1II 1 1 1 11 1 11 1 II Control Number: 49151 1 1 1 1 11 1 1 1 II 1 Item Number: 206 Addendum StartPage: 0 217 - SOAH DOCKET NO. 473-19-5 855 ‘-<-Qrt,`r-- PUC DOCKET NO. 2: 34 49154-:?L / :4 ;711, JOINT APPLICATION OF ONCOR ELECTRIC DELIVERY COMPANY LLC, § BEFORE THE STATE OFFICE CITY OF LUBBOCK, ACTING BY AND § THROUGH LUBBOCK POWER AND LIGHT, FOR A CERTIFICATE OF OF CONVENIENCE AND NECESSITY FOR § THE ABERNATHY TO NORTH TO NORTH LOOP 345/115-KV TRANSMISSION LINE IN HALE AND § ADMINISTRATIVE HEARINGS LUBBOCK COUNTIES DIRECT TESTIMONY OF DWIGHT ANDREWS ON BEHALF OF ANDREWS INTERVENORS Intervenors G. Randall Andrews, on behalf of himself and the entities Peacock Land Co., LLC, Restaurant Operators, Inc., and Broadway Rentals, LLC; and Dwight Andrews, on behalf of himself and the entity Candle Creek, LC (collectively, "Andrews Intervenors") hereby file this Direct Testimony of Dwight Andrews, which is attached, and stipulates that this Direct Testimony can be treated by all parties as if the answers were filed under oath. Respectfully submitted, SCOTT DOUGLASS & McCONNICO LLP 303 Colorado Street, Suite 2400 Austin, Texas 78701 512.495.6300 512.495.6399 Fax By: la-,a-e5 Catherine J. Webleing State Bar No. 21050055 [email protected] Stephanie C. Kover State Bar No. 24102042 [email protected] ATTORNEYS FOR ANDREWS INTERVENORS Direct Testimony of Dwight Andrews Page 1 of 62 September 4, 2019 On Behalf of Andrews Intervenors PUC Docket No. 49151 SOAI-1 Docket No. 473-19-5853 CERTIFICATE OF SERVICE I certify that a copy of this document will be served on all parties of record on September 4, 2019 in accordance with 16 TAC § 22.74 and the governing procedural orders. Catherine J. Webking Direct Testimony of Dwight Andrews Page 2 of 62 September 4, 2019 On Behalf of Andrews Intervenors PUC Docket No. 49151 SOAH Docket No. 473-19-5853 SOAH DOCKET NO. 473-19-5853 PUC DOCKET NO. 49151 JOINT APPLICATION OF ONCOR § ELECTRIC DELIVERY COMPANY LLC, § BEFORE THE STATE OFFICE CITY OF LUBBOCK, ACTING BY AND § THROUGH LUBBOCK POWER AND § LIGHT, FOR A CERTIFICATE OF § CONVENIENCE AND NECESSITY FOR § OF THE ABERNATHY TO NORTH TO § NORTH LOOP 345/115-KV § TRANSMISSION LINE IN HALE AND § LUBBOCK COUNTIES) § ADMINISTRATIVE HEARINGS DIRECT TESTIMONY OF DWIGHT ANDREWS ON BEHALF OF ANDREWS INTERVENORS SEPTEMBER 4, 2019 Direct Testimony of Dwight Andrews Page 3 of 62 September 4, 2019 On Behalf of Andrews Intervenors PUC Docket No. 49151 SOAH Docket No. 473-19-5853 DIRECT TESTIMONY OF DWIGHT ANDREWS ON BEHALF OF ANDREWS INTERVENORS TABLE OF CONTENTS I. INTRODUCTION AND BACKGROUND 5 II. PURPOSE AND SCOPE 5 III. THE CANDLE CREEK PROPERTY 6 IV. ROUTING IMPACTS ON THE PROPERTY AND LINKS OPPOSED. 10 V. CONCLUSION 12 EXHIBITS Attachment DA-I November 6, 2018 election sample ballot that includes Proposition A Attachment DA-2 Minutes from the June 10, 2019 Lubbock County Commissioner's Court meeting Attachment DA-3 Lubbock County Judge Orders signed June 11, 2019 authorizing collection of taxes for the Lubbock County Exposition Center Attachment DA-4 Newspaper and online articles on the Lubbock County Exposition Center Attachment DA-5 Photographs and aerial images of the Candle Creek Property Direct Testimony of Dwight Andrews Page 4 of 62 September 4, 2019 On Behalf of Andrews Intervenors PUC Docket No. 49151 SOAH Docket No. 473-19-5853 1 I. INTRODUCTION AND BACKGROUND 2 3 Q. Please state your name, occupation, and business address. 4 A. My name is Dwight Andrews. I am a self-employed in investments. My business 5 address is P.O. Box 600578, Dallas, Texas, 75360. 6 7 Q. Please briefly outline your educational and business background. 8 A. I have a Bachelor's degree in Business Administration from Texas Tech University, with 9 a major in accounting. I maintain a CPA license in the state of Texas, and a Texas real 10 estate broker's license. 11 12 Q. Have you ever testified before the Public Utility Commission before? 13 A. No, I have not. 14 15 II. PURPOSE AND SCOPE 16 17 Q. On whose behalf are you testifying in this proceeding? 18 A. I am testifying on behalf of both myself as an intervenor in this proceeding and on behalf 19 of Candle Creek, LC, a limited liability company of which I am the sole member and on 20 whose behalf I also intervened ("Candle Creek"). We are part of a larger intervenor 21 coalition that also includes G. Randall Andrews who intervened on behalf of himself and 22 the entities Peacock Land Co., LLC; Restaurant Operations, Inc.; and Broadway Rentals, 23 LLC. I will use the term "Andrews Intervenors" to refer to the intervenor coalition in the 24 collective. 25 26 Q. What is the purpose and scope of your testimony? 27 A. This testimony responds to the application filed by Oncor Electric Delivery Company 28 LLC (and previously by Sharyland Utilities, L.P.) and the City of Lubbock, acting by and 29 through Lubbock Power and Light ("Applicants") for transmission lines in a study area in 30 which Candle Creek owns properties. My testimony explains the potential impact of 31 various proposed transmission line links on properties owned by Candle Creek. Direct Testimony of Dwight Andrews Page 5 of 62 September 4, 2019 On Behalf of Andrews Intervenors PUC Docket No. 49151 SOAH Docket No. 473-19-5853 1 III. THE CANDLE CREEK PROPERTY 2 3 Q. What properties are owned by Candle Creek and located within the study area? 4 A. Candle Creek owns two adjacent large tracts of land that are located within the study area 5 for, and may be adversely impacted by, the Abernathy to North to North Loop 6 transmission line. The two tracts are identified in the Application as tracts R317188 and 7 R66269. Throughout my testimony, I will refer to these tracts collectively as the "Candle 8 Creek Property." 9 10 Q. Approximately where is the Candle Creek Property located within the study area? 11 A. The Candle Creek Property is located in the south-central portion of the study area, 12 approximately half-way between the Hillcrest Country Club and Berl Huffman Athletic 13 Complex to the west, and the Lubbock Country Club to the east. More specifically, the 14 Candle Creek Property is bordered by North Loop 289's Frontage Road to the south, 15 North University Avenue to the west and North Avenue Q to the east. The general 16 location of the Candle Creek Property is shown on Figure 1, which follows. 17 18 19 Figure 1: Aerial Image of the Candle Creek Property. 20 An approximation of the Candle Creek Property boundary is shown in gold. The North Loop 289 21 Frontage Road is shown bordering the Property to the south. 22 Direct Testimony of Dwight Andrews Page 6 of 62 September 4, 2019 On Behalf of Andrews Intervenors PUC Docket No. 49151 SOAH Docket No. 473-19-5853 1 Q. Please describe the Candle Creek Property and activities on it. 2 A. Lubbock County has selected the Candle Creek Property as the proposed location for the 3 new Lubbock County Exposition Center that is currently planned to be constructed and 4 opened by 2021. Currently, the Candle Creek Property is used for cotton farming. 5 6 Q. Please tell us what you know about the Lubbock County Exposition Center that is 7 proposed to be built on the Candle Creek property. 8 A. The new Exposition Center will replace the Lubbock Municipal Coliseum, and is planned 9 to house events such as the ABC Pro Rodeo that previously took place at the Municipal 10 Coliseum, as well as events like gymnastics tournaments, concerts, motocross events, and 11 livestock shows. It is planned that upon its development, Lubbock County would own 12 the property, and would lease it to a 501c3 nonprofit organization, which would oversee 13 the operations of the Exposition Center. 14 15 Q. When was the Candle Creek location for the Exposition Center revealed? 16 A. The proposed location for the Lubbock County Exposition Center on the Candle Creek 17 property was publicly revealed in October 2018. This was prior to giving voters the 18 opportunity to vote yes or no for increased Lubbock County hotel/motel and rental car 19 taxes to fund the project, under the Proposition A ballot initiative on the November 6, 20 2018 election ballot. A sample ballot that includes Proposition A is provided in 21 Attachment DA-1. 22 23 Q. Please tell us what you know about why the Candle Creek Property was selected as 24 the proposed location for the Exposition Center. 25 A. It is my understanding that the Exposition Center not only requires a large amount of 26 land, but also accessibility to major roads so that Exposition Center visitors will be able 27 to easily access it, and to increase visibility. Relatively close proximity to the City of 28 Lubbock's center is also a benefit. The Candle Creek Property provides all of these 29 benefits. 30 Further, the Candle Creek Property is a logical contender for this type of 31 recreational and community development. As shown in Figure 2, the Candle Creek Direct Testimony of Dwight Andrews Page 7 of 62 September 4, 2019 On Behalf of Andrews Intervenors PUC Docket No. 49151 SOAH Docket No. 473-19-5853 1 Property is at the center of a hub of five major recreational and park areas within the 2 study area: (1) Hillcrest Country Club is to its northwest, (2) the Berl Huffinan Athletic 3 Complex is to its west, (3) the Yellow House Canyon Park/Lubbock Lake Landmark, 4 which is along the Yellow House Draw, is to its west, (4) the Buddy Holly Recreation 5 Area and Hodges Park, also along the Yellow House Draw, are to its southwest, and (5) 6 the Lubbock Country Club, along the Blackwater Draw, is to its east.