How To Build A 230 Kv Transmission Line In Orange County

Transcription

1 STANDARD APPLICATION FOR A CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A PROPOSED TRANSMISSION LINE AND APPLICATION FOR A CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A PROPOSED TRANSMISSION LINE PURSUANT TO P.U.C. SUBST. R DOCKET NO Submit seven (7) copies of the application and all attachments supporting the application. If the application is being filed pursuant to P.U.C. Subst. R (b)(3)(D) or P.U.C. Subst. R , include in the application all direct testimony. The application and other necessary documents shall be submitted to: Public Utility Commission of Texas Attn: Filing Clerk 1701 N. Congress Ave. Austin, Texas

2 1. Applicant (Utility) Name: Entergy Texas, Inc. (ETI) Certificate Number: Street Address: 919 Congress Avenue, Suite 840, Austin, TX Mailing Address: 919 Congress Avenue, Suite 840, Austin, TX Please identify all entities that will hold an ownership interest or an investment interest in the proposed project but which are not subject to the Commission s jurisdiction. There are no such entities in the proposed project. 3. Person to Contact: For joint applications, provide all information for each applicant. Contact: Title/Position: Carl Olson, P.E. Manager, Regulatory Affairs Phone Number: (512) Mailing Address: 919 Congress Avenue, Suite 701, Austin, TX Address: colson1@entergy.com Legal Counsel: Paula Cyr Title/Position: Asst. General Counsel Phone Number: (512) Mailing Address: 919 Congress Avenue, Suite 840, Austin, TX Address: pcyr@entergy.com 4. Project Description: Provide a general description of the project, including the design voltage rating (kv), the operating voltage (kv), the CREZ Zone(s) (if any) where the project is located (all or in part), any substations and/or substation reactive compensation constructed as part of the project, and any series elements such as sectionalizing switching devices, series line compensation, etc. For HVDC transmission lines, the converter stations should be considered to be project components and should be addressed in the project description. Entergy Texas, Inc. (ETI) proposes to design and construct a new 230 kilovolt (kv) transmission line in Newton and Orange counties, Texas. The design voltage rating for this project is 230 kv and the operating voltage is also 230 kv. The new transmission line would connect the existing Hartburg Substation located south of Deweyville, Texas to the new proposed Chisholm Road Substation near the intersection of Linscomb Road and Joe Lane west of Farm-to- Market Road (FM) 1136 southwest of Mauriceville, Texas. ETI will install new equipment at both substations. The new transmission line will have a length of approximately 12.5 miles to 14.2 miles depending on the final route approved by the Public Utility Commission of Texas (PUC, PUCT or Commission). If the project will be owner by more than one party, briefly explain the ownership arrangements between the parties and provide a description of the portion(s) that will be owned by each party. Provide a description of the responsibilities of each party for implementing the project (design, Right-Of-Way acquisition, material procurement, construction, etc.). Not Applicable If applicable, identify and explain any deviation in transmission project components from the original transmission specifications as previously approved by the Commission or recommended by PURA organization. Not Applicable 5. Conductor and Structures: 2

3 Conductor Size and Type: 1272 ACSS Number of conductors per phase: One (1) conductor/ phase Continuous Summer Static Current Rating (A): 1957A Continuous Summer Static Line Capacity at Operating Voltage (MVA): 230kV Continuous Summer Static Line Capacity at Design Voltage (MVA): 230kV Type and Composition of Structures: Steel/concrete single circuit poles (delta and vertical) Height of Typical Structures: Single steel/concrete tangent and dead end structures will be utilized for the project. Tangent (in-line) poles would have a direct embed foundation with concrete backfill. Dead-end and angle poles would have drilled pier foundations. Soil borings will be obtained to design the foundations accordingly. Explain why these structures were selected; include such factors as landowner preference, engineering considerations, and costs comparisons to alternate structures that were considered. Provide dimensional drawings of the typical structures to be used in the project. Typical Single Pole Single Circuit Inline Delta Structure Typical Single Pole Single Circuit Dead-End Structure 3

4 For joint applications provide and separately identify the above required information regarding structures for the portion(s), of the project owned by each applicant. 6. Right-of-way: Miles of Right-of-Way: Miles of Circuit: Approximately Width of Right-of-Way:125 Percent of Right-of-Way Acquired: 1% (Route 1) 100% (Route 8) 1 For joint applications, provide and separately identify the above required information for each route for the portions(s) of the project owned by each applicant. Provide a brief description of the area traversed by the transmission line. Include a description of the general land uses in the area and the type of terrain crossed by the line. The majority of the study area is a rural setting with the exception of residential urban areas associated with all or part of the following cities, towns, Census Designated Place (CDP), or unincorporated communities: Deweyville CDP; Mauriceville CDP; and unincorporated communities of Hartburg and Little Cypress. The majority of the study area has been impacted by land improvements associated with agriculture, residential structures, roadways, and various utility corridors. Overall, the study area consists of open and forested land with scattered residential development with mostly flat topography and a system of canals. 7. Substations or Switching Stations: List the name of all existing HVDC converter stations, substations or switching stations that will be associated with the new transmission line. Provide documentation showing that the owner(s) of the existing HVDC converter stations substations and/or switching stations have agreed to the installation of the required project facilities. - Hartburg 230kV Substation: Install new 230kV Line Bay, including four (4) new 230kV Breakers, nine (9) 230kV Isolation Switches, three (3) 230kV Line Switch, Bus, Relay Panels, Control Cables and a new Control House; Relocate existing Line 195 to new 230kV Line Bay; Terminate new 230kV Chisholm Road Line to existing 230kV Line Bay - Sabine 230kV/138kV Substation: Replace eight (8) 230kV Breakers, Relay Panels and Control Cables. - Georgetown 230kV/138kV Substation: Upgrade relay and settings - Helbig 230kV/69kV Substation: Upgrade relay and settings List the name of all HVDC converter stations, substations or switching stations that will be associated with the new transmission line. Provide documentation showing the owner(s) of the new HVDC converter stations, substations and/or switching stations have agreed to the installation of the required project facilities. - Chisholm Road 230kV Switching Station: Build new 230kV 5 Breaker Ring Switching Station; Cut-In two (2) existing T-Lines creating four (4) T-Lines Chisholm - Hartburg (Line 195), Chisholm - Helbig (Line TBD), Chisholm - Georgetown (Line TBD) and Chisholm - Sabine (Line 572); and Terminate new 230kV Chisholm - Hartburg Line (Line TBD). 1 Negotiating purchase of 50 strip of land in fee near proposed Chisholm Road Substation and will also need to obtain applicable crossing permits. 4

5 8. Estimated Schedule: Estimated Dates of: Start Completion Right-of-way and Land Acquisition January 2016 December 2016 Engineering and Design March 2016 September 2016 Material and Equipment Procurement May 2016 December 2016 Construction of Facilities December 2016 May 2017 Energize Facilities May 2017 May Counties: Orange and Newton. 10. Municipalities: For each route, list all municipalities in which the route is to be constructed. For each applicant, attach a copy of the franchise, permit or other evidence of the city s consent held by the utility, if necessary or applicable. If franchise, permit, or other evidence of the city s consent had been previously filed, provided only the docket number of the application in which the consent was filed. Each applicant should provide this information only for the portion(s) of the project which will be owned by the applicant. City of Orange (See Attachment 1) 11. Affected Utilities: Identify any other electric utility served by the connected to facilities in this application. Describe how any other electric utility will be affected and the extent of the other utilities involvement in the construction of this project. Include any other electric utilities whose existing facilities will be utilized for the project (vacant circuit positions, ROW, substation sites and/or equipment, etc.) and provide documentation showing that the owner(s) of the existing facilities have agreed to the installation of the required project facilities. None 12. Financing: Describe the method of financing this project. For each applicant that is to be reimbursed for all of a portion of this project, identify the source and amount of the reimbursement (actual amount if known, estimated amount otherwise) and the portion(s) of the project for which the reimbursement will be made. The Company will finance the construction with funds from various sources including retained earnings, short-term loans, and capital securities which may be sold hereafter. 13. Estimated Costs: Provide cost estimates for each route of the proposed project using the following table. Provide a breakdown of Other costs by major cost category and amount. Provide the information for each route in an attachment to this application. Please see attached Table. (See Attachment 2) For joint applications provide and separately identify the above-required information for the portion(s) of the project owned by each applicant. 5

6 14. Need for the Proposed Project: For a standard application, describe the need for the construction and state how the proposed project will address the need. Describe the existing transmission system and conditions addressed by this application. For projects that are planned to accommodate load growth, provide historical load data and load projections for at least five years. For projects to accommodate load growth or to address reliability issues, provide a description of the steady state load flow analysis that justifies the project. For interconnection projects, provide any documentation from a transmission service customer, generator, transmission service provider, or other entity to establish that the proposed facilities are needed. For projects related to a Competitive Renewable Energy Zone, the foregoing requirements are not necessary; the applicant need only provide a specific reference to the pertinent portion(s) of an appropriate commission order specifying the facilities are needed. For all projects, provide any documentation of the review and recommendation of a PURA organization. PROPOSED PROJECT ETI is proposing the installation of a new 230 kv transmission line between Entergy s existing Hartburg Substation located on Indian Lake Road off of Ruliffe Road near Deweyville, Texas to a new switching station located near the intersection of Linscomb Road and Joe Lane, west of Farm to Market (FM) 1136, southwest of Mauriceville, Texas. The new switching station will be called Chisholm Road and is adjacent to existing transmission lines just south of Linscomb Road. The new transmission line is part of a larger project, the Orange County Project, that is being proposed to alleviate power flow limitations in ETI s east Texas service area. In addition to the new switching station and the new 230 kv transmission line, a second kv, 800 MVA autotransformer will also be installed at the Hartburg Substation and eight 230 kv circuit breakers at the Sabine generating station will be replaced to provide adequate fault interrupting capability due to the increase in the areas short circuit availability. DESCRIPTION OF THE EXISTING SYSTEM The ETI Hartburg Substation serves as a gateway for power flow from generating resources east and north of Southeast Texas to loads located in the ETI and surrounding service areas in Southeast Texas. Three 500 kv transmission lines terminate at this substation. One connects to the Mount Olive Substation located in Dubach, LA to the north, one connects to the Nelson Substation located in Westlake, LA to the east and one connects to the Cypress Substation which provides a path to continue to move power to the west from Hartburg Substation. The existing 500/230 kv transformer at Hartburg provides a strong source to the 230 kv transmission system at Hartburg which also helps facilitate the flow of electrical power to the west. This 230 kv transmission line connects to the Inland- Orange Substation located in Forest Height, TX, the McLewis Substation located at 6871 Highway 62 North in Orange, Texas and the Helbig Substation located at 8000 Helbig Road in Beaumont, Texas. The Cottonwood generating plant, owned by NRG, is also interconnected to the Hartburg Substation. 6

7 PROJECT NEED RELIABILITY This project will address the forecasted transmission reliability needs of ETI s service area. The project will help to prevent line and transformer overloads that violate both the North American Electric Reliability Council ( NERC ) Planning Standard (TPL-001-4) and Entergy s Transmission Planning Criteria. Considering the present transmission system topology and firm resource contracts in place, along with planned network resource additions and planned approved transmission upgrades, ETI has determined that the 230 kv line would be necessary by the summer of 2017 in order to continue to provide adequate and reliable service to ETI s customers in east Texas. By the summer peak of 2017, Entergy s analysis of the transmission facilities in the Orange County area of east Texas identified that a violation of a Category P3 Planning Event of the standard will occur. A P3 planning event is the contingency loss of a generator in addition to the loss of another system element which may including another generator (P3-1), a transmission line (P3-2), a transformer (P3-3) or a shunt device (P3-4). The Orange County Project is proposed as Entergy s corrective action plan to increase transmission capacity to address the reliability needs of the area. Deficiencies identified include the loss of the Cypress to Hartburg 500 kv line coupled with the loss of the Sabine Generating Unit 4 (TPL-001-4, category P3-2) resulting in overloads on the Hartburg 500/230 autotransformer and the Hartburg - Inland Orange - McLewis 230 kv line 195. Loss of the Hartburg 500/230 kv autotransformer coupled with the loss of the Sabine Generating Unit 4 (TPL-001-4, category P3-3) also results in overload of the Cypress to Amelia 230 kv line and the Cypress 500/230 kv autotransformer. The severity and timing of the overloads are detailed below in Table 2. The NERC planning standard does not allow for interruption of Firm Transmission Service or loss of Non-Consequential Load for either of these planning categories. Construction of the new Chisholm Road switching station, construction of the new 230 kv transmission line from Chisholm Road to Hartburg and installation of a new 500/230 kv autotransformer at Hartburg will mitigate these overloads. 7

8 CUSTOMER BLOCK LOAD ADDITIONS In addition to normal projected load forecast, ETI has also received multiple customer block load requests in the Beaumont/Port Arthur area. Since January 2014, thirteen individual load request ranging in load levels from 7 MW upwards to 200 MW located at various sites in the Beaumont and Port Arthur area have been received with proposed in-service dates ranging from 2015 to The in-service dates and proposed load values could change based on the customer s final requirements. If these block load requests ultimately connect to the ETI transmission system, the overloads in Table 1 will increase and the need for the Orange County Project will magnify. TRANSMISSION SERVICE REQUESTS The Orange County Project has also been previously identified as part of the solution sets for several transmission service requests including Oasis , , , and Although all of these transmission service requests were ultimately withdrawn, the analysis indicates that the project will help facilitate future transmission service in the area. STEADY STATE POWER FLOW ANALYSIS Steady state power flow analysis indicates that the loss of the Cypress to Hartburg 500 kv line 547 coupled with the loss of the Sabine 4 generator (NERC TPL-001-4, P3-2) causes an overload of the Hartburg to Helbig 230 kv line 195 and the Hartburg 500/230 kv autotransformer. The loss of the Hartburg 500/230 kv autotransformer coupled with the loss of the Sabine 4 generator will cause the Cypress to Amelia 230 kv line 488 to overload. The loss of the Cypress 500/230 kv autotransformer coupled with the loss of the Sabine 4 generator will cause the Cypress 500/138 kv autotransformer to overload. Severity and timing of these overloads is detailed below in Table 1. Table 1 ORANGE COUNTY OVERLOADS Overloaded Element Contingency Hartburg-Helbig 230 kv line 195 Hartburg 500/230 kv autotransformer Cypress Amelia 230 kv line 488 Cypress 500/230 kv autotransformer Sabine 4 + Cypress-Hartburg 500kV Sabine 4 + Cypress-Hartburg 500kV Sabine4 + Hartburg Autotransformer Sabine 4 + Cypress 500/138 kv autotransformer % % % % % % % % % % % % 106.8% % 110.6% % % % % % Overloads shown above are for summer peak models. Loading values are sensitive to forecasted loads in the ETI service area and dispatch of available generation resources. Loading does not include block load requests which may have been analyzed but not signed. 8

9 LOAD GROWTH ETI s historical peak demand for the last 5 years is shown in the following table: Peak Month/day/yr Peak hr Actual Peak Demand (kw) 7/14/ ,734,767 8/9/ ,135,675 8/18/ ,267,532 6/25/ ,197,370 8/7/ ,339,460 9/4/ ,953,797 Note: Actual Peak Demand obtained from Entergy s System Planning organization The ETI estimated projected peak demand is shown in the following table: Summer Peak Year Estimated Summer Peak (kw) ,699, ,845, ,954, ,049, ,102, ,194,000 Note: Forecast obtained from summer peak load flow models by summing all ETI Area zone bus loads. INDEPENDENT REVIEW This project was identified during Entergy s 2013 Base Plan development. Southwest Power Pool ( SPP ) served as the Independent Coordinator of Transmission (ICT) during the development of this plan and also identified the need for this project in their 2013 Base Plan. The ICT performed an independent review in accordance with Attachment K of Entergy s Transmission tariff and performed an independent reliability assessment of the transmission system. As part of this assessment, the ICT evaluated whether Entergy s Construction Plan complied with the planning criteria. They identified all transmission upgrades and construction projects necessary to comply with NERC and Entergy s planning criteria. The ICT s 2013 Base Plan can be found at: The Orange County Project was determined by the ICT as a necessary project and is listed as Project BP with an ISD of summer 2017 and can be found on page 3. For Entergy s 2014 Base Plan development, Midcontinent Independent System Operator (MISO) served as the ICT. The ICT s final plan can be found at: The ICT s plan identifies the Orange County Project as BP with an ISD of summer The project can be found on page 1 of their report. 9

10 On December 18, 2013, ETI along with Entergy Arkansas, Inc., Entergy Gulf States LLC, Entergy Louisiana LLC, Entergy New Orleans, Inc., and Entergy Mississippi, Inc. joined the MISO regional transmission organization. As part of the process for integration into MISO in accordance with the MISO Tariff, MISO submitted Attachment FF- 1A (List of Southern Region Planned Projects to be Excluded from Cost Allocation) to the Federal Energy Regulatory Commission ( FERC ). MISO s Attachment FF-1A identifies those projects that MISO will not evaluate through the MISO Transmission Expansion Plan ( MTEP ). These projects are generally referred to as previously planned or pre-planned. MISO has determined that, because such projects were not approved by MISO, but have been approved under the Southern Region entities transmission plans, these previously approved projects will be included in MISO s base planning models, but not in Appendix A to MTEP. The Orange County Project was included as one of the pre-planned projects in the Attachment FF-1A filing submitted by MISO to FERC. The December 18, 2013 filing, which includes the Orange County Project can be found on MISO s website at 18%20Docket%20No.%20ER %20(Attachment%20FF-1A).pdf SUMMARY The primary objectives for this project is to provide reliable transmission service for the ETI electric system, to allow for economic growth in the Beaumont/Port Arthur area, to mitigate constraints observed in Transmission Service Requests and to meet the requirements set forth in NERC Reliability standards. The solution being proposed will meet all of the objectives with the least impact to customers both from a cost standpoint and environmental. 15. Alternatives to Project: For a standard application, describe alternatives to the construction of this project (not routing options). Include an analysis of distribution alternatives, upgrading voltage or bundling of conductors of existing facilities, adding transformers, and for utilities that have not unbundled, distributed generation as alternatives to the project. Explain how the project overcomes the insufficiencies of the other options that were considered. DISTRIBUTION ALTERNATIVES Due to the nature of the issue being addressed by the proposed construction of the Orange County Project, distribution alternatives are not feasible. The overloads that result from the contingencies specified are a result of the total load and its forecasted growth in the ETI service area and surrounding areas and are broad based in nature requiring a transmission solution to increase transport levels into the region. Distribution solutions tend to be localized to specific areas where transmission capacity is adequate. Adding distribution facilities in the area such as feeders or transformers will not negate the overloads that result from the loss of generation and transmission capacity importing power into the region. DISTRIBUTED GENERATION (DG) Utility-owned DG is not a feasible economic solution. The costs of large DG units range from $250/kW (at best) for diesel generation to $7,400/kW for photovoltaic. Applying the least expensive technology to the 495 MW anticipated load increase from 2015 to 2025 would cost approximately $ million and would only meet the need for the short term. The approximate $55.6 million to build the proposed Orange County Project is less expensive and would provide long term benefits. Customer-owned DG is currently not adequately established to offset the area load growth. Customer supplied DG is non-firm energy that could not be depended on to lower system peak. With no DG production and the non-firm nature of future DG, these resources are not expected to meet the load growth in the region projected to be greater than 50 MW per year. Customer-owned DG facilities have proved not to affect the need for the proposed project. 10

11 TRANSMISSION ALTERNATIVES Alternative 1 Upgrading existing facilities The first alternative considered was to upgrade the existing 230 kv transmission lines (Hartburg to Helbig and Cypress to Amelia), install a second 500/230 kv, 800 MVA autotransformer at the existing Hartburg substation, and the addition of a second 500/230 kv, 600 MVA autotransformer at the existing Cypress Substation. The estimated total cost of this alternative is $89,974,000. This alternative was not chosen due to its higher estimated cost. Alternative 2 Hartburg to Cypress 500 kv The second alternative considered was to construct a new 32 mile, 500 kv line from the existing Hartburg Substation to the existing Cypress Substation, upgrade the existing Cypress to Bevil to Amelia 230 kv Line, and install a second 500/230 kv, 600 MVA autotransformer at Cypress. The estimated cost of this alternative was $101,869,000. This alternative was not chosen due to its higher estimated cost. Alternative 3 Hartburg to Cypress to Amelia 230 kv The third alternative considered was to construct a new 32 mile, 230 kv line from the existing Hartburg Substation to the existing Cypress Substation, construct a new 30 mile, 230 kv line from Cypress to the existing Amelia Substation, installation of a second kv, 800 MVA autotransformer at Hartburg, and the addition of a second kv, 600 MVA autotransformer at Cypress. The estimated cost of this alternative was $96,904,000. This alternative was not chosen due to its higher estimated cost. SUMMARY In summary, there are no feasible distribution alternatives to address the overloads that occur in the Orange County area as a result of the loss of the NERC category P3-2 and P3-3 contingencies. All transmission alternatives would be more costly than the Orange County Project, which is estimated at $55.6 million. 16. Schematic or Diagram: For a standard application, provide a schematic or diagram of the applicant s transmission system in the proximate area of the project. Show the location and voltage of exiting transmission lines and substations, and the location of the construction. Locate any taps, ties, meter points, or other facilities involving other utilities on the system schematic. New 230 kv transmission line (illustrative only) Chisholm Road Switching Station 500 kv 230 kv 138 kv Substation 11

12 17. Routing Study: Provide a brief summary of the routing study that includes a description of the process f selecting the study area, identifying routing constraints, selecting potential line segments, and the selection of the routes. Provide a copy of the complete routing study conducted by the utility or consultant. State which route the applicant believes best addresses the requirements of PURA and P.U.C. Substantive rules. ETI retained POWER Engineers, Inc. (POWER) to prepare the Environmental Assessment and Alternative Route Analysis for the Proposed Hartburg to Chisholm Road 230 kv Transmission Line Project in Orange and Newton counties, Texas (EA), provided as Attachment 3 to the Application. The objective of the EA was to provide information in support of this Application in addressing the requirements of Section (c)(4)(a)-(d) of the Texas Utilities Code, the PUCT CCN Application form, and PUC Substantive Rule By means of examination of existing environmental conditions, including the human and natural resources that are located in the project area, the EA evaluates the environmental effects that could result from the construction, operation, and maintenance of the proposed project. The EA may also be used in support of any additional local, state, or federal permitting activities that may be required for the proposed project. To assist POWER in its evaluation, ETI provided information regarding the project endpoints, the need for the project, engineering and design requirements, construction practices, and ROW requirements for the proposed project. Selecting the Study Area The first step in the process was to delineate a study area. This area needed to encompass the project termination points and include a large enough area within which a geographically diverse set of alternative routes could be located. The delineation of the study area for this project was dictated largely by the locations of existing and proposed ETI facilities including the Hartburg Substation and proposed Chisholm Road Substation as well as ETI s existing transmission lines. The study area for the Hartburg to Chisholm Road 230 kv project, as shown on Figure 2-1 of the EA, is an irregular pentagon shaped area approximately 8.9 to 10.5 miles east to west and 9.9 miles north to south and encompasses approximately 95 square miles in Newton and Orange counties. Routing Constraints Once the study area was defined, POWER collected environmental data related to land use, aesthetics, ecology, and cultural resources. Several methodologies were utilized to collect and review environmental and land use data including incorporation of readily available Geographic Information System (GIS) coverage with associated metadata; review of maps and published literature; review of files and records from numerous federal, state and local agencies;. conducting ground reconnaissance; reviewing available maps and aerial photography; reviewing previous studies conducted in the area; contacting a variety of local, state, and federal agencies; and considering criteria established in Section (c)(4)(A)-(D) of the Texas Utilities Code, the Commission s CCN application form, Commission Substantive Rule , and input from the public open house meeting. Using this information, the geographic locations of environmentally sensitive and other constraints were identified and located. Selection of Potential Routing Segments Preliminary alternative route segments were identified by evaluation of the constraints mapped for the study area and then by identifying routing opportunity areas such as existing corridors and other linear features. Through application of the routing criteria, as described above, 28 preliminary alternative route segments were identified and developed into potentially viable preliminary alternative routes for comparative purposes. These preliminary alternative route segments were further evaluated based on information received from government agencies, the public meetings, and additional landowner input. This eventually led to the identification for comparative purposes of 8 primary alternative routes. These routes were evaluated utilizing 42 land use and environmental criteria. Impacts were evaluated by POWER for each identified primary alternative route. As previously mentioned, the study area for this project is an irregular pentagon shaped area approximately 8.9 to 10.5 miles east to west and 9.9 miles north to south and encompasses approximately 95 square miles in Newton and Orange counties. Considering the distance to the project endpoints, the amount of area encompassed, and routing constraints, the 8 primary alternative routes evaluated in the EA represent an adequate number of reasonable, viable, geographically varied alternative routes for an approximately 12.5 to 14.2 mile project. Environmental/land use criteria data was collected for all of the segments that were used to develop the 8 primary alternative routes. Additionally, potentially affected landowners along all of the 28 primary alternative segments have been notified of the project. Therefore, to the extent necessary, various additional alternative routes could be formulated. 12

13 Specific discussion regarding selection of the study area, identification of constraints, the selection of potential preliminary alternative route segments, and the alternative route analysis is set forth in Section 2.0 of the EA. Selection of the alternative route the applicant believes best addresses the requirements of PURA and P.U.C. Substantive Rules. ETI used a consensus process to independently select Route 8 as the primary alternative route that ETI representatives believe best addresses the requirements of PURA and P.U.C. Substantive Rules for this project. ETI initially reviewed POWER s evaluation and recommendations, followed by a review of each alternative route. This review included the consideration of all of the factors and criteria listed in PURA and the P.U.C. Substantive Rules including potential environmental, cultural, and land use impacts, engineering constraints, public input and community values, estimated costs, system planning, and landowner, agency, and utility concerns and preferences. ETI concluded that, after reviewing the results of POWER S routing study and a wide range of factors including potential environmental impacts, monetary cost, landowner and agency concerns, engineering requirements, ROW easement procurement issues and construction issues that Route 8 is the route which best addresses the requirements of PURA and PUC substantive rules based on the following advantages: Route 8: has the lowest estimated cost; has the least number of newly affected habitable structures within 300 feet (nine); utilizes the most existing transmission line ROW at 13.9 miles (98 percent of its length) and would not need to obtain new ROW from private landowners; is tied with Route 6 with having the least number of pipeline crossings (16); does not cross within 1,000 feet of any cemeteries; does not cross through bottomland and/or riparian woodlands, has the shortest length across upland woodlands, at 0.2 miles; has the shortest length across bottomland/riparian and upland woodlands combined, at 0.2 miles; has the shortest length across NWI mapped wetlands, at 1.1 miles; and has the shortest length paralleling (within 100 feet to) streams or rivers (0.2 miles). And, like each of the primary alternative routes, Route 8: does not cross (or within 1,000 feet of) any parks or recreational areas; does not cross any lands irrigated by traveling systems (rolling or pivot type); does not cross any borrow pits, gravel pits, or quarries; is not within 10,000 feet of a private airstrip; is not within 5,000 feet of a heliport; is not within 10,000 feet of a public use airport having a runway greater than 3,200 feet; is not within 20,000 feet of a public use airport having a runway equal to 3,200 feet or less; is not within 200 feet of any water wells; is not within the foreground visual zone of any parks or recreational areas; crosses no known/occupied habitat of federally endangered or threatened species; crosses no NRHP-listed cultural resource sites, and is not located within 1,000 ft of any cultural NRHP-listed cultural resource sites. Based on this review and evaluation, ETI determined that each of the primary alternative routes was a feasible and acceptable alternative. 18. Public Meeting or Public Open House: Provide the date and location for each public meeting or public open house that was held in the accordance with P.U.C. PROC. R Provide a summary of each public meeting or public open house including the approximate number of attendants, and a copy of any survey provided to attendants and a summary of the responses received. For each public meeting or public open house provide a description of the method of notice, a copy of any notices, and the number of notices that were mailed and/or published. 13

14 ETI hosted a public meeting within the community to solicit comments, concerns and input from residents, landowners, public officials, and other interested parties. The purpose of this meeting was to: Promote a better understanding of the proposed project, including the purpose, need, potential benefits and impacts, and the PUC CCN application approval process; Inform the public with regard to the routing procedure, schedule, and decision-making process; and Ensure that the decision-making process adequately identifies and considers the values and concerns of the public and community leaders. The public meeting was held on July 15, 2014, from 4:00 p.m. to 7:00 p.m. at Little Cypress-Mauriceville ISD Administration Board Room, located at the intersection of FM 3247 and FM 1130 in Orange, Texas. Invitation letters were sent to landowners who owned property within 300 feet from the preliminary alternative route segments. ETI mailed 248 public meeting invitation letters to these landowners. Each landowner that received an invitation letter also received a map of the study area depicting the preliminary alternative route segments. At the meeting, regulatory representatives, customer service representatives, engineers, GIS analysts, and biologists were available from ETI and POWER to answer questions regarding the project. Manned information stations were set up that provided typical 230 kv pole types, a list of agencies contacted, land-use and environmental criteria for transmission lines, and an environmental and land use constraints map on aerial base. POWER also provided two GIS interactive stations operated by GIS analysts. These computer stations allowed attendees to view more detailed digital maps of alternative route segments and submit comments digitally and spatially. The information station format is advantageous because it facilitates one-on-one discussions and encourages personalized landowner interactions. Individuals in attendance were asked to sign their name on the sign-in sheet and were provided two handouts. The first handout was an information brochure that provided general information about the proposed project. The second handout was a questionnaire that solicited comments on the proposed project and an evaluation of the information presented at the public meeting. Individuals were asked to fill out the questionnaire after visiting the information stations and speaking with POWER and ETI representatives. Copies of the public notice letter with a map, brochure, and questionnaire are located in Appendix B of the EA. ETI sent 248 invitation letters to landowners. A total of 36 individuals signed the public meeting sign-in sheet with 16 individuals submitting questionnaire responses at or after the public meeting. This total represents approximately 44 percent of the individuals that signed in at the open house and 6 percent of the individuals that received an invitation letter. Results from the questionnaires were reviewed and analyzed, and most of the respondents agreed that the need for the Project was adequately explained. Section 6.0 in the EA discusses the public meeting and provides a summary of questionnaire responses. 19. Routing Maps: Base maps should be a full scale (one inch = not more than one mile) highway map of the county or counties involved, or other maps of comparable scale denoting sufficient cultural and natural features to permit location of all routes in the field. Provide a map (or maps) showing the study area, routing constraints, and all routes or line segments that were considered prior to the selection of the routes. Identify the routes and any existing facilities to be interconnected or coordinated with the project. Identify any taps, ties, meter points, or other facilities involving other utilities on the routing map. Show all exiting transmission facilities located in the study area. Include the locations of radio transmitters and other electronic installations, airstrips, irrigated pasture or cropland, parks and recreational areas, historical and archeological sites (subject to the instructions in Question 27), and any environmentally sensitive areas (subject to the instructions in Question 29). Provide aerial photographs of the study area displaying the date that the photographs were taken or maps that show (1) the location of each route with each route segment identified, (2) the locations of all major public roads including, as a minimum, all federal and state roadways, (3) the locations of all known habitable structures or groups of habitable structures (see Question 19 below) on properties directly affected by any route, and (4) the boundaries (approximate or estimated according to best available information if required) of all properties directly affected by any route 14

15 For each route, cross-reference each habitable structure (or group of habitable structures) and directly affected property identified on the maps or photographs with a list of corresponding landowner names and addresses and indicate which route segment affects each structure/group or property. Base Maps The map in Appendix C of the EA, titled Primary Alternative Route Segments with Constraints, produced at a scale of 1 inch = 1,500 ft., is provided in a map pocket in the EA. This map was produced using a USGS topographic base. This map depicts the study area for the project, locations of radio transmitters and other electronic installations, airports/airstrips, parks and recreational areas, historical sites, environmentally sensitive areas and other constraints. The maps also contain the alternative route segments for the project. For protection of the archaeological sites they are not shown on the map. The map in Appendix D of the EA, entitled Habitable Structures and Other Land Use Features in the Vicinity of the Primary Alternative Routes, which consists of aerial photography produced at a scale of 1 inch = 600 ft., is provided in a map pocket in the EA. The aerial photo-based maps include the locations of all known habitable structures located within 300 feet of the centerline of primary alternative routes on properties directly affected by the project. The habitable structures and other land use features map was produced using aerial imagery provided by the National Agriculture Imagery Program and was flown during the agricultural growing season of Base maps include sufficient cultural and natural features to permit location of the alternative routes in the field, and they depict existing electric transmission lines and substations (based on information available to POWER), and major public roads located within the study area, as applicable. Maps showing the study area and all segments that were presented at the open house meeting and considered prior to the selection of the primary alternative routes are presented in the EA. See specifically map Figure 2-2 and maps located in Appendices C and D. Directly Affected Property Maps Attachment 4 to this application includes a mapbook of 76, 11x17 sheets (utilizing aerial photography) titled Location of Directly Affected Properties, that identify directly affected properties, tract IDs, and the location of habitable structures (including labels) within 300 feet of the centerline of the transmission line alternatives from the Hartburg Substation to the proposed Chisholm Road Substation and approximate parcel boundary lines. These maps show the location of each proposed alternative route with each route segment identified, and the locations of all major public roads including all federal and state roadways. Attachment 5 to this application is a list of the owners of directly-affected properties and cross-references each habitable structure, or group of habitable structures, and directly-affected properties identified on the maps provided in Attachment 4 with a list of parcel/tract IDs and corresponding landowner names and addresses. Landowner names and addresses were obtained by review of information obtained from the Orange and Newton County Tax Appraisal Districts. ETI has also provided notice to landowners who received notice of ETI s Open House held for this project, but who are not directly affected as defined under P.U.C. PROC. R Permits: List any and all permits and/or approvals required by other governmental agencies for the construction of the proposed project. Indicate whether each permit has been obtained. The following permits/approvals will be obtained after PUC approval, but prior to the commencement of construction: 1. Where the proposed transmission line crosses a state-maintained road or highway, ETI will obtain a permit from TxDOT. If any portion of the transmission line will be accessed from a state-maintained road or highway, ETI will obtain a permit from TxDOT. 2. Where the proposed transmission line crosses Sabine River Authority (SRA) ROW, ETI will obtain a permit from SRA and will maintain necessary clearances when paralleling SRA ROW. 3. Where the proposed transmission line crosses through floodplains, ETI will obtain a floodplain permits from Newton and Orange Counties as needed prior to construction. 4. If more than one acre will be disturbed during construction of the project, a Storm Water Pollution Prevention Plan (SWPPP) will be prepared; and if more than five acres will be disturbed, a Notice of 15

16 Intent (NOI) will be submitted by ETI to the Texas Commission on Environmental Quality (TCEQ). The controls specified in the SWPPP will be monitored in the field. 5. Upon PUC selection of an approved transmission line route, ETI will conduct an assessment of the approved route to determine the need for any permits, or regulatory approvals that may be required from the U.S. Army Corps of Engineers (USACE), Texas Historical Commission (THC), and/or the U.S. Fish and Wildlife Service (USFWS). 6. ETI will report the transmission line project to the PUC on ETI s Monthly Construction Progress Report, beginning with the first report following the filing of a CCN application, and in each subsequent monthly progress report until construction is completed and actual project costs have been reported 7. The Texas General Land Office (TGLO) requires a miscellaneous easement for ROW across, through, and under state owned riverbeds and beds of navigable streams or tidally influenced waters. ETI will coordinate with the TGLO as needed after PUC approval of a route. 8. Where the proposed transmission line crosses a railroad, ETI will obtain a permit from the appropriate railroad authority. 21. Habitable structures: For each route list all single-family and multi-family dwellings and related structures, mobile homes, apartment buildings, commercial structures, industrial structures, business structures, churches, hospitals, nursing homes, schools, or other structures normally inhabited by humans or intended to be inhabited by humans on a daily or regular basis within 300 feet of the centerline if the proposed project will be constructed for operation at 230kV or less, or within 500 feet of the centerline if the proposed project will be constructed for operation at greater than 230kV. Provide a general description of each habitable structure and its distance from the centerline of the route. In cities, towns or rural subdivisions, houses can be identified in groups. Provide the number of habitable structures in each group and list the distance from the centerline of the route to the closet and the farthest habitable structure in the group. Locate all listed habitable structures or groups of structures on the routing map. The locations of habitable structures within 300 feet of the route centerline are listed and described with the direction and approximate distance from the route centerline in Section 7.1 Tables 7-2 through 7-9 of the EA and are shown on the Habitable Structures and Other Land use Features in the Vicinity of the Primary Alternative Routes map in Appendix D of the EA. The total numbers of habitable structures and newly affected habitable structures within 300 feet of each of the 8 primary alternative routes are provided in the table below. Newly affected habitable structures are habitable structures within 300 feet of an alternative route that are not currently affected by an existing transmission line. Primary Alternative Route Total Number of Habitable Structures within 300 feet of the Route Centerline Total Number of Newly Affected Habitable Structures within 300 feet of the Route Centerline Electronic Installations: For each route, list all commercial AM radio transmitters located within 10,000 feet of the center line of the route, and all FM radio transmitters, microwave relay stations, or other similar electronic installations located within 2,000 16

17 of the center line of the route. Provide a general description of each installation and its distance from the center line of the route. Locate all listed installations on a routing map. As shown in table 4-1 of the EA, the number of AM radio transmitters identified within 10,000 feet of the alternative routes ranges from zero (0) for alternative routes 1 through 7, to three (3) for Route 8. The number of FM radio transmitters, microwave towers, or other similar electronic installations within 2,000 feet of the alternative route centerlines ranges from one (1) for routes 1 through 7 of the alternative routes, to three (3) on Route 8. A listing, description, and approximate distance from the centerline for each of the primary alternative routes are presented in Section 7.1, Tables 7-2 through 7-9 of the EA, and the locations of these electronic installations are shown on the Habitable Structures and Other Land use Features in the Vicinity of the Primary Alternative Routes map in Appendix D of the EA. A list of each of the installations, nearest segment, and distance from nearest segment is provided in the table below. APPENDIX D MAP ID TOWER TYPE NEAREST SEGMENT DISTANCE FROM NEAREST SEGMENT (FEET)* 150 AM radio transmitter T 9, AM radio transmitter T 9, AM radio transmitter T 9, Other electronic installation (microwave) BB Other electronic installation (microwave) T 1, Other electronic installation (microwave) T 1,299 For additional information on electronic installations see Section and Section of the EA. None of the routes filed in this Application are anticipated to have any impact on the communication towers. 23. Airstrips: For each route, list all known private airstrips within 10,000 feet of the center line of the project. List all airports registered with the Federal Aviation Administration (FAA) with at least one runway more than 3,200 feet in length that are located within 20,000 feet of the center line of any route., For each such airport, indicate whether any transmission structures will exceed a 100:1 horizontal slope (one foot in height for each 100 feet in distance) from the closet point of the closet runway. List all listed airports registered with the FAA having no runway more than 3,200 feet in length that are located within 10,000 feet of the center line of any route. For each such airport, indicate whether any transmission structures will exceed a 50:1 horizontal slope from the closet point of the closet runway. List all heliports located within 5,000 feet of the center line of any route. For each such heliport, indicate whether any transmission structures will exceed a 25:1 horizontal slope from the closet point of the closest point of the closest landing and takeoff area of the heliport. Provide a general description of each listed private airstrip, registered airport, and heliport; and state the distance of each from the center line of each route. Locate and identify all listed airstrips, and heliports on a routing map. POWER s review of federal and state aviation/airport maps and directories, aerial photo interpretation and reconnaissance surveys, as well as information received from the TxDOT Division of Aviation, indicated that there are no known private airstrips within 10,000 feet of any of the alternative routes, there are no FAA-registered public or military use airports within 10,000 or 20,000 feet of the alternative routes, and there are no heliports located within 5,000 feet of the of the centerline of any of the alternative routes. 24. Irrigation System: For each route identify any pasture or cropland irrigated by traveling irrigation system (rolling or pivot type that will be traversed by the route. Provide a description of the irrigated land and state how it will be affected by each route (number and type of structures etc.) Locate any such irrigated pasture or cropland on a routing map. None of the alternative routes traverse lands irrigated by traveling irrigations systems (rolling or pivot type). 17

18 25. Notice: Notice is to be provided in accordance with P.U.C. PROC. R A. Provide a copy of the direct notice to owners of directly affected land. Attach a list of the names and addresses of the owners of directly affected land receiving notice. Please See Attachment 6. For the list of names and addresses of the directly affected landowners receiving notice see Attachment 5. B. Provide a copy of the written notice to utilities that are located with five miles of the routes. There are no utilities within five miles of the routes. C. Provide a copy of the written notice to county and municipal authorities. Please See Attachment 7. D. Provide a copy of the notice that is to be published in newspapers of general circulation in the counties in which the facilities are to be constructed. Attach a list of the newspapers that will publish the notice for this application. After the notice is published, provide the publisher s affidavits and tear sheets. Please See Attachment 8. ETI also provided notice to pipelines crossed by the proposed routes. Please see Attachment 9 for ETI s notice to pipelines. For a CREZ application, in addition to the requirement of P.U.C. PROC. R the applicant shall, not less than twenty=one (21) days before the filing of the application, submit to the Commission staff a generic copy of each type of alternative published and written notice for review. Staff s comments, if any, regarding the alternative notices will be provided to the applicant not later than seven days after receipt by Staff of the alternative notices, Applicant may take into consideration any comments made by Commission staff before the notices are published or sent by mail. 26. Parks and Recreation Areas: For each route, list all parks and recreational areas owned by a governmental body or an organized group, club, or church and located within 1,000 feet of the center line of the route. Provide a general description of each area and its distance from the center line. Identify the owner of the park or recreational area (public agency, church, club, etc.). List the sources used to identify the parks and recreational areas. Locate the listed sites on a routing map. POWER reviewed U.S. Geological Survey topographic maps, TxDOT county highway maps, various state, local, and federal sources, recent aerial photography, and conducted field reconnaissance to identify parks and recreation areas. Based on this review, POWER identified no parks or recreational areas located within 1,000 feet of the centerline of the primary alternative routes. 27. Historical and Archeological sites: For each route, list all historical and archeological sites known to the within 1,000 feet of the center line of the route. Include a description of each site and its distance from the center line. List the sources (national, state or local commission or societies) used to identify the sites. Locate all historical sites on a routing map. For the protection of the sites, archeological sites need not be shown on maps. Information from the Texas Historical Commission s (THC) Texas Archeological Sites Atlas (TASA) was acquired in addition to GIS shapefiles acquired from the Texas Archeological Research Laboratory (TARL) of the University of Texas at Austin to identify and map locations of previously recorded cultural (archeological and historical) resources within the study area. TxDOT s historic bridges database was also reviewed for bridges that are listed or determined eligible for listing on the National Register of Historic Places (NRHP). At the national level, National Park Service websites and data centers were reviewed to identify locations and boundaries for nationally designated historic landmarks, trails and battlefield monuments. The distance of each recorded cultural resource located within 1,000 feet from the nearest route was measured using GIS software (see Table 4-7 of the EA). No archeological sites are recorded within the ROWs of the alternative 18

19 routes. One archeological site, 41OR91, is mapped within 1,000 feet of the proposed alternative route centerlines. Site 41OR91, the remains of an historic kiln, is mapped as a point approximately 89 feet southeast of the alternative routes 1and 2 centerlines. The site is described as being 38 x 30 meters (approximately 125 x 98 feet), so it is likely to extend into the ROW. It has not been determined if the site meets the criteria for listing on the NRHP. One cemetery, the Wilkinson Cemetery, is located approximately 925 feet east of the centerlines of Alternative Routes 6 and 7. No National Register properties, National Register-listed or eligible bridges, cultural resources determined eligible for listing on the National Register, Historic Texas Cemeteries, or State Archeological Landmarks (SALs) are recorded within the alternative route ROWs, or within 1,000 feet of the alternative routes. No adverse impacts are anticipated for any of the previously recorded cultural resources from any of the alternative routes. It is anticipated that potential impacts to these sites will be mitigated through careful selection of routing alternatives and/or engineering design (spanning) and construction measures that will avoid direct impacts to the sites. Refer to Sections 3.8 and 4.8 for further discussion regarding cultural resources. No adverse impacts are anticipated for any of the previously recorded cultural resources from any of the alternative routes. It is anticipated that potential impacts to these sites will be mitigated through careful selection of routing alternatives and/or engineering design (spanning) and construction measures that will avoid direct impacts to the sites. 28. Coastal Management Program: For each route, indicate whether the route is located, either in whole or in part, within the coastal management program boundary as defined in 31 T.A.C If any route is, either in whole or in part, within the coastal management program boundary, indicate whether any part of the route is seaward of the Coastal Facilities Designation Line as defined in 31 T.A.C (a)(21). Using the designations in 31 T.A.C (b), identify the type(s) of Coastal Natural Resource Area(s) impacted by any part of the route and/or facilities. No part of any alternative route is located within the Coastal Management Program boundary, as defined in 31 T.A.C Environmental Impact: Provide copies of any and all environmental impact studies and/or assessments of the project. If no formal study was conducted for this project, explain how the routing and construction of this project will impact the environment. List the sources used to identify the existence or absence of sensitive environmental areas. Locate any environmentally sensitive areas on a routing map. In some instances, the location of the environmentally sensitive areas or the location of protected or endangered species should not be included on maps to ensure preservation of the areas or species. Within seven days after filing the application for the project, provide a copy of each environmental impact study and/or assessment to the Texas Parks and Wildlife Department (TPWD) for its review at the address below. Include with this application a copy of the letter of transmitted with which the studies/assessments were or will be sent to the TPWD. Wildlife Habitat Assessment Program Wildlife Division Texas Parks and Wildlife Department 4200 Smith School Road Austin, Texas Please see the EA. The EA describes the natural resources, cultural resources, land uses, and other sensitive areas that may occur in the project area. The EA also describes how the proposed project may impact the environment. Specifically, the EA includes data obtained from TPWD including the Texas Natural Diversity Database (TXNDD) and a list of Ecologically Significant Stream Segments (ESSS) in the study area. 30. ETI will provide a copy of the EA to TPWD within seven days after the application is filed. A copy of the letter of transmittal of the EA to TPWD is provided as Attachment 10 to this application. An affidavit confirming that the letter of transmittal and a copy of the EA were sent to TPWD will be filed with the PUC. Affidavit Attach a sworn affidavit from a qualified individual authorized by the applicant to verify and affirm that, to the best of their knowledge, all information provided, statements made, and matters set forth in this application and attachment are true and correct. 19