BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO

IN THE MATTER OF THE APPLICATION OF TRI-STATE GENERATION AND TRANSMISSION ASSOCIATION, INC. FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE BURLINGTON – LAMAR 230 KV TRANSMISSION LINE PROJECT AND FOR SPECIFIC FINDINGS WITH RESPECT TO MAGNETIC FIELDS AND AUDIBLE NOISE

) ) ) ) PROCEEDING NO. ______ ) ) ) )

_____________________________________________________________________

DIRECT TESTIMONY AND EXHIBITS OF CHRISTOPHER E. PINK

____________________________________________________________________

TABLE OF CONTENTS

Section Page I. INTRODUCTION AND QUALIFICATIONS .............................................................. 2

II. PURPOSE OF TESTIMONY .................................................................................... 3

III. TRI-STATE'S EXISTING TRANSMISSION SYSTEM IN THE PROJECT AREA ....................................................................................................................... 4

IV. PROJECT PURPOSE AND NEED .......................................................................... 7

V. ALTERNATIVES ANALYSIS .................................................................................. 12

VI. PROPOSED PROJECT ......................................................................................... 23

VII. PROJECT COORDINATION .................................................................................. 23

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I. INTRODUCTION AND QUALIFICATIONS 1

Q: PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 2

A: My name is Christopher E. Pink. My business address is 1100 West 116th 3

Avenue, Westminster, Colorado 80234. 4

Q: BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY? 5

A: I am employed by Tri-State Generation and Transmission Association, Inc. (“Tri-6

State”) as Manager, Technical Services/Bulk System Planning. 7

Q: ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS DOCKET? 8

A: I am testifying on behalf of Tri-State. 9

Q: HAVE YOU PREPARED A STATEMENT OF YOUR EXPERIENCE AND 10

QUALIFICATIONS? 11

A: Yes. A statement of my experience and qualifications is attached to my 12

testimony as Exhibit No. CEP-1. 13

Q: PLEASE DESCRIBE BRIEFLY YOUR BACKGROUND AND EXPERIENCE IN 14

THE ELECTRIC UTILITY INDUSTRY. 15

A: I have over 11 years of experience in the electric utility industry. In my present 16

position, I am responsible for planning, coordinating, directing, and providing 17

engineering support for the development of Tri-State’s transmission network 18

utilizing my knowledge of bulk power systems. Prior to joining Tri-State, I worked 19

as a system engineer at a distribution cooperative, a research engineer at a 20

national lab, and an electrical engineer at a consulting firm. I have undergraduate 21

and master’s degrees in engineering from the Colorado School of Mines. I am a 22

registered Professional Engineer in the State of Colorado. 23

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II. PURPOSE OF TESTIMONY 1

Q: WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? 2

A: My testimony discusses the purpose and need for the Burlington – Lamar 3

Transmission Line Project (the “Project”). Specifically, I will discuss the needs 4

related to load serving, reliability, and constraints on planned renewables that 5

give rise to the Project. I will also discuss the system studies that have been 6

performed which confirm and support the need for the Project. I will also 7

introduce Tri-State's other witnesses whose testimony supports the issuance of a 8

Certificate of Public Convenience and Necessity (“CPCN”) for the Project as 9

described in Tri-State’s Application. 10

Q. IS TRI-STATE PRESENTING TESTIMONY FROM OTHER WITNESSES IN 11

SUPPORT OF ITS CPCN APPLICATION? 12

A. Yes. In addition to my own testimony, Tri-State is sponsoring the direct 13

testimony of the following witnesses in support of its Application: 14

- Grant D. Lehman, Tri-State's Senior Manager, Transmission Engineering 15

and Construction, will describe the details of the proposed transmission line 16

design, the Project schedule, and estimated cost; 17

- Karl W. Myers, Tri-State's Manager of Transmission Siting and 18

Environmental Planning, will describe the land use, right-of-way, siting, and 19

permitting issues associated with the Project; and 20

- Dr. Robert Pearson, a consulting engineer, will address issues related to 21

magnetic fields and audible noise. 22

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Together, my testimony and the testimony of these witnesses provide a 1

comprehensive explanation of the Project and its underlying purpose and need. 2

III. TRI-STATE'S EXISTING TRANSMISSION SYSTEM IN THE PROJECT AREA 3

Q: PLEASE PROVIDE A BRIEF DESCRIPTION OF THE PROJECT. 4

A: The Project is a new single-circuit, 230 kV transmission line interconnecting Tri-5

State’s existing Burlington and Lamar substations. The new transmission line will 6

be approximately 90-110 miles long and will be constructed on wood H-frame 7

structures. Project facilities are shown in electric one-line diagram format in 8

Exhibit No. CEP-2. 9

Q: PLEASE DESCRIBE THE LOCATION OF THE PROJECT. 10

A: The Project will be located in Kit Carson, Cheyenne, Kiowa, and Prowers 11

counties and will cross areas served by Tri-State Member Systems K.C. Electric 12

Association and Southeast Colorado Power Association. A map of the Project 13

Area is included as Exhibit G to the CPCN Application. 14

Q: PLEASE DESCRIBE THE EXISTING TRANSMISSION AND GENERATION 15

SYSTEMS IN THE LAMAR AREA. 16

A: The transmission network in the Lamar area consists of two systems: 1) a 115 kV 17

load serving network; and 2) the Boone - Lamar 230 kV line. 18

The 115 kV network is owned and operated by Black Hills/Colorado Electric 19

Utility Company, L.P. and Tri-State. It serves all the load centers between Boone 20

and Lamar, including Rocky Ford, Las Animas, Vilas, Lamar, Holly, and La Junta, 21

among others. Transmission assessments have shown that the 115 kV network 22

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will be unable to serve all the Lamar area loads after a loss of the Boone – Lamar 1

230 kV line. 2

The Boone - Lamar 230 kV line serves no distribution systems directly. Its 3

primary purpose is to transfer bulk power into and out of the area. Tri-State 4

imports power from Boone 230 kV to Lamar 230 kV to serve Tri-State’s 115 kV 5

loads in the area. Public Service Company of Colorado (“PSCo”) utilizes the 230 6

kV line to transfer their Lamar area generation to their Front Range loads. PSCo 7

has 447 MW of generation connected at Lamar 230 kV, including the Lamar DC 8

Tie (± 210 MW), Colorado Green East and West Wind (162 MW), and Twin Butte 9

Wind (75 MW). The underlying 115 kV system is insufficient to transfer this 10

much power; thus, a scheme is in place to automatically trip all Lamar area 11

generation for an outage of the Boone – Lamar 230 kV line. Loss of the Boone – 12

Lamar 230 kV element is the most severe single contingency in the area. 13

Q: PLEASE DESCRIBE THE EXISTING TRANSMISSION AND GENERATION 14

SYSTEMS IN THE BURLINGTON AREA. 15

A: Like Lamar, the Burlington area transmission system presently consists of two 16

systems: 1) an underlying 115 kV load serving network; and 2) a single 230 kV 17

line. 18

There are several owners of the various 115 kV load serving networks, including 19

Western Area Power Administration, PSCo, Tri-State, and K.C. Electric 20

Association Inc. These networks serve the majority of the eastern Colorado load 21

centers, including Yuma, Wray, Idalia, and Burlington, among others. 22

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The 230 kV line connects Burlington, via Landsman Creek, to the Big Sandy – 1

Lincoln – Midway 230 kV system. 2

A second line, called Burlington – Wray 230 kV, is presently under development 3

and expected to be in service by 2016. It will connect Burlington to the Wray – 4

North Yuma 230 kV system to the North. A sizable amount of conventional and 5

renewable generation is connected and is planned to be connected at or near 6

Burlington. 7

The Burlington system is generation rich and transmission constrained. The 8

most significant issue is its ability to safely export power following an outage of 9

the Burlington – Big Sandy – Lincoln – Midway 230 kV system. During periods of 10

high generation, significant overloads on the underlying 115 kV network occur 11

following 230 kV outages. This condition is exacerbated during low-load, high-12

wind conditions. To ensure 115 kV overloads do not occur, the Burlington area 13

generation is restricted through operating procedures and agreements. This 14

situation presently restricts any new renewable generation in the Burlington area. 15

The future Burlington – Wray 230 kV project significantly relieves these 16

restrictions. It does not, however, provide sufficient relief to accommodate all 17

planned future generation. For example, Tri-State has plans for a 150 MW 18

network resource, named Carousel Wind, to be connected at Burlington 230 kV 19

in 2015. Lacking a significant transmission project, the output of Carousel Wind 20

will be limited during light load conditions to protect against 230 kV outages, 21

much like today’s existing Burlington area generation. 22

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In summary, even with the new Burlington - Wray 230 kV line, the Burlington 1

area transmission system still needs another outlet for planned generation. 2

Q: PLEASE DESCRIBE TRI-STATE’S RELATIONSHIP TO ITS MEMBER 3

SYSTEMS AND ITS LOAD SERVING AND RELIABILITY OBLIGATIONS. 4

A: Tri-State is a regional, wholesale electric power supplier owned by the 44 electric 5

cooperatives and public power districts (the “Member Systems”) that it serves in 6

Colorado, New Mexico, Nebraska, and Wyoming. Tri-State is obligated to 7

provide reliable, efficient, cost-based, wholesale power to these Member 8

Systems, who in turn provide retail electric service to their end-use member-9

consumers. Tri-State, as a regional transmission provider, also has the 10

obligation to provide reliable transmission service to its other network customers, 11

such as Public Service Company of New Mexico, the Municipal Energy Agency 12

of Nebraska, Arkansas River Power Authority, and PSCo, and to comply with all 13

North American Electric Reliability Corporation (“NERC”) and Western Electricity 14

Coordinating Council (“WECC”) transmission reliability standards. 15

IV. PROJECT PURPOSE AND NEED 16

Q: WHAT IS THE PURPOSE OF THE PROPOSED PROJECT? 17

A: The purpose of the Project is to alleviate existing and reasonably anticipated 18

future transmission system constraints and reliability issues in a manner that 19

aligns with elements of larger, strategic transmission initiatives in eastern 20

Colorado. 21

Q: ARE THERE SPECIFIC NEEDS THAT ARE ADDRESSED BY THE PROJECT? 22

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A: Yes, several reliability issues must be addressed in the eastern and southeastern 1

Colorado transmission systems that are mitigated by the Project: 2

1) Unacceptable voltages and voltage deviations in the Lamar area following a 3

Boone – Lamar 230 kV line outage; 4

2) Transmission constraints in the Lamar area; and 5

3) Transmission constraints in the Burlington area. 6

Q: ARE THERE OTHER BENEFITS OF THE PROJECT? 7

A: Yes. The Project provides increased operational flexibility for maintenance 8

outages, better transmission system performance following multiple 9

contingencies, reduced regional losses, and more stable voltages across a wide 10

range of system conditions. 11

The Project also increases transmission capacity in regions with a high potential 12

for new wind resources. This benefits stakeholders developing such projects, 13

supports public policy goals (e.g., SB13-252), and possibly increases 14

competition, thereby providing Tri-State a more diverse portfolio of generation 15

resources from which to choose. 16

Another benefit is that a new Burlington – Lamar transmission element aligns 17

with other major, strategic transmission projects in the region. Constructing the 18

Project is an important first step to ultimately meet some of the objectives of 19

these larger transmission projects. 20

Q: DESCRIBE HOW THE PROJECT ALIGNS WITH OTHER STRATEGIC 21

TRANSMISSION INITIATIVES IN EASTERN COLORADO? 22

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A: There are two major transmission initiatives in eastern Colorado that include new 1

infrastructure between the Lamar and Burlington areas. 2

One is the Lamar – Front Range Project. It includes new transmission lines 3

interconnecting Lamar, Burlington, Big Sandy, Missile Site, Story, Pawnee, and 4

Vilas. It is described as “a multi-faceted transmission project designed to 5

enhance the high-voltage transmission network in eastern Colorado.” More 6

details for the Lamar – Front Range project are included in the Lamar – Front 7

Range Transmission Project Feasibility Study Report attached as Exhibit No. 8

CEP-3. 9

Another is the High Plains Express initiative. Its goals are to significantly 10

strengthen the eastern portion of the Western grid. Larger than the Lamar – 11

Front Range Project, it also includes transmission ties between Wray, Burlington, 12

Lamar, and Vilas, among others. More details for the High Plains Express 13

project are included in the High Plains Express Transmission Project Feasibility 14

Study Report attached as Exhibit No. CEP-4. 15

While the Burlington – Lamar Project does not by itself accomplish all of the 16

objectives of the Lamar – Front Range or High Plains Express projects, it is an 17

important first step to ultimately meet some of the objectives of those initiatives. 18

Q: WHAT STUDIES HAVE BEEN CONDUCTED THAT HAVE IDENTIFIED AND 19

CONFIRMED OR OTHERWISE SUPPORTED THE NEED FOR THE 20

PROJECT? 21

A: There have been many, including: 1) Tri-State’s various transmission 22

performance assessments; 2) the Lamar – Front Range Project study (Exhibit 23

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No. CEP-3); 3) the High Plains Express Project study (Exhibit No. CEP-4); and 1

4) recent generator interconnection studies for Tri-State wind resources to be 2

connected at Burlington. While each study addressed slightly different needs, 3

they all confirm and support improvements that include interconnecting the 4

Burlington and Lamar transmission systems. 5

The following exhibits are relevant studies that describe the need or benefits of 6

transmission system improvements between Burlington and Lamar: 7

1) Exhibit No. CEP-3: “Lamar – Front Range Transmission Project 8

Feasibility Study Report.” This study describes a major transmission 9

project in eastern Colorado that includes a transmission connection 10

between Burlington and Lamar, among other elements. 11

2) Exhibit No. CEP-4: “High Plains Express Transmission Project 12

Feasibility Study Report.” This study describes another strategic 13

transmission project in eastern Colorado that includes a transmission 14

connection between Burlington and Lamar, among other elements. 15

3) Exhibit No. CEP-5: “Tri-State Transmission Planning Assessment (Per 16

TPL-001a, TPL-002a, TPL-003a, and TPL-004).” This study identified, 17

among other things, unacceptable voltages and voltage deviations in the 18

Lamar area following a Boone – Lamar 230 kV outage. 19

4) Exhibit No. CEP-6: “Burlington – Lamar 345/230 kV Impact and 2013 20

Post TPL Assessment Study.” A follow up to the TPL assessment, this 21

study compared alternatives and ensured the adequacy of a new 22

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Burlington – Lamar 230 kV line in solving the Lamar area performance 1

issues. 2

5) Exhibit No. CEP-7: “Interconnection System Impact Re-Study Final 3

Report – April 22, 2014.” This study identified transmission system 4

constraints around Burlington following the installation of a new 150 MW 5

wind resource during light load, high wind conditions (2018 light autumn). 6

It concluded that a new Burlington – Lamar 230 kV line would relieve the 7

identified constraints. 8

6) Exhibit No. CEP-8: “Supplemental Study to the Burlington – Lamar 9

345/230 kV Impact and 2013 Post TPL Assessment Study.” A new 10

transmission line between Burlington and Lamar will improve the 11

transmission capacity in both areas. This study analyzed potential new 12

generation injection levels after installation of a single Burlington – Lamar 13

230 kV line. 14

7) Exhibit No. CEP-9: “Burlington – Lamar 230 kV Losses Evaluation.” A 15

new transmission line in the area will reduce the system’s overall 16

impedance, which will reduce losses and thus increase overall system 17

efficiency. This study enumerates the potential impact of the Project on 18

system losses and determines if an upgraded project is economically 19

justifiable based on reduced losses. 20

8) Exhibit No. CEP-10: “Interconnection System Impact Study Final Report 21

Generator Interconnection Request No. TI-13-0221 (POI Lamar 22

Substation).” This study identified reliability issues around Lamar both 23

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prior to and following the installation of a new 100 MW wind resource at 1

Lamar. A dynamic stability sensitivity case was run, and it concluded that 2

with a Burlington – Lamar 230 kV element modeled, all simulated 3

contingencies resulted in acceptable system performance. 4

V. ALTERNATIVES ANALYSIS 5

Q: BEFORE WE DISCUSS THE PROPOSED PROJECT, DID TRI-STATE 6

CONSIDER ANY NON-TRANSMISSION ALTERNATIVES TO MEET THE 7

IDENTIFIED NEEDS? 8

A: Yes. Tri-State considered at a high level whether the identified needs could be 9

met through a generation solution or a solution involving energy efficiency or 10

demand side management (“EE/DSM”) measures. Tri-State also considered 11

whether it was feasible to take no action at all. 12

Q: WHAT CONCLUSIONS DID TRI-STATE REACH WITH REGARD TO 13

WHETHER A GENERATION ALTERNATIVE COULD SATISFY THE 14

IDENTIFIED NEEDS? 15

A: Since two of the needs being addressed by the Project are to relieve 16

transmission constraints imposed on existing and planned generation, it was 17

determined early on that additional generation would not be a viable solution. 18

Q: WHAT CONCLUSIONS DID TRI-STATE REACH WITH REGARD TO 19

WHETHER AN EE/DSM ALTERNATIVE COULD SATISFY THE IDENTIFIED 20

NEEDS? 21

A: Being generation rich, the transmission constraints in the Burlington and Lamar 22

areas are exacerbated by reduced local loads. With less power consumed 23

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locally, more power is exported over the limited transmission networks. EE/DSM 1

alternatives would reduce loads and therefore, would not mitigate the 2

transmission constraint issues. 3

Q: IS IT FEASIBLE FOR TRI-STATE TO TAKE NO ACTION WITH REGARD TO 4

THE IDENTIFIED NEEDS? 5

A: No. Tri-State, WECC, and NERC transmission performance criteria require 6

levels of system performance that will not be met if no action is taken. 7

Q: WHAT CONCLUSION DID TRI-STATE REACH WITH REGARD TO THE 8

APPROPRIATE MEANS TO ADDRESS THE IDENTIFIED NEEDS IN 9

EASTERN COLORADO? 10

A: Consistent with the various studies previously identified, Tri-State determined 11

that the most appropriate means to address the present and future needs in 12

eastern Colorado is through transmission system improvements between 13

Burlington and Lamar. 14

Q: PLEASE DESCRIBE TRI-STATE’S GENERAL ASSUMPTIONS AND 15

METHODOLOGY. 16

A: As discussed earlier, Tri-State utilized many different studies, covering a range of 17

alternatives, to determine the best solution. The final decision was based on a 18

broad spectrum of potential future scenarios. The Tri-State Transmission 19

Planning Assessment (Exhibit No. CEP-5), for example, utilized five base case 20

assumptions spanning nine years under heavy and light, winter and summer 21

scenarios. Likewise, the Burlington – Lamar 345/230 kV Impact and 2013 Post 22

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TPL Assessment Study (Exhibit No. CEP-6), focused on 2019 heavy summer 1

and light autumn cases. 2

Other studies similarly included diverse assumptions, which are outlined in their 3

respective reports. The various analyses identified an assortment of issues, but 4

all pointed to alternatives involving a new transmission line between Burlington 5

and Lamar. 6

The methodologies employed power flow analyses under system intact, single 7

contingency, and in some cases, multiple outage conditions. System 8

performance was judged against Tri-State’s planning criteria and applicable 9

NERC and WECC reliability criteria. 10

Q: PLEASE DESCRIBE THE GENERAL TRANSMISSION ALTERNATIVES THAT 11

WERE CONSIDERED. 12

A: The alternatives considered varied from study to study. Having determined that 13

a transmission solution was most appropriate, Tri-State primarily based its 14

decision on the consideration of two studies and their corresponding alternatives. 15

The first study was the Burlington – Lamar 345/230 kV Impact and 2013 Post 16

TPL Assessment Study (Exhibit No. CEP-6). The study focused on mitigating 17

reliability and transmission constraint issues in and around the Lamar area. It 18

analyzed the following three alternatives: 19

1) A 90-110 mile transmission line between the Burlington and Lamar 20

substations. One option of this alternative considered construction of a 21

new single-circuit transmission line on steel lattice structures capable of 22

operating at 345 kV but operated initially at 230 kV. A second option 23

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considered construction of a single-circuit 230 kV transmission line on 1

wood H-frame structures. 2

2) A single-circuit 230 kV transmission line on wood H-frame structures 3

extending approximately 97 miles between the Lamar and Lincoln 4

substations. 5

3) A single-circuit 230 kV transmission line on wood H-frame structures 6

extending approximately 121 miles between the Lamar and Midway 7

substations. 8

The second study was the Interconnection System Impact Re-Study Final 9

Report – April 22, 2014 (Exhibit No. CEP-7). This study assessed impacts and 10

mitigation of specific transmission constraints for Tri-State’s planned 150 MW 11

network wind resource in the Burlington area. The study considered three 12

approaches to eliminate 115 kV overloads that the additional generation caused: 13

1) Reduce the project generation size; 14

2) Increase the ratings of the overloaded lines by upgrading them; and 15

3) Construct a new transmission line into the project area. 16

In addition to the primary studies, Tri-State also considered the results of the 17

Lamar – Front Range Study (Exhibit No. CEP-3) and High Plains Express Study 18

(Exhibit No. CEP-4). While the range of their alternatives went beyond the 19

scope of Tri-State’s specific requirements, the Lamar – Front Range and High 20

Plains Express conclusions were considered when evaluating how Tri-State’s 21

needs fit in a larger context. 22

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Q: PLEASE SUMMARIZE THE RESULTS OF TRI-STATE’S “BURLINGTON – 1

LAMAR 345/230 KV IMPACT AND 2013 POST TPL ASSESSMENT STUDY” 2

(EXHIBIT NO. CEP-6). 3

A: This study confirmed the load serving, reliability, and generation delivery 4

concerns associated with an outage of the Boone – Lamar 230 kV transmission 5

line. The analysis determined that all three alternatives studied, including both 6

options associated with the Burlington - Lamar alternative, mitigated the 7

concerns around Lamar. The analysis also showed negligible performance 8

differences between constructing the Burlington – Lamar transmission alternative 9

for either 230 kV or 345 kV operation. 10

Q: PLEASE SUMMARIZE THE RESULTS OF TRI-STATE’S 11

“INTERCONNECTION SYSTEM IMPACT RE-STUDY FINAL REPORT – 12

APRIL 22, 2014” (EXHIBIT NO. CEP-7). 13

A: Overloads on the 115 kV load serving network around Burlington were identified 14

with the generation facility at full output following various 230 kV line outages. 15

Proposed mitigation included reduction in generation output, rebuilding existing 16

115 kV lines, or construction of a new transmission line to the Burlington area. 17

The Burlington – Lamar 230 kV line was modeled and the results demonstrated 18

that it mitigates the identified 115 kV overloads. 19

Q: PLEASE SUMMARIZE THE RESULTS OF TRI-STATE’S 20

“INTERCONNECTION SYSTEM IMPACT STUDY FINAL REPORT 21

GENERATOR INTERCONNECTION REQUEST NO. TI-13-0221 (POI LAMAR 22

SUBSTATION).” (EXHIBIT NO. CEP-10). 23

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A: Loss of the Boone - Lamar 230 kV line (with cross-trip scheme) failed to 1

converge in the model. A dynamic stability sensitivity case was run modeling the 2

planned Burlington - Lamar 230 kV line. A solution was obtained for loss of the 3

Boone - Lamar 230 kV line (no cross trip), and the study results confirmed that all 4

simulated contingencies were compliant with the NERC/WECC criteria. 5

Q: PLEASE SYNTHESIZE THE RESULTS OF TRI-STATE’S “BURLINGTON – 6

LAMAR 345/230 KV IMPACT AND 2013 POST TPL ASSESSMENT STUDY” 7

(EXHIBIT NO. CEP-6), “INTERCONNECTION SYSTEM IMPACT RE-STUDY 8

FINAL REPORT – APRIL 22, 2014” (EXHIBIT NO. CEP-7), AND 9

“INTERCONNECTION SYSTEM IMPACT STUDY FINAL REPORT 10

GENERATOR INTERCONNECTION REQUEST NO. TI-13-0221 (POI LAMAR 11

SUBSTATION)” (EXHIBIT NO. CEP-10). 12

A: Each study was performed independently and evaluated alternatives unique to 13

their focus. 14

The Burlington – Lamar 345/230 kV Impact and 2013 Post TPL Assessment 15

Study concentrated on resolving problems caused by an outage of the Boone – 16

Lamar 230 kV line. The study found three 230 kV alternatives that mitigate the 17

reliability issues in the Lamar region: Lincoln – Lamar 230 kV, Midway - Lamar 18

230 kV, or Burlington – Lamar 230 kV. It concluded that a new Burlington – 19

Lamar 230 kV element was preferred and would greatly improve the transmission 20

system in eastern Colorado. 21

The Interconnection System Impact Re-study Final Report – April 22, 2014 22

identified constraints on a new 150 MW wind farm near Burlington. The study 23

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recommended three possible approaches to mitigate the constraints: 1) a new 1

Burlington - Lamar 230 kV line; 2) significant rebuilds to other 115 kV lines; or 3) 2

curtailing the wind farm output. The last being the least desirable approach, 3

obviously. 4

The Interconnection System Impact Study Final Report Generator 5

Interconnection Request No. TI-13-0221 (POI Lamar Substation) found that the 6

system model failed to converge for a loss of the Boone – Lamar 230 kV line, 7

even before the proposed generation project was included. A new Burlington – 8

Lamar 230 kV element was modeled in dynamic simulations and proper 9

transmission system performance was achieved both with and without the 10

additional generation. 11

New transmission facilities are large and expensive endeavors. Preferably, they 12

meet several needs and address multiple issues. In the case of the proposed 13

Project, three independent studies demonstrated that this single transmission line 14

would significantly improve two relatively independent transmission systems – an 15

ideal outcome for any transmission project. 16

Q: PLEASE SUMMARIZE THE RELEVANT RESULTS OF THE “LAMAR – 17

FRONT RANGE TRANSMISSION PROJECT FEASIBILITY STUDY REPORT” 18

(EXHIBIT NO. CEP-3) AND THE “HIGH PLAINS EXPRESS TRANSMISSION 19

PROJECT FEASIBILITY STUDY REPORT” (EXHIBIT NO. CEP-4). 20

A: Both studies describe major conceptual transmission projects in eastern 21

Colorado. They each include a transmission circuit between Burlington and 22

Lamar, as part of a larger transmission project. The studies contemplate 23

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generation injection, import and export capability, and access to energy resource 1

zones, among other things. For purposes of this testimony, the salient point is 2

that a high voltage path from Story to Wray to Burlington to Lamar was deemed 3

necessary by these studies. 4

Q: GIVEN THAT BOTH BURLINGTON TRANSMISSION OPTIONS PERFORMED 5

WELL RELATIVE TO THE IDENTIFIED PROJECT NEEDS IN THE 6

“BURLINGTON – LAMAR 345/230 kV IMPACT AND 2013 POST TPL 7

ASSESSMENT STUDY” (EXHIBIT NO. CEP-6), HOW DID TRI-STATE SELECT 8

A PREFERRED PROJECT AMONG THESE ALTERNATIVES? 9

A: Tri-State first considered rough, plus-or-minus 30%, cost estimates for each 10

alternative for comparative purposes. These estimates are set forth below and in 11

Table 1 of Exhibit No. CEP-6. I note that these cost estimates differ from the 12

actual engineering level cost estimates as provided in Grant Lehman’s testimony. 13

Planning studies require relative ranking, so instead of creating detailed costs for 14

each alternative, plus or minus 30% costs allow relative ranking while avoiding 15

the expense of developing detailed facility estimates. 16

Alternative Description Conductor (ACSR) 2014 ($000)

1 Burlington – Lamar 345 kV Lattice Steel (100 miles) (operate at 230 kV without Burlington 345/230 kV transformer) 2-1272 164,000

1A Burlington – Lamar 230 kV Wood H-Frame (100 miles) 1272 81,000 2 Lamar-Lincoln 230 kV Wood H-Frame (97 miles) 1272 79,000 3 Lamar-Midway 230 kV Wood H-Frame (121 miles) 1272 98,000

17

Tri-State next considered its presently identified needs as well as the reasonably 18

anticipated transmission system needs in the Project area. Based on costs and 19

transmission system needs, Tri-State determined that Alternative 1A was the 20

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most appropriate, and as no other parties expressed interest in an expansion of 1

the project, Alternative 1A was deemed the preferred alternative. 2

Q: YOU MENTIONED THE “REASONABLY ANTICIPATED TRANSMISSION 3

SYSTEM NEEDS IN THE PROJECT AREA.” DID TRI-STATE CONSIDER 4

ANY ALTERNATIVES TO THE PROPOSED PROJECT THAT MIGHT 5

ACCOMMODATE FUTURE TRANSMISSION SYSTEM NEEDS IN THE 6

PROJECT AREA? 7

A: Yes. Tri-State recognizes that other stakeholders may have immediate and 8

longer-term needs in the Project area, so Tri-State reached out in public forums, 9

planning forums, and by solicitation letter that was published in the CCPG venue 10

and was picked up by industry media. None of the responses to the solicitation 11

letter identified any need for increasing the capacity of the Project. 12

Tri-State considered the possibility of constructing the Burlington – Lamar 13

transmission line to be capable of 345 kV operation, but operating it initially at 14

230 kV. Tri-State determined that the relative cost of such construction – more 15

than twice the estimated cost of the Project as per Exhibit No. CEP-6 – could 16

not be justified based on Tri-State’s present and reasonably anticipated needs. 17

Furthermore, since the transmission systems at either end only include 230 kV 18

infrastructure, the benefits of 345 kV construction cannot be realized without 19

multiple surrounding transmission system improvements that may or may not 20

occur. Tri-State also considered the possibility of installing the proposed single-21

circuit 230 kV transmission line on double-circuit structures with the other side of 22

the structure left vacant to accommodate potential future generation. 23

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Nevertheless, it was found that the additional cost of such structures would be 1

more than double the original costs. This is an increase that Tri-State cannot 2

justify based on its own needs and without financial participation in the Project by 3

other stakeholders. I discuss Tri-State’s efforts and outreach to solicit 4

participation in the Project by other stakeholders in Section VII, below, of my 5

testimony. 6

Q: DID TRI-STATE STUDY THE CAPABILITIES OF THE PROPOSED PROJECT 7

WITH RESPECT TO ACCOMMODATING EXISTING AND FUTURE 8

GENERATION IN THE AREA? 9

A: Yes. Tri-State performed a supplemental study to its post TPL Assessment 10

called “Supplemental Study to the Burlington – Lamar 345/230 kV Impact and 11

2013 Post TPL Assessment Study” (Exhibit No. CEP-8). This study analyzed 12

potential new generation injection levels after installation of a single-circuit 13

Burlington – Lamar 230 kV line. Based on evaluations of varying generation 14

injection levels at Lamar, Tri-State’s studies found that the system could 15

accommodate approximately 738 MW of combined generation at the Burlington 16

and Lamar 230 kV buses. The studies also demonstrated that with the new 17

Burlington – Lamar 230 kV line, between 245 and 477 MW of generation could 18

remain connected at Lamar following a loss of the Boone – Lamar 230 kV 19

transmission line. This is a significant improvement since at present, all 20

generation at Lamar is tripped for the same outage. 21

The exact amount of new generation that could be installed following the Project 22

depends on the manner in which the existing generation portfolio is managed 23

21 2005162440_3

and future load levels. Nevertheless, the Project is certain to provide some level 1

of opportunity for increased renewable generation in the region. Exhibit No. 2

CEP-8 provides more details. 3

Q: DID TRI-STATE STUDY THE IMPACT OF THE PROPOSED PROJECT ON 4

REGIONAL LOSSES AND CONSIDER ALTERNATIVES THAT COULD 5

FURTHER REDUCE LOSSES IN THE AREA? 6

A: Yes. Tri-State performed the “Burlington – Lamar 230 kV Losses 7

Evaluation” study (Exhibit No. CEP-9) to quantify the proposed Project’s benefit 8

to regional transmission system losses and to consider alternatives that could 9

potentially reduce losses further. The study found that with the proposed Project 10

installed, area losses would be reduced by 0.4 MW to 6 MW depending on 11

seasonal loading and generation dispatch conditions. The study also determined 12

that losses could be further reduced by 0.7 MW if bundled, rather than single, 13

1272 ACSR conductors were used. Unfortunately, 0.7 MW is a very small 14

improvement considering the bundled-conductor’s significantly higher 15

construction costs. All the regional transmission stakeholders, including Tri-16

State, will benefit from the reduced system losses that single 1272 ACSR 17

construction would provide. While bundled-conductor construction could provide 18

even more benefits, given the marginal amount of those benefits, the significant 19

costs, and the absence of participation by other stakeholders in this regard, it 20

was concluded by inspection that the benefits do not justify the additional costs in 21

the context of this Project. Tri-State cannot justify bundled-conductor 22

construction in light of Tri-State’s needs. 23

22 2005162440_3

VI. PROPOSED PROJECT 1

Q: PLEASE DESCRIBE THE TRANSMISSION SYSTEM IMPROVEMENTS THAT 2

WILL BE CONSTRUCTED AS PART OF ALTERNATIVE 1A. 3

A: The Project will include a new, single-circuit 230 kV transmission line extending 4

approximately 90-110 miles between the Burlington and Lamar substations. The 5

Project will also entail the installation of certain new equipment in each of the 6

existing substations, which may require their expansion. 7

Further, as discussed in the testimonies of Mr. Lehman and Mr. Myers, a single-8

circuit, 230 kV transmission line is typically constructed on a right-of-way 150 feet 9

wide. While Tri-State believes that the Project as proposed will meet its needs 10

into the reasonably foreseeable future, Tri-State is exploring the costs and 11

feasibility of acquiring additional rights-of-way that may facilitate the construction 12

of a second Burlington – Lamar transmission circuit should that be necessary in 13

the future. Tri-State intends to pay particular attention during the siting and 14

permitting process to any locations where right-of-way “bottlenecks” might impair 15

the ability to construct future transmission system improvements between 16

Burlington and Lamar. 17

VII. PROJECT COORDINATION 18

Q: DID TRI-STATE SOLICIT INTEREST FROM OTHER TRANSMISSION 19

STAKEHOLDERS FOR PARTICIPATION IN THE PROJECT? 20

A: Yes. On April 16, 2014, Tri-State sent a letter to various transmission owners 21

and operators and to independent transmission companies soliciting their interest 22

in expanding the capacity of the Project. A copy of Tri-State’s solicitation letter is 23

23 2005162440_3

attached as Exhibit No. CEP-11 to my testimony. Tri-State informed the 1

recipients that it was considering a new 230 kV transmission line between the 2

existing Burlington and Lamar substations, and solicited interest from parties who 3

may be interested in expanding the capacity of the Project to accommodate 4

additional needs and purposes. Two stakeholders expressed interest in building 5

the Project for Tri-State; however, no stakeholders expressed an interest in 6

participating to expand the capacity of the Project. 7

Q: DID TRI-STATE COORDINATE THE PROJECT WITH OTHER 8

TRANSMISSION OWNERS, OPERATORS, AND STAKEHOLDERS? 9

A: Yes, this Project has been discussed and coordinated in numerous venues. The 10

need for a new transmission element between Burlington and Lamar has been 11

discussed either explicitly or in the context of the larger Lamar – Front Range 12

project in each of Tri-State’s public FERC 890 and CO PUC Rule 3627 13

stakeholder outreach meetings since October 2011, including: October 17, 2011; 14

December 2, 2011; January 14, 2013; April 11, 2013; August 6, 2013; and 15

November 5, 2013. 16

Further, this Project was either specifically mentioned, or on the list of projects 17

open for discussion at all Colorado Coordinated Planning Group meetings during 18

that time. It has been included in each of Tri-State’s list of projects in the 19

WestConnect 10 year reports since 2012. Lastly, it has been posted on Tri-20

State’s webpage of 3627 projects since 2012. Stakeholders have had the 21

opportunity to email or comment through the webpage directly with Tri-State staff 22

with any concerns, questions, or recommendations. 23

24 2005162440_3

Q: WAS THE PROJECT INCLUDED IN TRI-STATE’S 2014 TEN-YEAR 1

TRANSMISSION PLAN? 2

A: Yes. I would note, however, that the Burlington – Lamar transmission project 3

included in the 2014 Ten-Year Plan contemplated construction of a 345 kV 4

transmission line that would be operated initially at 230 kV. For the reasons 5

discussed above, Tri-State has determined that the identified needs can be met 6

appropriately through construction of a single-circuit 230 kV transmission line. 7

Q: WAS THE PROJECT INCLUDED IN TRI-STATE’S 2012 TEN-YEAR 8

TRANSMISSION PLAN? 9

A: Yes, as an element in the larger Lamar – Front Range Transmission Project. In 10

Decision No. R12-1431, the Commission found that Tri-State’s 2012 Ten-Year 11

Transmission Plan, as part of the Joint Ten-Year Plan coordinated with PSCo 12

and Black Hills Energy, complied with Rule 3627 and was adequate for purposes 13

of that rule. 14

Q: IS THE PROJECT CONSISTENT WITH THE COORDINATED TRANSMISSION 15

PLANNING GOALS OF COMMISSION RULE 3627? 16

A: Yes. The Project was developed through an open, transparent, and coordinated 17

process that considered the needs and plans of other transmission owners, 18

operators, and stakeholders, so as to evaluate the possibility of a joint project 19

that could meet the needs of other transmission providers and stakeholders. In 20

developing the Project, Tri-State also actively solicited the input of other 21

transmission system stakeholders and ensured they had a meaningful 22

opportunity to participate in and provide input to the development of the Project. 23

25 2005162440_3

The Project does not negatively impact the system of any other transmission 1

provider or the overall transmission system in the near-term or within the long-2

term transmission planning horizon. The Project does not duplicate the existing 3

or planned facilities of any other transmission provider. As discussed in greater 4

detail in Tri-State’s February 1, 2014 Rule 3627 filing, the Project, as part of Tri-5

State’s coordinated ten-year transmission plan, contributes to the efficient 6

utilization of the transmission system on a best-cost basis, meets all applicable 7

regulatory criteria, complies with or supports compliance with all legal and 8

regulatory requirements, including Tri-State’s renewable electricity standard 9

obligations and resource adequacy requirements, and is consistent with 10

applicable transmission planning requirements under Federal Energy Regulatory 11

Commission Order 890. 12

Q: HOW DOES THE PROJECT COMPLEMENT TRI-STATE’S LONGER RANGE 13

PLANS IN EASTERN COLORADO? 14

A: In addition to the near-term load serving, reliability, and generation benefits I 15

have discussed, the Project also complements Tri-State’s long-range plans for 16

improvements to the bulk electric system in eastern Colorado. 17

While Tri-State’s anticipated resource needs do not justify a project the size of 18

Lamar – Front Range, staged elements of the Lamar – Front Range project do 19

accommodate more reasonably anticipated resource injection needs. Tri-State 20

has studied various scenarios in eastern Colorado, including increased Lamar 21

injection levels from 608 MW to 780 MW. In each of these scenarios, a new 230 22

kV transmission element between Burlington and Lamar was a critical first piece 23

26 2005162440_3

of any final build-out. Other elements could include increased transmission 1

between Lamar and Comanche and Burlington and Big Sandy. In summary, the 2

Burlington – Lamar 230 kV line aligns with, and is the appropriate first step for 3

most reasonable transmission build-out scenarios for eastern Colorado. 4

Q: WAS THE PROJECT INCLUDED IN TRI-STATE’S 2014 RULE 3206 FILING? 5

A: As a component of the larger Lamar – Front Range Project, yes, it was, but as a 6

separate, stand-alone project, it was not individually identified. As discussed 7

previously, the Burlington – Lamar transmission line was originally proposed as 8

part of the larger Lamar – Front Range Project. The Lamar – Front Range 9

Project was included in Tri-State’s 2010 Rule 3206 filing, and in Decision No. 10

C10-0644, the Commission determined that a CPCN was required for that 11

project. The Lamar – Front Range Project was included as an “Ongoing Project” 12

in Tri-State’s 2014 Rule 3206 filing. Consistent with the Commission’s previous 13

Decision and the Commission’s CPCN rules, Tri-State is applying for a CPCN for 14

the Burlington – Lamar 230 kV Transmission Line Project as a stand-alone 15

project. 16

Q: DOES THIS CONCLUDE YOUR DIRECT TESTIMONY? 17

A: Yes. 18

27 2005162440_3