BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND
IN THE MATTER OF THE APPLICATION ) OF THE POTOMAC EDISON COMPANY ) FOR A CERTIFICATE OF PUBLIC ) CONVENIENCE AND NECESSITY TO ) Case No. ______MODIFY THE RINGGOLD-CATOCTIN ) TRANSMISSION LINE IN FREDERICK AND ) WASHINGTON COUNTIES, MARYLAND )
APPLICATION FOR GRANT OR WAIVER OF A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY
Pursuant to Section 7-207 of the Maryland Public Utility Companies Article of the
Maryland Annotated Code (2010) (“PUC”), and Title 20, Subtitle 79 of the Code of Maryland
Regulations (“COMAR”), The Potomac Edison Company (the “Applicant” or “Potomac
Edison”) submits this application (the “Application”) to the Maryland Public Service
Commission (the “Commission”) for a Certificate of Public Convenience and Necessity
(“CPCN”) requesting authorization to modify an existing transmission line located in Frederick
and Washington Counties. The modifications will include rebuilding an existing single-circuit
138 kV transmission line to a 230kV transmission line that traverses a 9.8-mile stretch between
Ringgold Substation and Catoctin Substation. Potomac Edison’s proposed rebuild will mitigate
thermal reliability violations of both FirstEnergy and PJM planning criteria that would be at risk
of occurring beginning in 2020.
In the alternative, because this project involves an existing overhead transmission line,
the Company respectfully requests that the Commission waive the requirement to obtain a CPCN
pursuant to PUC Section 7-207(b)(3)(ii), of the Maryland Code. Potomac Edison offers this
Application and the accompanying testimony to demonstrate good cause why the waiver should
be granted. I. INTRODUCTION
The Ringgold-Catoctin Transmission Line Project (the “Project”) will rebuild an existing single-circuit 138 kV transmission line to a single-circuit 230 kV transmission line.1 The line as rebuilt would also support future double-circuit 230 kV operation to provide further reinforcement to maintain reliability.2 This Project encompasses the transmission line route beginning at
Ringgold Substation, located near Smithsburg, Maryland, and traversing in an easterly direction
for 9.8 miles to Catoctin Substation, located near Thurmont, Maryland. See Project Map at
Exhibit 1.
Potomac Edison is proposing to construct the rebuild almost entirely within the existing transmission line ROW. However, only the first 0.8 miles of the line, beginning at Ringgold
Substation and ending at the seventh structure, will be relocated slightly to avoid two locations where the line crosses under an existing double-circuit 230 kV tower line. Specifically, the existing Frostown Junction (Boonsboro-Doubs-Ringgold) 230 kV line and the Monocacy-
Ringgold 230 kV line will be transferred to new, double-circuit steel poles for the first few spans out of Ringgold Substation. After the first 0.8 miles, the two centerlines will diverge, and these lines will transfer back to the existing tower line. Avoiding the two crossing locations is advantageous because it eliminates the need to install taller line structures at the crossing locations and, although it would be a rare occurrence, it removes the potential for a conductor of the upper circuits to fall into the lower circuits. Also, at Catoctin Substation, an additional 0.1-
1 Separate from the Ringgold-Catoctin rebuild, a new Garfield Substation is planned for the approximate midpoint of this transmission line as part of local distribution reliability upgrade. Potomac Edison will file a waiver request to build a tap line for this new substation; the Company currently expects to make that filing in the first part of 2018.
2 Potomac Edison will file a new CPCN application with the Commission if, in the future, the Company determines that a second 230 kV line should be added.
-2- mile line segment will be added, entirely on substation property owned by Potomac Edison, to terminate the line into the relocated deadend structure.
Both the Ringgold and Catoctin Substations will require modifications to accommodate this Project. Ringgold Substation will be expanded by approximately 180 feet by 264 feet on property owned by Potomac Edison, and Catoctin Substation will be expanded by approximately
120 feet by 310 feet also on property owned by Potomac Edison. Both expansions and associated equipment will allow for the conversion of the Project to 230kV. The relocated
Monocacy-Ringgold and Frostown Junction (Boonsboro-Doubs-Ringgold) 230kV lines will terminate into new Ringgold Substation bay locations.
Because this project is a modification of existing transmission facilities, an analysis of alternative routes is not required. See COMAR 20.79.04.03(B). However, Potomac Edison did evaluate the existing line segments to determine if there were areas that would benefit from an alternate routing of the transmission line. The Company also evaluated the option to construct an entirely new 138 kV line between the Ringgold and Catoctin substations. As described more fully in the accompanying testimony, Potomac Edison determined that the modification proposed in this Application is the best and most economical solution to address the above-noted reliability issues and future needs. Notably, the project team concluded that the Catoctin Substation is situated in an area that would prevent the route from shifting in any direction due to significant congestion and development outside of its footprint.
The Project will address reliability concerns associated with the construction of the PJM
Market Efficiency 230 kV Transource Independence Energy Connection Project (“Transource
-3- Project”).3 In the 2016 PJM Regional Transmission Expansion Plan (“RTEP”) for the 2020 study year, PJM identified thermal reliability criteria violation of NERC Category P6 (previously
NERC Category C) contingencies for the (N-1-1) outage of the Eaglehead-Monocacy 230 kV line in conjunction with the Lime Kiln-Montgomery 230 kV line, if the Transource Project is built. Potomac Edison confirmed this thermal reliability criteria violation of 103% criterion limit. Furthermore, in the 2017 RTEP for the 2022 study year, PJM identified thermal reliability criteria violations of NERC Category P1 (previously NERC Category B), NERC Category P2
(previously NERC Category C), and NERC Category P6 (previously NERC Category C) contingencies for various outages that include (at a minimum) loss of a single Ringgold 230/138 kV transformer. Potomac Edison confirmed these thermal reliability criteria violations on the
Ringgold 230/138 kV transformers of up to 124% criterion limit. Potomac Edison’s proposed rebuild was confirmed by PJM as adequately addressing these thermal reliability criteria violations.
Potomac Edison respectfully requests that the Commission either waive the CPCN requirement for good cause shown or: (i) issue a procedural schedule that will permit the
Commission to enter a final order granting the CPCN not later than March 2019; and (ii) grant such additional authorizations, waivers, approvals and other relief as may be necessary to permit
Potomac Edison to begin the work needed to rebuild the Ringgold-Carroll transmission line and make the modifications described above. This Application is supported by the Direct Testimony of four witnesses, which are attached as Exhibits 2 through 5 to this Application.
3 The Transource Project is an overhead electric transmission project planned to be built in two segments. The west segment will be 25 miles in length, beginning at a new substation to be built in Franklin County, Pennsylvania, and terminating at the Ringgold Substation.
-4- II. INFORMATION REQUIRED UNDER COMAR 20.79.01.04
A. Name of the Applicant
The name of the applicant is The Potomac Edison Company.
B. Address of Applicant’s Principal Business Office
The principal business address is 800 Cabin Hill Drive, Greensburg, Pennsylvania 15601.
C. The Persons Authorized To Receive Notice
The persons authorized to receive notices and communications with respect to this
Application are:
Jeffrey P. Trout, Senior Corporate Counsel FirstEnergy Corp. 800 Cabin Hill Drive Greensburg, PA 15601 (724) 838-6621 [email protected]
and
Robin D. Leone Saul Ewing Arnstein & Lehr LLP 500 E. Pratt Street, 8th Floor Baltimore, MD 21202 (410) 332-8600 [email protected]
D. Locations at Which A Copy of This Application May Be Inspected By The Public
The public may inspect a copy of this Application at the following locations:
Smithsburg Library Thurmont Regional Library 66 West Water Street 76 East Moser Road Smithsburg, Maryland 21783 Thurmont, Maryland 21788
E. Local, State and Federal Government Agencies Having Authority to Approve or Disapprove the Construction or Operation of the Project
Potomac Edison will need to obtain a CPCN from the Maryland Public Service
Commission. In addition to consultations with multiple state and federal agencies, Potomac
-5- Edison will seek additional authorizations, approvals, review or consulatations from the
following agencies: U.S. Army Corps of Engineers, U.S. Fish and Wildlife Service, Federal
Aviation Administration, National Park Service, Maryland Department of Environment,
Maryland Historical Trust, Maryland Department of Natural Resources, Maryland State
Highway Administration, Frederick and Catoctin Soil Conservation District, Frederick County
Division of Planning and Permitting, Washington County Soil Conservation District,
Washington County Plan Review and Permitting Department, and the Town of Thurmont. For a
complete list of approvals sought, please refer to the Direct Testimony of Amanda B.
Habershaw, which accompanies this Application.
F. The Information Described Under COMAR 20.79.04.01 For Transmission Lines
See Part III below.
G. A General Description of the Transmission Line
As described in the Introduction, the Project consists of a modification to one line
segment along an existing corridor. Exhibit 1, which accompanies this Application, shows the
location of the existing transmission line and substation facilities associated with the Project.
The proposed rebuild will utilize almost all of the existing electric utility corridor and will
require a minor relocation of the first 0.8 miles of the line. Also, at Catoctin Substation, an
additional 0.1-mile line segment will be added, entirely on substation property owned by
Potomac Edison, to terminate the line into the relocated deadend structure. Currently, all 9.8
miles of the existing line is built on 80 wood pole structures. See Exhibit JPI-1, attached to the
Direct Testimony of Jeffrey P. Irons, which accompanies this Application. Based on preliminary
engineering, all of the existing wood H-frame structures will be replaced with self-supporting
steel poles (see Exhibits JPI-2 through JPI-5) that will generally be located within ten feet of the existing structures. The existing structures range in height from 48 to 84 feet (above-ground
-6- height), with an average height of 62 feet. For the rebuild, the new steel poles will range in
height from 95 to 130 feet (above-ground height), with an average height of 114 feet.
In addition to installing new poles and related equipment, the project team will modify
the Ringgold and Catoctin Substations. Both will require expansion on property owned by
Potomac Edison. Due to the substation expansions, minor alterations to the locations of two
existing 230 kV lines will be necessary and will require the acquisition of a small amount of
additional ROW.
H. An Implementation Schedule For The Project
The Project schedule is divided into three construction seasons: Spring 2019, Fall 2019
and Spring 2020. The project in-service date, as directed by PJM, is June 1, 2020.
I. The Environmental Information Required Under COMAR 20.79.04.04 For Transmission Lines
See Part VI below.
III. INFORMATION REQUIRED UNDER COMAR 20.79.04.01
A.(1) An Explanation of the Need for the Project In Meeting Demands For Service
As described in the Introduction, Potomac Edison is seeking approval to rebuild the
existing single-circuit 138 kV line to a single-circuit 230 kV line that will accommodate later
expansion to double-circuit 230 kV operation, if needed. The rebuild is needed to mitigate future
thermal reliability criteria violations of both FirstEnergy and PJM planning criteria that were
identified as part of PJM’s RTEP analysis related to construction of the Transource Project. This
rebuild is a proposed, criteria-driven electric reliability transmission enhancement to Potomac
Edison’s transmission system consisting of rebuilding the Ringgold-Catoctin 138 kV
transmission line and expanding the two substations at the terminal ends of the rebuilt line.
-7- The Direct Testimony of Andrew Horne, submitted with this Application, further describes the PJM and Potomac Edison studies that led to both entities determining that this project is required to maintain reliability in Western Maryland.
A.(2) A Description of the Effect of the Project on System Reliability and Stability
The project will increase the loadability on the existing 138 kV path by increasing the capacity of the path from the loop-fed Ringgold Substation to the presently loop-fed Catoctin
Substation. In addition, by upgrading the line to accommodate future, double-circuit 230 kV operation, the Project will prevent the occurrence of future potential reliability problems likely to arise from the increased flows through the circuit due to the addition of the Transource Project.
A.(3) A Description of the Consequences If the Project Is Not Approved
Failure to rebuild the path by the June 1, 2020 in-service date could result in thermal overloads on the Ringgold-Catoctin 138 kV line, electric grid congestion, curtailed generation, and reduced reliability for the surrounding area. This could result in potential outages for
Potomac Edison customers to mitigate the potential thermal violation, as well as increased electrical power costs for Maryland. Specifically, the project is necessary to mitigate:
(1) potential thermal overloads that are expected to occur once the Transource Project is built and upon the loss of the Eaglehead-Monocacy 230 kV line in conjunction with the Lime Kiln-
Montgomery 230 kV line beginning in 2020; and (2) potential thermal overloads that are expected to occur for various outages that include (at a minimum) loss of a single Ringgold
230/138 kV transformer beginning in 2022.
If these contingencies are incurred at or near system peak loading conditions after the
Transource Project is constructed, it is anticipated that the loading on the Ringgold-Catoctin 138 kV line will exceed the thermal criterion limit for the facility, potentially causing power
-8- interruptions for the customers served by the eastern half of Potomac Edison's system to mitigate
the thermal criterion condition. Customers in parts of Carroll, Frederick, Howard and
Montgomery counties could be without power until facilities could be returned to service. If the
Project is delayed or not approved, the risk of these conditions occurring will increase, as will the
severity of those conditions should these outages occur.
A.(4) An Explanation of the Cost Effectiveness of the Project, Including an Estimate of Capital Cost and Operating Cost
The current authorized budget for this project is $74.3 million for rebuilding the existing
transmission lines, including relocating or rearranging the lines where necessary, as well as for
necessary substation modifications. As described in the Direct Testimony of Andrew Horne, the
proposed modification is the most cost-effective alternative for addressing the identified needs.
A.(5) A Description of the Impact of the Project on the Economies of the State
Potomac Edison’s additional investment will result in a small increase to the tax base in
Frederick and Washington Counties. The real estate property tax for the first year following the
in-service date of the project is estimated to be roughly $2.2 million. The actual property tax
levied on Potomac Edison may be different from this estimate because it is based on a number of
factors, including assessed values of real and personal property, operating income and other
variables. Due to the modest size of the work force, Potomac Edison does not anticipate
significant taxes or spending associated with the work force, which is estimated at 20-30 workers
during the construction period.
IV. INFORMATION REQUIRED UNDER COMAR 20.79.04.02
A. Engineering and Construction Features
A complete description of the engineering and construction features of the Project,
including ROW dimensions and specific components of the line and circuits, is contained in the
-9- Direct Testimony of Jeffrey P. Irons, submitted with this Application. Briefly, this is a 9.8-mile
rebuild of an existing single-circuit 138 kV transmission line into a single-circuit 230 kV
transmission line, with construction of all but 0.8 miles occurring along the existing center line.
Aged, double-wood poles will be replaced with single, galvanized steel poles. On average, the
height of the new steel poles will be approximately 52 feet taller than the existing wooden
structures. Additionally, the width of the physical structures within the existing ROW will be
decreased by replacing the double-wood poles with a single steel structure and removing some
supporting guy wires. The decreased width of the structures will benefit active agricultural
fields, providing fewer obstacles and more crop area.
Each phase of the three-phase line will consist of a single conductor. For the majority of the
line, the three phases will be attached to the steel pole structures in either a vertical or delta phase
configuration. Currently, the conductors are attached in a horizontal configuration. The existing
conductor type is 336.4 thousand circular mils (“KCM”), 26/7 aluminum conductor steel
reinforced (“ACSR”), also known as linnet. The size and type of the proposed conductor is 1272
KCM, 45/7 ACSR, also known as bittern. The new conductors will have an increased diameter of approximately one-half inch, which results in an ampacity increase of approximately 386 percent when operated at 230 kV.
The Project will employ an average span length of 603 feet. The summer normal operating capacity of the rebuilt line will be 617 MVA at 230 kV.
B. Property Acquired or to be Acquired
Potomac Edison anticipates the need to acquire some additional property or ROW to
accommodate the relocation of the first 0.8 miles of the line. The amount of acreage needed for
this relocation is 0.60 acres.
-10- C. Access Roads For Construction or Maintenance
Construction access routes will be installed in accordance with the approved Soil Erosion and Sedimentation Control Plan and, where possible, will utilize existing roads, private farm lanes, private forest roads and similar paths. It is not typical Potomac Edison practice to install permanent access roads. Where new access routes are needed for construction, the routes will be re-graded to pre-construction contours and re-vegetated with appropriate vegetation upon completion of construction. If requested by the property owner, consideration will be given to allowing the access route improvements to remain in place. Further information regarding construction access associated with the Project appears in the Direct Testimony of Jeffrey P.
Irons.
D. Location and Identification of Sites From Which The Project Would Clearly Be Visible
Because the Project is a rebuild in an area where the rolling and incised terrain creates limited visibility, the viewshed impacts of the proposed structures are anticipated to be minor. In general, there will be only minor changes to the physical attributes associated with the ROW and, therefore, little impact to the present landscape. Based on Potomac Edison’s assessment, the Project will have an insignificant viewshed impact on some historic and natural resources.
Specifically, the line is visible where it crosses through Cunningham Falls State Park, as well as from the Appalachian National Trail and the Ridenour Swamp Wildlife Management Area, but the line has been visible in these areas since it was constructed in the 1950s. Further information regarding visual impacts associated with the Project and the results of a viewshed analysis appears in the Direct Testimony of Amanda B. Habershaw.
-11- E. Construction Within the 100-Year Floodplain
Currently, there are no structures located within a 100-year floodplain, although final
engineering and new poles may require relocation of structures to the floodplain. In the event
structures will be located within the floodplain, applicable permits and approvals will be secured
prior to construction. Additionally, direct impacts to streams are expected to be avoided during
construction using culverts, temporary bridges, and matting.
F. Location and Identification of Public Airports Within One Mile of the Line
The Project is not located within one mile of any public airport.
G. Depiction on Topographical Map
The required map is filed with this Application as Exhibits ABH-1a and ABH-1b
(confidential) to the Direct Testimony of Amanda B. Habershaw.
V. INFORMATION REQUIRED UNDER COMAR 20.79.04.03
A. Description of Each Alternative Route Considered
Due to the fact that this project is a modification to an existing transmission line, under
COMAR 20.79.04.03.B, alternative routes need not be evaluated. However, the project team
evaluated the existing line segments to determine if there were areas that would benefit from an
alternate routing of the transmission line, as well as considered the option of constructing a new
138 kV line between the two substations. The Company determined that the use of the existing
route, with the slight modifications proposed, offers significant advantages over alternative
routes or an entirely new line. Details concerning the scope of the project team’s assessment and
its methodology can be found in the Direct Testimony of Amanda B. Habershaw and of Andrew
P. Horne.
-12- VI. INFORMATION REQUIRED UNDER COMAR 20.79.04.04
A. General Description of the Physical, Biological, Aesthetic and Cultural Features, and Conditions of the Site and Adjacent Areas
With respect to existing physical and biological features and conditions, the central and
western regions of Maryland are home to an assortment of wildlife habitat, ranging from
mountainous, hardwood forests in the west to flat, open agricultural and intermittent, wooded
areas in the Piedmont to the east. A variety of wildlife species are found throughout these
habitats, including several species of common game mammals and birds. The ROW corridors
provide foraging and nesting habitat for edge-adapted species, rare plant refugia, nesting and
hunting sites for raptors, botanical diversity for invertebrate species, and other advantages.
These corridors are occasionally home to threatened and endangered species because of the
limited presence of this type of habitat in surrounding areas. Consultations with relevant
agencies are under way to determine if any such species are rare, threatened or endangered and
to minimize impacts to species and their habitat within the Project ROW.
Within the Project area, incised streams cut through the mountainous areas while
wetlands and slower-moving tributaries predominate the less mountainous areas around the
Ringgold and Catoctin Substations. The Thurmont Watershed is located approximately
0.25-mile south of the existing ROW on the western end of the Project, and preliminary analysis
indicates that there are ten streams that cross through the ROW, with approximately 1,257 linear
feet of streams existing within the ROW. Additionally, the existing ROW crosses through
approximately 1.091 acres of wetlands, none of which are included in the National Wetlands
Inventory. Only one wetland of special state concern is located within the ROW itself, inside the
Ridenour Swamp area, which is preserved in a Heritage Conservation Fund Site for educational
purposes. Another property crossed by the ROW has a conservation easement in place for
-13- protection of headwaters, agricultural land, and viewshed, as a Maryland Environmental Trust property. The existing transmission line predates the conservation deeds associated with both locations.
With respect to existing aesthetic and cultural features and conditions, several rural, recreational and agricultural areas, along with churches, libraries and other institutional features, are located in the Project area. Ecological and recreational features include Catoctin Mountain
Park, Cunningham Falls State Park, South Mountain State Park, the Catoctin Mountain
Greenways and Catoctin Trail, and the South Mountain Greenways. The South Mountain
Natural Environmental Area, which encompasses a portion of the Appalachian Trail, and the
Ridenour Swamp Wildlife Management Area directly intersect with the Project ROW. Finally, a review of cultural resource files maintained by the Maryland Historical Trust (“MHT”) identified
17 recorded cultural resources within 0.25-mile of the Project, consisting of 5 surveyed historic architectural resources and 12 archaeological sites. These historic architectural resources include the Thurmont Historic District, an NRHP-eligible historic district with its southern boundary terminating within the Project ROW, and the Heart of the Civil War Heritage Area, which surrounds Thurmont. Significant archaeological features include two sites that have been recommended for NRHP listing.
Further information regarding the physical, biological, aesthetic and cultural features and conditions of the site and adjacent areas is provided in the Direct Testimony of Amanda B.
Habershaw.
B. Summary of the Environmental and Socioeconomic Effects of Construction and Operation of the Project
The impact of this project on the natural, cultural and historical features of the surrounding environment will be minimal because the Project predominantly uses the existing
-14- ROW. Significantly, the portion of the Project requiring new ROW is in a predominantly non- forested area near the Ringgold Substation; therefore only minor impacts to flora are anticipated.
Maintenance along the ROW will result in the clearing of some minimal trees and brush, which would be necessary whether or not the line is rebuilt. Additional vegetation removal necessary for construction and clearance will be limited to the existing ROW, identified danger trees and proposed temporary access roads. Maintenance of ROW corridors will often mimic natural disturbances in the environment and create early successional habitats that are beneficial to certain species of flora and fauna. These corridors are occasionally home to threatened and endangered species because of the limited presence of this type of habitat in surrounding areas.
Because the line is existing and the current, maintained ROW will be used for the most part, changes or additional impacts from construction to the habitat of these species are not expected.
Based on the design, which assumes the placement of structures in the same, or approximately the same, locations as existing structures, the Project is expected to have a relatively minor impact on streams, wetlands and other aquatic resources. Moreover, temporary access, construction staging and pole installation sites will be reviewed to avoid wetland and stream impacts to the extent practicable. However, steel pole construction requires more substantial access areas at the pole locations because of the equipment necessary for installation.
Concrete trucks, cranes, bucket trucks and ancillary vehicles must be able to access and move around the installation area. Temporary impacts from construction will be mitigated in accordance with the Maryland Stormwater Management Act and the Maryland Standards and
Specifications for Soil Erosion and Sediment Control regulations regarding stormwater management. As necessary, the project team will obtain the required authorizations from the
Maryland Department of the Environment and the U.S. Army Corps of Engineers
-15- With respect to socioeconomic effects, Potomac Edison anticipates that its additional investment will result in a small increase to the tax base in Frederick and Washington Counties.
The real estate property tax for the first year following the in-service date of the project is estimated to be roughly $2.2 million. The actual property tax levied on Potomac Edison may be different from this estimate because it is based on a number of factors, including assessed values of real and personal property, operating income and other variables. Because the construction workforce is not expected to exceed 60-70 workers during peak construction periods, Potomac
Edison does not anticipate a significant addition of taxes or spending associated with the workforce.
Further information regarding the environmental effects of construction and operation of the project is provided in the Direct Testimony of Amanda B. Habershaw, and further information regarding socioeconomic effects is provided in the Direct Testimony of John J.
Rostock, Jr.
C. A Copy of All Studies of the Environmental Impact of the Project
Reports of field delineations, including for streams and wetlands, will be provided once the survey work is completed.
D. A Statement of the Ability to Conform to the Applicable Environmental Standards
Potomac Edison confirms that it has the ability and will conform to the applicable environmental requirements.
VII. PUC § 7-209 ALTERNATIVES TO CONSTRUCTION OF TRANSMISSION LINES
Section 7-209 of the PUC Article requires that the Commission examine alternatives to the construction of a new transmission line in a service area, including the use of an existing transmission line of another company if that existing line is convenient to the service area or the
-16- use of that line best promotes economic and efficient service to the public. Although this is a modification of an existing line and not construction of a new line, as described more fully above and in the Direct Testimony of Andrew Horne, Potomac Edison has evaluated alternatives to the
Project, including modifications to segments of the existing line or construction of an entirely new 138 kV line, and has concluded that none of the alternatives will adequately address the identified violations as effectively and cost-efficiently as the proposed Project.
VIII. SUPPORTING DOCUMENTATION
A. Testimony in Support of the Project
Attached to and made a part of this Application as Exhibits 2 through 5 are the Direct
Testimony and exhibits of the following witnesses:
• Amanda B. Habershaw, Staff Scientist, will describe the existing transmission line route and discuss the environmental, land use, and visual impacts of the project on the surrounding environment.
• Jeffrey P. Irons, Supervisor, Transmission Design Group, will describe the engineering details of the proposed project.
• Andrew P. Horne, Supervisor, Transmission Planning, will discuss the purpose of and electrical necessity for the proposed project, including the specific facilities Potomac Edison proposes to modify; the need for the project in meeting demands for service; the effect of the project on system stability and reliability; the consequences if the Project is delayed or not approved; and the cost effectiveness of the project and the reason for its selection over other alternatives considered.
• John J. Rostock, Jr., Analyst V, Rates and Regulatory Affairs, will discuss project financing, cost allocation, and cost impact on residential customers, as well as the tax benefits to the state and local region resulting from this project.
This testimony, together with the Application, fully satisfies the requirements of Md. Code Ann.,
Pub. Util. Cos. § 7-207 and COMAR 20.79.04.
IX. CONCLUSION
Completion of the Project is required by June 1, 2020 to assure the reliability of Potomac
Edison’s regional system, including in parts of Frederick and Washington Counties. Based on
-17- the foregoing, Potomac Edison respectfully requests that the Commission issue a Certificate of
Public Convenience and Necessity for the Ringgold-Catoctin Transmission Line Project to
Potomac Edison as requested in this Application, and grant such additional authorizations,
waivers, approvals, and other relief as may be necessary, including the authority to rearrange
facilities to accommodate substation modifications and the authority to exercise condemnation, if
necessary, to permit the modification of the Ringgold-Catoctin Transmission Line.
In the alternative, Potomac Edison offers this Application and the accompanying
testimony as good cause for the Commission to waive the CPCN requirement pursuant to Md.
Code Ann., Pub. Util. Cos. § 7-207(b)(3)(ii).
Respectfully submitted,
______Robin D. Leone, Esquire Jeffrey P. Trout, Senior Corporate Counsel* Saul Ewing Arnstein & Lehr LLP FirstEnergy Corp. 500 East Pratt Street 800 Cabin Hill Drive Baltimore, MD 21202 Greensburg, PA 15601 (Phone) 410-332-8600 (Phone) 724-838-6621
* Not admitted to practice in Maryland.
-18-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd day of December, 2017, pursuant to COMAR 20.79.02.02, the foregoing Application of The Potomac Edison Company for a Certificate of Public Convenience and Necessity was mailed, postage prepaid, to the following:
Ben Grumbles, Secretary (four copies) Maryland Department of the Environment 1800 Washington Blvd. Baltimore, MD 21230
Wendi W. Peters, Secretary (one copy) Maryland Department of Planning 301 W. Preston Street, Suite 1101 Baltimore, MD 21201
Mark J. Belton, Secretary (six copies) Maryland Department of Natural Resources Tawes State Office Building 580 Taylor Avenue Annapolis, MD 21401
Mike Gill, Secretary (one copy) Maryland Department of Commerce 401 East Pratt Street Baltimore, MD 21202
Pete K. Rahn, Secretary (one copy) Maryland Department of Transportation 7201 Corporate Center Drive Hanover, MD 21076
Ricky D. Smith, Sr., Executive Director/CEO (one copy) Maryland Aviation Administration P.O. Box 8766 BWI Airport, MD 21240-0766
Gregory Slater, Administrator (one copy) Maryland State Highway Administration 707 North Calvert Street Baltimore, MD 21202-3601
Ryan Zinke, Secretary (one copy) U.S. Department of the Interior 1849 C Street, NW Washington, D.C. 20240
Kevin J. McIntyre, Chair (one copy) Federal Energy Regulatory Commission 888 First Street, NE Washington, D.C. 20426
Michael Huerta, Administrator (one copy) Federal Aviation Administration 800 Independence Avenue, SW Washington, D.C. 20591
Mary Beth Tung, Director (one copy) Maryland Energy Administration 1800 Washington Blvd., Suite 755 Baltimore, MD 21230
Paula M. Carmody, Esquire (one copy) Maryland Office of People’s Counsel 6 Saint Paul Street, Suite 2102 Baltimore, MD 21202
Greg Sheehan, Principal Deputy Director (one copy) U.S. Fish and Wildlife Service 1849 C Street, NW Washington, DC 20240
John A. Kinaird, Mayor (one copy) Board of Commissioners of the Town of Thurmont 615 East Main Street, P.O. Box 17 Thurmont, MD 21788
Chris Jakubiak, Town Planner (one copy) Thurmont Planning & Zoning 615 East Main Street, P.O. Box 17 Thurmont, MD 21788
Randy Cubbedge, Chairman (one copy) Planning and Zoning Commission Town of Thurmont 615 East Main Street, P.O. Box 17 Thurmont, MD 21788
Mildred Myers, Mayor (one copy) Smithsburg Town Council Smithsburg Town Hall 21 West Water Street, P.O. Box 237 Smithsburg, MD 21783
Randy Dick, Zoning Administrator (one copy) Smithsburg Planning & Zoning Dept. 21 West Water Street Smithsburg, MD 21783
Greg White, Chairman (one copy) Smithsburg Planning Commission Smithsburg Town Hall 21 West Water Street Smithsburg, MD 21783
Jan H. Gardner (one copy) Frederick County Executive Winchester Hall 12 East Church Street Frederick, MD 21701
Bud Otis, President (one copy) Frederick County Council Winchester Hall 12 East Church Street Frederick, MD 21701
Steven C. Horn, Director (one copy) Frederick County Division of Planning & Permitting 30 North Market Street Frederick, MD 21701
Anthony Bruscia, Chair (one copy) Frederick County Planning Commission Winchester Hall 12 East Church Street Frederick, MD 21701
Terry L. Baker, President (one copy) Washington County Commissioners 100 West Washington Street, Room 1101 Hagerstown, MD 21740
Stephen Goodrich, Director (one copy) Washington County Department of Planning and Zoning County Administrative Complex 100 West Washington Street, Suite 2600 Hagerstown, MD 21740
Clint Wiley, Chairman (one copy) Washington County Planning Commission County Administrative Complex 100 West Washington Street, Suite 2600 Hagerstown, MD 21740
______Robin D. Leone