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PPRP Exhibit __ (SSP-1)

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PPRP Exhibit __ (SSP-1) PPRP Exhibit __ (SSP-1) BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND In the matter of the Application of Potomac Electric ) Power Company for a Certificate of Public Convenience ) and Necessity to Rebuild an Existing Double Circuit ) Case 9329 230kV Overhead Tower Line on Existing Right-Of-Way ) from the Burtonsville Substation to the Takoma ) Substation in Prince George’s County, Maryland ) DIRECT TESTIMONY OF Sandra Shaw Patty ON BEHALF OF THE MARYLAND DEPARTMENT OF NATURAL RESOURCES POWER PLANT RESEARCH PROGRAM Tawes State Office Bldg., B-3 Annapolis, MD 21401 410-260-8668 February 18, 2014 1 Q. PLEASE STATE YOUR NAME, POSITION AND BUSINESS 2 ADDRESS. 3 A. Sandra Shaw Patty, Manager of Transmission Projects for the Power Plant 4 Research Program (PPRP) in the Department of Natural Resources (DNR), 5 Tawes State Office Building, Annapolis, Maryland 21401. 6 Q. HOW LONG HAVE YOU HELD THIS POSITION? 7 A. I have held this position since March 1991. 8 Q. WHAT ARE YOUR RESPONSIBILITIES IN THIS POSITION? 9 A. I provide technical and administrative direction on a wide variety of 10 environmental assessment projects and tasks performed by PPRP staff and 11 consultants related to transmission line issues. My responsibilities include 12 defining issues and evaluating studies and analyses necessary to provide 13 a comprehensive assessment of environmental impacts associated with 14 the construction and operation of transmission lines. DNR and other State 15 agencies use the results of these assessments in the licensing and 16 administrative proceedings for transmission line projects. PPRP’s role in 17 the licensing of transmission lines is presented later in this testimony. 18 PPRP is supported by integrator contracts that address economic (Exeter 19 Associates), atmospheric (ERM), biological (Versar, Inc.), and engineering 20 (ERM) issues. Under my direction, appropriate members of these staffs 21 participated in the review and evaluation of the documents submitted by 22 PEPCO and also in field investigations. 23 Q. WHAT EXPERIENCE DO YOU HAVE IN TRANSMISSION LINE 24 EVALUATION AND IMPACT ASSESSMENT? 25 A. Prior to joining PPRP, I was employed by Allegheny Power Service 1 1 Corporation, a member company of Allegheny Power Systems, as an 2 Environmental Analyst from 1974 to 1991. In that position, I was 3 responsible for conducting environmental assessments of electric utility 4 transmission projects, substations, and power stations. I have prepared 5 and presented expert testimony before regulatory agencies in 6 Pennsylvania, Maryland, and West Virginia regarding environmental 7 issues. I have participated in the review, siting and analysis of at least five 8 major generating stations, and over 250 miles of transmission facilities. 9 Q. WHAT IS YOUR EDUCATIONAL BACKGROUND? 10 A. I received my Bachelor of Science Degree in Biology in 1973 from 11 California State College, and a Masters in Civil Engineering, Energy 12 Resources, in 1983 from the University of Pittsburgh. 13 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY TODAY? 14 A. The purpose of my testimony is to provide the Maryland Public Service 15 Commission (PSC) with the findings and preliminary recommendations of 16 PPRP and other Reviewing State agencies concerning the CPCN 17 application by PEPCO in this proceeding. Specifically, PEPCO is 18 proposing to rebuild 9.9 miles of a 230 kV transmission line within 19 existing right-of-way (ROW) in Prince George’s County, Maryland, 20 originating at PEPCO’s Burtonsville Substation in Burtonsville, Maryland, 21 running through the Metzerott Road East Substation (Metzerott) in 22 Adelphi, Maryland, and terminating at the Takoma Substation in Takoma 23 Park, Maryland (Project). My testimony summarizes PPRP's evaluation 24 and initial recommendations with respect to the proposed Project. 25 Q. HAVE YOU REVIEWED THE SUBMISSIONS FROM PEPCO FOR 26 THIS PROJECT? 2 1 A. Yes. I have reviewed PEPCO’s CPCN application materials, including 2 direct testimony and related exhibits, filed with the PSC on June 21, 2013 3 (CPCN Application). I have reviewed PEPCO’s responses to data requests 4 and participated in a meeting with PEPCO on May 29, 2013. Under my 5 direction, PPRP’s consultants participated in a conference call with 6 PEPCO on January 28, 2014. Also, my consultants and I participated in a 7 field review of the Project on November 5, 2013. 8 Q. PLEASE PROVIDE A BRIEF DESCRIPTION OF THE PROPOSED 9 PROJECT. 10 A. The Project will rebuild the East Burtonsville to Takoma Park 230 kV 11 transmission line. The line is approximately 9.9 miles long, extending 6.6 12 miles from the Burtonsville Substation through the Metzerott Substation, 13 then running 3.3 miles from the Metzerott Substation and terminating at 14 the Takoma Substation in Takoma Park, Maryland. The Project will 15 consist of removing the existing lattice towers and replacing them with 52 16 new double circuit single steel pole structures. The Project will share the 17 right-of-way (ROW) with another 230 kV double circuit transmission line, 18 as well as existing 13 kV, 34 kV and 69 kV distribution lines that are 19 located along the edges of the ROW in certain areas of the rebuild. The 20 ROW is generally 250 feet wide; however, the ROW varies from 186 feet to 21 300 feet in certain areas of the Project. The new single steel poles will be 22 offset 62.5 feet from the ROW centerline and will range in heights between 23 118 to 173 feet above ground with an average span length between poles 24 of 1000 feet. Much of the Project ROW consists of PEPCO-owned real 25 property; however, PEPCO will be responsible for obtaining a Special Use 26 Permit from the United States Department of Agriculture (USDA) for 27 construction on Beltsville Agricultural Research Center. 3 1 Q. WHAT IS THE STATUS OF PPRP'S ENVIRONMENTAL AND 2 SOCIOECONOMIC EVALUATION OF THE PROJECT? 3 A. This filing represents a summary of the technical and environmental 4 analyses of the Project completed to date. These initial recommendations 5 may be modified up to 15 days after the close of the public comment 6 period. If no such modifications are warranted, the initial 7 recommendations will constitute the final recommendations. 8 Need for the Burtonsville to Takoma Park Transmission Rebuild Project 9 Q. HAS PEPCO PROVIDED INFORMATION ON WHY THE PROJECT IS 10 NEEDED? 11 A. Yes. According to PEPCO the need to rebuild the line is based on several 12 considerations, including: rebuilding the line before reliability concerns 13 make it more difficult and costly to schedule construction outages 14 necessary for rebuilding the line; aging infrastructure concerns because 15 the lattice towers have been in place since 1958; and given the fact that 16 PEPCO has had to put in place temporary measures because the existing 17 circuits do not meet NERC clearance requirements. Based upon PEPCO’s 18 load projections, the line should be rebuilt by June 1, 2015 to ensure that 19 construction of the Project can be completed over a single eight month 20 construction outage window following the 2014 summer season. A later 21 in-service date raises concerns that construction of the line would have to 22 be performed in stages, thereby adding to the overall cost of the Project. 23 Q. HAS PPRP EVALUATED THE MATERIALS PROVIDED BY THE 24 APPLICANT RELATED TO THE NEED FOR THE PROJECT? 25 A. Yes. This Project involves rebuilding a 9.9-mile transmission line on 26 existing right-of-way. PPRP has reviewed the materials included in 4 1 PEPCO’s CPCN Application, as well as responses to data requests. Based 2 on this review, PPRP does not take issue with PEPCO’s representations 3 that it is reasonable to proceed with the Project at this time. 4 The Application and Supporting Information 5 Q. DID PEPCO SUBMIT ANY EXHIBITS OR DOCUMENTS THAT 6 ASSESSED THE ENVIRONMENTAL IMPACTS OF THE PROJECT? 7 A. Yes. PEPCO’s environmental analyses of the Project were submitted with 8 its CPCN Application. As part of the Application, PEPCO provided the 9 Burtonsville to Takoma Environmental Review Document, (ERD), dated 10 June 21, 2013. The ERD includes a site evaluation, aerial photographs and 11 topographic maps, showing the proposed Project location, data sheets and 12 structure sketches, and an assessment of expected effects. Also, attached 13 to the ERD, were 11 appendices, including a compilation of Agency 14 correspondence, a wetlands delineation report, a rare and threatened 15 species list, a rare and threatened species survey, a raptor nest survey, a 16 habitat suitability assessment for rare and threatened species, a list of 17 PEPCO’s Best Management Practices, an Integrated Vegetation 18 Management plan, an alternate route analysis, and detailed project plan 19 maps. PEPCO also provided a report identifying petroleum- and/or 20 hazardous substance contaminated sites located near the Project ROW. 21 After reviewing all this information, PPRP concluded that the information 22 provided in the Application was sufficient to conduct the State's review. 23 Impact Assessment 24 Q. DID PPRP CONDUCT AN INDEPENDENT EVALUATION OF THE 25 POTENTIAL ENVIRONMENTAL EFFECTS OF THE PROPOSED 26 TRANSMISSION LINE PROJECT? 5 1 A. Yes. PPRP reviewed the Applicant's Direct Testimony and ERD, 2 evaluated the potential environmental impacts using data from a variety 3 of sources, consulted with other Reviewing State agencies, and observed 4 conditions in the ROW during a field inspection. Based on analysis of the 5 information provided by these sources, PPRP assessed the potential effects 6 of the Project on streams and non-tidal wetlands; rare, threatened, and 7 endangered species; forest resources and Maryland’s green infrastructure 8 network; and land use and vegetation management in the relevant 9 portions of Prince George’s County.
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