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The utilities have ignored the capacity of the existing system.
Presently, approximately 185 megawatts (MW) of generation can be added in the San Luis Valley with minor upgrades to the existing transmission system. With the 60 MW of new solar generation that is planned for development, this will only leave around 125 MW for any future development plans. New transmission is required to account for future development and to address the current reliability concerns of this existing system. Without the proposed transmission line, the existing system is constrained to handle present and future development.
The utilities overlook a "bottleneck" situation at Pueblo and Walsenburg in proposing this transmission line.
Both utilities have conducted extensive planning and engineering studies to ensure adequate capacity and available contract path at both the proposed Calumet substation near Walsenburg and the proposed termination point for this project at the Comanche station south of Pueblo. Both utilities are working to ensure the interaction between both areas is adequately considered for any additional generation resources. As such, the utilities are not ignoring the interaction between generation installed in the San Luis Valley and the Walsenburg area in their proposed project. The utilities' identified this potential interaction early in their studies prior to proposing the project. The proposed northern alternatives would create a "bottleneck" situation at the Poncha substation, due to limited transmission capacity on the existing lines.
The utilities have provided inadequate opportunities for public input and have ignored property owners.
Public and agency input is an integral part of the utilities' process to communicate the need for the project and to responsibly site the transmission line. The utilities have been proactive in developing communications materials including this project Web site, a routine newsletter, responses to concerned landowners and citizens, as a well as tools including a phone number, email and mailing address where comments, questions and concerns can be sent and responded to in a timely fashion.
The Rural Utility Service (RUS) held NEPA scoping meetings in August of 2009. In addition to the RUS's solicitation of input on the scope of the NEPA effort, input was also requested regarding preliminary alternative corridors for line siting. Public input has been a key factor in selection and refinement of alternative routes for the transmission line. Information has been shared with the public and comments sought via the project website and informational newsletters. The utilities intend to hold route refinement workshops to gather additional input on further refinements and potential identification of a preferred route. Additionally, updated project information will be available at the next round of RUS scoping meetings to solicit input for the content of the environmental impact statement (EIS).
The utilities focused on a limited study area that avoided other alternatives and worked within a "box."
Both utilities have conducted numerous studies that researched the viability of various system alternatives, including alternatives for new transmission lines to the north over Poncha Pass. In addition, the utilities have considered all proposals introduced by Trinchera Ranch since applications were filed for Certificates of Public Convenience and Necessity (CPCN) in May of 2009. This includes a thorough analysis of the Ranch's consultants' studies, such as the Brubaker report. In addition, Trinchera Ranch accuses the utilities of not giving them ample opportunity to ask questions and address concerns. This accusation is flat out untrue. One only has to review the thousands of pages of discovery requested by Trinchera Ranch during the CPCN proceeding, the numerous depositions of utility employees by Trinchera Ranch lawyers, and the voluminous testimony provided by utility employees during the PUC proceedings. The fact is, the utilities have studied and evaluated the northern alternatives several times and concluded the same: they do not make sense from a reliability or economic standpoint, and feel that proceeding with such a proposal is not in the best interests of Colorado ratepayers.
During its studies in 2008, Tri-State never looked at alternatives and drew straight lines to the north, south, east and west, which provides incorrect mileages based on approximate mileages of proposed routes currently being used for the project.
This claim refers to one portion of the 2008 study that screened alternatives' ability to resolve the voltage collapse reliability concern. Tri-State stated very clearly that the voltage collapse problem would be solved with another 230kV transmission line that terminated at points to the north, east, south, or west. However, voltage collapse is only one issue that was addressed. When utilities plan for projects, a primary focal point in determining the purpose and need of the project is also determining what is best for their members and Colorado consumers as a whole. In choosing the San Luis Valley to Walsenburg transmission line, this same study also recognized the benefits of looped service from a separate electrical source and strengthening of the Walsenburg area transmission system, and the benefits of connecting to the north-south "Front Range" transmission system that can aid in development of renewable energy projects.
It also recognized the reliability concerns of adding another northern transmission line utilizing a common radial corridor and constraints of the existing transmission system connected to Poncha Substation. In addition to these concerns for a new line connecting to Poncha, Trinchera Ranch's favored alternative travels past Poncha all the way to Leadville – likely impacting hundreds, if not thousands, of landowners. In essence, the sole goal for Trinchera Ranch is to redefine the purpose and need of the project in order to keep it off the Ranch property.
From Xcel Energy's perspective, the west to east proposal connects two identified renewable energy zones and creates an inherent contract path to new infrastructure located at Comanche, which ultimately connects this project to the state's bulk transmission system.
The utilities proposal impacts scenery and natural resources and the proposed transmission "cuts a wide swath of land" needed for easements.
In its arguments, Trinchera Ranch emphasizes the natural habitats, scenic resources, and open space of the Trinchera and Blanca ranches, and argues that a northern route would not result in serious impacts. Trinchera Ranch provides no analysis of resources, communities and additional numbers of private land owners that would be affected by a Trinchera northern alternative and ignores the impacts that may result.
Poncha Pass and the diverse landscapes of the Arkansas River north and east from Poncha Pass to the Leadville and Pueblo areas are highly valued and deeply respected by those who live and recreate there. This popular region of Colorado contains large expanses of public lands with a variety of animal and plant species habitats. The region also includes designated wilderness and wilderness study areas. The public lands here are also able to be viewed, accessed, and utilized by thousands of people each year.
The Sangre de Cristo Mountains, Mount Ouray, the Collegiate Range, Pikes Peak, and the Royal Gorge Bridge and Park and various scenic byways are just a few of the features that can be viewed by those living and recreating in this highly diverse and scenic area of Colorado.
Alamosa, Saguache, Chaffee, Fremont, Lake, El Paso and Rio Grande counties could also be impacted by Trinchera Ranch's numerous alternatives, in addition to Pueblo and Huerfano Counties for the line that is still necessary between the Pueblo and Walsenburg areas. There are several communities in these areas that could be affected, including, but not limited to, Poncha Springs, Salida, Buena Vista, Leadville, and Canon City.
Trinchera's longer northern route alternatives contain no analysis or consideration of any environmentally sensitive or scenic public lands, or the number or location of property owners that may be affected. The utilities acknowledge the scenic and natural resource value of the San Luis Valley and surrounding area. Efforts to minimize impacts to visual and other resources are a primary factor in the process to responsibly site the transmission line.
These are yet more reasons that both Tri-State and Xcel Energy stand by their studies that identifies the west to east proposed alternative as the route that meets the project's purpose and need while taking into account cost and potential environmental impacts.
The Trinchera Ranch proposal is $50M cheaper than that proposed by the utilities.
Quite simply, this is another case where Trinchera Ranch is attempting to redefine the project in order to keep it off the Ranch property. In citing its costs, Trinchera Ranch is proposing a single circuit line, not the proposed double-circuit needed to meet the purpose and need of the project as proposed by the utilities. A double-circuit line is a more robust line that accounts for reliability concerns of serving loads in the San Luis Valley while also accounting for the stability and capacity to enable solar development.
As has been stated numerous times by the utilities and recognized by the Administrative Law Judge that heard the arguments and proposals of Trinchera Ranch during the CPCN proceeding, they also understate the total costs of their alternatives, including their proposed 114-plus mile line to near Leadville.
With the numerous shortfalls of their proposed 114-plus mile line and other alternatives, it is easy to see that their proposal is not in the best interest of Colorado's ratepayers.
A northern alternative provides the same redundant "loop" transmission infrastructure that is proposed in the utilities' project.
Plain and simple, this is false. The same sources they claim from the east and the west exist at Poncha today, which then serves the San Luis Valley from one point in the transmission system. This does not create the redundant loop a new west to east line would create.
A new line going north fully addresses reliability.
A fourth line going north from Alamosa to Poncha, as concluded in the Alternative Evaluation and Macro Corridor studies, would minimally resolve the voltage collapse reliability concern. But voltage collapse is only part of the reliability challenge, hence reliability is narrowly being defined. A fourth line does not provide a separate source of electricity. The connection from the San Luis Valley to the Walsenburg area at Calumet Substation provides for a second separate source of power to the San Luis Valley while also strengthening the transmission system in the Walsenburg area. In addition, Trinchera Ranch's single-circuit line proposal versus the utilities' proposed double-circuit line will never provide the reliability needed for planned and future renewable energy generation in the San Luis Valley. In essence, Trinchera Ranch's "fourth line" proposal does not address the purpose and need of the project, in its ultimate goal of keeping the proposed line off ranch property.
There were no fatal flaws found in the northern route in the utilities' fatal flaw analysis
The fatal flaw study referred to is a very high-level study included in the 2008 Alternative Evaluation whose primary purpose is to eliminate alternatives early in the process for feasibility concerns such as obvious major siting issues. Examples would be traversing rugged terrain not suited for a transmission line, impacting National Parks, etc. The fatal flaw analysis was only one component in selecting the west to east route.
The utilities can construct a new transmission line to the north in a phased approach
Tri-State and Public Service have thoroughly reviewed Trinchera's proposals and have determined numerous downsides that don't make this a feasible solution to the joint needs of the companies and their customers and members. When planning and proposing the utilities proposed transmission project, it was done with the purpose that it will serve both the short- and long-term electric grid requirements in southern Colorado and support the goals of the New Energy Economy. This project is a prime example of coordinated efforts to ensure reliable power delivery throughout the region while working to meet state mandates and goals for new energy generation. That being said, it is important the utilities build transmission for not only present, but future need to ensure not only reliable electricity, but also ensure infrastructure is in place for future renewable energy development. As was identified in the original 2007 Senate Bill 91 report, the foremost challenge to development of renewable resources is transmission constraints. This includes the inability of utilities to construct high voltage transmission lines in a timely manner. Transmission projects are routinely at least a 5-7 year process, compared to a much shorter construction period for renewable resources, which is closer to two years.
The utilities can rebuild one of the existing transmission lines to the north as a phased development approach
Existing transmission constraints at Poncha to allow delivery to utility customers (similar to the concerns with Trinchera's northern alternatives) also exist for these proposals. Additionally, the timing of this approach would be a concern. In addition to these concerns, this approach also does not consider the operational and reliability concerns to the San Luis Valley of electrical service from a single transmission line during reconstruction of one of the two existing lines. That is, should an outage occur on the one operational line during the construction phase of such a project, most – if not all – of the San Luis Valley would go dark.
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