain tumors and magnetic fields to explore the association in the larger pooled population. Ten case-control studies of childhood brain tumors were identified that met the inclusion criteria. No statistically significant associations with brain tumors were found in any of the three exposure levels, compared to average exposure less than 1 mg. A sub-group of five studies with information on calculated or measured magnetic fields greater than 3-4 mg reported a combined odds ratio that was elevated but not statistically significant. Kheifets et al (2010b) pooled data from studies of childhood leukemia and magnetic fields to update the previous meta-analyses on this topic published in The authors identified seven subsequent case-control studies of childhood leukemia that included measured or calculated magnetic field levels. Results showed an overall weak association with leukemia for the highest estimated long-term average exposure level (4 mg or higher) that was slightly elevated, but could not be distinguished from chance. This study confirms a positive association between average magnetic field levels greater than 3 mg and childhood leukemia, but the association could not be distinguished from chance due to small numbers. Kroll et al. (2010) re-evaluated a previous study in the United Kingdom that had reported childhood leukemia was associated with distance of a child s home at birth from a power line (Draper et al, 2005). Distance is considered a poor estimate of magnetic field exposure; therefore, Kroll et al. repeated the study using calculated magnetic field levels from nearby power lines. The results showed a weak, non-significant association between leukemia and the calculated magnetic fields from high-voltage power lines. As a result of small numbers and incomplete information, no strong conclusions can be drawn from this study. Recent research by McNamee et al. (2010a) examined how acute exposure of human subjects to 60-Hz magnetic fields affected human heart rate, heart rate variability and skin blood perfusion; no effects of exposure to an 18,000 mg magnetic field on these measures were reported. A similar 87

99 study by these investigators also reported no effects of these parameters at a lower magnetic field intensity of 2,000 mg (McNamee et al., 2010b). References Chung M-K, Yu W-J, Kim Y-B, Myung S-H. Lack of a co-promotion effect of 60 Hz circularly polarized magnetic fields on spontaneous development of lymphoma in AKR mice. Bioelectromagnetics 31: , Coble JB, Dosemeci M, Stewart PA, Blair A, Bowman J, Fine HA, Shapiro WR, Selker RG, Loeffler JS, Black PM, Linet MS, Inskip PD. Occupational exposure to magnetic fields and the risk of brain tumors. Neuro Oncol, Epub in advance of publication DOI: / European Health Risk Assessment Network on Electromagnetic Fields Exposure (EFHRAN). Risk Analysis of Human Exposure to Electromagnetic Fields. Executive Agency for Health and Consumers, February International Commission on Non-Ionizing Radiation Protection (ICNIRP). Exposure to Static and Low Frequency Electromagnetic Fields, Biological Effects and Health Consequences (0-100 khz) - Review of the Scientific Evidence on Dosimetry, Biological Effects, Epidemiological Observations, and Health Consequences Concerning Exposure to Static and Low Frequency Electromagnetic Fields (0-100 khz). Matthes R, McKinlay AF, Bernhardt JH, Vecchia P, Beyret B (eds.). International Commission on Non-Ionizing Radiation Protection, Kheifets L, Ahlbom A, Crespi CM, Feychting M, Johanson C, Monroe J, Murphy MFG, Oksuzyan S, Preston-Martin S, Roman E, Saito T, Savitz D, Schuz J, Simpson J, Swanson J, Tynes T, Verkasalo P, Mezei G. A pooled analysis of extremely low-frequency magnetic fields and childhood brain tumors. American Journal of Epidemiology 172: , 2010a. Kheifets L, Ahlbom A, Crespi CM, Draper G, Hagihara J, Lowenthal RM, Mezei G, Oksuzyan S, Schuz J, Swanson J, Titarelli A, Vinceti M, Wunsch Filho V. Pooled analysis of recent studies on magnetic fields and childhood leukemia. Br J Cancer 103: , 2010b. Kroll ME, Swanson J, Vincent TJ, Draper GJ. Childhood cancer and magnetic fields from high-voltage power lines in England and Wales: a casecontrol study. Br J Cancer 103: , McNamee DA, Corbacio M, Weller JK, Brown S, Prato FS, Thomas AW, Legros AG. The cardiovascular response to an acute 1800-p.T, 60-Hz 88

100 magnetic field exposure in humans. Int Arch Occup Environ Health 83: , 2010a. McNamee DA, Corbacio M, Weller JK, Brown S, Stodilka RZ, Prato FS, Bureau Y, Thomas AW, Legros AG. The response of the human circulatory system to an acute 200-~tT, 60-Hz magnetic field exposure. Int Arch Occup Environ Health. DOI /s May 2010b. Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR). Possible Effects of Electromagnetic Fields (EMF) on Human Health. European Commission. Directorate C - Public Health and Risk Assessment, risk/committees/04 scenihr/docs/scenihr o 007.pdf Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) for the Directorate-General for Health & Consumers of the European Commission. Health Effects of Exposure to EMF. January http ://ec.europa.eu/health/archive/ph_risk/committees/o4_scenihr/docs/scenihr o 022.pdf Swedish Radiation Protection Authority (SSI). Fifth annual report from SSI s Independent Expert Group on Electromagnetic Fields, 2007: Recent Research on EMF and Health Risks. SSI Rapport 2008: pdf World Health Organization (WHO). Environmental Health Criteria 238: Extremely Low Frequency (ELF) Fields. WHO, Geneva, Switzerland, ISBN ,

101 NOTICE A. Furnish a proposed route description to be used for public notice purposes. Provide a map of suitable scale showing the route of the proposed project. Response: A map of the Proposed Route and Alternate Routes is provided as Attachment V.A. A written description of the Proposed and Alternate Routes for the Project is as follows: The Proposed Route commences at a tap-point along the Loudoun- Brambleton 230 kv transmission line, approximately 800 feet south of Route 50. The Proposed Route angles to the north from the tap-point for 1,200 feet to parallel Route 50 on the south side of the roadway. The Proposed Route continues to Route 50 for approximately two miles, crossing to the north side of Route 50, east of the intersection with Loudoun County Parkway/Old Ox Road. The Proposed Route continues to parallel Route 50 for 1.3 miles on the north side of the road. At this point, the Proposed Route angles to the northeast, away from Route 50, to avoid development immediately adjacent to the roadway (approximately 0.2 mile). On the east side the development the Proposed Route angles sharply to the south, crossing Route 50 and entering the proposed Poland Road Substation property. Altemate Route A commences at a northem tap-point along the Loudoun- Brambleton 230 kv transmission line, approximately 1,500 feet north of Route 50, at the intersection of Racefield Lane. Alternate Route A parallels Racefield Lane for approximately 2,000 feet from the tap-point, before turning sharply to the southeast to follow parcel boundaries for 1 mile. At this point, Alternate Route A turns sharply to the south to parallel Amethyst Road for 800 feet, then turns sharply to the east to parallel Route 50 on the north side of the roadway. Alternate Route A parallels Route 50 for approximately 4,500 feet before crossing over Route 50 and then paralleling the south side of Route 50 for approximately 700 feet. Alternate Route A then turns east for approximately 1,700 feet and crosses over Route 50. At this point Alternate Route A turns south parallel to the east side of Vance Road for approximately 700 feet. The route then turns east and follows the edge of the quarry property for 1,600 feet before turning east still parallel to the edge of the quarry. At this point the route turns south until reaching Route 50 and then turns east to directly parallel Route 50 for 1.0 mile into the proposed Poland Road Substation, as described above under the Proposed Route. Alternate Route B commences at a tap-point along the Loudoun-Brambleton 230 kv transmission line, approximately 800 feet south of Route 50. Alternate Route B angles to the north from the tap-point for 1,200 feet to 90

102 parallel Route 50 on the south side of the roadway. Altemate Route B continues parallel to the south side of Route 50 for approximately 3.5 miles and enters the proposed Poland Road Substation. Alternate Route B is identical to the Proposed Route until it crosses Loudoun County Parkway.

103 Attachment V,A !

104 NOTICE B. List Company offices at which members of the public may inspect the application. Response: The Application is available at the following locations: Dominion Virginia Power OJRP 12th Floor 701 E. Cary Street Richmond, Virginia Attn: Ben Saunders Dominion Virginia Power Lincoln Park II 3072 Centreville Road Herndon, Virginia Attn: Tim Sargeant Loudoun County Planning Department 1 Harrison Street, S.E. Leesburg, VA Attn: Julie Pastor 93

105 V. NOTICE Co List all federal, state, and local agencies and/or officials who may reasonably be expected to have an interest in the proposed construction and to whom the Company has or will furnish a copy of the application. Response: Ms. Bettina Sullivan, Manager [2 electronic copies] (mail to Ms. Valerie Fulcher, Executive Secretary Senior) Office of Environmental Impact Review Department of Environmental Quality 629 East Main Street Richmond, Virginia Mr. Thomas A. Farah Regional Director Department of Environmental Quality Northern Regional Office Crown Court Woodbridge, Virginia Mr. James R. Cromwell District Environmental Programs Manager Virginia Department of Transportation 1401 E. Broad Street Richmond, Virginia Ms. Renee Hypes [electronic] Virginia Natural Heritage Program 600 East Main Street; 24th Floor Richmond, VA Ms. Robbie Rhur Planning Bureau Virginia Department of Conservation and Recreation 203 Governor Street Richmond, Virginia Ms. Amy Ewing Wildlife Biologist Virginia Game & Inland Fisheries 4010 West Broad Street Richmond, Virginia 23:~30 94

106 Mr. Roger Kitchen Virginia Department of Historic Resources 2801 Kensington Avenue Richmond, Virginia Mr. Tony Watkinson Chief of Habitat Management Virginia Marine Resources Commission 2600 Washington Avenue - 3rd Floor Newport News, Virginia Mr. Ron Stouffer U.S. Army Corps of Engineers Northern Virginia Field Office Triangle Shopping Plaza, Suite 213 Dumfries, Virginia Mr. Keith Tignor Endangered Species Coordinator Virginia Department of Agriculture and Consumer Services 102 Governor Street Richmond, Virginia Ms. Martha Little [electronic] Deputy Director of Stewardship Virginia Outdoors Foundation Main Street Centre 600 East Main Street, Suite 402 Richmond, Virginia Mr. Buck Kline Director, Forestland Conservation Division Virginia Department of Forestry Fontaine Research Park 900 Natural Resources Drive, Suite 800 Charlottesville, Virginia Mr. John T. Hart Virginia Department of Aviation 5702 Gulfstream Road Richmond, Virginia

107 Mr. Doug Steiner Construction Program Integration P.O. Box Washington Dulles International Airport Washington, D.C Mr. Kaj Dentler Airport Director Leesburg Executive Airport 25 West Market Street Leesburg, Virginia Mr. Scott K. York Chairman, Board of Supervisors Loudoun County P.O. Box 7000 Leesburg, Virginia Mr. Tim Hemstreet County Administrator Loudoun County 1 Harrison Street, SE Mail Stop #02 Leesburg, Virginia Ms. Julie Pastor Director of Planning Loudon County 1 Harrison Street, S.E., 3r ~ Floor, Mail Stop #62 Leesburg, VA Mr. Mark Peterson Chairman, Goose Creek Scenic River Advisory Committee Loudoun Water Way Ashbum, Virginia Ms. Katherine Rudacille Northern Virginia Park Authority 5400 Fox Road Fairfax Station, Virginia

108

109 DIRECT TESTIMONY OF MARK R. GILL ON BEHALF OF VIRGINIA ELECTRIC AND POWER COMPANY BEFORE THE STATE CORPORATION COMMISSION OF VIRGINIA CASE NO. PUE Please state your name and position with Virginia Electric and Power Company ("Dominion Virginia Power" or the "Company"). My name is Mark R. Gill, and I am a Consulting Engineer in the Electric Transmission Planning group of the Company. My office is located at One James River Plaza, 701 East Cary Street, Richmond, Virginia What is your educational and professional background? I received a Bachelor of Science degree in Electrical Engineering from the University of Virginia in I have been licensed as a Professional Engineer in the Commonwealth of Virginia since I have been employed by the Company for 26 years. My experience with the Company includes Customer Service ( ), Circuit Calculations/System Protection ( ), Distribution Planning ( ) and Transmission Planning (2007-Present) Q. What are your responsibilities as a Consulting Engineer? A. I have responsibility for planning the Company s electric transmission system in the northern Virginia area for voltages of 69 kv through 500 kv.

110 What is the purpose of your direct testimony? In order to provide service requested by a retail electric service customer (the "Customer") for a new data center campus in Loudoun County, Virginia, to maintain reliable service for the overall growth in the area, and to comply with mandatory North American Electric Reliability Corporation ("NERC") Reliability Standards by increasing transmission capacity, the Company proposes to construct in Loudoun County, Virginia a new kv Poland Road Substation and a new approximately 4.0-mile overhead 230 kv double circuit transmission line between a tap of existing 230 kv Loudoun-Brambleton Line #2094 ("Poland Road Junction") and the proposed Poland Road Substation ("Poland Road Loop") (the Poland Road Loop and Poland Road Substation, collectively, the "Project") My direct testimony will discuss the need for, and benefits of, the Project from a transmission planning perspective. I am co-sponsoring Sections I.A through I.C, I.E and I.I of the Appendix with Company witness Harrison S. Potter. I am also sponsoring Section I.H of the Appendix mo Please provide an overview of the Company s transmission system and the transmission planning process. Dominion Virginia Power s transmission system is responsible for providing transmission service to the Company s retail customers and also to the customers of Old Dominion Electric Cooperative, Northern Virginia Electric Cooperative, Virginia Municipal Electric Association, and Central Virginia Electric Cooperative in Virginia, as well as the customers in North Carolina of North 2

111 Carolina Electric Membership Cooperative and North Carolina Eastem Municipal Power Agency. The Company needs to be able to maintain the overall, long-term reliability of its transmission system, as its customers require more power in the future Dominion Virginia Power is part of the Eastern Interconnection transmission grid, meaning it is interconnected, directly or indirectly, with all of the other transmission systems in the U.S. and Canada between the Rocky Mountains and the Atlantic coast, except Quebec and most of Texas. All of the transmission systems in the Eastern Interconnection are dependent on each other for support in moving bulk power through the transmission system and for reliability support. Dominion Virginia Power s transmission system is extremely reliant on a robust and reliable regional transmission system Dominion Virginia Power also is part of the PJM Interconnection L.L.C. ("PJM") regional transmission organization (RTO) providing service to a large portion of the eastern United States. PJM is currently responsible for ensuring the reliability and coordinating the movement of electricity through all or parts of Delaware, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia and the District of Columbia. This service area has a population of about 60 million and on July 21, 2011, set a record high of 158,450 MW for summer peak demand, of which Dominion Virginia Power s load portion was approximately 19,636 MW serving 2.4 million customers. On July 22, 2011 the Company set a record high of 20,061 MW for summer peak demand. On February 20, 2015, the Company set a winter

112 and all-time record demand of 21, 651 MW. Moreover, based on the 2015 PJM Load Forecast, the Dominion Zone is expected to be one of the fastest growing zones in PJM with an average growth rate of 1.7% over the next ten years compared to the PJM average of 1.0% over the same period As a Transmission Owner in PJM s planning region, the Company fully participates in PJM s transmission planning process under PJM s Regional Transmission Expansion Plan Protocol and is obligated under the PJM Operating Agreement to construct, operate and own transmission facilities as designated by PJM in its annual Regional Transmission Expansion Plan ("RTEP"). Each year, PJM, Transmission Owners and other stakeholders conduct a thorough study of the electric transmission grid and, based upon the findings, consider proposals to address the system needs identified by the study. At the conclusion of this process, the PJM Board approves its annual RTEP Please describe the load area served by the Project. The Customer s East Gate Campus development is on approximately 47 acres and is located south of Washington Dulles International Airport ("Dulles Airport"), approximately 3.3 miles west of Route 28 along Route 50. The Customer has requested retail electric service from Dominion Virginia Power. The total Customer load at East Gate Campus is projected to be approximately 152 MW, consisting of four buildings. The proposed new electric transmission facilities must be in service by June of 2018 to serve the Customer s new development. 4

113 Qo Please describe the present transmission system in the vicinity of the proposed Poland Road Substation. As presented in Appendix Attachment I.E. 1, Dominion Virginia Power s existing utility system in the vicinity of the proposed Poland Road Substation includes two switching stations (Loudoun and Mosby) that exclusively network transmission lines and do not contain distribution transformers or distribution circuits to serve local loads. Also presented in Attachment I.E.1 are the five stations containing distribution-level voltages in the vicinity of the proposed Project (Brambleton, Dulles, Discovery, Sully, and Walney). These five stations are networked by lines from three overhead 230 kv transmission corridors The Company s existing Brambleton Switching Station ("Brambleton Station") is 4.5 straight-line miles northwest from the Customer s East Gate Campus. Brambleton Station is located west of Dulles Airport at the intersection of the north/south Pleasant View to Loudoun Station corridor and the Brambleton to Shellhorn Substation corridor. Brambleton Station contains nine 230 kv breakers arranged in breaker-and-a-half configuration, one 84 MVA kv transformer and three 34.5 kv distribution circuits. A planned expansion includes a second kv 84 MVA transformer and two additional distribution circuits. NOVEC s Brambleton Delivery Point ("DP"), located at and sourced from Brambleton Station, contains two 40 MVA kv transformers; four 34.5 kv distribution circuits; two 30 MVA kv transformers; and eight 12.5 kv distribution circuits. 5

114 Two 500 kv lines and six overhead 230 kv lines currently terminate at Brambleton Station, with approval of a third 500 kv line proposed by the Company pending before the Commission in Case No. PUE Emanating from the north are 500 kv Brambleton-Goose Creek Line #558, 230 kv Brambleton-Pleasant View Line #201, and 230 kv Brambleton-Beaumeade Line #227. Leaving the station from the south are 500 kv Brambleton-Mosby Line #590, 230 kv Brambleton-Loudoun Line #2045, and 230 kv Brambleton- Loudoun Line #2094. Existing 230 kv Brambleton-Enterprise Line #2095 and Brambleton-BECO Line #2137 (Brambleton-Pacific by 2016) leave the station to the east The other four substations in the vicinity (Dulles, Discovery, Sully, and Walriey) are located in the overhead corridor that roughly parallels Route 28 (Sully Road) east of Dulles Airport and crosses Route 50 south of Dulles Airport Dulles Substation is the northernmost station of the four and is the terminus for 230 kv Loudoun-Dulles Line #2008 and Dulles-Reston Line #2115. Dulles Substation also contains one 75 MVA and one 84 MVA kV transformer, six 34.5 kv distribution circuits, two 56 MVA kV transformers, and six 13.2 kv distribution circuits Discovery Substation, approximately 1.8 miles south of Dulles Substation, is the terminus for 230 kv Sully-Discovery Line #2107 and Discovery-Reston Line #2043. Discovery Substation also contains two 33 MVA kv transformers servicing on-site customer load.

115 1 2 3 Sully Substation is located south of Discovery Substation, approximately 1.2 miles east of the main Route 28 corridor. Sully Substation contains two 75 MVA kv transformers and six 34.5 kv distribution circuits Walhey Substation is approximately 2.5 straight-line miles southeast of the Customer s East Gate Campus. Walney Substation is the southernmost station of the four in this corridor and contains two 75 MVA transformers and six 34.5 kv distribution circuits. A planned expansion of this substation includes a new kv 84 MVA transformer along with three 34.5 kv distribution circuits Why do the proposed Poland Road Substation and Poland Road Loop need to be built at this time? Company witness Harrison Potter describes the need for Poland Road Substation Ao Please explain how the mandatory NERC Reliability Standards relate to the need for the proposed Poland Road Substation. Federally mandated NERC Reliability Standards establish minimum criteria with which all public utilities must comply as components of the interstate electric transmission system. Moreover, the Energy Policy Act of 2005 mandates that electric utilities must follow these NERC Reliability Standards, and utilities could be fined up to $1 million a day per violation if found to be in non-compliance. NERC has been designated by the Federal Energy Regulatory Commission as the Electric Reliability Organization for the U.S In order to comply with mandatory NERC Reliability Standards, the Company maintains NERC-compliant "Facility Connection Requirements," which include 7

116 the Company s Transmission Planning Criteria. Appendix Attachment I.A.3 provides the relevant excerpt pertaining to the loading on a radial transmission line. In accordance with these criteria, the proposed network feed to Poland Road Substation, via the Poland Road Loop, will ensure future NERC compliance by eliminating the potential for loading in excess of 100 MW on a radial line Ao Has the Company considered whether there are feasible alternatives to construction of the proposed facilities? Yes. In addition to the distribution alternatives discussed in the prefiled direct testimony of Company witness Potter, the Company also considered several transmission alternatives that were rejected in favor of the proposed Project. Section I.C of the Appendix discusses these alternatives and the reasons they were found to be inferior to the Project. Those alternatives are described in Section I.C. of the Appendix How will the proposed Project affect economic development in Virginia? The Project is needed to assure reliability of the transmission and distribution systems in the local area. A robust and reliable system is an important part of economic development in Virginia. The proposed Project will support continued economic development in Virginia by reinforcing the transmission system in Loudoun County in order to maintain and improve reliability in the local area that includes the additional load requirements of the Customer s new high-technology campus. Have you reviewed the demand-side resources incorporated in the Company s planning studies used in support of this application, as directed 8

117 by the Commission in its Order issued on November 26, 2013, in Case No. PUE This Project is being driven by a large block load addition from a single customer that must be served from an on-site substation which requires a transmission source. The need to construct the double circuit 230 kv transmission line proposed by the Company fo.r this Project would not be diminished or eliminated, and is in fact wholly unaffected, by the application of demand-side resources. 8 9 Does this conclude your prepared direct testimony? Yes, it does. 9

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