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Cont ol mber: 48909

Item Number: 297

Addendum StartPage: 0

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JOINT APPLICATION OF SHARYLAND UTILITIES, L.P. AND THE CITY OF LUCCOCK, ACTING BY AND THROUGH LUBBOCK POWER & LIGHT, FOR A CERTIFICATE OF CONVENIENCE AND NECESSITY

OF

FOR THE WADSWORTH TO NEW OLIVER TO FARMLAND 345-KV TRANSMISSION LINE IN LUBBOCK AND LYNN COUNTIES AND THE SOUTHEAST TO NEW OLIVER TO OLIVER 115-KV TRANSMISSION LINE IN LUBBOCK COUNTY

ADMINISTRATIVE HEARINGS

DIRECT TESTIMONY OF T. BRIAN ALMON ON BEHALF OF BMWB COALITION

T. Brian Almon, on behalf of Robert Melcher, Jon Fehleison, as Executor of

the Estate of Robert Fehleison, All Saints Episcopal, Steven Hill, Jeffery and Cathy

Johnson and FLP Ramar, LTD. (collectively "BMWB Coalition"). files this Direct

Testimony, which is attached. Testimony can be treated by all parties as if the answers

were filed under oath.

Respectfully Submitted,

BURDETT, MORGAN, WILLIAMSON & BOYKIN, LLP 701 South Taylor, Suite 440, LB 103 Amarillo, Texas 79101 Telephone: (806) 358-8116 Facsimile: (806) 350-7642

E-Mail: [email protected]

ATTORNEY FOR BMWB COALITION

Direct Testimony of T. Brian Almon

Page 1

SOAH DOCKET NO. 473-19-2405

ULJCtIT;L1TY CO;slMISSIr'sP PUC DOCKET NO. 48909

BEFORE THE STATE OFFI FILING CLEA

7_97

CERT FICATE OF SERVICE

I certify that on the 06 day of May, 2019 a true and correct copy of the

preceding document was served in accordance with PROC. R. 22.74 and SOAH Order

No. 2 in this docket.

Direct Testimony of T. Brian Almon Page 2

SOAH DOCKET NO. 473-19-2405 PUC DOCKET NO. 48909

§ § § § § § § § § § § § §

JOINT APPLICATION OF SHARYLAND UTILITIES, L.P. AND THE CITY OF LUCCOCK, ACTING BY AND THROUGH LUBBOCK POWER & LIGHT, FOR A CERTIFICATE OF CONVENIENCE AND NECESSITY FOR THE WADSWORTH TO NEW OLIVER TO FARMLAND 345-KV TRANSMISSION LINE IN LUBBOCK AND LYNN COUNTIES AND THE SOUTHEAST TO NEW OLIVER TO OLIVER 115-KV TRANSMISSION LINE IN LUBBOCK COUNTY

BEFORE THE STATE OFFICE

OF

ADMINISTRATIVE HEARINGS

DIRECT TESTIMONY

OF

T. BRIAN ALMON

ON BEHALF OF

ROBERT MELCHER, JON FEHLEISON, ALL SAINTS EPISCOPAL, STEVEN HILL, JEFFERY & CATHY JOHNSON AND FLP RAMAR, LTD.

MAY 7, 2019


PUC Docket No. 48909 SOAH Docket No. 473-19-2405

DIRECT TESTIMONY OF T. BRIAN ALMON

TABLE OF CONTENTS

I. STATEMENT OF QUALIFICATIONS 5

II. PURPOSE OF TESTIMONY 6

III. SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS 7

IV. PROJECT DESCRIPTION 8

V. ROUTE SELECTION FOR THE SNO LINE 1 1

VI. ROUTE SELECTION FOR THE WNF LINE 1 6

VII. COMPARING PROJECT ROUTES (WNF AND SNO) 1 8

EXHIBITS BA-1 Qualifications of T. Brian Almon BA-2 List of Dockets Containing Testimony of T. Brian Almon BA-3 Comparison of Routes SNO 2 and 9 BA-4 Comparison of Route Combinations

WORKPAPER Response to Question 4 of Hill's 2nd Request for Information



1 I. STATEMENT OF QUALIFICATIONS

2 Q. Please state your name, occupation and business address.

3 A. My name is T. Brian Almon. I am a consultant testifying on behalf of Robert

4 Melcher, Jon Fehleison, All Saints Episcopal, Steven Hill, Jeffery & Cathy Johnson

5 and FLP Ramar, Ltd. in this case. My business address is 343 Bonnabel Blvd.,

6 Metairie, Louisiana, 70005.

7 Q. Please briefly outline your educational and professional background.

8 A. I have a Bachelor of Science degree in Mining Engineering and a Master of Business

9 Administration degree. My forty-four years of professional experience include mine

10 operating, mine planning, coal marketing to the electric utility industry, and utility

11 regulation. I retired from the Public Utility Commission of Texas (PUCT) in

12 December, 2011 as the Director of Electric Transmission Analysis after 23 years of

13 employment. During sixteen years of my employment with the PUCT, I supervised a

14 staff whose primary duty was to review and file recommendations on applications for

15 amendments to certificate of convenience and necessity for transmission lines. A more

16 detailed resume is provided in Exhibit BA-1. Each year I personally reviewed from

17 eight to fifteen transmission Certificate of Convenience and Necessity (CCN)

18 applications as they were filed with the PUCT. I also personally filed testimony on

19 fourteen transmission line cases.

20 Q. Have you previously testified as an expert before the Commission?

21 A. Yes. A list of the dockets in which I have testified is provided in Exhibit BA-2.



1 II. PURPOSE OF TESTIMONY

2 Q. What is the purpose of your testimony in this proceeding?

3 A. My testimony evaluates the application of Sharyland Utilities L.P. and Lubbock Power

4 & Light (collectively, Applicants) for the proposed transmission line project described

5 as the Wadsworth to New Oliver to Farmland 345-kV transmission line (WNF Line)

6 and the Southeast to New Oliver to Oliver 115-kV transmission line (SNO Line).

7 Q. What law, regulations and Commission orders have you referred to in making

8 your evaluation and arriving at your conclusions and recommendations?

9 A. For my evaluation, I have referred to PURA § 37.056 and 37.0541, P.U.C. SUBST. R.

10 25.101(b)(3) and the Order of Referral and Preliminary Order in this proceeding. My

11 testimony is also based on my knowledge of commission precedent regarding

12 transmission line CCNs.

13 Q. How is your testimony organized?

14 A. My testimony begins in Section I with a statement of my qualifications. In Section II,

15 I discuss the purpose of my testimony. Section III presents a summary of my

16 conclusions and recommendations for this proceeding. In Section IV, I describe the

17 transmission project submitted by Applicants. In Section V, I discuss my evaluation

18 of the 14 alternative routes for the SNO Line. In Section VI, I present my evaluation

19 of the 22 alternative routes for the WNF Line. I conclude my testimony in Section VII

20 with a comparison of the SNO and WNF line combinations.

21 Q. Have you prepared any exhibits related to your testimony?

22 A. Yes. They are attached to my testimony.

23 Q. Were these exhibits prepared by you or under your supervision?



1 A. Yes.

2 Q. What did you rely upon to reach your conclusions?

3 A. I have relied upon the Application, Testimony and Responses to Request for

4 Information (RFI) filed by the Applicants and intervenors. Included in the Application

5 is Attachment No. 1 - Environmental Assessment and Alternative Route Analysis (EA)

6 prepared by POWER ENGINEERS, INC. (POWER).

7 III. SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS

8 Q. Please summarize the conclusions that you have reached as a result of your

9 analysis.

10 A. I conclude the following:

11 1. Applicants presented an adequate number of geographically diverse alternative

12 routes in their application for the WNF Line and the SNO Line.

13 2. The Applicants considered the routing criteria as defined by PURA and the

14 PUCT Substantive Rules in its route assessment for the WNF and SNO Lines.

15 3. For the WNF Line, Routes 6 and 7 best addresses the requirements of PURA

16 and the PUCT Substantive Rules when compared to the other 21 Routes and,

17 importantly, in conjunction with the SNO Line routes.

18 4. For the SNO Line, Route 2 best addresses the requirements of PURA and the

19 PUCT Substantive Rules when compared to the other 13 Routes and,

20 importantly, in conjunction with the WNF Line routes.

21 Q. What is your recommendation?



1 A. I recommend that the Judge and the Commission should approve Routes WNF 6 and

2 SNO 2 as the routes that best addresses the requirements of PURA and the PUCT

3 Substantive Rules. Alternatively, Routes WNF 7 and SNO 2 should be approved.

4 IV. PROJECT DESCRIPTION

5 Q. What is your understanding of the project in the Applicants application?

6 A. The Applicants propose to construct the WNF Line to connect LP&L's existing

7 Wadsworth Station (which will be expanded by Sharyland to include a new 345-kV

8 switchyard), located on the east side of Lubbock in Lubbock County, to Sharyland's

9 existing Farmland Station, and located southeast of Tahoka in Lynn County.

10 The Applicants also propose to construct the 115-kV SNO Line to connect LP &L's

11 existing Southeast Station, located on the south side of Lubbock in Lubbock County,

12 to LP&L's existing Oliver Station, also located on the south side of Lubbock in

13 Lubbock County. Like the WNF Line, the SNO Line will be routed through one of two

14 alternative locations for the New Oliver Station, located on the southeast side of

15 Lubbock in Lubbock County.1

16 Q. What is the purpose for connecting the WNF and SNO Lines?

17 A. The connection of the WNF and SNO Lines at either one of the alternative locations

18 for the New Oliver Station will allow for the transfer of power from the 345-kV WNF

19 Line to the 115-kV SNO Line and directly into the LP&L's northern 115-kV loop.

1 Application, page 4.



1 Q. Is it reasonable to integrate the evaluation of the routing for the WNF and SNO

2 Lines?

3 A. Yes. Both the WNF and SNO Lines are required to provide power to the LP&L's loop.

4 Also, both the WNF and SNO routes that are ultimately selected by the Commission

5 must connect at the same location for the North Oliver Station. The Commission

6 recognizes the need to consolidate two transmission line CCN cases where two

7 transmission lines share an interconnected point as stated in PURA 37.0541.

8 Combining the two proposed transmission lines will achieve the best overall result to

9 address the need for the project and to satisfy the impacted landowners in the study

10 area.2

11 Q. How did the Applicants present the alternative routes and their connection with

12 the North Oliver Station?

13 A. For the WNF alternative routes, the Applicants present Routes 1 through 11 connecting

14 with North Oliver Option 1 and Routes 12 through 22 connecting with North Oliver

15 Option 2. For the SNO alternative routes, the Applicants present Routes 1 through 7

16 connecting with North Oliver Option 1 and Routes 8 through 14 connecting with North

17 Oliver Option 2.

18 Q. Which of the North Oliver Options do Routes WNF 20 and SNO 9 use?

19 A. WNF 20 and SNO 9, which the Applicants believe are the routes that best address the

20 requirements of PURA and the Commission's Substantive Rules, connect at North

21 Oliver Option 2.

22 Q. How did POWER support the Applicants application?

2 Response to Hill RFI 2-4.



1 A. Sharyland (the Applicant responsible for construction of the Project) contracted with

2 POWER to perform a routing study and prepare the Environmental Assessment for the

3 Project.3 Ultimately, 22 primary alternative routes for the WNF Line and 14 primary

4 alternative routes for the SNO Line were selected that represent an adequate number of

5 reasonable and geographically differentiated primary alternative routes to consider for

6 this Project. POWER recommended WNF 20 for the WNF Line and SNO 9 for the

7 SNO Line as the primary alternative routes that best address the requirements of PURA

8 and the Commission's Substantive Rules from an environmental and land use

9 perspective, based primarily on an evaluation of the 45 objective environmental criteria

10 that encompass applicable portions of the statute and the rules.4 After reviewing the

11 results of POWER's evaluation in addition to considering estimated costs and other

12 factors including engineering and construction constraints, as well as agency and

13 landowner concerns, Applicants also selected WNF 20 and SNO 9 as the routes that

14 best address the requirements of PURA and the Commission's Substantive Rules.5

15 Q. Has the need for the proposed project been reviewed by ERCOT and approved

16 by the Commission?

17 A. Yes. In 2015, the Commission directed ERCOT to conduct a study identifying the

18 transmission system improvements necessary to integrate Lubbock Power & Light

19 (LP&L) into the ERCOT system. In June 2016, ERCOT issued its "Study of the

20 Integration of the Lubbock Power & Light System into the ERCOT System" ("ERCOT

21 Integration Study"). The Commission determined that the Wadsworth to New Oliver

3 McClanahan testimony, page 4 (Bates 6).

4 McClanahan, page 9-10 (Bates 11-12).

5 McClanahan, page 11 (Bates 13).



1 to Farmland 345-kilovolt ("kV") transmission line (the "WNF Line") and the Southeast

2 to New Oliver to Oliver 115-kV transmission line (the "SNO Line") (collectively, the

3 "Project") are necessary for the integration determined to be in the public interest in

4 Docket No. 47576.6

5 Q. Do you conclude that the Applicants procedures and evaluations provided a

6 suitable number of alternative routes for the consideration of the Commission?

7 A. Yes. I conclude that the Applicants with input from POWER performed a reasonable

8 and comprehensive evaluation that addressed all of the requirements of PURA and the

9 PUCT Substantive Rules and provided a suitable number of alternative routes.

10 V. ROUTE SELECTION FOR THE SNO LINE

1 1 Q. What are the routing options for the SNO Line?

12 A. Joint Applicants are proposing 14 geographically diverse alternative routes for the SNO

13 Line. The lengths of these routes range from 14.0 miles for SNO Route 3, to 25.9 miles

14 for SNO Route 1. The estimated costs for these routes range from approximately

15 $49,726,000 for SNO Route 2 to approximately $61,415,000 for SNO Route 11,

16 including costs to construct the 115-kV portion of the New Oliver Station and modify

17 the existing Southeast, Oliver, and Wadsworth (115-kV portion) stations.

18 The alternative routes for the SNO Line exit either directly from the Southeast Station

19 or from one of two alternative Points of Interconnect ("POI 1" or "POI 2") on an

20 existing, LP&L-owned 230-kV transmission line (which would be disconnected from

6 McCalla testimony, pages 4-5 (Bates 6-7).



1 SPP and repurposed to connect the Southeast Station to ERCOT if one of these two

2 alternative POIs is selected) and generally proceed east/southeast to one of the

3 proposed New Oliver Station alternative locations. Then, the alternative routes

4 generally proceed back west/northwest to the Oliver Station, which is approximately

5 2.4 miles southwest of the Southeast Station.7

6 Q. How did the Applicants make the selection of SNO Route 9 as the route that best

7 addresses the requirements of PURA and the Commission's Substantive Rules?

8 A. The Applicants considered the recommendation of POWER which utilized the 45

9 routing criteria and balanced that analysis with engineering, design, and construction

10 constraints, costs, grid reliability, public input, and community values to make the

11 selection of SNO Route 9.8

12 Q. Did you use the same routing criteria and other Applicants factors to perform

13 your evaluation of the 14 alternative routes for the SNO Line?

14 A. Yes.

15 Q. From your evaluation which of the 14 alternative routes did you conclude best

16 addresses the requirements of PURA and the PUCT Substantive Rules?

17 A. I concluded that SNO Route 2 best addresses the requirements of PURA and the PUCT

18 Substantive Rules.

19 Q. What was POWER's rank for SNO Route 2 in its evaluation?

20 A. POWER consensus ranking of SNO Route 2 was that it was the second best route

21 compared with the other 13 routes.

7 Vaughn testimony page 6-7 (Bates 8-9).

8 Attachment 8 of the Application, page 4 (Bates 142).



1 Q. Why do you not agree with POWER's ranking for SNO Route 2?

2 A. I made a comparison of SNO Routes 2 and 9 using the 45 routing criteria along with

3 the costs and public input. This comparison is provided below and on Exhibit BA-3.

4 The Applicants stated that the following criteria favored SNO Route 9 over the other

5 13 routes including SNO Route 2.9 After each criterion, I provide my analysis and

6 conclusion in italics.

7 o Has the fifth shortest length, at 17.8 miles;

8 o Route 2 is 15.1 miles long, making it shorter by 2.7 miles than Route 9.

9 o Has the second lowest estimated cost, at approximately $20,688,000;

10 o Route 2 is less expensive at an approximate cost of $18,478,000.

11 o Has the least number of habitable structures within 300 feet, at 123;

12 o Route 2 has only 4 more habitable structures within 300 feet at 127 making it

13 the second least number of the 14 routes which range up to 306 habitable

14 structures.

15 o Is tied with one route as having the second greatest length parallel to existing

16 transmission line ROW, at 2.1 miles;

17 o Route 2 is the other route with 2. 1 miles of its length parallel to existing

18 transmission line ROW.

19 o Has the fourth longest length parallel to other existing compatible ROW

20 (highways, roads, railways, etc.), at 11.9 miles;

21 o Route 2 is parallel to other existing compatible ROW for 7.3 miles, but when

22 comparing the distance that a route parallels existing transmission lines, other

9 Attachment 8 of the Application, pages 4-5 (Bates 1).


1

2

3 o


existing compatible ROW and apparent property lines, Route 2 parallels 14.5

miles to 14.01 miles for Route 9.

Is tied with one route as having the least number of transmission line crossings,

4 at four;

5 o Route 2 is the other route which is tied with Route 9 for the number of

6 transmission line crossings, at four.

7 o Is not within 1,000 feet of any cemeteries;

8 o Route 2 is also not within 1,000 feet of any cemeteries.

9 o Is within 10,000 feet of only one AM transmitter;

10 o Route 2 also has one AM transmitter within 10,000 feet.

11 o Is tied with three other routes as having the third least number of FM radio

12 transmitters, microwave towers, and other electronic installations within 2,000

13 feet;

14 o Route 2 has only one more electronic installation within 2,000 feet than Route

15 9.

16 o Has the second least number of water wells within 200 feet, at 30;

17 o Route 2 has 36 water wells within 200 feet. The range for the number of water

18 wells for the 14 routes is 27 to 60.

19 o Has the fifth shortest length through the foreground visual zone of interstate,

20 U.S. and state highways, at 7.6 miles;

21 o Route 2 is tied with one other route for the second shortest length, at 7.2 miles.

22 o Has the second shortest length through upland woodlands, at 0.01 mile;

23 o Route 2 has the shortest length through upland woodlands, at .002 mile.



1 o Is tied with one other route as having the shortest length through National

2 Wetlands Inventory ("NWr)-mapped wetlands, at 0.1 mile;

3 o Route 2 also has 0.1 mile through NW1 mapped wetlands.

4 o Is tied with several routes as having the shortest length through prairie dog

5 towns, at 0.1 mile;

6 o Route 2 also has 0.1 mile through prairie dog towns.

7 o Is tied with one other route as having the shortest length through FEMA-

8 mapped 100-year floodplains, at 0.1 mile;

9 o Route 2 is the other route that has a 0.1 mile length through FEMA-mapped

10 100-year f loodplains.

11 o Does not cross nor is within 1,000 feet of National Register-listed or —

12 determined eligible archeological or historic sites.

13 o Route 2 also does not cross nor is within 1,000 feet any eligible sites.

14 After an evaluation of the criteria that POWER used to select SNO Route 9, I came to

15 a different conclusion. Of the 16 criteria that POWER used to determine SNO Route

16 9 to be the route that best addresses the requirements of PURA and the PUCT

17 Substantive Rules, Routes SNO 2 and SNO 9 each have four favorable criteria and

18 eight criteria that are the same. Route SNO 2 is shorter by 2.7 miles and less expensive

19 by approximately $2,210,000. Route SNO 9 has more length paralleling other existing

20 compatible ROW, but when considering the paralleling by all compatible ROW and

21 apparent property lines, Route SNO 2 is more favorable with paralleling of 14.5 miles

22 or 96 percent of the route compared to 14.01 miles or 79 percent of the route for SNO

23 Route 9. The difference of 6 additional water wells for SNO Route 2 is not a major

24 significance when considering the range for water wells on all the routes. The



1 Applicants have indicated that any problems with water well location can be mitigated.

2 One more electronic installation for SNO Route 2 is also not significant in the overall

3 evaluation. SNO Route 2 does have four more habitable structures but I conclude that

4 it is not a reasonable investment to spend more than $2,000,000 to avoid four habitable

5 structures. Therefore, I conclude that SNO Route 2 best addresses the requirements of

6 PURA and the PUCT Substantive Rules.

7 Q. Is there a feature on Route SNO 2 that may potentially be impacted by the

8 construction on this route?

9 A. Yes. There is a private airstrip located south of Segments B18A and B18B identified

10 as the Bartos Farm Airstrip10. Since this is a private airstrip there are no FAA

11 regulations that would preclude the construction of the transmission line near the Bartos

12 Farm Airstrip.

13 VI. ROUTE SELECTION FOR THE WNF LINE

14 Q. What are the routing options for the WNF Line?

15 A. Applicants are proposing 22 geographically diverse alternative routes for the WNF

16 Line. The lengths of these routes range from 41.9 miles for Route WNF 20, to 52.9

17 miles for Route WNF 12. The estimated cost for these routes range from approximately

18 $88,407,000 for Route WNF 20, to approximately $103,944,000 for Route WNF 4,

19 including costs to construct the 345- kV portion of the New Oliver Station and modify

20 the existing Wadsworth and Farmland stations.

10 Application, page 200 (Bates 880) and Figure 3-2b.



1 The alternative routes for the WNF Line exit the Wadsworth Station and generally

2 proceed south to one of the proposed New Oliver Station alternative locations, and then

3 generally proceed further south to the Farmland Station.11

4 Q. What WNF route has POWER and the Applicants determined best addresses the

5 requirements of PURA and the PUCT Substantive Rules?

6 A. Both POWER and the Applicants determined that WNF Route 20 best addresses the

7 requirements of PURA and the PUCT Substantive Rules.12

8 Q. How did you start your evaluation of the WNF routes proposed by the Joint

9 Applicants?

10 A. Since I recommended SNO 2 route that goes through New Oliver Option 1, I limited

11 my evaluation to the first 11 alternative WNF routes because they are the only ones

12 which also use New Oliver Option 1.

13 Q. Which WNF routes of the eleven that go through New Oliver Option 1 are you

14 recommending?

15 A. I have evaluated the eleven routes and I am recommending either Routes WNF 6 or

16 WNF 7 as routes that best address the requirements of PURA and the Substantive

17 Rules. Both have features that are favorable when compared to the other nine

18 alternative routes.

19 Q. How did POWER rank Routes WNF 6 and WNF 7?

20 A. POWER ranked Routes WNF 7 and WNF 6 second and third respectively after Route

21 WNF 20.

I I Vaughn testimony page 6 (Bates 8).

12 Attachment 8 of the Application, page 1 (Bates 139).



1 Q. How does Route WNF 20 compare with Route WNF 6 and Route WNF 7?

2 A. The Joint Applicants present comparative comments for Route WNF 20 in the

3 Application,13 but Route WNF 6 and Route WNF 7 do have criteria which are more

4 favorable than Route WNF 20. For example:

5 Both Route WNF 6 and Route WNF 7 have fewer habitable structures within 500 feet

6 of the centerline at 7 and 8 respectively compared to 14 for Route WNF 20. When

7 considering the newly affected habitable structures, Routs WNF 6 and Route WNF 7,

8 again have fewer structures at 5 and 6 respectively compared to 13 structures for Route

9 WNF 20. Both Route WNF 6 and Route WNF 7 have more of their length parallel to

10 existing transmission line ROW at 6.5 miles compared to 0 miles for Route WNF 20.

11 Also, both Route WNF 6 (8.0 miles) and Route WNF 7 (8.9 miles) have more of their

12 length parallel to apparent property lines than Route WNF 20 (1.8 miles). When length

13 of route paralleling all existing and compatible ROW is considered, Route WNF 20

14 only has 36.6 miles paralleling whereas Route WNF 6 has 40.1 miles and Route WNF

15 7 has 37.5 miles. When considering aesthetics in criteria 29-31, Route WNF 20 is more

16 visible on highways, county roads and near parks and recreational areas (24.7 miles)

17 than Routes WNF 6 or 7 (20.3 and 17.2 miles, respectively).

18 VII. COMPARING PROJECT ROUTES (WNF AND SNO)

19 Q. Should your recommended route combinations be compared to the route

20 combination recommended by the Applicants?

13 Application page 2-3, (Bates 140-141)



1 A. As I previously stated, it is reasonable to evaluate the WNF and SNO routes as one

2 project as directed by PURA 37.0541. Therefore, I present on Exhibit BA-4, a

3 comparison of each criteria for the combined routes for consideration by the

4 administrative judges and the Commission.

5 Q. How do the criteria for the route combinations you recommend compare with the

6 criteria of the route combination that the Applicants are recommending?

7 Exhibit BA-4 shows that the combination of Routes SNO 2 and WNF 6 has 12 criteria

8 that are more favorable when compared to the same criteria for the combination of

9 Routes SNO 9 and WNF 20, including the number of habitable structures, number of

10 newly affected habitable structures and the paralleling of existing transmission lines

11 and apparent property lines. The combination of Routes SNO 2 and WNF 7 has 16

12 criteria that are more favorable when compared to the same criteria for the combination

13 of Routes SNO 9 and WNF 20 including cost, length, number of habitable structures,

14 number of existing water wells within 200 feet of ROW, and length of ROW within the

15 foreground visual zone of highways and roads.

16 Q. What is your conclusion about the combination of routes?

17 A. I conclude that both the combination of Routes SNO 2 and WNF 6 and combination of

18 Routes SNO 2 and WNF 7 better address the requirements of PURA and the PUCT

19 Substantive Rules than the combination of Routes SNO 9 and WNF 20. As between

20 the combination of Routes SNO 2 and WNF 6 and Routes SNO 2 and WNF 7, the

21 combination of Routes SNO 2 and WNF 6 are more favorable in several respects,

22 including number of habitable structures and newly affected habitable structures,

23 length of route parallel to other existing compatible ROW, total paralleling

24 (combination of Criteria Nos. 5,6 & 7 — length of route parallel to existing transmission



1 lines, other existing compatible ROW and apparent property lines), length of route

2 through land irrigated by traveling systems, length of route through pasture and

3 rangeland, and length of route across mapped NWI wetlands and Playa Lakes, whereas

4 Routes SNO 2 and WNF 7 are more favorable with regard to items including cost,

5 length, paralleling apparent property lines, length of ROW through cropland, the

6 number of water wells in the ROW and estimated length within the foreground visual

7 zone of highways, roads and parks.

8 Q. What is your recommendation?

9 A. I recommend that the Judge and the Commission should approve Routes WNF 6 and

10 SNO 2 as the routes that best addresses the requirements of PURA and the PUCT

11 Substantive Rules. Alternatively, Routes WNF 7 and SNO 2 should be approved.

12 Q. Does this conclude your testimony?

13 A. Yes.



EXHIBIT BA-1

Qualifications of T. Brian Almon



EXHIBIT BA-1

QUALIFICATIONS

OF

T. BRIAN ALMON

I received a Bachelor of Science in Mining Engineering from the University of Arizona in 1967 and a Master of Business Administration degree from the same university in 1973. I also attended Virginia Polytechnic Institute and State University for postgraduate studies in mining engineering during 1968 and 1969. I have attended seminars on coal supply agreements, economic evaluation of mining projects, and regulation of electric utilities.

After receiving my BS degree, I was employed with New Jersey Zinc Company as a Mine Engineer (Austinville, Virginia). In 1970, I joined the Anaconda Company as an Assistant Shift Foreman at the Twin Buttes copper mine (Sahuarita, Arizona). After completion of my MBA degree, I was employed by El Paso Coal Company (El Paso, Texas), a subsidiary of El Paso Natural Gas Company, in several positions: Development Engineer, Senior Development Engineer, Administrator of Technical Staff, Administrator of Technical Staff & Coal Marketing, and Manager of Coal Marketing and Technical Services.

As an engineer, my responsibilities included planning and cost estimating for surface coal mines. As administrator and manager, I was responsible for economic evaluation of coal projects, coal analyses, computer program development, forecasting the fuel needs of electric utilities, and marketing El Paso Coal Company's coal properties located in four westem states.

In 1980 I joined Tenneco Coal Company (Houston, Texas) as Manager of Coal Marketing with responsibility for marketing Texas and Mississippi lignite to electric utilities. My duties included the determination of future fuel needs for the electric utilities in Texas. I followed very closely the activities of utilities and competing coal companies. I also tracked prices of competing fuels and coal transportation.

In May 1988, I began my employment with the Commission as a Fuel Engineer. My duties included evaluating utility fuel procurement management practices, forecasting short and long-term fuel prices, recommending depreciation rates and fuel inventory levels, and supporting Commission projects in the fuel area. In December 1993, I became Manager of Engineering with responsibility over fuel, power plant engineering, and transmission line siting. On October 1, 1995, as part of an agency-wide reorganization, I assumed the responsibility for fuel as Assistant Director of Fuel Analysis. On January 9, 1998, I assumed the responsibility for fuel and engineering as an Assistant Director in the Electric Industry Analysis Division. When I retired from the PUCT in December, 2011, my title was Director of the Electric Transmission Analysis Section in the Infrastructure and Reliability Division with essentially the same duties.



EXHIBIT BA-2

List of Dockets Containing Testimony of T. Brian Almon



EXHIBIT BA-2 LIST OF DOCKETS CONTAINING TESTIMONY OF

T. BRIAN ALMON

PUC DOCKET

DESCRIPTION NUMBER

48668 Joint Application of Sharyland Utilities, L.P. and City of Lubbock Acting by and through Lubbock Power & Light for a Certificate of Convenience and Necessity for the Proposed Abernathy to Wadsworth 345 kV Transmission Line in Hale and Lubbock Counties, Texas [Direct Testimony — Route Selection] (March 13, 2019)

48625 Joint Application of Sharyland Utilities, L.P. and City of Lubbock Acting by and through Lubbock Power & Light for a Certificate of Convenience and Necessity for the Proposed Ogallala to Abernathy 345 KV Transmission Line in Castro, Hale, and Swisher Counties, Texas [Direct Testimony — Route Selection] (February 15, 2019) [Rebuttal Testimony — Route Selection] (March 22, 2019)

46429 Application of Brazos Electric Power Cooperative, Inc. for Amendment to its Certificate of Convenience and Necessity for a 138-kv Transmission Line in Collin County [Direct Testimony - Route Adequacy] (March 3, 2017) [Direct Testimony — Route Selection] (April 28, 2017) [Rebuttal Testimony — Route Selection] (June 13, 2017)

46042 Application of Southwestern Public Service Company to Amend its Certificate of Convenience and Necessity for a Proposed 345-KV Transmission Line within Hale, Hockley, Lubbock, Terry, and Yoakum Counties (TUCO to Yoakum) [Direct Testimony — Route Selection] (December 5, 2016) [Rebuttal Testimony — Route Selection] (December 16, 2016)

45170 Application of Brazos Electric Power Cooperative, Inc. to Amend a Certificate of Convenience and Necessity for a 138-kV Double Circuit Transmission Line in Collin and Denton Counties [Direct Testimony — Route Selection] (February 22, 2016)

44837 Application of AEP Texas Central to Amend a Certificate of Convenience and Necessity for a Proposed 138-kV Transmission Line in Bee County and Goliad County, Texas [Direct Testimony — Route Selection] (December 7, 2015)

[Rebuttal Testimony — Route Selection] (February 2, 2016)

44547 Application of Centerpoint Energy Houston Electric, LLC to Amend a Certificate of Convenience and Necessity for a Proposed 345-kV Transmission Line Within Grimes, Harris, and Waller Counties [Direct Testimony — Route Adequacy] (June 15, 2015) [Direct Testimony — Route selection] (July 13, 2015) [Rebuttal Testimony — Route selection] (July 31, 2015)



43878 Application of Brazos Electric Power Cooperative, Inc. To Amend a Certificate of Convenience and Necessity for a 138-kV Double Circuit Transmission Line in Collin and Denton Counties [Direct Testimony — Route selection] (July 26, 2015)

43599 Application of LCRA Transmission Services Corporation to Amend its Certificate of Convenience and Necessity for the Proposed Blumenthal Substation and 138-KV Transmission Line Project in Blanco, Gillespie, and Kendall Counties, Texas [Direct Testimony — Route selection] (April 6, 2015)

41606 Joint Application of Electric Transmission Texas, LLC and Sharyland Utilities to Amend its Certificate of Convenience and Necessity for the North Edinburg to Loma Alta Double-Circuit 345-KV Transmission Line in Hidalgo and Cameron Counties, Texas [Direct Testimony — Route adequacy] (September 17, 2013)

38743 Application of Electric Transmission Texas, LLC to Amend its Certificate of Convenience and necessity for the Tesla to Edith Clarke to Clear Crossing to West Shackelford 345-kV CREZ Transmission Line in Childress, Cottle, Hardeman, Foard, Knox, Hasdell, Jones, and Shackelford Counties [Direct Testimony — Route selection] (January 7, 2011)

38480 Application of Texas-New Mexico Power Company for Authority to Change Rates [Direct Testimony — Self-insurance & storm hardening] (November 15, 2010)

38354 Application of LCRA Transmission Services Corporation to Amend its Certificate of Convenience and Necessity for the McCamey D to Kendall to Gillespie 345-kV CREZ Transmission Line in Schleicher, Mason, Gillespie, Kerr and Kendall Counties [Direct Testimony — Route Selection (October 11, 2010)

38339 Application of CenterPoint Energy Houston, LLC for Authority to Change Rates [Direct Testimony — Self-insurance] (September 17, 2010)

38230 Application of Lone Star Transmission, LLC for a Certificate of Convenience and Necessity for the Central A to Central C to Sam Smith/Navarro Proposed CREZ Transmission Line [Direct Testimony — Route Selection] (August 26, 2010)

38361 Application of El Paso Electric Company to Reconcile Fuel Costs (Severed from PUC Docket 37690) [Direct Testimony — Recovery of Mine Closing Costs] (July 16, 2010)



37744 Application of Entergy Texas, Inc. For Authority to Change Rates and Reconcile Fuel Costs [Direct Testimony — Coal supply for Nelson 6 power plant and third-party power contract] (June 16, 2010)

37162 Application of Southwestern Electric Power Company for Authority to Reconcile Fuel Costs [Direct Testimony — Performance of Pirkey and Dolet Hills power plants] (May 13, 2010)

37448 Application of LCRA Transmission Services Corporation to Amend its Certificate of Convenience and Necessity for the Gillespie to Newton 345-kV CRES Transmission Line in Gillespie, Llano, San Saba, Burnet, and Lampasas Counties, Texas [Direct Testimony — Route Selection] (January 20, 2010)

36025 Application of Texas-New Mexico Power Company for Authority to Change Rates [Direct Testimony — Self-insurance] (June 3, 2009)

35665 Commission Staff s Petition for Selection of Entities Responsible for Transmission Improvements Necessary to Deliver Renewable Energy from Competitive Renewable Energy Zones [Direct Testimony — Assignment of TSP for CREZ Projects] (October 28, 2008) [Rebuttal Testimony — Priority & default projects and proposed joint venture] (November 14, 2008)

35763 Application of Southwestern Public Service Company for Authority to Change Rates, to Reconcile Fuel and Purchased Power Costs for 2006 and 2007, and to Provide a Credit for Fuel Cost Savings [Direct Testimony — Storm restoration and reserve amount] (October 21, 2008)

34800 Application of Entergy Gulf States, Inc. for Authority to Change Rates and to Reconcile Fuel Costs [Direct Testimony — Revenue Requirement and Fuel Phases] (April 18, 2008)

34077 Joint Report and Application of Oncor Electric Delivery Company and Texas Energy Future Holdings Limited Partnership Pursuant to PURA §14.101 [Direct Testimony — Reliability Standard] (September 21, 2007) [Direct Testimony — Support of Stipulation] (October 24, 2007)

33672 Commission Staff s Petition for Designation of Competitive Renewable Energy Zones



[Direct Testimony — Designation of CREZ in Texas] (April 24, 2007) [Rebuttal Testimony — Designation of CREZ in Texas] (May 21, 2007) [Corrected Direct and Rebuttal Testimony] (June 4, 2007)

33309 Application of AEP Texas Central Company for Authority to Change Rates [Direct Testimony — Self Insurance Plan and Catastrophe Reserve] (March 23, 2007)

32766 Application of Southwestern Public Service Company for: (1) Authority to Change Rates; (2) Reconciliation of its Fuel Costs for 2004 and 2005; (3) Authority to Revise the Semi-Annual Formulae Originally Approved in Docket No. 27751 Used to Adjust its Fuel Factors; and (4) Related Relief [Direct Testimony — Coal Issues] (January 12, 2007)

32018 Notice of Violation by TXU Electric Delivery of PURA §38.005, Relating to Electric Service Reliability Measures and P.U.C. Subst. R. 25.52, Relating to Reliability and Continuity of Service [Direct Testimony — Appropriate Penalty] (July 13, 2006)

31824 Application of the Electric Reliability Council of Texas for Approval of the ERCOT System Administrative Fee [Direct Testimony — Review of Technical Expenditures] (January 23, 2006)

31064 Application of AEP Texas North Company and Taylor Electric Cooperative, Inc. for Clarification of Service Area Boundary in Taylor County [Direct Testimony — Boundary Determination] (November 8, 2005)

30143 Petition of El Paso Electric Company to Reconcile Fuel Costs [Direct Testimony — Purchased Power and Off-system Sales] (March 2, 2005)

29801 Application of Southwestern Public Service Company for Reconciliation of its Fuel Costs for 2002 and 2003, A Finding of Special Circumstances and Related Relief [Direct Testimony — Coal Inventory and Wheeling Expenses] (November 2, 2004)

28813 Petition to Inquire into the Reasonableness of the Rates and Services of Cap Rock Energy Corporation [Direct Testimony — Funding Catastrophe Reserve] (September 13, 2004)

29526 Application of Centerpoint Energy Houston Electric LLC, Reliant Energy Retail Services, LLC and Texas Genco LP to Determine Stranded Costs and Other True-Up Balances Pursuant to PURA §39.262 [Direct Testimony — Environmental Cleanup Costs]



(June 7, 2004)

28906 Application of LCRA Transmission Services Corporation to Change Rates [Direct Testimony — Allowable expenses and post test-year adjustments] (May 11, 2004)

29206 Application of Texas-New Mexico Power Company, First Choice Power, Inc. and Texas Generating Company, LP., To Finalize Stranded Costs Under PURA §39.262 [Direct Testimony — Price re-determination of lignite price] (April 2, 2004)

28840 Application of AEP Texas Central Company for Authority to Change Rates [Direct Testimony — Plant in Service] (February 17, 2004)

28045 Application of Southwestern Electric Power Company for Authority to Reconcile Fuel Costs [Direct Testimony — Reasonable and Necessary Expenses and Prudent Management] (November 12, 2003)

27576 Application of Texas-New Mexico Power Company for Reconciliation of Fuel Costs [Direct Testimony — Price predetermination & alternate fuels] (July 25, 2003)

26194 Petition of El Paso Electric Company to Reconcile Fuel Costs [Direct Testimony — Necessary Expenses and Off-System Sales] (April 24, 2003)

26195 Joint Application of Texas Genco, LP and Centerpoint Energy Houston Electric, LLC to Reconcile Eligible Fuel Revenues and Expenses Pursuant to Subst. R. 25.236 [Direct Testimony — Recovery of Post-Mine Reclamation Cost] (January 7, 2003)

25778 Emergency Complaint of Henry A. Miller, Et Al. Against American Electric Power Company and Request for an Emergency Cease and Desist Order [Direct Testimony — Issues related to Ordering Paragraphs in Docket No. 21741] (August 20, 2002)

24835 Petition of Reliant Energy, Incorporated for Approval of Environmental Cleanup Costs Plan [Direct Testimony — Technical Issues of Application] (January 15, 2002)

20314 Application of Hino Electric Power Company for a Certificate of Convenience and Necessity in Cameron, Willacy, and Hidalgo Counties [Direct Testimony — Technical Issues of Application] (October 25, 2001)



20125 Application of Beaumont Power & Light Company for a Certificate of Convenience and Necessity in Jefferson County, Texas [Direct Testimony — Technical Issues of Application] (October 25, 2001)

19950 Application of Corpus Christi Power & Light Company for a Certificate of Convenience and Necessity in Nueces and San Patricio Counties [Direct Testimony — Technical Issues of Application] (October 25, 2001)

23550 Application of Entergy Gulf States, Inc. for the Authority to Reconcile Fuel Costs [Direct Testimony — Nuclear PBR and Outage] (July 13, 2001)

23477 Application of West Texas Utilities Company for the Authority to Reconcile Fuel Costs [Direct Testimony — Fuel Purchases] (August 20, 2001)

22356 Application of Entergy Gulf States, Inc. for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public utility Commission Substantive Rule §25.344 [Direct Testimony — Environmental Cleanup Cost Recovery] (January 16, 2001)

22355 Application of Reliant Energy Incorporated for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public Utility Commission Substantive Rule §25.344 [Direct Testimony — Transmission and Distribution Capital Expenditures] (December 18, 2000)

22350 Application of TXU Electric Company for Approval of unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public Utility Commission Substantive Rule §25.344 [Direct Testimony — Environmental Cleanup Cost Recovery] (October 13, 2000)

22352 Application of Central Power and Light Company for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public Utility Commission Substantive Rule §25.344 [Direct Testimony - Environmental Cleanup Cost Recovery] (October 6, 2000)

22344 Generic Issues Associated with Application for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.210 and Public Utility Commission Substantive Rule §25.344 [Direct Testimony — O&M Escalators] (July 27, 2000) [Rebuttal Testimony](August 3, 2000) [Errata for Direct](August 3, 2000)

17525 Application of Southwestern Public Service Company for Certification of Qualifying Facility Purchased Power Contract under Section 2.209 of PURA 95



[Direct Testimony — Fuel Price Risk (August 19. 1997)

16628 Petition of the Lower Colorado River Authority to Reconcile its Fuel Revenues and Expenses and For Other Relief [Direct Testimony — Coal, Gas, Oil & Purchased Power Reconciliation] (May 8, 1997)

15195 Application of Texas Utilities Electric Company for a Reconciliation of Fuel Costs [Direct Testimony — Mine Productivity (October 7, 1996)

14965 Application of Central Power and Light Company for Authority to Change Rates and Reconcile Fuel Costs [Direct Testimony — Fuel PBR in Competitive Issues Phase] (July 18, 1996)

15102 Application of Gulf States Utilities Company to Reconcile Its Fuel Costs, for Permission to Delay Requesting a Surcharge, or in the Alternative, for a Surcharge to Recover Under-recovered Fuel Expense [Direct Testimony — Reconciliation of Fossil Fuel] (July 8, 1996)

14893 Petition of Sam Rayburn G & T Electric Cooperative, Inc. for Authority to Change Rates [Direct Testimony — Coal Inventory, Non-reconcilable and Eligible Fuel Expense] (January 18, 1996)

14499 Petition of Southwestern Public Service Company for Findings of Special Circumstances and For Associated Waivers [Direct Testimony] (November 21, 1995)

12065 Complaint of Kenneth D. Williams against Houston Lighting & Power Company [Direct Testimony — Trinity Mine Investment] (November 29, 1994)

12820 Petition of the General Counsel for and Inquiry into the Reasonableness of the Rates and Services of Central Pore and Light Company [Direct Testimony — Plant Held for Future Use] (October 17, 1994)

12855 Application of Southwestern Electric Power Company to Reconcile Fuel Costs and Request for Accounting Order [Direct Testimony — Coal Issues] (August 10, 1994) [Supplemental Testimony] (August 29, 1994)



11520 Petition of the General Counsel for an Inquiry into the Reasonableness of Rates and Services of Southwestern Public Service Company [Direct Testimony — Revenue Requirement Phase] (July 29, 1993)

11735 Application of Texas Utilities Electric Company for Authority to Change Rates [Direct Testimony — Fuel Phase] (July 13, 1993) [Direct Testimony — Revenue Requirement Phase (July 13, 1993

11292 Application of Entergy Company and Gulf States Utilities Company for Sale, Transfer, or Merger [Direct Testimony — Fuel Price Forecast (January 8, 1993) [Surrebuttal Testimony] (February 12, 1993)

10894 Application of Gulf States Utilities Company to Reconcile Fuel Costs, Establish New Fixed Fuel Factors, and Recover its Under-recovered Fuel Expenses [Direct Testimony — Fuel Price Forecast, Fuel Reconciliation] (August 28, 1992)

11011 Petition of Southwestern Public Services Company for a Fuel Reconciliation [Direct Testimony — Fuel Reconciliation] (August 4, 1992)

10982 Application of Sam Rayburn G&T Electric Cooperative, Inc. for Authority to Change Rates [Direct Testimony — Purchase Power, Non-reconcilable Fuel Expenses, Fuel Price Forecast, Fuel Inventory, Fuel Reconciliation] (June 3, 1992)

10092 Petition of Houston Lighting & Power Company for Reconciliation of Fuel Costs [Direct Testimony — Fuel Reconciliation] (March, 1991) [Supplemental Testimony] (June21, 1992)

10200 Application of Texas-New Mexico Power Company for Authority to Change Rates, Prudence Phase [Direct Testimony — Fuel Inventory, Fuel Price Forecast] Prudence (November 8, 1991) Revenue Requirement (December 13, 1991) Fuel (December 13, 1991)

9850 Petition of Houston Lighting & Power Company for Authority to Change Rates [Direct Testimony — Fuel Inventory, Depreciation, Non-reconcilable Fuel Expenses] (February 19, 1991)

9300 Application of Texas Utilities Electric Company for Authority to Change Rates [Direct Testimony — Fuel Reconciliation]



(June, 1990)

9030 Petition of the General Counsel for a Fuel Reconciliation for Southwestern Public Service Company [Direct Testimony — Fuel Reconciliation] (May, 1990)

9561 Application of Central Power and Light Company for Authority to Change Rates [Direct Testimony — Fuel Reconciliation, Fuel Price Forecast, Fuel Inventory] (August, 1990)

9491 Application of Texas-New Mexico Power Company for Authority to Change Rates [Direct Testimony — Fuel Price Forecast, Fuel Inventory] (July, 1990)

9427 Application of Lower Colorado River Authority for Authority to Change Rates [Direct Testimony — Prudence of Cummins Creek] (July, 1990)

8900 Petition of the General Counsel for a Fuel Reconciliation for Southwestern Electric Power Company [Direct Testimony — Coal and Lignite Reconciliation] (January, 1990) [Supplemental Testimony] (January, 1990)

8646 Petition and Statement of Intent of Central Power and Light Company to Change Rates [Direct Testimony — Fuel Reconciliation, Fuel Management, Coal Inventory, Coal Price Forecast, Non-reconcilable Fuel Expenses, Plant Held for Future Use] (May — December, 1989)

8595 Application of Sam Rayburn G & T Electric Cooperative, Inc. for Authority to Change Rates [Direct Testimony — Fuel Reconciliation, Non-reconcilable Fuel Expenses, Fuel Price Forecast] (April, 1989)

8588 Application of El Paso Electric Company for Reconciliation of Fuel [Direct Testimony — Fuel Reconciliation] (August, 1989)

8425 Petition of Houston Lighting & Power Company for Authority to Change Rates, Phases I & II [Direct Testimony — Fuel Reconciliation. Non-reconcilable Fuel Expenses] (March, 1989)

8400 Application of Lower Colorado River Authority to Change Rates [Direct Testimony — Fuel Reconciliation, Non-reconcilable Fuel Expenses, Fuel Price Forecast, Prudence Review] (March, 1989)



6692 Application of Texas-New Mexico Power Company for Certification of a Lignite-Fired Generation Station in Robertson County, Texas (Remand) [Direct Testimony — Fuel Price Forecast] (June, 1990)

8095 Application of Texas-New Mexico Power Company for Authority to Change Rates [Direct Testimony - Purchased Power Expenses] (July, 1988)

8280 Application of Southwestern Electric Power Company for Authority to Increase Interim Fixed Fuel Factors [Direct Testimony - Fuel Price Forecast] (November, 1988)

8328 Petition of West Texas Utilities Company for Order to Increase Fixed Fuel Factors [Direct Testimony - Fuel Price Forecast] (November, 1988)



EXHIBIT BA-3 Comparison of Routes SNO 2 and 9

Evaluation Criteria SNO 2 SNO 9 COST 49,726 51,936

1 Length of alternative route (miles) 15.1 17.8

2 Number of habitable structures' within 300/500 feet of route centerline

127 123

3 Number of newly affected habitable structures2 within 300/500 feet of ROW centerline

113 109

4 Length of route utilizing existing electric transmission line ROW

0 0

5 Length of route parallel to existing transmission line ROW

2.1 2.1

6 Length of route parallel to other existing compatible ROW (highways, roads, railways, etc.)

7.3 11.9

7 Length of route parallel to apparent property lines3

5.1 0.01

8 Length of route parallel to pipeline ROW 0 0

g Length of route through parks and/or recreational areas4

0 0

10 Number of parks/recreational areas4 crossed by route centerline

0 0

11 Number of additional parks/recreational areas4 within 1,000 feet of route centerline

0 0

12 Length of route through cropland 11.4 13.6

13 Length of route through land irrigated by traveling systems (rolling or pivot type)

1.5 1.2

14

Length of route through pasture/rangeland (including Conservation Reserve Program lands)

3.2 3.8

15 Number of aqueduct crossings 2 2

16 Number of pipeline crossings 8 20

17 Number of transmission line crossings

4 4



18 Number of Interstate, U.S. and State Highway (IH, U.S. Hwy and SH) crossings

1 1

19 Number of farm-to-market (FM) and/or ranch-to-market (RM) road crossings

2 4

20 Number of cemeteries within 1,000 feet of the route centerline

0 0

21

Number of FAA registered airports5 with at least one runway more than 3,200 feet in length located within 20,000 feet of route centerline

1 1

22

Number of FAA registered airports5 having no runway more than 3,200 feet in length located within 10,000 feet of route centerline

0 0

23 Number of private airstrips within 10,000 feet of the route centerline

1 1

24 Number of heliports within 5,000 feet of the route centerline

0 0

25 Number of commercial AM radio transmitters within 10,000 feet of the route centerline

1 1

26

Number of FM radio transmitters, microwave towers, and other electronic installations within 2,000 feet of route centerline

3 2

27 Number of existing water wells within 200 feet of the route centerline

36 30

28 Number of existing oil and gas wells within 200 feet of the route centerline

0 0

Aesthetics

29

Estimated length of ROW within foreground visual zone6 of Interstate, U.S. and State Highways

7.2 7.6

30

Estimated length of ROW within foreground visual zone6 of farm-to-market and/or ranch-to-market roads

5.7 3.5

31 Estimated length of ROW within foreground visual zone6 of parks and/or recreational areas4

0.0 0.0

Ecology

32 Length of ROW through upland woodlands

0.002 0.01

33 Length of ROW through bottomland and/or riparian woodlands

0.0 0.0

Direct Testimony of T. Brian Almon

Page 35


34 Length of route across mapped National Wetlands Inventory (NWI) wetlands and Playa Lakes

0.1 0.1

35 Length of ROW across known prairie dog towns

0.1 0.1

36 Length of ROW across known habitat of federally listed endangered or threatened species

0 0

37 Length of route across open water (lakes, ponds, etc.)

0 0

38 Number of stream and/or river crossings

0 0

39 Length of ROW parallel (within 100 feet) to streams or rivers

0 0

40

Length of route across Federal Emergency Management Agency (FEMA) mapped100-year floodplains7

0.1 0.1

Cultural Resources

41 Number of recorded historic or prehistoric sites crossed by route

1 1

42 Number of additional recorded historic or prehistoric sites within 1,000 feet of route centerline

4 3

43 Number of National Register listed or determined-eligible sites crossed by route centerline

0 0

44

Number of additional National Register listed or determined-eligible sites within 1,000 feet of route centerline

0 0

45 Length of ROW across areas of high archeological and/or historical site potential

3.1 3.7



EXHIBIT BA-4 Comparison of Route Combinations

Criteria with zero value not included on Exhibit

ROUTE COMBINATIONS

9 & 20

2 & 7

2 & 6

COST 140,343 139,491 141,557

1 Length of alternative route (miles) 59.80 59.00 60.4

2 Number of habitable structures1 within 500 feet of route centerline 137.00 135.00 134.0

3 Number of newly affected habitable structures2 within 500 feet of ROW centerline 122.00 119.00 118.0

5 Length of route parallel to existing transmission line ROW 2.10 8.60 8.6

6 Length of route parallel to other existing compatible ROW (highways, roads, railways, etc.) 46.70 29.40 32.9

7 Length of route parallel to apparent property lines3 1.81 14.00 13.1

11 Number of additional parks/recreational areas4 within 1,000 feet of route centerline 0.00 0.00 1.0

12 Length of route through cropland 47.70 45.10 46.8

13 Length of route through land irrigated by traveling systems (rolling or pivot type) 2.80 4.00 3.7

14 Length of route through pasture/rangeland (including Conservation Reserve Program lands) 10.40 12.60 12.0

15 Number of Aqueduct crossings 4.00 5.00 5.0

16 Number of pipeline crossings 30.00 19.00 19.0

17 Number of transmission line crossings 12.00 15.00 15.0

18 Number of Interstate, U.S. and State Highway (IH, U.S. Hwy and SH) crossings 4 4 4

19 Number of farm-to-market (FM) and/or ranch-to-market (RM) road crossings 11.00 10.00 10.0

21 Number of FAA registered airports5 with at least one runway more than 3,200 feet in length located viAthin 20,000 feet of route centerline 2.00 3.00 3.0

23 Number of private airstrips within 10,000 feet of the route centerline 2.00 2 CO 2.0

25 Number of commercial AM radio transmitters within 10,000 feet of the route centerline 3.00 3 CC 3.0

26 Number of FM radio transmitters, microwave towers, and other electronic installations within 2,000 feet of route centerline 2.00 3.00 3.0

27 Number of existing water wells within 200 feet of the route centerline 103.00 96.00 115.0

28 Number of existing oil and gas wells within 200 feet of the route centerline 1.00 1.00 2.0

Aesthetics

29 Estimated length of ROW within foreground visual zone6 of Interstate, U.S. and State Highways 21.80 18.60 19.7

30 Estimated length of ROW within foreground visual zone6 of farm-to-market and/or ranch-to-market roads 14.00 11.50 12.0

31 Estimated length of ROW within foreground visual zone6 of parks and/or recreational areas4 0.00 0.00 1.5

Ecology

32 Length of ROW through upland woodlands 0.15 0.09 0.10

33 Length of ROW through bottomland and/or riparian woodlands 0.56 0.20 0.20

Direct Testimony of T. Brian Almon Pagc 37


34 Length of route across mapped National Wetlands Inventory (NWI) wetlands and Playa Lakes 1.10 1.10 1.00

35 Length of ROW across known prairie dog towns 0.40 0.20 0.40

37 Length of route across open water (lakes, ponds, playa lakes, etc.) 0.12 0.02 0.12

38 Number of stream and/or river crossings 2.00 2.00 2.00

40 Length of route across Federal Emergency Management Agency (FEMA) mapped100-year floodplains 1.10

,... : ..

_.2.00

Cultural Resources 41 Number of recorded historic or prehistoric sites crossed by route 1.0 1.0 1.0

42 Number of additional recorded historic or prehistoric sites within 1,000 feet of route centerline 3.0

.• .. • -

45 Length of ROW across areas of high archeological and/or historical site potential 14.5 16 4 18.1

YELLOW — Routes 9 & 20 more favorable than either Routes 2 & 6 or 2 & 7. GREEN — Routes 2 & 6 or Routes 2 & 7 more favorable than Routes 9 & 20. ORANGE — Routes 2 & 6 or Routes 2 & 7 less favorable than Routes 9 & 20. No color — Routes 9 & 20 equal or less favorable than Routes 2 & 6 or 2 & 7.


WORKPAPER JOINT APPLICANTS RESPONSE TO STEVEN HILL'S

SECOND REQUEST FOR INFORMATION

HILL 2-4:

Please confirm that the WNF and SNO transmission lines approved by the Commission need to use the same location for the New Oliver Station. If not, please explain.

Response:

Confirmed.

Preparer: Troy Vaughn Sponsor: Troy Vaughn

Joint Applicants' Response to Steven Hill's Second Request for Information PUC Docket No. 48909/SOAH Docket No. 473-19-2405

6 Direct Testimony of T. Brian Almon Page 39

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