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Best Regards, I /;,Rm Daniel P DANIEL P. DUTHIE Attorney and Counselor at Law P.O. BOX 8 BELLVALE,I{Y 10912 .i'i;?li;[ii,, duthie@strate gicoower.com February 28,2020 Hon. Michelle Phillips Secretary NYS Public Service Commission 3 Empire State Plaza Albany, NY 12223-1350 Administrative Law Judge Anthony Belsito Department of Public Service Commission Staff 3 Empire State Plaza Albany, NY 12223-1350 Case 19-T-0684 - NY Transco Article VII Application Dear Secretary Phillips and Judge Belsito: Please find attached Form RFIF, Request for Intervenor Funding on behalf of the Towns of Livingston, Milan and Pleasant Valley along with Farmers and Friends of Claverack; Farmers and Friends of Livingston and Walnut Grove Farm. There are supporting Appendices A through L that will be separately e-mailed due to size constraints. I inadvertently left out Farmers and Friends of Claverack from the Form RFIF so I will correct that error and resend. Best regards, i /;,rM Daniel P. Duthie DPD:bsb cc:: Parties Form RFIF (3123117) Request for lntervenor Funds for use in PSL Article Vll Proceedinq lnstructions: Provide allapplicable information by filling in thetext boxes as indicated. lf necessary, attach additional information in a separate document. This request is to be submitted either electronically (preferred)or by regular mail. To submit this request electronically, save your changes and attach it to an e-mail sent to: [email protected] To submit this request by regular mail, print it and mail it to: Secretary NYS Public Service Commission 3 Empire State Plaza Albany, NY 12223-1350 PLEASE NOTE: Copies must be sent to the Presiding Officer and the other parties. TO THE PRESIDING OFFICER: I hereby provide a requestfor intervenorfunds, in accordance with 16 NYCRR 85-2.4 (d), in the following Article Vll case: CaseNumber(s): 19-T-0684 TitleofCase(s): Application of New York Transco LLC for a Certificate of Environmental Compatibility and Public Need Pursuant to Article VII of the New York Public Service Law to Construct, Operate, and Maintain a New, Double-Circuit 54.5 Mile 3451115 Kilovolt Electric Transmission Line and Related Facilities Located in the Town of Schodack, Rensselaer County; the Towns of Stuyvesant, Stockport, Ghent, Claverack, Livingston, Gallatin, and Clermont in Columbia County; and the Towns of Milan, Clinton, and Pleasant Valley in Dutchess County. Nameof Party: Towns of Livingston, Milan and Pleasant Valley, Farmers and Families for Livingston and Walnut Grove Farm Contact Person: Daniel P. Duthie Firm Name: Daniel P. Duthie, Esq. Contact Address: PO Box 8 Bellvale, NY 10912 Contact Telephone 845-988-0453 Contact E-mail Address: [email protected] Alternate Contact Person: AngelaJ. Maier-Lore Firm Name: Angela J. Maier-Lore, Esq Attorney for the Town of Milan 17 St. John Street Red Hook, New York 12571 Contact Telephone: 845-758-6563 Contact e-mail; [email protected] Amount of Funds Requested: $166,350.00 1. Please state the: (a) number of persons the requesting party represents: Five: The Towns of Livingston, Milan and Pleasant Valley; Farmers and Friends of Claverack ("FFC"); Farmers and Families of Livingston ("FFL") and Walnut Grove Farm ("Walnut Grove") (b) nature of the interests the requesting party represents: The three towns have governmental and representational interests in this Article Vll proceeding. While the application states that the new transmission line will stay within existing ROWs, it also states that the new towers will be fewer in number but will be 10 feet taller on average. This can have an adverse impact on the viewshed. Town of Livinqston The Town of Livingston, Columbia County, was founded in 1788 and has a total land area of 39.0 square miles with a population of 3,646 as of the 2010 census. The land grant for Livingston Manor was made in 1686 to Robert Livingston. The region was made a district in 1772, and the town of Livingston was founded in 1788, being one of the original towns of the county. ln 1710, the area was used to settle Palatine Germans. The Burroughs-Foland Farm, Forth House, Linlithgo Reformed Church of Livingston, Henry W. Livingston House, Richmond Hill, and St. John's Evangelical Lutheran Church are listed on the National Register of Historic Places Town of Milan The Town of Milan is located on the northern border of Dutchess County, New York, and covers an area of 36 square miles. According to the 2010 U.S. Census, the Town's population is 237A. Many of these residents are multi-generational residents of the Town. These residents and landowners include, amongst others, farmers, war veterans, doctors, laborers, nurses, students, attorneys, judges, secretaries, retirees - all of who take great pride in where they live and raise their families. The Town currently has a large high voltage power corridor, approximately 400 feet wide and consisting of four side by side towers, which runs approximately eight (8) miles through the Town. The electric transmission line proposed to be constructed would also run the same distance through the Town within this existing right-of-way (ROW) The Town residents who live in the vicinity of the power line corridor have safety concerns regarding the lroquois Gas Pipeline, with relation to the work to be performed by Transco, which must be answered. No major work has been done in the area of the pipeline since it was constructed. There are 1,799 parcels of real property located in the Town. 138 of these parcels, or approximately 7.670/o, are located on the existing corridor and will be directly affected by the proposed route. Town of Pleasant Vallev The Town of Pleasant Valley, located in Central Dutchess County, was established in 1821. It has a population of 9,672 and an area of 32.92 square miles. lt has three hamlets: Pleasant Valley, Salt Point and Washington Hollow. Pleasant Valley is home to one of, if not the largest substations in New York. lt will be a terminus for the new high-voltage transmission line. Because of all of the other transmission lines coming into and out of the Pleasant Valley Substation, the NY Transco project will be significantly taller than existing transmission lines. ln addition, a significant capacitor bank will be constructed in the vicinity of the substation. Capacitor banks create noise and will require mitigation. FFC FFL is interested in how the new high-voltage transmission line will impact localfarming and residents along its path. FFL Like FFC, FFL is interested in how the new high-voltage transmission line will impact local farming and residents along its path. Walnut Grove Walnut Grove grows black currants and was responsible for overturning a 10O-year ban on growing currants because it was thought to produce a disease that adversely affected white pine trees. With scientific backing, Gov. George Pataki overturned the ban. Black currants have the twice the antioxidants of blueberries, four times the vitamin C of oranges, more potassium than bananas, calciurn, iron, manganese, magnesium and riboflavin. Herei nafter ("Appl icants") 2. Please state the: (a) availability of funds from the resources of the requesting party: There are no funds in the Towns' budget for to enable participation. FFL has limited funds and Walnut Grove's budget does not include funds sufficient to participate in this case. (b) availability of funds from the sources other than the requesting party: The Applicants are not aware of any other funding sources. ( c) efforts that have been made to obtain funds from othersources: See response to 2(b) 3. lf therequestingpartyrepresents ownersoroccupantsof realpropertyalong theroute of the proposed facility, oranyalternate route specified bytheApplicant, provide the location of such property relative to all routes specified as reasonable in the application. The Applicants intend to make their positions available as the proceeding progresses. At the present time there is only one route that has been proposed. 4. State the amount of funds being sought: $166,350.00 Broken down as follows: Dr. Richard Smarden (Viewshed analysis) $ 8,000.00 Dr. Gidon Eshel (Forecast of demand and energy) $ 4,500.00 J. Theodore Fink (GreenPlan, Environmental Consultant) $10,000.00 Dr. Erik Kiviat (Hudsonia, Ltd., Environmental ConsultantO $10,000.00 EMF Consultant $20,000.00 (est.) Noise Consultant $15,000.00 (est.) Angela J. Maier-Lore, Esq. $12,450.00 Daniel P. Duthie, P.E., Esq. $81,900.00 Three Mailings to residents and businesses in Towns $ 4.500.00 Total $166,350.00 5(a) lf expert witnesses, consultants, attorneys,orothersaretobeemployed,provide,tothe extent possible, the name and qualifications of each person to be employed: Curriculum Vitae of Dr. Richard Smardon see Appendix A. Curriculum Vitae of Dr. Gidon Eshel see Appendix B. Curriculum Vitae of J. Theodore Fink see Appendix C Curriculum Vitae of Dr. Erik Kiviat see Appendix D Curriculum Vitae of Angela J. Maier-Lore see Appendix E Curriculum Vitae of Daniel P. Duthie see Appendix F 5(b) lf expertwitnesses, consultants, attorneys, orothers are to be employed and it is not possible to providethe nameofeach persontobeemployed, provideforeach personthatcannotbe named a statement of the necessary professional qualifications forthe person: N/A 6. Provide, if known, the name of anyother interested person orentityth atmay,oris intending to, employ any such expert witnesses, consultants, attorneys, or others: The experts identified in paragraphs 4 and 5(a) will be retained by the Applicants and will share cost on a pro-rata basis. Cost that are unique to a party will not be shared, e.9., noise effects from the capacity banks in Pleasant Valley will be a direct cost to that Town. 7 . For all expert witnesses, consultants, attorneys, or others to be employed, provide a detailed statement of: (a) the services to be provided: Dr.
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