STATE OF VERMONT PUBLIC SERVICE BOARD Docket No. 6860 Petitions of Vermont Electric Power Company, Inc. (VELCO) and Green Mountain Power Corporation (GMP) for a certificate of public good, pursuant to 30 V.S.A. Section 248, authorizing VELCO to construct the so-called Northwest Vermont Reliability Project, said project to include: (1) upgrades at 12 existing VELCO and GMP substations located in Charlotte, Essex, Hartford, New Haven, North Ferrisburgh, Poultney, Shelburne, South Burlington, Vergennes, West Rutland, Williamstown, and Williston, Vermont; (2) the construction of a new 345 kV transmission line from West Rutland to New Haven; (3) the reconstruction of a portion of a 34.5 kV and 46 kV transmission line from New Haven to South Burlington; and (4) the reconductoring of a 115 kV transmission line from Williamstown to Barre, Vermont AND amendment to VELCO petition to provide for: (1) proposed modifications to the route of the line between New Haven and South Burlington, specifically in the City of Vergennes and the Towns of Ferrisburgh, Charlotte and Shelburne; (2) proposed changes to the substations located in Vergennes, Shelburne, Charlotte and South Burlington; and (3) proposed changes to pole heights. PROPOSED FINDINGS AND BRIEF SUBMITTED BY PETITIONERS, VERMONT ELECTRIC POWER COMPANY, INC. AND GREEN MOUNTAIN POWER CORPORATION NOVEMBER 24, 2004 TABLE OF CONTENTS I. INTRODUCTION ...........................................................1 OVERVIEW ...........................................................1 PROCEDURAL BACKGROUND .........................................10 CONCLUSION ........................................................13 II. FINDINGS ...............................................................13 BACKGROUND .......................................................13 THE PROJECT ........................................................20 PROJECT COST .......................................................32 SECTION 248(B) FINDINGS .............................................33 Orderly Development of the Region .....................................33 Need for Present and Future Demand for Services ..........................40 System Stability and Reliability ........................................82 Economic Benefit to the State .........................................83 Aesthetics, Historic Sites and Water Purity, the Natural Environment and Public Health and Safety .......................................88 Public Health and Safety ..............................................88 Electric and Magnetic Field (“EMF”) Exposure ........................89 Water Purity, the Natural Environment .................................102 Outstanding Resource Waters .........................................103 Water and Air Pollution .............................................103 Water Pollution ................................................103 Air Pollution ..................................................103 Noise ........................................................104 Headwaters .......................................................106 Waste Disposal ....................................................107 Water Conservation ................................................108 Floodways ........................................................108 Streams ..........................................................109 Shorelines ........................................................112 Wetlands .........................................................113 Sufficiency of Water and Burden on Existing Water Supply .................117 Soil Erosion ......................................................117 Traffic ...........................................................118 Educational and Municipal Services ....................................119 Rare and Irreplaceable Natural Areas ...................................119 Necessary Wildlife Habitat and Endangered Species .......................122 Primary Agricultural Soils ...........................................128 Scenic or Natural Beauty of the Area, Aesthetics ..........................130 Substation Lighting .............................................174 Undergrounding Proposals .......................................176 Historic Sites ......................................................191 Development Affecting Public Investments ..............................201 Consistency with Resource Selection--Integrated Resource Plan .............201 Compliance With Electric Energy Plan .................................202 Outstanding Water Resources .........................................206 Existing Transmission Facilities .......................................206 III. COMMENTS OF THE PUBLIC ............................................206 IV. DISCUSSION RE: POST-CERTIFICATION SECTION 248 REVIEW .............207 V. FINDINGS SPECIFIC TO GREEN MOUNTAIN POWER CORPORATION .........210 VI. CONCLUSION ..........................................................213 APPENDIX A - PROPOSED ORDER APPENDIX B - PROPOSED CERTIFICATE OF PUBLIC GOOD STATE OF VERMONT PUBLIC SERVICE BOARD Docket No. 6860 Petitions of Vermont Electric Power Company, Inc. (VELCO) and Green Mountain Power Corporation (GMP) for a certificate of public good, pursuant to 30 V.S.A. Section 248, authorizing VELCO to construct the so-called Northwest Vermont Reliability Project, said project to include: (1) upgrades at 12 existing VELCO and GMP substations located in Charlotte, Essex, Hartford, New Haven, North Ferrisburgh, Poultney, Shelburne, South Burlington, Vergennes, West Rutland, Williamstown, and Williston, Vermont; (2) the construction of a new 345 kV transmission line from West Rutland to New Haven; (3) the reconstruction of a portion of a 34.5 kV and 46 kV transmission line from New Haven to South Burlington; and (4) the reconductoring of a 115 kV transmission line from Williamstown to Barre, Vermont AND amendment to VELCO petition to provide for: (1) proposed modifications to the route of the line between New Haven and South Burlington, specifically in the City of Vergennes and the Towns of Ferrisburgh, Charlotte and Shelburne; (2) proposed changes to the substations located in Vergennes, Shelburne, Charlotte and South Burlington; and (3) proposed changes to pole heights. PROPOSED FINDINGS AND BRIEF SUBMITTED BY PETITIONERS, VERMONT ELECTRIC POWER COMPANY, INC. AND GREEN MOUNTAIN POWER CORPORATION I. INTRODUCTION OVERVIEW This case concerns Petitions filed with the Public Service Board (“Board”) by Vermont Electric Power Company, Inc. ("VELCO") and Green Mountain Power Corp. (“GMP”) (collectively, the “Petitioners”), on June 5 and June 9, 2003, respectively, seeking a certificate of public good ("CPG") pursuant to 30 V.S.A. § 248, to build a coordinated series of improvements to the VELCO transmission system designed to solve serious reliability problems in northwest Vermont and to provide adequate and reliable transmission service to the state of Vermont and to the systems with which it interconnects (collectively the “Project” or “NRP”). Docket No. 6860 Brief of VELCO and GMP November 24, 2004 Page 2 of 214 The Reliability Problem The transmission system in Vermont has served the state well for many years in essentially its present configuration. Some of its principal elements, however, are up to forty years old. Major upgrades have been postponed to a point where small-scale upgrades are no longer effective. In the face of tremendous growth in load over this time, the margin built into the system has been depleted. Transmission system studies performed by VELCO demonstrate that the Vermont transmission system is becoming increasingly susceptible to system failures and widespread outages (i.e., blackouts). The greatest concern centers on, but is not exclusively limited to, the transmission system that serves the northwest part of the state – Chittenden, Franklin, Grand Isle and northern Addison Counties. This is the major load center of the state, and it is also where load is growing the fastest. Presently, Vermont is exposed to voltage collapse if there is a long- term outage of the Highgate Converter combined with the loss of any of the other three remaining 115 kV lines supplying northwest Vermont. Such an outage, if it were to occur during existing peak summer conditions, could result in a blackout for over half of Vermont’s load (encompassing all of northwest Vermont) and possibly cascade to neighboring systems. The Independent System Operator of New England (“ISO-NE”), the organization charged by the Federal Energy Regulatory Commission ("FERC") with ensuring the reliability of the New England regional transmission system, has reported that the “Northwest Vermont area faces serious reliability problems due to weak interconnections with the bulk transmission system and a lack of generating resources and distributed resources in the region.”1 The reliability problem is exacerbated by the fact that Vermont’s two most critical transmission elements -- the Plattsburgh to Sand Bar 115 kV line ("PV-20") and the Highgate Converter -- are vulnerable to and have experienced extended equipment failures or outages in recent years. In 1 ISO New England Board approved RTEP02 (Regional Transmission Expansion Plan), section 1.4.4, page 14. Docket No. 6860 Brief of VELCO and GMP November 24, 2004 Page 3 of 214 fact, the Phase Angle Regulator (“PAR”) located at Plattsburgh to control PV-20 flows, failed again on April 11, 2003, further weakening an already stressed transmission system.