APPLICATION FOR APPROVAL AND CERTIFICATION OF ELECTRICAL TRANSMISSION LINE

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3 APPALACHIAN POWER COMPANY BEFORE THE VIRGINIA STATE CORPORATION COMMISSION CASE NO. PUE APPLICATION FOR APPROVAL AND CERTIFICATION OF ELECTRICAL TRANSMISSION LINE Bland Area Improvements 138 kv Transmission Line Rebuild Project VOLUME 1 OF 2 Application, Testimony & Response to Guidelines September, 2015

4 CONTENTS Bland Area Improvements 138 kv Transmission Line Rebuild Project VOLUME 1 - Application, Testimony, & Response to Guidelines LIST OF EXHIBITS, MAPS AND ATTACHMENTS GLOSSARY OF TERMS & ABBREVIATIONS EXECUTIVE SUMMARY APPLICATION TESTIMONY Direct Testimony of Evan R. Wilcox, P.E. (Project Need) Direct Testimony of Timothy B. Earhart, P.E. (Project Engineering) Direct Testimony of Richard Gutman, P.E. (EMF) Direct Testimony of Timothy B. Gaul (Siting and Environmental) RESPONSE TO GUIDELINES Section I. Necessity for the Proposed Project Section II. Description of the Proposed Project Section III. Impact of Line on Scenic, Environmental, and Historic Features Section IV. Health Aspects of EMF Section V. Notice EXHIBITS VOLUME 2 - Route Selection Study ( RSS ) and DEQ Supplement LIST OF EXHIBITS, MAPS & ATTACHMENTS ROUTE SELECTION STUDY RSS Maps RSS Attachments DEQ SUPPLEMENT DEQ Attachments i

5 LIST OF EXHIBITS, MAPS & ATTACHMENTS Bland Area Improvements 138 kv Transmission Line Rebuild Project VOLUME 1 EXHIBITS EXHIBIT 1: EXHIBIT 2: EXHIBIT 3: EXHIBIT 4: EXHIBIT 5: EXHIBIT 6: EXHIBIT 7: EXHIBIT 8: EXHIBIT 9: EXHIBIT 10: EXHIBIT 11: EXHIBIT 12: EXHIBIT 13: EXHIBIT 14: GENERAL LOCATION MAP PUBLIC NOTICE MAP GENERAL HIGHWAY MAP & EXISTING TRANSMISSION FACILITIES (BLAND AND WYTHE COUNTIES) PRESENT TRANSMISSION SYSTEM GIS CONSTRAINTS MAP SET EXISTING 69 KV STRUCTURES AND CONTEXT PHOTOGRAPH SET PROPOSED 138 KV TRANSMISSION STRUCTURES PROPOSED REBUILD VISUAL SIMULATIONS EXISTING BLAND SUBSTATION (TO BE RETIRED) EXISTING WYTHE SUBSTATION (NO IMPROVEMENTS) PROPOSED PROGRESS PARK SUBSTATION IMPROVEMENTS PROPOSED TOWN CREEK SUBSTATION PUBLIC OPEN HOUSE PHOTOGRAPHS MEMORANDUM OF UNDERSTANDING BETWEEN APPALACHIAN AND THE U.S. FOREST SERVICE (NOVEMBER, 2003) VOLUME 2 RSS MAPS MAP 1: MAP 2: MAP 3: MAP 4: MAP 5: MAP 6: MAP 7: MAP 8: MAP 9: MAP 10: MAP 11: MAP 12: EXISTING SOUTH BLUEFIELD-WYTHE 69 KV LINE STUDY AREA STUDY SEGMENT NETWORK ALTERNATIVE SEGMENT NETWORK ALTERNATIVE SEGMENTS IN NORTH FOCUS AREA ALTERNATIVE SEGMENTS IN CENTRAL FOCUS AREA ALTERNATIVE SEGMENTS IN SOUTH FOCUS AREA WATER RESOURCES IN NORTH FOCUS AREA WATER RESOURCES IN CENTRAL FOCUS AREA WATER RESOURCES IN SOUTH FOCUS AREA LAND USE IN NORTH FOCUS AREA LAND USE IN CENTRAL FOCUS AREA ii

6 LIST OF EXHIBITS, MAPS & ATTACHMENTS Bland Area Improvements 138 kv Transmission Line Rebuild Project MAP 13: MAP 14: MAP 15: MAP 16: LAND USE IN SOUTH FOCUS AREA RECREATION AND AESTHETICS CULTURAL RESOURCES PREFERRED ROUTE RSS ATTACHMENTS ATTACHMENT 1: ROUTING TEAM ATTACHMENT 2: GIS DATA SOURCES ATTACHMENT 3: AGENCY CONTACTS DEQ SUPPLEMENT ATTACHMENTS ATTACHMENT 2.A.1: VMRC RESPONSE ATTACHMENT 2.B.1: DEQ DESKTOP WETLAND DELINEATION REPORT ATTACHMENT 2.C.1: HAZARDOUS WASTE INFORMATION ATTACHMENT 2.D.1: VDCR, VDGIF, AND USFWS LETTERS ATTACHMENT 2.E.1: VDHR HISTORIC RESOURCES PRE APPLICATION REPORT ATTACHMENT 2.F.1: VDCR KARST PROGRAM CORRESPONDENCE ATTACHMENT 2.G.1: VDOT LETTER iii

7 Bland Area Improvements GLOSSARY OF TERMS & ABBREVIATIONS 138 kv Transmission Line Rebuild Project ACSR ACSS AEP AEPSC Appalachian APE Application Approx. BMP Circuit cmil Commission Company CPCN DEQ DEQ Supplement EDR EHV ELF EMF EPRI FAA FERC GESCS GIS HV ICNIRP IEEE kv kv/m Line mg MVA MW MOA or MOU NEPA NERC NESC NRHP OATT OPGW OWWP Aluminum Conductor Steel Reinforced Aluminum Conductor Steel Supported American Electric Power Company, Inc.(parent company of Appalachian) American Electric Power Service Corporation Appalachian Power Company (a unit of AEP) Area of Potential Effect Collectively refers to the application requesting Commission approval for the proposed Project, together with all of the supporting testimony, Response to Guidelines, DEQ Supplement, tables, exhibits, attachments, figures and maps, etc. Approximately Best Management Practice An electrical connection between two substations located along a Line route. A transmission line sometimes holds two circuits (double-circuit line). Circular mil (conductor size) Virginia State Corporation Commission Appalachian Power Company (a unit of AEP) Certificate of Public Convenience and Necessity Virginia Department of Environmental Quality The analysis included in Volume 2 of this application which addresses the environmental and historic features associated with the Project. Environmental Data Review, Inc. Extra High Voltage Extremely Low Frequency Electric and Magnetic Fields Electric Power Research Institute Federal Aviation Administration Federal Energy Regulatory Commission General Erosion and Sediment Control Specifications Geographic Information System High Voltage International Commission on Non-ionizing Radiation Protection Institute of Electrical and Electronics Engineers Kilovolt (1,000 volts) Kilovolt/Meter (a unit of measurement for electric fields) Transmission Line or Power Line Milligauss (a unit of measurement for magnetic fields) Mega Volt Ampere Megawatts Memorandum of Agreement or Understanding National Environmental Policy Act North American Electric Reliability Corporation National Electrical Safety Code National Register of Historic Places PJM Open Access Transmission Tariff Optical Ground Wire DEQ Office of Wetlands & Water Protection iv

8 Bland Area Improvements GLOSSARY OF TERMS & ABBREVIATIONS 138 kv Transmission Line Rebuild Project PJM Project Response to Guidelines ROW ROWs RTO SCC SUP USEPA USFWS USFS USGS VDCR VDGIF VDH VDHR VDMME VDOA VDOF VDOT VLR VMRC VNHP VOF WHO PJM Interconnection, L.L.C. - the RTO that coordinates the movement of wholesale electricity in parts of the Northeast, Mid-Atlantic and Midwest. The Virginia portion of the South Bluefield Town Creek Progress Park 138 kv Transmission Line and the Town Creek Response to Guidelines of Minimum Requirements for Transmission Line Applications Filed under Virginia Code Section and The Utility Facilities Act issued by the Commission s Division of Energy Regulation on May 10, Right-of-Way (Typically, the ROW will be 100 feet wide. However, the ROW could be more than 100 feet wide in a few locations, as needed to accommodate guy wires and to ensure compliance with safety requirements in certain conductor blow-out conditions.) Rights-of-Way Regional Transmission Organization Virginia State Corporation Commission Special Use Permit United States Environmental Protection Agency U.S. Fish and Wildlife Service United States Forest Service United States Geological Survey Virginia Department of Conservation and Recreation Virginia Department of Game & Inland Fisheries Virginia Department of Health Virginia Department of Historic Resources Virginia Department of Mines, Minerals and Energy Virginia Department of Aviation Virginia Department of Forestry Virginia Department of Transportation Virginia Landmarks Register Virginia Marine Resources Commission Virginia Natural Heritage Program Virginia Outdoors Foundation World Health Organization v

9 EXECUTIVE SUMMARY Bland Area Improvements 138 kv Transmission Line Rebuild Project Existing Typical Structure Steel Lattice Towers - approximately 55 tall. Proposed Typical Structures Steel H-Frame and Guyed-V Structures - approximately 90 to 100 tall (see Exhibit 7 to view all proposed structures). Appalachian Power Company (Appalachian), a unit of American Electric Power Company, Inc. (AEP), is seeking approval of the Virginia portions of certain system upgrades and improvements to enhance system reliability and operational flexibility for areas in Bland, Tazewell, and Wythe Counties, Virginia, and Mercer County, West Virginia (such Virginia portions, the "Project"). In general, the Project consists primarily of: (a) the 25.2 mile rebuild of the existing 90 year old South Bluefield Bland Wythe 69 kv line to 138 kv, and (b) replacement of Appalachian's existing Bland 69 kv in Bland County, Virginia, with a new Town Creek 138 kv in order to accommodate the rebuilt line. Over 80%of the rebuild will be either located in the existing 69 kv line right-of-way ( ROW ) (15.8 miles) or adjacent to existing transmission line ROW (5.1 miles). The estimated cost of the Project is approximately $68 million. The rebuild is needed prior to the winter peak loading season. Construction would begin in early The existing South Bluefield Bland Wythe 69 kilovolt (kv) line (see Exhibit 1 and 6), built in 1925, has reached the end of its useful life and must be rebuilt. To serve the growing population and development in the area, the 69 kv line will be rebuilt as a robust 138 kv line. The rebuild will also address thermal and voltage deviation and magnitude reliability criteria violations predicted to occur in 2018, provide enhanced system reliability and operational flexibility, and allow for future economic development in the area. Additionally, the rebuild addresses Appalachian's obligation pursuant to a 2003 Memorandum of Understanding with the U.S. Forest Service to relocate the existing 69 kv line crossing of National Forest land on Rich Mountain. Finally, the Rebuild provides an additional power source to the Progress Park in Wythe County. vi

10 EXECUTIVE SUMMARY Bland Area Improvements 138 kv Transmission Line Rebuild Project The majority of the 25.2 mile Virginia portion of the rebuilt line will be constructed in the existing 69 kv 100-foot ROW, which generally follows Interstate 77 in a north-south direction between Bluefield, West Virginia and Wytheville, Virginia. The rebuilt line, however, departs from the existing ROW in Virginia in three locations for a total of 9.4 miles due to (a) the relocation of the existing 69 kv line crossing of Rich Mountain (the "Rich Mountain Relocation"), (b) the relocation to connect with the new Town Creek (the "Town Creek Relocation"), which will replace the existing Bland 69 kv in order to accommodate the rebuilt line, and (c) the relocation to accommodate the change in the southern terminus of the rebuilt line from the existing Wythe to the existing Progress Park (the "Progress Park Relocation")(see Exhibit 1, page 2 of 2, and Exhibit 5, in Volume 1 of this Application). Appalachian retained the Louis Berger Group, Inc. ( LB ) as its routing and environmental consultant to review the rebuild segments, develop alternative segments at the relocation areas and complete a Route Selection Study ( RSS ), included in Volume 2 of this Application. The Company supports LB s conclusion that the identified Preferred Route (see Exhibit 5 in Volume 1 of this Application) is the superior route. As supported by the RSS, the Preferred Route reasonably avoids or minimizes adverse impacts on the scenic assets, historic districts and environment of the area concerned. For these reasons and others described in this Application, Appalachian will be able to acquire ROW, engineer, build, operate, and maintain the proposed project along the Preferred Route efficiently and effectively, while minimizing overall environmental impact. In contrast, the rejected alternative segments would impact more residences, conflict to a greater degree with existing and future land use, and require greater line length and number of transmission line structures, all of which result in additional environmental impact, inconvenience to landowners and cost. See Section II.A.7 of the Response to Guidelines (in Volume 1 of this Application) and the RSS (in Volume 2 of this Application) for further description of the environmental assessment, siting analysis, and methods. vii

11 COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION APPLICATION OF APPALACHIAN POWER COMPANY CASE NO. PUE for Approval and Certification of the Bland Area Improvements 138 kv Transmission Line Rebuild Project under Title 56 of the Code of Virginia APPALACHIAN POWER COMPANY ("Appalachian" or the "Company"), a corporation duly organized and existing under the laws of the Commonwealth of Virginia, represents as follows: 1. Appalachian is a Virginia public service corporation providing electric service in Virginia and West Virginia and having an address of P.O. Box 2021, Roanoke, Virginia The Company proposes to construct, own, operate and maintain the Bland Area Improvements 138 kv Transmission Line Rebuild Project, which consists generally of rebuilding an obsolete 69 kv subtransmission line (built in 1925 and located primarily in Bland County, Virginia with the remainder located in Wythe County, Virginia and a small portion in Mercer County, West Virginia) as a robust new 138 kv transmission line. The rebuilt line will be referred to in its entirety as the South Bluefield Town Creek Progress Park 138 kv Transmission Line. The entire project (including the Virginia and West Virginia components, as well as the associated substation improvements described below) is referred to hereinafter as the "Rebuild." The Virginia components of the Rebuild are referred to hereinafter as the "Project." The proposed South Bluefield Town Creek Progress Park 138 kv Transmission Line will be

12 approximately 26 miles long, with approximately 25.2 miles to be located in Virginia and approximately 0.7 mile to be located in West Virginia. 3. The Project includes the following (see also Exhibit 2): (a) a rebuild of approximately 15.8 miles of the Virginia portion of the existing South Bluefield Bland Wythe 69 kv line to 138 kv; (b) construction of approximately 5.1 miles of 138 kv line in new right-of-way ("ROW"), of which 2.9 miles is parallel to the existing Progress Park 138 kv Extension, to connect the rebuilt line to a new terminus at Appalachian's existing Progress Park located just east of Wytheville; (c) associated substation improvements at Appalachian's existing Progress Park ; (d) construction of approximately 3.3 miles of 138 kv line in new ROW that will depart from the existing 69 kv line ROW near the top of Buckhorn Mountain and run to the southwest to cross Clear Fork Creek Road and then turn south to parallel the existing Rich Mountain crossing of Appalachian's Jacksons Ferry - Wyoming 765 kv Transmission Line and then rejoin the existing 69 kv line ROW just south of Rich Mountain; 1 (e) replacement of Appalachian's existing Bland 69 kv in Virginia with a new Town Creek 138 kv in order to accommodate the rebuilt line; (f) construction of approximately 0.9 mile of new construction in new ROW that will depart to the southeast from the existing 69 kv line ROW just south of the existing travel plaza on U.S. Route 52 and then run south adjacent to I-77 to the proposed new Town Creek and then southwest to reconnect with the existing 69 kv line ROW; and (g) the removal of approximately 6.7 miles of the Virginia portion of the existing South Bluefield Bland Wythe 69 kv line. 1 This deviation from the existing 69 kv line ROW will satisfy Appalachian's commitment to remove the existing 69 kv line crossing of National Forest land on Rich Mountain in accordance with a November, 2003, Memorandum of Understanding between Appalachian and the U.S. Forest Service (the "USFS MOU") in connection with Appalachian's Jacksons Ferry Wyoming 765 kv Transmission Line (previously approved in SCC Case No. PUE970766). See the direct testimony of Company witness Earhart for further description. 2

13 4. The West Virginia components of the Rebuild include rebuilding to 138 kv approximately 0.7 mile of the existing 69 kv line in existing ROW from the West Virginia border to the South Bluefield in Mercer County, West Virginia, as well as associated substation improvements at Appalachian's existing South Bluefield and South Princeton s in Mercer County, West Virginia The Rebuild will ensure adequate and reliable electric service and accommodate future growth in Bland and Tazewell Counties, Virginia, and Mercer County, West Virginia by mitigating thermal and voltage reliability criteria violations projected to affect those areas under certain N-1 and N-1-1 outage scenarios during winter peak loading conditions. The Rebuild will also enhance system reliability by rebuilding an obsolete 90 year old 69 kv line as a robust new 138 kv line. Finally, the Rebuild will satisfy the requirement of the USFS MOU to remove the existing 69 kv line crossing on Rich Mountain. 6. Because the South Bluefield Town Creek Progress Park 138 kv Transmission Line will consist largely of a rebuild of an existing Appalachian 69 kv line, the majority of the Project will be constructed on existing ROW that has been owned and used by Appalachian for about 90 years. However, some supplemental and new ROW easements will be necessary. 7. In support of this application, the Company is filing the testimony of: (a) (b) (c) (d) Evan R. Wilcox as to need; Timothy B. Earhart with regard to engineering characteristics; Richard Gutman regarding electric and magnetic field levels; and Timothy B. Gaul regarding environmental matters and route development. 2 An application for authority to construct the West Virginia portion of the Rebuild in Mercer County, West Virginia will be filed with the Public Service Commission of West Virginia in the near future. 3

14 8. The Company is also filing (a) a Response to Guidelines, responding to the "Guidelines of Minimum Requirements for Transmission Line Application Filed under Virginia Code Section and The Utility Facilities Act" issued by the Commission's Division of Energy Regulation on May 10, 1991; (b) a Route Selection Study and a DEQ Supplement prepared by the Company's environmental consultant, Louis Berger Group, Inc.; and (c) related tables, exhibits, attachments and maps (including digital geographic information system map sets ("GIS Constraints Maps") and GIS shapefiles of the Project on CD-ROM). 9. The Company's testimony, Response to Guidelines, Route Selection Study, DEQ Supplement and related materials filed with this application establish that: (a) The Rebuild is needed and the public convenience and necessity require the construction of the Rebuild by Appalachian; (b) The proposed route for the Project reasonably minimizes adverse impact on the scenic assets, historic districts and environment of the area in which the Project will be located; and (c) The Rebuild will support and facilitate economic development within Bland, Wythe and Tazewell Counties. 10. The proposed in-service date for the Rebuild is December 1, If the Commission approves the Project, the Company estimates that it will need approximately 30 months after entry of the Commission's final approving order for engineering, design, right-ofway acquisition, permitting, material procurement and construction to place the Rebuild in service. Accordingly, the Company asks that the Commission expedite its consideration of this application to the extent permitted under applicable law. The Company therefore requests: 4

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16 Hector Garcia, Esq. (VSB #48304) AMERICAN ELECTRIC POWER SERVICE CORPORATION 1 Riverside Plaza Columbus, OH (614) hgarcia1@aep.com Counsel for Appalachian Power Company 6

17 Exhibit No. Witness: ERW DIRECT TESTIMONY OF EVAN R. WILCOX FOR APPALACHIAN POWER COMPANY IN VIRGINIA S.C.C. CASE NO. PUE Q: Please state your name, position and business address. A: My name is Evan R. Wilcox. I am Director, East Transmission Planning for American Electric Power Service Corporation ( AEPSC ). AEPSC is a subsidiary of American Electric Power, Inc. ( AEP ) that provides corporate support services to the operating subsidiaries of AEP, including Appalachian Power Company ( Appalachian or Company ). My business address is 700 Morrison Road, Gahanna, Ohio Q: Please review your educational background and your work experience. A: I hold a Bachelor of Science degree in Electrical Engineering from The Ohio State University (Columbus, Ohio) and a Master s Degree in Business Administration from Capital University (Columbus, Ohio). I am a licensed professional engineer in the State of Ohio. I joined AEPSC in 2001 as an engineer in the cooperative education program with rotations in Transmission Planning, Protection and Control Engineering, Station Projects Engineering and Transmission Field Services. I served as an engineer in the East Transmission Planning section from that period until 2007 where I performed system planning and generator interconnection studies. In 2007, I moved into the Transmission Strategy and Business Development group where I was responsible for coordination with Regional Transmission Organizations, technical support, and the development of transmission joint-venture business partnerships. In 2010, I was promoted to the position of Manager, Interstate Transmission Planning and was responsible for a group dedicated to performing reliability studies for extra high voltage

18 Exhibit No. Witness: ERW Page 2 of 6 ( EHV ) transmission projects and new economic (market efficiency) planning functions. In 2011, I became Director, East Transmission Planning, where I oversee all transmission planning and project development functions for AEP s eastern states in the PJM region, as well as technical support for AEP s transmission joint ventures in other regions. Q: Mr. Wilcox, what are your responsibilities as related to the proposed project? A: As Director of Transmission Planning, my primary role is to ensure adequate and reliable service to customers served by the AEP transmission and subtransmission (below 138 kv) systems. With respect to this project, I oversee the reliability assessment of the transmission system under normal and contingency conditions; and the development of viable solutions to alleviate identified reliability concerns. Q: What is the purpose of your testimony in this proceeding? A: The purpose of my testimony is to support certain aspects of Appalachian s application to this Commission for approval and certification of the Virginia portions of the Bland Area Improvements 138 kv Transmission Line Rebuild Project (the entire project is hereinafter referred to as the Rebuild ). Q: Which of the specific materials included in the application are you sponsoring? A: I am responsible for Section I of the Response to Guidelines (the "Response to Guidelines") filed by the Company together with its application in response to the Commission Staff's "Guidelines of Minimum Requirements for Transmission Line Applications Filed Under Virginia Code Section and The Utility Facilities Act." I am also responsible for Exhibit 4 to the Response to Guidelines.

19 Exhibit No. Witness: ERW Page 3 of 6 Q: Were the portions of the filing which you are sponsoring prepared by you or under your A: Yes. supervision and direction? Q: Please summarize the need for the Rebuild. A: In order to maintain reliability and to accommodate future load growth, AEP continuously studies the real time performance of its transmission and subtransmission network under projected peak loading conditions. As a result of this continuous assessment process, AEP has identified significant reliability concerns associated with elements of its transmission and subtransmission systems serving customers located in Bland and Tazewell Counties, Virginia and Mercer County, West Virginia. As detailed in Section I of the Response to Guidelines, AEP transmission planning studies indicate that, under projected winter peak loading conditions, thermal overloads and violations of reliability criteria for voltage magnitude and deviation will occur within the affected load area upon the occurrence of certain contingencies. Additionally, the subtransmission system serving these areas includes the 90 year old South Bluefield - Wythe 69 kv line, which is in a physically deteriorated condition commensurate with its age, has no lightning protection (shield wires) and needs to be replaced as it has reached the end of its useful life. Finally, pursuant to a November, 2003, Memorandum of Understanding (the "USFS MOU") between Appalachian and the U.S. Forest Service ("USFS") in connection with Appalachian's Jacksons Ferry - Wyoming 765 kv transmission line (approved in SCC Case No. PUE970766), Appalachian is required to remove the South Bluefield - Wythe 69 kv line's current

20 Exhibit No. Witness: ERW Page 4 of 6 crossing of National Forest land on Rich Mountain when the line reaches the end of its useful life and in any event no later than December 31, 2018 AEP has developed a project to address all of the foregoing issues by rebuilding the obsolete South Bluefield Wythe 69 kv subtransmission line (located primarily in Bland County, Virginia with the remainder located in Wythe County, Virginia and a small portion in Mercer County, West Virginia) as a robust new 138 kv transmission line, together with certain related substation improvements. The related substation improvements include a new Town Creek 138 kv that will replace the existing Bland 69 kv, which is the primary power source for most of Bland County. Q: Mr. Wilcox, please summarize the benefits of the Rebuild. A: The Rebuild will (i) provide a comprehensive solution for the reliability concerns identified in the affected load area in Bland and Tazewell Counties, Virginia and Mercer County, West Virginia, (ii) accomplish the replacement of a 90 year old 69 kv line that has reached the end of its useful life, and (iii) satisfy Appalachian's commitment under the USFS MOU to remove the existing 69 kv line crossing of Rich Mountain. The Rebuild will also improve the capacity of the transmission system in the affected load area to accommodate future load growth and will provide an additional power source to the Progress Park in Wythe County. Q: What effect will the Rebuild have on economic development in the Commonwealth? A: The Rebuild will have a positive effect on economic development within the Commonwealth. The Rebuild will accomplish this by furthering many of the energy

21 1 2 Exhibit No. Witness: ERW Page 5 of 6 objectives listed in Virginia Code 67-01, such as ensuring an adequate and reliable energy supply, establishing sufficient supply and delivery infrastructure to maintain reliable energy availability, and optimizing intrastate use of energy supply and delivery to maximize energy availability and reliability to the benefit of all user classes. Q: What is the estimated cost for the Virginia portion of the Rebuild? A: The estimated cost of the Virginia portions of the Rebuild is approximately $68 million. The estimated cost of the entire Rebuild is $78 million. Q: What is the desired in-service date for the Rebuild? A: The desired in-service date is December 1, Q: Please summarize the foregoing testimony. A: The foregoing testimony can be summarized as follows: AEP has identified significant reliability concerns associated with elements of its transmission and subtransmission systems serving customers located in Bland and Tazewell Counties, Virginia and Mercer County, West Virginia. Under projected winter peak loading conditions, thermal overloads and violations of reliability criteria for voltage magnitude and deviation will occur within the affected load area upon the occurrence of certain contingencies. Additionally, the 90 year old South Bluefield Wythe 69 kv line has reached the end of its useful life and needs to be replaced. Finally, AEP is required under the USFS MOU to remove the existing 69 kv crossing of Rich Mountain The Rebuild will address these issues by rebuilding the obsolete South Bluefield Wythe 69 kv line (located primarily in Bland County, Virginia with the

22 1 2 3 Exhibit No. Witness: ERW Page 6 of 6 remainder located in Wythe County, Virginia and a small portion in Mercer County, West Virginia) as a robust new 138 kv transmission line, together with certain related substation improvements The Rebuild will have a positive effect on economic development within the Commonwealth by ensuring an adequate and reliable energy supply for the benefit of all user classes in the affected load area The estimated cost of the Virginia portions of the Rebuild is approximately $68 million. The estimated cost of the entire Rebuild is $78 million. The desired inservice date for the Rebuild is December 1, Q: Does this conclude your testimony? A: Yes.

23 Exhibit No. Witness: TBE DIRECT TESTIMONY OF TIMOTHY B. EARHART, P.E. FOR APPALACHIAN POWER COMPANY IN VIRGINIA S.C.C. CASE NO. PUE Q: Please state your name, position and business address. A: My name is Timothy B. Earhart. I am Supervisor, Transmission Line Engineering for American Electric Power Service Corporation ( AEPSC ). AEPSC is a subsidiary of American Electric Power Company, Inc. ( AEP ) that provides corporate support services to the operating subsidiaries of AEP, including Appalachian Power Company ( Appalachian or Company ). My business address is 1800 Loch Haven Drive, Meters & Stores Bldg., Roanoke, Virginia Q: Please review your educational background and your work experience. A: In 1982, I received a B.S. degree in Civil Engineering from the University of Missouri at Columbia. I am a licensed professional engineer in the State of Virginia. I joined Appalachian in 1983 as a Civil Engineer. I was promoted to the position of Civil Engineer, Senior in 1989; and to Supervisor, Transmission Line Engineering in I am responsible for coordinating and directing the engineering for AEP's transmission lines (34.5 kv through 765 kv) in the states of Virginia, West Virginia, Tennessee and Kentucky. Q: Mr. Earhart, what is the purpose of your testimony in this proceeding? A: The purpose of my testimony is to support certain aspects in Appalachian s application (the Application ) to this Commission for approval and certification of the Virginia portions of the proposed Bland Area Improvements 138 kv Transmission Line Rebuild

24 Exhibit No. Witness: TBE Page 2 of Project (the "Rebuild"; the Virginia portions thereof, the "Project"). In this connection, I am sponsoring various sections of the Response to Guidelines (the "Response to Guidelines") filed by the Company together with the Application in response to the Commission Staff's "Guidelines of Minimum Requirements for Transmission Line Applications Filed Under Virginia Code Section and The Utility Facilities Act. Q: What are your responsibilities as related to the Project? A: As Supervisor, Transmission Line Engineering, my primary duties involve the oversight of the engineering, logistical, and other technical requirements associated with the construction, operation and maintenance of the Project. Q: Which specific materials included in the Response to Guidelines are you sponsoring? A: I am sponsoring (1) the information describing the transmission line and engineering components of the Project set forth in the Response to Guidelines, Sections I.D, II and V, excluding Section II.A.2 and Section II.A.7; (2) Exhibits 2, 3 and 6 through 14; (3) three hard copies of the county highway maps for Bland and Wythe Counties showing the Project (also on CD-ROM submitted to the Commission with the Application); and (4) GIS shapefiles of the Project on CD-ROM submitted to the Commission with the Application. Q: Were the portions of Appalachian s filing that you are sponsoring prepared by you or under your supervision and direction? A: Yes. Q: Please describe the Rebuild.

25 Exhibit No. Witness: TBE Page 3 of A: The Rebuild consists generally of (a) an approximately 25.9 mile rebuild of an existing 69 kv line to 138 kv, approximately 25.2 miles of which will be located in Virginia and approximately 0.7 miles of which will be located in West Virginia (the rebuilt line in its entirety will be referred to as the South Bluefield Town Creek Progress Park 138 kv Transmission Line ), (b) replacement of Appalachian's existing Bland 69 kv in Bland County, Virginia with a new Town Creek 138 kv in order to accommodate the rebuilt line, and (c) associated substation improvements at Appalachian s existing South Bluefield and South Princeton s in West Virginia and its existing Progress Park in Virginia. Q: Has the West Virginia portion of the Rebuild been approved? A: Not yet. An application for authority to construct the 0.7 mile West Virginia portion of the Rebuild and associated substation improvements in Mercer County, West Virginia will be filed with the Public Service Commission of West Virginia in the near future. Q: Please summarize the design and operational features of the proposed transmission line. A: As described in detail in Section II.B of the Response to Guidelines, the proposed South Bluefield Town Creek Progress Park 138 kv Transmission Line will be a single circuit three-phase design and have a nominal phase-to-phase voltage of 138 kv. Q: What structure types will be used in connection with the construction of the proposed transmission line? A: Structure types will be determined during final engineering, which includes ground survey and geotechnical studies. Nevertheless, the Company anticipates utilizing primarily guyed-v lattice towers, H-frame steel poles and monopole steel structures in

26 Exhibit No. Witness: TBE Page 4 of connection with the construction of the Project. For additional details, see the Response to Guidelines, Section II.B, and Exhibit 7 filed with the Application. Q: Please describe the condition of the existing 69 kv line and structures. A; The existing 69 kv line is about 90 years old and is in a physically deteriorated condition commensurate with its age. Additionally, the structures do not have shield wires for lightning protection, and there is no practical way to reconfigure the structures to add shield wires. See existing structure photograph Exhibit 6 of Volume 1 of the Application. The line and structures were constructed around 1925 (initially constructed and operated as an 88 kv line but currently operated at 69 kv). The line has reached the end of its useful life and needs to be replaced. Q: Please compare the structures on the existing 69 kv line with the structures for the proposed rebuilt line. A: The typical structure used on the existing 69 kv line is a single circuit steel lattice tower, approximately 55 feet tall with an approximate 24 foot cross arm, located within a 100- foot wide right-of-way ("ROW"). The proposed 138 kv structures are approximately 90 to 100 feet tall with an approximately 32 to 48 foot cross arm, located within a 100-foot wide ROW (see Exhibit 7 of Volume 1 of the Application). A decrease of approximately 20% in the total number of transmission line structures within the portion of the existing ROW that will be used for the rebuilt line is expected as a result of the taller and more efficient proposed structures. See Section II.B of the Response to Guidelines for further detail. Q: Please describe the Company s role in the route development process.

27 Exhibit No. Witness: TBE Page 5 of A: First, Appalachian retained the Louis Berger Group, Inc. ( LB ) to (a) develop and evaluate study segments and route alternatives for the Project, and (b) select a preferred route that reasonably minimizes adverse impact on environmental resources and is consistent with the Project siting criteria and technical requirements. Second, the Company assisted the LB team in developing the routing guidelines and technical guidelines listed in the Route Selection Study ( RSS ) included in Volume 2 of the Application; also see Section II.A.7 of the Response to Guidelines. Third, Company representatives participated in numerous stakeholder meetings with government officials, businesses and landowners. Lastly, Company engineers conducted extensive desktop reviews and field reviews of the proposed routes to validate feasibility from an engineering standpoint. Q: Did the Company consider public and stakeholder input during route development? A: Yes. Public participation and stakeholder input was very important. To this end, Appalachian held a public open house concerning the Project on March 26, The open house was preceded by extensive public notification campaigns. Approximately 62 participants attended the open house. At the open house, representatives of Appalachian and LB provided information on the Project, were available to answer questions, and collected comments. Additionally, the public was able to comment electronically and obtain additional information regarding the Project through Appalachian s website. Further, the Company and/or LB met with several interested landowners privately at their request. Lastly, LB and the Company made extensive contacts with federal, state and

28 Exhibit No. Witness: TBE Page 6 of local government agency representatives to solicit input. LB, where appropriate, applied the resulting input to develop, analyze and modify the study segments and routes. Q: What is the Company s opinion on the Preferred Route identified in the RSS? A: The Company supports LB s conclusion that the Preferred Route is the superior route. The majority (over 80%) of the proposed 25.2 mile Virginia portion of the Preferred Route will be located in the existing 69 kv line ROW (15.8 miles) or adjacent to existing transmission line ROW (5.1 miles). Using existing ROW is consistent with public preferences, SCC Staff guidelines, and the preference in Code of Virginia and for paralleling or utilizing existing ROWs for new transmission facilities when feasible. Furthermore, as supported by the RSS, the Preferred Route reasonably avoids or minimizes adverse impacts on the scenic assets, historic districts and environment of the area concerned. See LB s RSS, included in Volume 2 of the Application, for a detailed description and comparison of the alternative routes. Q: Why is the Company submitting a 500-foot Corridor in which a 100-foot ROW will be located? A: While the majority of the proposed transmission line will be located in the existing 69 kv line ROW or adjacent to existing ROW, the Company needs the flexibility to shift the centerline of the 100-foot ROW for the transmission line up to 200 feet in either direction from the centerline shown in the Application as necessary to address issues that become evident only after completion of final engineering, ground survey and interviews with landowners. Nonetheless, the Company believes the centerline shown in the Application, is the most suitable alignment based upon preliminary analysis. The Company will

29 Exhibit No. Witness: TBE Page 7 of provide notice to potentially affected landowners within the 500-foot corridor as required by the Commission and applicable law. Q: Why does the Preferred Route incorporate an expansion of the 500 foot corridor in the vicinity of the U.S. Route 52 crossing near the community of Bland, as shown on Exhibit 5 of Volume 1 of the Application (the "Expanded Corridor")? A; The Expanded Corridor is needed because the rebuilt line requires a new 138 kv substation (to be called the Town Creek ), which will replace the existing 69 kv Bland. The existing 69 kv substation site, which will be decommissioned, cannot accommodate the new 138 kv transformer and related equipment needed to connect the rebuilt line to the distribution system serving Bland County. The Company has preliminarily identified several possible sites within the Expanded Corridor for the new substation, as discussed in the RSS report included with this Application as Volume 2. Based on its preliminary analysis, the Company has made an initial determination that the site shown on Exhibit 5 of Volume 1 of the Application appears to be the most suitable location for the new substation. However, detailed ground surveys, site design, geotechnical and other engineering studies, environmental studies and consultations with landowners will be required before a location for the substation can be finalized. The Expanded Corridor will afford the Company the flexibility to determine the final substation location after completing those surveys, studies, design work and landowner consultations. Q: What factors will the Company consider in determining the final location for the new substation?

30 Exhibit No. Witness: TBE Page 8 of A: The Company will consider the following factors: Minimization of impacts on existing land use, visual resources and natural resources. Proximity to the existing Bland, transmission line and distribution system. Topography, constructability and geotechnical characteristics. Ability to build a permanent access road to the site for construction, transformer transportation and on-going operation and maintenance. Minimization of transmission line structure angles and interstate crossings when entering and exiting the new substation. Land purchase costs. Landowner preferences. Q: Please describe the proposed transmission line route. A: The proposed South Bluefield Town Creek Progress Park 138 kv Transmission Line will be constructed on a 100-foot ROW to be located within a 500-foot corridor. Because the new line will be a rebuild of an existing Appalachian 69 kv line, the majority of the new line will be constructed on ROW already acquired by Appalachian (see Section II.A.4). The rebuilt line will depart from the existing ROW in Virginia in three locations (see Exhibit 1, page 2 of 2 and Exhibit 5) for a total of 9.4 miles due to (a) the relocation of the existing 69 kv line crossing of Rich Mountain (the "Rich Mountain Relocation"), (b) the relocation to connect with the new Town Creek (the "Town Creek Relocation"), which will replace the existing Bland 69 kv in order to

31 Exhibit No. Witness: TBE Page 9 of accommodate the rebuilt line, and (c) the relocation to accommodate the change in the southern terminus of the rebuilt line from the existing Wythe to the existing Progress Park (the "Progress Park Relocation"). There may be other minor deviations from the existing ROW based upon the results of final survey, line design and ROW negotiations. Such discrete adjustments are typical during a rebuild project. Nevertheless, except as noted above, the majority of the rebuilt line will be generally in, adjacent to or near the existing 69 kv line corridor. Q: Please explain the Rich Mountain Relocation. A: This deviation from the existing 69 kv line ROW will satisfy Appalachian s commitment to remove the existing 69 kv line crossing of National Forest land on Rich Mountain in accordance with a November, 2003, Memorandum of Understanding ( MOU ) between Appalachian and the U.S. Forest Service ("USFS") in connection with Appalachian's Jacksons Ferry-Wyoming 765 kv transmission line (see Exhibit 14 of Volume 1 of the Application). Q: What is the Company's position regarding the Rich Mountain Relocation? A: Rich Mountain in this area has very rugged and steep slopes. Under the terms of the USFS MOU, using the existing 69 kv line crossing of Rich Mountain for the Rebuild was not an option. If it had been possible to use the existing 69 kv line crossing of Rich Mountain, new access roads would have been required because the existing line was constructed in the 1920s using mules and mule trails that no longer exist. Because the relocation parallels the existing Jacksons Ferry-Wyoming 765 kv transmission line (put into service in 2006), the Company will be able to use the 765 kv line s existing access

32 Exhibit No. Witness: TBE Page 10 of roads to construct the Rebuild up and over Rich Mountain. By using these existing access roads, the natural and visual impacts will be decreased as compared to constructing new roads on very difficult terrain on Rich Mountain. Furthermore, the relocation will also reduce visual impacts by permitting the very visible existing 69 kv line ROW cut on the ridge of Rich Mountain to return to a natural state and moving the rebuilt line to the west adjacent to the existing 765 kv line. Accordingly, the Company's position is that the relocation is a prudent choice. Q: How much of the proposed line will cross National Forest property, and what approvals and permits are required for the National Forest crossing? A: Approximately 7.3 miles of the proposed line crosses National Forest property, approximately 6.1 miles of which is on the existing 100-foot ROW and approximately 1.2 miles of which will require a new 100-foot ROW (see Exhibit 5 of Volume 1 of the Application). A special use permit ( SUP ) from the USFS will be required in connection with the Rich Mountain Relocation and the associated access roads in order to rebuild the existing 69 kv line located on National Forest land. An environmental assessment ( EA ), pursuant to National Environmental Protection Act ( NEPA ) requirements, will be completed to assess potential environmental impacts associated with the proposed federal action (issuance of an SUP). Q: What is the status of the SUP? A: The Company has been working closely with the USFS since the spring of 2014 and environmental/biological field studies on National Forest land began this year. The Company filed the SUP application in June of The Company expects impacts on

33 Exhibit No. Witness: TBE Page 11 of National Forest land to be minimal and will mitigate as required. The draft EA is expected to be complete in the summer of 2016 and the Company expects the SUP to be issued by the end of Q: Why is the Progress Park Relocation necessary? A: The proposed South Bluefield Town Creek Progress Park 138 kv Transmission Line will terminate at the nearby and existing Progress Park 138 kv (put in service in 2007). The existing South Bluefield Bland Wythe 69 kv line currently connects to the existing Wythe. Due to the Wythe s configuration and physical constraints, the proposed 138 kv line cannot terminate at the Wythe. The retired 69 kv position at Wythe cannot be used by the 138 kv line and there are no empty 138 kv positions. Accordingly, it was determined that ending the new 138 kv line at the nearby Progress Park, where there is ample space, would be electrically equivalent and the best location. Q: Please describe the area traversed by the proposed transmission line. A: The majority of the line is located in Bland County, where it crosses rugged and forested mountainous areas with small amounts of open pasture land. The sparse population is concentrated in the valleys. The rest of the line is located in Wythe County, where it crosses several mountain ridges and then traverses more rolling terrain with open pasture and cropland as it proceeds to its terminus at the Progress Park. Q: How wide is the proposed 138 kv line ROW? A: Typically for 138 kv transmission lines, the ROW will be 100 feet wide. However, the ROW could be more than 100 feet wide in a few locations, as needed to ensure

34 Exhibit No. Witness: TBE Page 12 of compliance with safety requirements in certain conductor blow-out conditions. Locations requiring a wider ROW are typically located in long spans between structures, where the conductors can sway out sideways during extreme weather conditions. The ROW in those locations typically would not be more than 125 feet wide, except in a very few instances involving unusually steep terrain and very long spans, where the ROW could be up to 175 feet wide. Also, in certain limited locations, the ROW may be more than 100 feet wide as necessary to accommodate guy wires that extend more than 50 feet from the ROW centerline. Guy wires are needed to support the guyed-v structures and certain angle structures to be used for the Project. Although in most instances, the guy wires will not extend more than 70 feet from the ROW centerline, in a very few instances involving unusually steep terrain, the guy wires could extend up to 100 feet from the ROW centerline. The precise location and extent of the places where the ROW would need to be more than 100 feet wide to accommodate conductor blowout conditions and guy wires cannot be determined until completion of detailed ground surveys and final engineering. Q: How wide is the existing 69 kv line ROW? A: The existing South Bluefield - Bland -Wythe 69 kv line ROW is approximately 100 feet wide. Consequently, in most instances, the existing ROW easements will be sufficient to accommodate the new 138 kv line. Nevertheless, a few of the existing easements may need to be amended or renewed to accommodate the new line. Q: Are there any dwellings in the existing and proposed ROW? A: Three residential structures are currently located in the existing 69 kv line ROW. Subject to final engineering and ground survey, Appalachian has determined that two of

35 Exhibit No. Witness: TBE Page 13 of the structures can be avoided with a minor modification of the existing ROW centerline. Therefore, one existing dwelling will need to be removed. Q: Please summarize the Project s required land acquisition and easements. A: The following easements and land acquisition will be required for the Project: A few of the ROW easements on the existing 69 kv line will need to be amended or renewed to accommodate the new line. The existing 69 kv line ROW easements generally include ingress and egress rights; nevertheless, some new third-party access road easements (or, in the case of land owned by the United States and under the jurisdiction of the U.S. Forest Service, a special use permit) will be required. Approximately 9.4 miles of new 100-foot wide ROW in Virginia will be required to accommodate the Rich Mountain Relocation, the Town Creek Relocation and the Progress Park Relocation. New easements may be required to accommodate additional minor deviations from the existing ROW. The new Town Creek will require the purchase of an approximately 5.0 acre parcel in fee. Approximately 2.0 miles of existing distribution, presently located within the existing 69 kv line ROW, will be relocated adjacent to the transmission ROW; therefore, 2.0 miles of new 40-foot distribution ROW will be required to accommodate the proposed construction for the new 138 kv. The relocation is shown on Exhibit 5 of Volume 1 of the Application (tiles 16 through 18).