STATE OF VERMONT
PUBLIC SERVICE BOARD
Petition of Vermont Transco, LLC, and
Vermont Electric Power Company, Inc.
(collectively, “VELCO”), and Central Vermont
Public Service Corporation (“CVPS”) for a
Certificate of Public Good, pursuant to 30
V.S.A. § 248, for the “Southern Loop Project,”
located in Vernon, Guilford, Brattleboro,
Dummerston, Newfane, Brookline, Townshend,
Grafton, Windham, Andover, Chester, Ludlow
and Cavendish, Vermont, consisting of the
following elements: (1) a new, approximately
51-mile, 345 kV transmission line between
Vernon-Cavendish, to be built parallel to and
within the same utility right-of-way as
VELCO’s existing Vernon-Cavendish 345 kV
line; (2) a new VELCO 345/115 kV Vernon
substation, to be located just north of the
Vermont Yankee Nuclear Power Station; (3) a
new 345/115/46 kV Newfane substation; (4) a
new, approximately one-mile, 345 kV
transmission line loop between the new
Newfane substation and the new VernonCavendish 345 kV line; (5) expansion of
VELCO’s Coolidge substation in Cavendish,
Vermont; and (6) the implementing of
incremental energy efficiency to defer
transmission upgrades in Southern Vermont
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Docket No. ____
PREFILED TESTIMONY OF
JOHN STAMATOV
ON BEHALF OF
PETITIONERS
November 8, 2007
The purpose of Mr. Stamatov’s testimony is to describe VELCO’s construction access
practices, as well as the potential impacts of the Project under certain of the criteria in
10 V.S.A. § 6086(a)(1) through (a)(9)(K).
TABLE OF CONTENTS
1.
Introduction ..............................................................................................................1
2.
Construction Access Practices .................................................................................2
3.
Air Pollution, 10 V.S.A. § 6086(a)(1) ...................................................................11
4.
Waste Disposal, 10 V.S.A. § 6086(a)(1)(B) ..........................................................12
5.
Water Supply and Water Conservation, 10 V.S.A. § 6086(a)(1)(C) .....................13
6.
Traffic, 10 V.S.A. § 6086(a)(5) .............................................................................14
7.
Waterways, 10 V.S.A. § 6086(a)(5) ......................................................................14
8.
Educational and Municipal Services, 10 V.S.A. § 6086(a)(6)&(7) .......................15
9.
Development Affecting Public Investments, 10 V.S.A. § 6086(a)(9)(K) .............16
EXHIBITS
Exhibit Petitioners JS-1
Resume of John Stamatov
Exhibit Petitioners JS-2
VELCO Best Management Practices for Construction
Access
Exhibit Petitioners JS-3
VELCO Lamoille County Reliability Project Stream
Crossings Plan
STATE OF VERMONT
PUBLIC SERVICE BOARD
Petition of Vermont Transco, LLC, and
Vermont Electric Power Company, Inc.
(collectively, “VELCO”), and Central Vermont
Public Service Corporation (“CVPS”) for a
Certificate of Public Good, pursuant to 30
V.S.A. § 248, for the “Southern Loop Project,”
located in Vernon, Guilford, Brattleboro,
Dummerston, Newfane, Brookline, Townshend,
Grafton, Windham, Andover, Chester, Ludlow
and Cavendish, Vermont, consisting of the
following elements: (1) a new, approximately
51-mile, 345 kV transmission line between
Vernon-Cavendish, to be built parallel to and
within the same utility right-of-way as
VELCO’s existing Vernon-Cavendish 345 kV
line; (2) a new VELCO 345/115 kV Vernon
substation, to be located just north of the
Vermont Yankee Nuclear Power Station; (3) a
new 345/115/46 kV Newfane substation; (4) a
new, approximately one-mile, 345 kV
transmission line loop between the new
Newfane substation and the new VernonCavendish 345 kV line; (5) expansion of
VELCO’s Coolidge substation in Cavendish,
Vermont; and (6) the implementing of
incremental energy efficiency to defer
transmission upgrades in Southern Vermont
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Docket No. ____
PREFILED TESTIMONY OF
JOHN STAMATOV
ON BEHALF OF
PETITIONERS
1
1.
Introduction
2
Q1.
Please state your name, business address, and qualifications.
3
A1.
My name is John R. Stamatov. My business address is Vermont Electric
4
Power Company, Inc. (“VELCO”), 366 Pinnacle Ridge Road, Rutland,
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 2 of 16
1
Vermont 05701. I have worked in the environmental field since graduating
2
from the University of Vermont in 1984 with a B.S. in Civil Engineering.
3
Currently, I am the Manager of Regulatory Affairs for VELCO. I am
4
responsible for providing environmental permitting and compliance support to
5
VELCO’s capital construction program, including the Southern Loop Project
6
(the “Project”). I also play a key role in providing environmental training to
7
VELCO personnel, as well as contractors and consultants. My resume is
8
attached as Exhibit Petitioners JS-1.
9
10
Q2.
What is the purpose of your testimony?
11
A2.
The purpose of my testimony is to generally describe VELCO’s construction
12
access practices, as well as the potential impacts of the Project under certain
13
of the criteria in 10 V.S.A. §§ 6086(a)(1) through (a)(9)(k).
14
15
16
2.
Q3.
How does VELCO intend to access the Project transmission line rights-of-way
(“Project ROWs”) during construction?
17
18
Construction Access Practices
A3.
VELCO’s Best Management Practices for Construction Access, which are
19
included with this filing as Exhibit Petitioners JS-2, detail VELCO’s
20
construction access practices generally. Exhibit Petitioners JS-3 is the
21
VELCO Lamoille County Reliability Project Stream Crossings Plan, which
22
VELCO developed and submitted in the recent Lamoille Project docket, to
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 3 of 16
1
specify VELCO’s access practices in areas involving stream crossings.
2
Generally, to minimize impacts to the environment, VELCO attempts to use
3
existing access roads whenever possible. Access roads include:
4
1) In-corridor, existing access roads. This access is characterized as
5
existing maintenance roads that are presently in use to provide access
6
to the existing transmission lines in the Project ROWs. These existing
7
roads are used by VELCO (or by CVPS in the case of the Newfane
8
Loop) for access to conduct routine and emergency maintenance work,
9
vegetation management work, and general field reconnaissance and
10
line patrol work. In many sections of the Vernon to Cavendish 345 kV
11
ROW between road crossings, existing in-corridor access roads
12
traverse the cleared corridor. Some locations already have existing
13
culverts and/or historic fill roads, which will be utilized to the fullest
14
extent possible.
15
2) New, in-corridor access roads. In many locations, new in-corridor
16
access will be required to allow equipment to travel from the existing
17
in-corridor access road to work areas within the corridor, including
18
new structure work areas and lay down areas. Typically, these roads
19
are simply paths, and no road building (e.g., cut/fill) is required. Often,
20
wood chips are used to create a road base, thereby eliminating the need
21
to disturb earth to level or grade the road bed. In these cases, vehicles
22
and equipment simply travel overland, and no special ground
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 4 of 16
1
preparation is required. In certain cases, where travel is required
2
through or along steep banks or through terrain that is simply too
3
rough for overland vehicle travel, use of construction mats, or in some
4
cases, construction or road building may be required. Road building
5
typically involves earthwork to create a suitable road base and road
6
grade. In some cases, blasting is required. This type of road
7
preparation is often referred to as cut and fill work.
8
9
3) Existing off-corridor access roads. The most common off-corridor
access road is a public town or state road. It is from these roads that
10
construction crews gain access to the vast majority of the Project
11
ROWs. In some cases, driveways, logging trails, recreation paths,
12
abandoned town roads, or other types of existing roads are used, if
13
direct corridor access from a public roadway is not available.
14
4) New off-corridor access routes. In rare cases, a new access road is
15
required to gain access to the corridor. Like new in-corridor access
16
roads, road building may or may not be required when creating new
17
off-corridor access routes.
18
19
Whether an access road is in- or off-corridor, it is VELCO’s strong preference
20
to use existing access roads, as this results in minimal natural and cultural
21
resources impacts, and much less road building is required. This approach
22
also significantly lowers construction costs.
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 5 of 16
1
2
Q4.
3
4
Has VELCO identified where off-corridor access will be required to
implement the Southern Loop Project?
A4.
Yes. We have studied the entire Project area and have identified locations
5
where access to the Project ROWs will be used. These access roads are
6
shown on Exhibit Petitioners SD-2, Figure 1.
7
8
Q5.
Has VELCO evaluated these access routes for natural and cultural resources?
9
A5.
Yes. Access routes to the Project ROWs were identified in consultation with
10
our environmental and archaeological consultants. In addition, the entire
11
width of the Project ROWs has been evaluated by our environmental and
12
archaeological consultants. The technical reports submitted with this filing by
13
TRC Environmental (“TRC”) (Exhibit Petitioners SD-2) and by Dr. Hope
14
Luhman of The Louis Berger Group, Inc. (“Berger”) (Exhibit Petitioners HL-
15
1) address the Project’s potential impacts upon these resources. With this
16
information, we can determine the best alignment for access roads so as to
17
avoid or minimize impacts to natural and cultural resources.
18
19
Q6.
20
21
22
What steps does VELCO take to minimize construction impacts to natural and
cultural resources?
A6.
As described above, VELCO first attempts to use existing access roads to the
greatest extent possible. This is the case for both in-corridor and off-corridor
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 6 of 16
1
access. When existing access roads are not suitable, VELCO will create a
2
new access road. For the off-corridor access identified on Exhibit Petitioners
3
SD-2, Figure 1, VELCO was able to identify existing roads, as described
4
above. At this time, I do not believe any new off-corridor access roads will be
5
required for the Project.
6
7
Once VELCO identifies an access road for use (new or existing), its
8
environmental team must identify the possible impacts to natural and cultural
9
resources, including streams, wetlands, rare, irreplaceable and natural areas
10
(“RINA”), rare, threatened or endangered species (“RTE”), soil erosion, and
11
archaeological sensitive areas or sites. To complete the evaluation process, all
12
access roads are evaluated by our environmental scientists and archaeologists
13
(in-house and consultants).
14
15
Q7.
16
17
What is the process to assess the chosen access roads for impacts to cultural
resources?
A7.
Construction access to and within the corridor is considered part of the Area
18
of Potential Effect (“APE”), as described in greater detail in the prefiled
19
testimony of Dr. Luhman accompanying this Petition. All access roads, with
20
the exception of improved roadways or paths (e.g., public roads, improved
21
gravel/dirt driveways and paths), are evaluated by VELCO’s archaeology
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 7 of 16
1
consultants. This evaluation has been done by Berger and is included in the
2
technical reports submitted with this filing (Exhibit Petitioners HL-1).
3
4
If an access road passes through an area that is considered archaeologically
5
sensitive or it transects a known archaeological site, it will be further
6
evaluated, as described in Dr. Luhman’s testimony. If, after a further
7
evaluation, a sensitive area or site is determined to be significant and eligible
8
for listing on the State and/or National Register of Historic Places, VELCO
9
will attempt to completely avoid the site by selecting a different access road or
10
changing the access road alignment. If such a realignment is not possible,
11
VELCO will undertake the appropriate site testing and data recovery in
12
conformance with the guidelines and requirements of the Vermont Division
13
for Historic Preservation (“DHP”) and the U.S. Army Corps of Engineers
14
(“ACOE”).
15
16
Q8.
17
18
What is the process to evaluate access roads with respect to other
environmental concerns, such as streams, wetlands or RINAs/RTEs?
A8.
All access roads, with the exception of improved roadways, are evaluated by
19
VELCO to determine potential impacts to wetlands and/or other
20
environmentally sensitive areas. This evaluation has been done and is
21
included in the Natural Resource Report submitted with this filing (Exhibit
22
Petitioners SD-2). When impacts are identified, VELCO attempts to identify
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 8 of 16
1
alternative access roads or develop impact mitigation measures consistent
2
with applicable regulatory requirements. As noted in Section 3.1 and 9 of the
3
Natural Resources Report, existing in-corridor access/maintenance roads
4
traverse through the Project ROWs. In some locations, these roads cross
5
streams and delineated wetlands. Some locations have existing culverts
6
and/or historic fill roads, which will be utilized to the fullest extent possible.
7
When no existing access road is present and a wetland must be crossed, access
8
impacts will be mitigated by traversing wetlands when the ground is frozen,
9
dry, or with use of construction matting that minimizes rutting, soil
10
compaction, and vegetation root damage. In some cases, VELCO may
11
propose permanent wetland crossings, which would involve soil grading and
12
possible placement of fill. These will be proposed only where repeated and
13
possibly frequent crossing will be necessary for future maintenance of the
14
transmission lines and corridor. In these situations, creating a more
15
permanent crossing will result in fewer overall impacts to the wetlands. The
16
same type of approach will be used for stream crossings. Use of existing
17
roads and avoidance will be followed; where new access is needed, the roads
18
will be perpendicular or near perpendicular to the stream channel wherever
19
possible to minimize span distance of the crossings. Construction timber mats
20
and pre-fabricated temporary bridges will be used where appropriate, in
21
accordance with applicable permit requirements.
22
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 9 of 16
1
Typical soil erosion prevention and sediment control (“EPSC”) measures,
2
such as siltation fencing and hay bales, will be developed for areas where soil
3
erosion may impact water quality, and they become conditions in the
4
stormwater discharge permit. These types of activities and standard EPSC
5
measures have been permitted for other VELCO projects.
6
7
Q9.
When does VELCO anticipate filing for Project permits?
8
A9.
VELCO plans to file permit applications for this Project during the first
9
quarter of 2008.
10
11
Q10.
Is construction access considered in the environmental permitting process?
12
A10.
Yes. With respect to wetlands and soil erosion, once we have identified
13
impacts through the process discussed above, VELCO will identify these
14
impacts in the permit applications for the ACOE Section 404 permit, the
15
Vermont Agency of Natural Resources (“ANR”) Conditional Use
16
Determination, and the construction stormwater discharge permits.
17
18
Q11.
What steps are taken to avoid RTE species?
19
A11.
Detailed information on the RTE species is presented in the technical report
20
submitted with this filing by TRC (Exhibit Petitioners SD-2). Like other
21
natural resources, VELCO attempts to minimize impacts on RTE areas by
22
simply avoiding them altogether. Access roads will be aligned to avoid these
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 10 of 16
1
areas, and when RTE areas are close to construction zones, these areas are
2
fenced to ensure equipment does not enter the area.
3
4
Q12.
5
6
What does VELCO do to ensure that construction crews adhere to the
prescribed access roads and operate within designated work zones?
A12.
Before entering the field, construction crews receive environmental sensitivity
7
training. In this training, VELCO educates the crews as to the importance of
8
protecting Vermont’s natural and cultural resources. Then, we review with
9
the crews the permit-specific requirements and conditions that VELCO must
10
adhere to so that these resources are protected and that VELCO completes the
11
work in accordance with the permit conditions. Finally, we introduce the
12
crews to the various procedures and processes that must be followed to
13
execute the work in a manner that is safe, consistent with the design, and
14
compliant with the applicable permits and regulatory requirements. Examples
15
of these processes and procedures include:
16

17
18
Daily tailboard meeting to review safety, environmental, and cultural
resource concerns;

19
Best Management Practices for installation of erosions control
measures;
20

Understanding of roles and responsibilities;
21

Emergency notification procedures;
22

Inspection/monitoring requirements and procedures; and
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 11 of 16

1
Review of Project plans.
2
3
Q13.
Are access roads depicted on Project plans?
4
A13.
Yes. Contractors are provided with detailed Project plans that show, among
5
other things, construction plan/profile views, archaeological sites, streams,
6
wetlands and access roads. The plans also identify the entire length of the off-
7
corridor access roads, beginning from their point of origin at a public access
8
point.
9
10
11
3.
Q14.
12
13
Air Pollution, 10 V.S.A. § 6086(a)(1)
What steps will VELCO undertake during construction to reduce air
pollution?
A14.
During construction, there will be minimal, short-term impacts from
14
construction equipment (e.g., diesel and gasoline powered trucks and
15
equipment). For tree clearing, trees/brush will be chipped – not burned. Dust
16
control, when necessary, will be accomplished through application of water or
17
calcium chloride on construction access roads and other areas disturbed by
18
construction. Any noise resulting from Project construction will result
19
primarily from operation of construction equipment. Post-construction, there
20
will be no air emissions from the ongoing operation of this Project. Post-
21
construction noise at the three substations (Vernon, Newfane, and Coolidge) is
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 12 of 16
1
addressed separately in the prefiled testimony of Kenneth Kaliski and the
2
associated Exhibits.
3
4
4.
Waste Disposal, 10 V.S.A. § 6086(a)(1)(B)
5
Q15.
Please discuss Petitioners’ plans regarding waste disposal.
6
A15.
The Project will meet the applicable Vermont Department of Environmental
7
Conservation (“DEC”) regulations for waste disposal. It will not involve the
8
injection of waste materials or any harmful toxic substances into groundwater
9
or wells.
10
11
As described in the prefiled testimony of Michael Barrett and associated
12
Exhibits, to minimize the possibility of a mineral oil release from power
13
transformers to the underlying soil and/or groundwater, each new substation
14
transformer will each be mounted on a concrete foundation with an integral oil
15
retention system. The oil retention systems have been designed in accordance
16
with ANSI/IEEE Standard 980, IEEE Guide for Containment and Control of
17
Oils Spills in Substations, and is consistent with the design used by VELCO in
18
the design of other substation upgrades approved by this Board.
19
20
With respect to solid waste, the generation of construction debris from the
21
Project will be minimal. Construction debris will be disposed of at an
22
approved construction and demolition debris landfill.
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 13 of 16
1
2
At the Vernon substation, a septic tank/leach field system will be constructed
3
to handle sanitary wastewater from the toilet and sink to be located within the
4
control building. The substation toilet facilities are used infrequently,
5
primarily by maintenance personnel, as the substations are not manned. The
6
toilet facility will be constructed in accordance with applicable Department of
7
Environmental Conservation regulations, and VELCO will obtain a water
8
supply, wastewater disposal permit from DEC prior to construction of the
9
toilet facility.
10
11
12
5.
Q16.
13
14
Water Supply and Water Conservation, 10 V.S.A. § 6086(a)(1)(C)
What impact will the Project have on water supply and water conservation
measures?
A16.
Presently, water consumption at the Coolidge substation is insignificant, as the
15
only water-consuming fixtures include a toilet, sink, and an emergency eye
16
wash/shower device. No changes with respect to these fixtures are planned at
17
this facility. A water supply well is planned for the Vernon substation;
18
however, the water use anticipated for this facility (e.g., toilet, sink, eye-wash
19
station) will be infrequent and minimal. No water-consuming fixtures are
20
planned for the Newfane substation.
21
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 14 of 16
1
2
6.
Q17.
3
4
Traffic, 10 V.S.A. § 6086(a)(5)
Please describe the potential Project impacts with respect to use of public
roads.
A17.
As far as Project impacts upon highways, during delivery of large Project
5
equipment on roadways and during construction of the Project transmission
6
lines at highway and road crossings, Petitioners will employ the services of
7
sheriffs and other traffic control personnel to manage traffic flow. Petitioners
8
will also obtain all required highway crossing permits. No public roads will
9
need to be excavated in order to complete this Project.
10
11
Q18.
Will railway transportation be affected by the Project?
12
A18.
The new 345 kV Vernon to Coolidge transmission line will span railroad
13
crossings in two locations: one in Vernon just north of the Vermont Yankee
14
Nuclear Power Station, and a second in Ludlow, on the south side of Route
15
103. The line has been designed to meet applicable clearances at these
16
crossings, and will not have any adverse effect on railway transportation
17
systems or railway operations.
18
19
7.
Waterways, 10 V.S.A. § 6086(a)(5)
20
Q19.
Will the transmission line span any navigable waters?
21
A19.
No. However, the new 345 kV line will span a small inlet to the Connecticut
22
River between structures 4S and 5S in Vernon. From a practicable standpoint,
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 15 of 16
1
this will have no impact on river transportation and navigation. The ACOE
2
does have permit jurisdiction of this crossing as the Connecticut River is
3
considered a navigable water under Section 10 of the Rivers and Harbors Act
4
of 1899. VELCO will consult with both the ACOE and the U.S. Coast Guard
5
to ensure that this crossing conforms with ACOE and/or U.S. Coast Guard
6
requirements.
7
8
9
8.
Q20.
10
11
Educational and Municipal Services, 10 V.S.A. § 6086(a)(6)&(7)
Is the Project expected to impact educational and municipal services in the
affected municipalities?
A20.
The Project will have no impact upon educational services provided by local
12
school systems, other than to enhance the reliability of the electrical service
13
currently provided. As such, there will be no adverse impact upon educational
14
services.
15
16
The Project will not impact municipal or governmental services, other than
17
requiring some coordination with local law and traffic enforcement services to
18
coordinate the safe delivery of large equipment or over-sized loads to
19
substations, staging areas and the corridor. This coordination is minor in
20
nature and occurs typically just in advance of equipment/material deliveries.
21
No adverse impact is anticipated.
22
Southern Loop Project, PSB Docket No. ____
Prefiled Testimony of John Stamatov
November 8, 2007
Page 16 of 16
1
2
3
4
9.
Q21.
5
6
Development Affecting Public Investments, 10 V.S.A.
§ 6086(a)(9)(K)
Will the Project negatively impact government or public utility facilities
services or lands?
A21.
No. “Electric generation facilities” are included in the definition of public
7
investment as found in Criterion 9(K) of Act 250. As Dean LaForest and
8
Chris Diebold explain in their prefiled testimony accompanying this Petition,
9
failure to upgrade the transmission facilities as they presently exist, given the
10
reliability risks that he describes, poses the greatest jeopardy to public
11
investments.
12
13
The new Vernon to Cavendish 345 kV line will span across several highways
14
and public roads, including Interstate 89 in Vernon. No pole structures will be
15
constructed within the road rights of way. The Project transmission lines will
16
also span several rivers, as noted in the report prepared by TRC (Exhibit
17
Petitioners SD-2). As discussed in the TRC Report, Petitioners will undertake
18
appropriate construction and EPSC measures to protect these resources.
19
20
Based on title research of adjoining property owners, no other potentially-
21
affected public lands were identified.
22
23
Q22.
Does this conclude your testimony?
24
A22.
Yes