BEFORE THE PUBLIC SERVICE COMMlSSlON

IN TH€ MATTER OF THE APPLICATION OF SOUTHWESTERN ELECTRIC POWER COMPANY 1 FOR A CERTIFICATE OF PUBLIC CONVENIENCE DOCKET NO. 06-172-U AND NECESSITY TO REBUILD AND CONVERT ITS EXISTING 69 KV TRANSMISSION LINE TU 161 KV 1 BETWEEN SWEPCO'S FAYETTEVILLE AND NORTH ) FAYETTEVILLE SUBSTATIONS, ALL LOCATED IN WASHINGTON COUNTY IN ARKANSAS

REBUTTAL TESTIMONY

OF GEORGE W. CARPENTER

March 16,2007 BEFORE THE ARKANSAS PUBLfC SERVICE COMMISSION

IN THE MATTER OF THE APPLICATION OF SOUTHWESTERN ELECTRIC POWER COMPANY I G FOR A GERTIFKATE OF PUBLIC CONVENIENCE 1 DOCKET NO.06- I 72. i AND NECESSfTY TO REBUILD AND CONVERT ITS ) 8 EXISTING 69 KV TRANSMlSSlON LINE TO 161 KV ) 9 BETWEEN SWEPCO’S FAYETTEVILLE AND NORTH ) 10 FAYETTEVILLE SUBSTATIONS, ALL LOCATED IN ) 11 WASHfNGTON COUNTY iN ARKANSAS 1

I2 REBUTTAL TESTIMONY OF GEORGE W. CARPENTER

13 Q. Please state your name.

14 A. My name is George W, Carpenter

1s Q. Are you the same George W. Carpenter that filed testimony previously

16 in this case?

17 A. Yes.

is Q. Are there corrections to your earlier filed testimony?

19 A. Yes. Throughout my testimony, I make reference to the mute study

20 pehrmed by P8S8J. f have been provided corrected pages 4-28 and 4-29

21 to that study. Those corrected pages are attached hereto and incorporated

22 into my orjginal Exhibit C as though set out therein word fur word.

23 Q. Have you had the opportunity to review the public comments and the

24 Petition to Intervene filed by Irene Pritchard and Thomas Brown?

25 A. Yes.

26 Q. In Attachment 1 to the Petition to Intervene filed by Irene Pritchard and

27 Thomas Brown, the statement is made that the “edge of town” route has

REBUlTAL TESTIMONY GEORGE W. CARPENTER an estimated cos4 of $9,572,036.00 to $t0,072,036.00. Is this cost

estimate accurate?

A. No, it is not. The "edge of town" mute suggested by PrifchardlBrown would

cost in excess of $15 million. The added cost for the transmission line aione

would be $12.f miIlion, In addition, there would be right-of-way costs of

approximatety $3.7 million, assuming acquisition of right-of-way at an average

1 of $50,000.00per acre. This estimate is likely conservative, with some data

8 supporting higher right-of-way costs that could double easement acquisition

9 costs, pushing total transmission costs to approximately $20 million.

10 Q. Are there other examples of above ground transmission lines traversing

11 cityscapes with which you are familiar?

12 A. Yes. Most cities have overhead transmission lines to provide reliable sources

t3 to their substations serving their distribution load, which are typically centrally

14 located mar the city's load centers. Most of these systems, like Fayetteville,

15 have evolved over time as the city grew and the electrical system developed

16 to meet the growing electrical demand.

17 Several cities of comparable size to Fayetteville in this region have

18 overhead transmission lines supplying their electrical needs. There are

19 transmission lines in downtown Little Rock, Arkansas along Markham Street,

20 which are even greater in size than the transmission line proposed in this

21 docket. Attached to this rebuttal testimony as Exhibit "A is a series of

12 photographs showing these transmission facilities in Little Rock.

REBUITAL TESTIMONY GEORGE W. CARPENTER 1 In Tulsa, Oklahoma there are 738 kV transmission overhead lines in

several downtown areas, some within two blocks of my office at Public

Service Company of Oklahoma, sister company to SWEPCO. Attached as

Exhibit “B” is a series of photographs, which depict the overhead transmission

5 fines in the greater downtown Tulsa area.

6 Shreveport, Louisiana, home of SWEPCO’s headquarters, also has

7 overhead transmission lines in the downtown area to serve electrical loads.

8 Attached as Exhibit ‘IC” is another series of photographs, which depict

9 transmission lines in downtown Shreveport in the Red River District along the

IO parkway and river. This is an entertainment district as well as the location for

It the recent fitming af several movies. These tines run directly in front of

12 several older buildings that have been renovated, as well as through the site

13 of Festival Plaza which is the location of several festivals throughout the year,

14 including the Red River Revel.

is Q. The City of Fayettevilte has suggested that the upgrade of the existing

1b transmission line with “larger more massive towers will impact the ‘view

17 shed’ of 01d Main”. Are the assertions of the City of Fayetteville

18 correct?

19 A, No. First, there is no plan to rebuild the existing 69 kV single pole line in the

20 Fayetteville project with towers, which usually refers to steel lattice towers

21 with multiple legs in contrast to a single pole design. The existing wooden

22 poles, averaging approximately 65 feet in height, will be replaced with single

23 steel poles, which are anticipated to average approximately 85 feet in height.

REBUTT A1 TEST1 MONY GEORGE W. CARPENTER 4of8 Second, the notion that the single steel poles replacing the existing

wood poles would ”impact the view shed of Old Main” fails to recognize that

other development is occurring in the area that will have a

significant impact to any “view shed”. This nation that the new steel pules,

being a few feet taller and a few inches greater in diameter than the existing

wood poles, would have a significant impact on the view of Old Main from

7 anywhere in the Dickson Street area is incorrect. In fact, this notion ignores

8 the fact that existing trees already mask the view of Old Main in most

9 locations and that new development in the Dickson Street area will in fact

10 result in a much greater impact to any view of Old Main and will help hide the

II view of the new poles. In order to allow the Commission and others to

12 visualize the change in appearance, I have commissioned the preparation of

13 simulated photographs which depict a before and after view of the proposed

14 transmission the in the Dickson Street area, in relationship to the evolution of

building development in the area. Attached hereto as Exhibit “D” is a series

of drawings which illustrate my point.

Lastly, attached to my testimony is a DVD, marked Exhibit “F” that

shows the view of Old Main (or lack thereof) a5 one walks and drives along

Dickson Street. Lafayette and Maple Streets in Fayetteville, Arkansas. In

20 fact, the view of Old Main would be much more substantially impacted by

II foltowing one of the alternate routes included in the routing study

22 commissioned by SWEPCO. One tine segment included in the route study

23 routed the line on Arkansas Street. directly in front of and at nearty the same

REBUITAL TESTIMONY GEORGE W. CARPENTER 5 of 8 elevation (instead of a block east and at a considerably lower elevation)

where the Old Main view would be much more impacted.

3 Q. Who prepared the DVD marked as Exhibit “F?”

4 A. This film was taken by Franklin Everts of Ozark Film and Video Productions.

5 3804 Kelley Avenue, Springdale, Arkansas, 72762 on Monday, March 12,

G 2007.

7 Q. Does Exhibit “F” accurately depict the conditions existing in

8 Fayetteville, Arkansas In the area which is the subject of this docket?

9 A. Yes, it does.

IO Q. Are there other projects in the City of Fayetteville that will impact the

11 view shed of Old Main?

12 A. Yes. There is presently under wnstruction a multistoried condominium

13 complex on Dickson Street called ‘The Lofts” on the southwest corner of

14 Gregg and Dickson streets. This complex will be taller than the typical

15 transmission poles that will be installed in the Dickson Street area. “The

16 Lofts” can been seen in the 3‘ picture of Exhibit “0” which is looking in a

17 southwesterly direction at the Gregg Street and Dickson Street intersection.

18 The model of ‘The Lofts” depicted herein is the exact model of the planned

19 building prepared by and supplied tu SWEPCO by the .

In addition, the City of Fayetteville officials have indicated that they anticipate an additional development on what is now the Mr. Tux property on

the nortt.lwest corner of Gregg and Dickson streets. This building is projected

to be at least 6 stories in height, making it approximately as tall as the

REBUTTAL TESTIMONY GEORGE W. CARPENTER 6of8 proposed new steel poles, and is depicted by a typical building model in the

4’ picture of Exhibit I’D.”

Also mentioned by the City of Fayetteville was the potential for a

multistory building on the southeast corner of Gregg and Dickson streets.

This potential development is depicted by a typical building model in the 5’

picture of Exhibit “0.” As can be clearly seen by the simulation, the

7 commercial building developments will, in most cases, be as tall or taller than

8 the proposed steel poles and will have a much greater impact to the area

9 ‘view shed”, as well as shield the transmission line.

10 Q. The City of Fayetteville has suggested that SWEPCO should bear the

11 cost of burying the transmission lines in the two and one half block area

I2 between Dickson Street and Maple Street. What is the estimated cost to

I3 bury the transmission lines for that distance? i? A. I’m told that costs to bury the electric facilities in this area should be estimated

15 in the $5 million range. This estimate does not include the cost to bury the

16 existing distribution lines, nor does it include the associated trenching costs.

17 Q, Is this a reasonable expense for all of the ratepayers of Southwestern

1s Electric Power Company to absorb?

19 A. No it is not. For customers throughout the state, or even in the other areas of

20 Fayetteville, to share the burden of burying overhead lines that have existed

11 for approximately 80 years for the benefit of 2 blocks would not be a

22 reasonable, or typical, distribution of costs. However, SWEPCO has

23 indicated for well over a year to the City of Fayetteviile that it would bury the

REBUlTAL TESTtMUNY GEORGE W. CARPENTER lines if the City of Fayetteville would bear the difference between the cost af

overhead construction and the cost of burying the transmission lines.

Q. Has the City of Fayetteville indicated any willingness to pay for the

added cost?

A. No. The local SWEPCO representatives have indicated the City has not

indicated it would bear this cost, as is also evidenced by the City's Petition to

7 Intervene wherein it states that costs should be borne by SW EPCO.

8 Q. If the transmission andlor distribution tines were to be buried in the two

9 and one half block area as described above, would that completely

10 eliminate any evidence of electrical transmission facilities in the

11 Dickson to Mapte Street area?

12 A. No, it would not. In order to bury transmission lines, there is a substantial

13 structure required at each terminus of the area buried. Also, distribution

I4 switchgear must be installed to distribute the electrical service to area homes

15 and businesses. Attached to this testimony as Exhibit "E" are a series of

16 photographs depicting a typical transmission transition structure from

17 overhead to underground. Similar structures would be located at the terminus

18 jn the Dickson Street area as well as in the Maple Street area. Exhibit "E"

19 also depicts typical distribution switchgear that must be installed, that is not

20 required with the present overhead distribution service. SWEPCO Witness

21 Floyd Hornaday also discusses distribution components in his testimony.

,Q- Does this conclude your testimony?

23 A. Yes.

REBUTTAL TESTIMONY GEORGE W. CARPENTER 8of8 CERTIFICATE OF SERVICE

I David R. Matthews, attorney for SWEPCO, state that I have on this l6 day of m,2007. served by electronic mail or mailed a true and correct copy of the above and foregoing instnrrnent to the following in the United States mail, postage prepaid:

H. Edward Skinner William C Adkisson Southwest Power Pout Inc. GRADDY & ADKISSON P.O. Drawer 947 P.O. Box 396 Arkadelphia, AR 77923 Conway, AR 72033

Chades M. Kester Kit Williams. City Attorney The Kester Law Firm City of Fayetteville P.O.Box 184 113 W. Mountain, Suite 302 Fayetteville, AR 72702-0184 Fayetteville, AR 72701-6083

Mr. Lori Burrows 1 rene Prichard APSC General Staff Thomas Brown do00 Center Street 339 North Gregg Ave. Little Rock, AR 72203 Fayetteville, AR 72701

Heather H. Starnes Regulatory Attorney Southwest Power Pool Inc. 415 n. McKinley, Suite 140 Little Rock, AR 72205 Document No. 060322 PBS&J Job No. 520799

ENVIRONMENTALASSESSMENT AND ALTERNATIVEROUTE ANALYSIS FOR THE PROPOSED FAYETTEVILLETO NORTH FAYETTEVILLE161-KV TRANSMISSIONLINE CONVERSIONPROJECT WASHINGTONCOUNTY, ARKANSAS

Prepared for:

Southwestern Electric Power Company Shreveport, Louisiana

Prepared by:

PBS&J 18383 Preston Road Suite 500 Dallas, 75252

December 2006 Revised March 2007

Printed on recycled paper the highest agricultural income in the state. Other important economic endeavors include education and industry. The University of Arkansas is the largest employer in the region.

4.9.6 IMPACTS

Prior to underthng any impacts andysis, the project historian conducted a limited records review. This review began with a search of the Arkansas Historic Preservation Program website, during which ten Nationa1 Register of Historic Places (NRHP) listed properties were identified on the University of Arkamis, Fayetteville campus. These included:

1. Agriculture Building 2. Business Administration Building (currently Ozark Hall j 3. Chemistry Building 4. Chi Omega Greek Theater 5. Ella Carnall Ha11 women’s dormitory and dining hall (cumntIy the Inn at Carnall Hall) 6. Home Economics Building (currentiy School of Human Environmental Sciences) 7. Old Men’s Gymnasium (was University Museum until 2003) 8. Old Main (currently I. William FuIbright College of Arts and Sciences) 9. Student Union Building (currently Memorial Hall) 10. Vol Waiker Hall (formerly library, currently houses the School of Architecture)

The numbers correspond to the approximate location of sites keyed on Figure 3-1 (revised March 8, 2007). Subsequently, the researcher explored the University of Arkansas website to locate the buildings and to identify any other resources with local designations. As a result of this search, the project historian discovered that there are thirty historical markers created by the university located within the study area.

The University website also provided information about the school’s farm, known as the Arkansas Agricultural Experiment Station (AAES). This facility comprises the majority of the campus’ “nortli grounds.” Though there are no state- or nationaIIy-designated resources in this area, the farm itself may be significant depending upon its level of historic integrity. An excerpt from the history of the experimental farm, available on the School of Agriculture’s homepage, reveals that the university was founded under the Morrill Act of 1862, making it an agricultural university. The AAES was established in 1888, and more research needs to be undertaken to detennine how much, if any, of the original complex and grounds are still intact.

In addition to sites on the campus, the researcher used the Arkansas Preservation Program website to identify twenty-eight individually listed National Register properties, including two cemeteries and a monument, and two National Register historic residential districts at other locations within the pro-ject area. These include:

5207991050323 4-28 11. Chi Omega Chapter House (940 Maple Street) 12. Evergreen Cemetery (comer of University and Williams Streets) 13. (550 W. Dickson Street) 14. Gregg House (339 N. Gregg Street) 15. Hantz House (855 Fairview Drive) 16. John S. Vest House (21 N. West Street) 17. Lewis Brothers Building (I S. Block Avenue) 18. Mrs. Young Building (5 S. Block Avenue) 19. Old Bank of Fayetteville BuiIding (100 W. Center Skeet) 20. Mount Nord Historic District (Mount Nord Avenue) 21. Rdge House (230 W. Center Street) 22. Strengthen the Arm of Libzrty Monument (North Street, northeast of Park Avenue) 33. Tharp House (1 5 N. West Avenue) 24. Troy Gordon House (9 E. Dickson Street) 25. Walker-Stone House (207 W. Center Street) 26. Villa Rosa (6 17 W. Eafayette Street) 27. Magnolia Company Filling Station (429 W. Lafayette Street) 28. Waterman-Archer House (2 148 Markham) 29. Wilson Park Historic District (bounded by College Avenue, Wilson Avenue, Maple Street, and Louise Street) 30. Fayetteville National Cemetery (700 Government Avenue) 3 1. CIack House (725 E.Dogwood Lane) 32. E. Fay and Gus Jones House (1330 N. Hiilcrest Avenue) 33. Guisinger Building (E. Mountain Street in the southeast corner of the Town Square) 34. Headquarters House (I I8 E. Dickson) 35. Lynn Shelton American Legion Post #27 (28 S. College Road) 36. Old Post Office (Tow Square) 37. Wade-Heenvagen House (338 Washington Avenue N.) 38. Washington County Courthouse (College Avenue and E. Center Street) 39. Washington County Jail (College Avenue and County Avenue) 40. Witson-Pittman-Campbell-GregoryHouse (405 E. Dickson Road)

Alternative 1 (No-Action) would have no impacts to existing culturaYhistonca1 sites in the study area.

520799J060323 4-29 ImJ Page revised March 8,20af Exhibit A Urban Transmission Lines Downtown Little Rock, AR Exhibit B Urban Transmission Lines Downtown Tulsa, OK

..'I.,.., , Exhibit C Urban Tmnsmission tines Downtown Shmvepart, LA Exhibit D Fayetteville Dickson Street Area View Shed Evolution

E

Exhibit E Electrical Transmission and Distribution Typical Underground FaciI ities

I

Typical I2kV 1;5 I Amp Switchgear

"I ....C ISigma Chi Potential Switchgear Site