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 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Docket No. ____ PREFILED TESTIMONY OF TIMOTHY UPTON ON BEHALF OF PETITIONERS November 8, 2007 The purpose of Mr. Upton’s testimony is to address the impacts of the Project upon orderly development of the region and municipalities where the Project is proposed, in accordance with 30 V.S.A. § 248(b)(1). TABLE OF CONTENTS 1. Introduction ......................................................................................................... 1 2. Overview ............................................................................................................. 2 3. Orderly Development.......................................................................................... 3 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.11 3.12 3.13 3.14 3.15 Vernon................................................................................................................. 4 Guilford ............................................................................................................... 6 Brattleboro .......................................................................................................... 8 Dummerston ........................................................................................................ 9 Newfane ............................................................................................................ 12 Brookline........................................................................................................... 16 Townshend ........................................................................................................ 17 Grafton .............................................................................................................. 20 Windham ........................................................................................................... 21 Andover............................................................................................................. 22 Chester .............................................................................................................. 24 Ludlow .............................................................................................................. 26 Cavendish .......................................................................................................... 28 Windham Regional Commission ...................................................................... 30 Southern Windsor County Regional Planning Commission ............................. 34 4 Conclusion ........................................................................................................ 36 EXHIBITS Exhibit Petitioners TOU-1 Resume of Timothy Upton Exhibit Petitioners TOU-2 Vernon Town Plan 2003 (excerpts) Exhibit Petitioners TOU-3 Guilford Town Plan 2005 (excerpts) Exhibit Petitioners TOU-4 Brattleboro Town Plan 2003 (excerpts) Exhibit Petitioners TOU-5 Dummerston Town Plan 2004 (excerpts) Exhibit Petitioners TOU-6 Newfane Town Plan 2006 (excerpts) Exhibit Petitioners TOU-7 Brookline Town Plan 2005 (excerpts) Exhibit Petitioners TOU-8 Townshend Town Plan 2003 (excerpts) Exhibit Petitioners TOU-9 Grafton Town Plan 2003 (excerpts) Exhibit Petitioners TOU-10 Windham Town Plan 2004 (excerpts) Exhibit Petitioners TOU-11 Andover Town Plan 1998 (excerpts) Exhibit Petitioners TOU-12 Chester Town Plan 2003 (excerpts) Exhibit Petitioners TOU-13 Ludlow Town Plan 2004 (excerpts) Exhibit Petitioners TOU-14 Cavendish Town Plan 2007 (excerpts) Exhibit Petitioners TOU-15 Windham Regional Plan 2006 (excerpts) Exhibit Petitioners TOU-16 Southern Windsor County Regional Plan 2003 (excerpts) 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 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Docket No. ____ PREFILED TESTIMONY OF TIMOTHY UPTON ON BEHALF OF PETITIONERS 1 1. Introduction 2 Q1. Please state your name and business address. 3 A1. My name is Timothy Upton, and my business address is 77 Grove St., Rutland, 4 VT 05701. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 2 of 37 1 2 Q2. By whom are you employed and in what position? 3 A2. I am employed by Central Vermont Public Service Corporation (“CVPS”) as 4 Manager of Environmental Affairs. 5 6 Q3. Please describe your educational background and work experience. 7 A3. I have worked at CVPS since 1999. Prior to that I worked as a land use planner 8 for Southern Windsor County Regional Planning Commission in Ascutney, 9 Vermont. I received a Master’s Degree in Natural Resources Planning in 1993 10 from the University of Vermont, and a degree as Master of Studies in 11 Environmental Law in 1995 from the Vermont Law School. My resume is 12 attached as Exhibit Petitioners TOU-1. 13 14 Q4. Have you testified previously before the Public Service Board? 15 A4. Yes. I have provided testimony on the behalf of CVPS, most recently in Dockets 16 7267, 7266, and 7246. 17 18 2. Overview 19 Q5. What is the purpose of your testimony? 20 A5. 30 V.S.A. § 248(b)(1) requires applicants for a transmission upgrade to provide 21 evidence that the Project will not unduly interfere with the orderly development of Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 3 of 37 1 the region, with due consideration having been given to the recommendations of 2 the municipal and regional planning commissions, the recommendations of the 3 municipal legislative bodies, and the land conservation measures contained in 4 local and regional plans. My testimony, along with that of VELCO witness 5 Kerrick Johnson, will address the Project’s conformance with this criterion. 6 7 Q6. Are you familiar with the proposed Project? 8 A6. Yes. I have attended numerous Project meetings with VELCO and CVPS engineers and planning personnel, coordinated with VELCO’s environmental 9 10 consultants and staff of the Vermont Agency of Natural Resources, and physically 11 viewed the entire Project area. I have also reviewed the various reports, plans, 12 orthophotos, and other materials concerning the Project’s impacts. 13 14 15 3. Q7. 16 17 Orderly Development Which local communities and regional planning jurisdictions will be directly impacted by the proposed Project? A7. The affected municipalities include: the towns of Vernon, Guilford, Brattleboro, 18 Dummerston, Newfane, Brookline, Townshend, Grafton, and Windham, each of 19 which is a member of the Windham Regional Commission; and the towns of 20 Andover, Chester, Ludlow and Cavendish, each of which is a member of the 21 Southern Windsor County Regional Planning Commission. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 4 of 37 1 2 3.1 Vernon 3 Q8. Please discuss the Project upgrades in the Town of Vernon. 4 A8. The proposed upgrades in Vernon are a new 345/115 kV substation, proposed to 5 be located immediately north of the existing Vermont Yankee generation facility 6 and substation yard, and an approximately 2.8-mile portion of the approximately 7 51-mile, 345 kV transmission line between Vernon and Cavendish; these Project 8 upgrades are described in more detail in the testimonies of Michael Barrett 9 (substation upgrades) and William F. McNamara (line upgrades) and 10 corresponding exhibits. 11 12 Q9. Have you reviewed the Vernon Town Plan? 13 A9. Yes. Excerpts are attached as Exhibit Petitioners TOU-2. Q10. Please identify sections of the Vernon Town Plan that relate to the siting of 14 15 16 17 electric transmission facilities. A10. The Vernon Town Plan encourages public utilities to use existing corridors in 18 order to minimize environmental impact and to assist desired development 19 patterns. (Vernon Town Plan at 4 and 34.) The Vernon Town Plan also states 20 that efforts will be made by the Town of Vernon to influence public utility Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 5 of 37 1 companies to bury utility lines in areas of greatest scenic or historic value, in town 2 centers and residential subdivisions. (Vernon Town Plan at 35.) 3 4 Q11. 5 6 Please identify land conservation measures in the Vernon Town Plan that are affected by the Project. A11. The Vernon Town Plan does not contain any land conservation measures that 7 apply to the Project. The Plan contains a provision regarding environmental 8 changes and vehicular access to the Vernon Black Gum Swamp; however, the 9 swamp is not located in the Project area. 10 11 Q12. Have the Petitioners considered recommendations of the Vernon Planning 12 Commission and Selectboard and the land conservation measures contained in 13 Vernon Town Plan? 14 A12. Yes. The Petitioners have designed the Project to optimize the use of the existing 15 utility corridor in Vernon. In addition, the Project’s environmental and aesthetic 16 reports and testimony of John Stamatov address strategies regarding avoidance 17 and minimization of impacts to natural resources. The Petitioners are aware of 18 the desire for new transmission lines to be placed underground in areas of greatest 19 scenic or historic value or in town centers. Undergrounding is not proposed in 20 Vernon; the new transmission lines will be constructed in the existing utility 21 corridor, and will not create new impacts in the areas of concern identified in the Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 6 of 37 1 Plan. Therefore, the additional costs of underground construction are not 2 justified. 3 4 As described in the testimony of Mr. Johnson, the Vernon Selectboard and 5 Planning Commission were provided with Project plans on June 1, 2007, and 6 VELCO staff met with Selectboard and Planning Commission members on 7 August 21, 2007 to discuss the Project in more detail. As of October 29, 2007 8 neither body recommended changes to the Project as designed. Should the 9 Selectboard or Planning Commission provide recommendations after that date, 10 VELCO and CVPS will consider them and provide them to the Board and all 11 parties. 12 13 3.2 Guilford 14 Q13. Please discuss the Project upgrades in the Town of Guilford. 15 A13. The proposed upgrades in Guilford are an approximately 3.7-mile portion of the 16 51-mile, 345 kV transmission line between Vernon and Cavendish. 17 18 Q14. Have you reviewed the Guilford Town Plan? 19 A14. Yes. Excerpts are attached as Exhibit Petitioners TOU-3. 20 Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 7 of 37 1 Q15. 2 3 Please identify sections of the Guilford Town Plan that relate to the siting of electric transmission facilities. A15. As part of its “Public Utility Corridors Policy” the Guilford Town Plan contains 4 the following statements: “In order to reduce their impact, new or expanded 5 public utility corridors . . . shall be placed, where feasible, within or parallel with 6 existing roads and utility rights-of-way. This will reduce their visual impact on 7 the landscape and will also facilitate maintenance.” (Guilford Town Plan at 17.) 8 There are no applicable land conservation measures in the Guilford Town Plan. 9 10 Q16. Have the Petitioners considered the recommendations of the Town of Guilford 11 Planning Commission and Selectboard and the land conservation measures 12 contained in Guilford Town Plan, if any? 13 A16. Yes. The Petitioners have designed the Project to be placed within the existing 14 utility right-of-way. In addition, the Project’s environmental and aesthetic reports 15 and testimony of Mr. Stamatov address strategies regarding the further avoidance 16 and minimization of visual impacts on the landscape. 17 18 As described in the testimony of Mr. Johnson, the Guilford Selectboard and 19 Planning Commission were provided with Project plans on June 1, 2007, and 20 VELCO staff met with the Selectboard on August 27, 2007 to discuss the Project 21 in more detail. As of October 29, 2007 neither body recommended changes to the Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 8 of 37 1 Project as designed. Should the Selectboard or Planning Commission provide 2 recommendations after that date, VELCO and CVPS will consider them and 3 provide them to the Board and all parties. 4 5 3.3 Brattleboro 6 Q17. Please discuss the Project upgrades in the Town of Brattleboro. 7 A17. The proposed upgrades in Brattleboro are an approximately 5.7-mile portion of 8 the 51-mile, 345 kV transmission line between Vernon and Cavendish. 9 10 Q18. Have you reviewed the Brattleboro Town Plan? 11 A18. Yes. Excerpts are attached as Exhibit Petitioners TOU-4. Q19. Please identify sections of the Brattleboro Town Plan that relate to the siting of 12 13 14 15 electric transmission facilities. A19. The Brattleboro Town Plan notes that the Southern Loop has been identified as a 16 constrained transmission and distribution area and includes a policy that the town 17 should site energy transmission or generation corridors or facilities so as to “avoid 18 aquifers, important plant and animal habitats or communities, and historic 19 resources” and “minimize their usual impact on ridgelines, slopes and open 20 areas.” (Brattleboro Town Plan at 65-66 and 72.) 21 Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 9 of 37 1 Q20. Have the Petitioners considered recommendations of the Brattleboro Planning 2 Commission and Selectboard and the land conservation measures contained in 3 Brattleboro Town Plan, if any? 4 A20. Yes. The Petitioners have designed the Project to optimize the use of the existing 5 utility corridor in Brattleboro. In addition, the Project’s environmental and 6 aesthetic reports and testimony of Mr. Stamatov address strategies regarding the 7 avoidance and minimization of impacts to natural and historic resources. There 8 are no applicable land conservation measures in the Brattleboro Town Plan. 9 10 As described in the testimony of Mr. Johnson, the Brattleboro Selectboard and 11 Planning Commission were provided with Project plans on June 1, 2007, and 12 VELCO staff met with Selectboard and Planning Commission members on 13 August 21, 2007 to discuss the Project in more detail. On September 17, 2007 the 14 Brattleboro Planning Commission provided comments on the Project (see Exhibit 15 Petitioners KJ-14). The Commission expressed conditional support for the 16 Project, including requests that the Petitioners adequately address ongoing energy 17 conservation efforts, the potential for public health impacts, and the quality of life 18 of local residents. 19 20 21 3.4 Q21. Dummerston Please discuss the Project upgrades in the Town of Dummerston. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 10 of 37 1 A21. The proposed upgrades in Dummerston are: (1) a 1,200-foot section of the 2 approximately one mile, 345 kV transmission line loop between the new Newfane 3 substation and the new Vernon-Cavendish 345 kV line, and (2) an approximately 4 4.9-mile portion of the 51-mile, 345 kV transmission line between Vernon and 5 Cavendish. 6 7 Q22. Have you reviewed the Dummerston Town Plan? 8 A22. Yes. Excerpts are attached as Exhibit Petitioners TOU-5. Q23. Please identify sections of the Dummerston Town Plan that relate to the siting of 9 10 11 12 electric transmission facilities. A23. The Dummerston Town Plan includes a policy to “[l]ocate generation facilities 13 and transmission corridors to minimize impacts on the environment and on 14 historic, recreational, and scenic facilities and sites.” (Dummerston Town Plan at 15 33.) While there are no specific land conservation measures in the Plan, the 16 Future Land Use Map does identify several areas as “Conservation Resource” 17 lands. These areas are overlay districts, and encompass parts of a number of 18 different underlying land use classifications. According to the Plan, Conservation 19 Resource lands include “those areas that are fragile environmentally and 20 aesthetically and/or areas that contain natural resources such as animal habitats, 21 cultural resources, farms or forests that should be protected for sustainable use Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 11 of 37 1 now and in the future.” (Dummerston Town Plan at 63-64.) A small portion of 2 each element of the Project in Dummerston (the new Vernon-Cavendish 345 kV 3 line and the proposed 345 kV loop) is located in the Conservation Resource 4 district. 5 6 Q24. Have the Petitioners considered recommendations of the Dummerston Planning 7 Commission and Selectboard and the land conservation measures contained in 8 Dummerston Town Plan, if any? 9 A24. Yes. The Petitioners have designed the Project to optimize the use of the existing 10 utility corridor in Dummerston. As the result of public input and extensive 11 discussions with members of the Planning Commission (described below), the 12 necessary substation upgrades have been relocated from the existing CVPS 13 substation in West Dummerston to a location in Newfane that lies along the 14 existing CVPS 46 kV right-of-way. The relocation will avoid impacts to locally 15 and regionally significant wildlife habitat and other natural, historic, recreational, 16 and scenic resources. By maximizing use of existing rights of way, the Project 17 also maximizes the protection of locally-identified natural and cultural resources 18 for sustainable use. The Project’s environmental and aesthetic reports and 19 testimony of Mr. Stamatov discuss in further detail the avoidance and 20 minimization of impacts to natural and cultural resources. 21 Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 12 of 37 1 As described in the testimony of Mr. Johnson, the Dummerston Selectboard and 2 Planning Commission were provided with Project plans on June 1, 2007. A 3 public meeting was held on July 11, 2007, at which significant concerns were 4 expressed regarding the initial proposal to construct a 345 kV loop connecting the 5 proposed Vernon-Cavendish line with the existing CVPS Dummerston substation. 6 The area proposed for the loop has been the subject of considerable planning 7 efforts at the local level, aimed at keeping the area in its present undeveloped 8 state. As a result of this feedback, VELCO and CVPS met with members of the 9 Dummerston Planning Commission and Selectboard on two occasions to discuss 10 possible alternatives to the initial proposal. Several alternatives were discussed, 11 and it was agreed that the best option would be to move the substation to a 12 location between Route 30 and the West River in the town of Newfane. Further 13 discussions with municipal officials in Newfane, as well as landowners in 14 Newfane and Dummerston, led to the decision to change the Project design and 15 formally propose the “Newfane” alternative. On September 14, 2007 the 16 Dummerston Planning Commission provided comments on the revised proposal 17 (see Exhibit Petitioners KJ-14), which indicate support for the amended proposal 18 with the substation located at the Newfane site. 19 20 21 3.5 Q25. Newfane Please discuss the Project upgrades in the Town of Newfane. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 13 of 37 1 A25. The proposed upgrades in Newfane are (1) a new VELCO 345/115/46 kV 2 substation, (2) an approximately one-mile portion of the 51-mile, 345 kV 3 transmission line between Vernon and Cavendish located adjacent to the 4 Dummerston-Newfane border, and (3) an approximately one-mile, 345 kV 5 VELCO transmission line loop between the new Newfane substation and the new 6 Vernon-Cavendish 345 kV line. 7 8 Q26. Have you reviewed the Newfane Town Plan? 9 A26. Yes. Excerpts are attached as Exhibit Petitioners TOU-6. Q27. Please identify sections of the Newfane Town Plan that relate to the siting of 10 11 12 13 electric transmission facilities. A27. The Newfane Town Plan does not contain recommendations directly relating to 14 the siting of electric transmission facilities. Part of the 345 kV loop will be 15 located in an area classified as “Resource” land on the Plan’s Proposed Land Use 16 map. The remainder of the lines, and the substation, will be located in “Rural” 17 land. Resource District Policies include, “Restrict development to uses and 18 activities that will not diminish the ecological function, scenic and natural beauty, 19 and natural character of these areas.” (Newfane Town Plan at 13.) Rural District 20 policies allow a mix of residential and commercial uses, “so long as those uses are 21 compatible with one another and do not cause excessive noise, pollution or Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 14 of 37 1 disturbance.” (Newfane Town Plan at 14.) Rural District Policies also seek to 2 limit commercial development to “paved roads.” (Newfane Town Plan at 14.) 3 4 The proposed 345 kV lines will be located within and adjacent to an existing 5 transmission corridor, avoiding any major changes to the scenic value or natural 6 character of the area. As explained in the Project environmental reports and 7 testimony of Mr. Stamatov, line construction and maintenance will not reduce the 8 ecological function of the area. The new Newfane substation will be accessed 9 from Route 30, will replace an existing gravel extraction operation, and will not 10 cause excessive noise or pollution. 11 12 The Newfane Town Plan contains a discussion of the special land use problems 13 that are posed by sand and gravel operations. The Plan states, “By their very 14 nature, sand and gravel pits can be one of the most visibly destructive intrusions 15 of any local land use regularly practiced in Newfane.” (Newfane Town Plan at 16 43.) The Newfane substation will reduce the local effects identified in the 17 Newfane Town Plan, and ensure the reclamation of the existing sand and gravel 18 pit. 19 Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 15 of 37 1 Q28. Have the Petitioners considered the recommendations of the Newfane Planning 2 Commission and Selectboard and the land conservation measures contained in 3 Newfane Town Plan, if any? 4 A28. Yes. The Petitioners have designed the Project to optimize the use of the existing 5 utility corridor in Newfane. In addition, the Project’s environmental and aesthetic 6 reports and testimony of Mr. Stamatov address strategies regarding avoidance and 7 minimization of impacts to scenic and natural resources. The Newfane Town 8 Plan does not contain any land conservation measures. 9 10 As described in the testimony of Mr. Johnson, the Newfane Selectboard and 11 Planning Commission were provided with Project plans on June 1, 2007, and 12 VELCO staff met with Selectboard and Planning Commission members on 13 August 16, 2007 to discuss the Project in more detail – including the proposal to 14 place the substation in Newfane. The Selectboard held a public meeting on 15 September 17, 2007 for the purpose of receiving public input on the substation 16 plans and issued Preliminary Comments on September 18, 2007 (see Exhibit 17 Petitioners KJ-14). Petitioners expect that both bodies will be afforded ample 18 time to respond to recent design changes and make recommendations, including 19 time beyond the filing of the Petition if necessary. VELCO and CVPS will 20 consider any such recommendations and provide them to the Board and all 21 parties. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 16 of 37 1 2 3.6 Brookline 3 Q29. Please discuss the Project upgrades in the Town of Brookline. 4 A29. The proposed upgrade in Brookline is an approximately 3.8-mile portion of the 5 51-mile, 345 kV transmission line between Vernon and Cavendish. 6 7 Q30. Have you reviewed the Brookline Town Plan? 8 A30. Yes. Excerpts are attached as Exhibit Petitioners TOU-7. Q31. Please identify sections of the Brookline Town Plan that relate to the siting of 9 10 11 12 electric transmission facilities. A31. The Brookline Town Plan does not contain recommendations directly relating to 13 the siting of electric transmission facilities. The Plan’s Scenic Resources Map 14 includes the land located between Grassy Brook Rd. and Hill Rd. an area crossed 15 by the existing and proposed transmission lines. The Plan contains a land use 16 policy to require public utilities to “minimize the impact on the environment and 17 to assist desire development patterns.” (Brookline Town Plan at 39.) 18 19 Q32. Have the Petitioners considered the recommendations of the Brookline Planning 20 Commission and Selectboard and the land conservation measures contained in 21 Brookline Town Plan, if any? Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 17 of 37 1 A32. Yes. The Petitioners have designed the Project to make use of the existing utility 2 corridor in Brookline, which will effectively minimize any impacts on natural 3 resources and areas identified as important scenic resources. In addition, the 4 Project’s environmental and aesthetic reports and testimony of Mr. Stamatov 5 address strategies regarding the avoidance and minimization of impacts on natural 6 and scenic resources. There are no relevant land conservation measures in the 7 Brookline Town Plan. 8 9 As described in the testimony of Mr. Johnson, the Brookline Selectboard and 10 Planning Commission were provided with Project plans on June 1, 2007, and 11 VELCO staff met with Selectboard and Planning Commission members on 12 September 5, 2007 to discuss the Project in more detail. As of October 29, 2007 13 neither body recommended changes to the Project as designed. Should the 14 Selectboard or Planning Commission provide recommendations after that date, 15 VELCO and CVPS will consider them and provide them to the Board and all 16 parties. 17 18 3.7 Townshend 19 Q33. Please discuss the Project upgrades in the Town of Townshend. 20 A33. The proposed Project upgrade in Townshend is an approximately 9-mile portion 21 of the 51-mile, 345 kV transmission line between Vernon and Cavendish. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 18 of 37 1 2 Q34. Have you reviewed the Townshend Town plan? 3 A34. Yes. Excerpts are attached as Exhibit Petitioners TOU-8. Q35. Please identify recommendations in the Townshend Town Plan that relate to the 4 5 6 7 siting of electric transmission facilities. A35. The Townshend Town Plan seeks to ensure that public utility companies have 8 demonstrated that they are maximizing efficiencies and assisting customers in 9 energy conservation before constructing additional generation and transmission 10 facilities. (Townshend Town Plan at 25.) The Plan encourages new transmission 11 proposals to use existing rights way and corridors. (Townshend Town Plan at 12 25.) In those areas designated as Resource Lands, the Plan contains a policy to 13 “[c]onstruct corridors for new energy transmission facilities only when needed, 14 and then adjacent to and parallel to existing operational energy transmission 15 facility corridors. Minimize their visual impact on ridge lines, slopes, and open 16 areas, and avoid important natural resources.” (Townshend Town Plan at 9.) 17 18 Q36. Have the Petitioners considered the recommendations of the Townshend Planning 19 Commission and Selectboard and the land conservation measures contained in the 20 Townshend Town Plan, if any? Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 19 of 37 1 A36. Yes. As discussed in the testimony of CVPS witnesses Rip Kirby and Kim Jones, 2 CVPS has undertaken extensive energy conservation measures along the Southern 3 Loop, and continues to look for ways to maintain reliable service through the use 4 of targeted conservation efforts. As discussed in the testimony of witnesses Dean 5 L. LaForest and Christopher Diebold, VELCO has vigorously pursued the 6 implementation of non-transmission alternatives on the regional network. In 7 addition, the Project environmental and aesthetic reports and testimony of Mr. 8 Stamatov address strategies regarding the avoidance and minimization of 9 environmental and aesthetic impacts. The Plan does not contain any land 10 conservation measures. 11 12 As described in the testimony of Mr. Johnson, the Townshend Selectboard and 13 Planning Commission were provided with Project plans on June 1, 2007, and 14 VELCO staff met with Selectboard and Planning Commission members on 15 August 22, 2007 to discuss the Project in more detail. As of October 29, 2007 16 neither body recommended changes to the Project as designed. Should the 17 Selectboard or Planning Commission provide recommendations after that date, 18 VELCO and CVPS will consider them and provide them to the Board and all 19 parties. 20 21 Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 20 of 37 1 3.8 Grafton 2 Q37. Please discuss the Project upgrades in the Town of Grafton. 3 A37. The proposed upgrade in Grafton is an approximately 1-mile portion of the 51- 4 mile, 345 kV transmission line between Vernon and Cavendish. 5 6 Q38. Have you reviewed the Grafton Town plan? 7 A38. Yes. Excerpts are attached as Exhibit Petitioners TOU-9. Q39. Please identify sections of the Grafton Town Plan that relate to the siting of 8 9 10 11 electric transmission facilities. A39. The Grafton Town Plan does not contain any language specifically related to the 12 siting of electric transmission facilities. The Plan generally encourages the 13 minimization of impacts on water quality, wildlife habitat, recreation, and scenic 14 resources. (Grafton Town Plan at 10-17.) 15 16 Q40. Have the Petitioners considered the recommendations of the Grafton Planning 17 Commission and Selectboard and the land conservation measures contained in the 18 Grafton Town Plan, if any? 19 A40. Yes. The Project will be located within an existing transmission right of way, 20 thereby avoiding and minimizing scenic and natural resource impacts to the 21 greatest extent feasible. In addition, the Project’s environmental and aesthetic Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 21 of 37 1 reports and testimony of Mr. Stamatov address strategies regarding the avoidance 2 and minimization of environmental and aesthetic impacts. There are no land 3 conservation measures in the Plan. 4 5 As described in the testimony of Mr. Johnson, the Grafton Selectboard and 6 Planning Commission were provided with Project plans on June 1, 2007, and the 7 Grafton Town Administrator indicated that the Town had no concerns with the 8 Project. The Grafton Selectboard indicated its support of the Project in its letter 9 dated September 20, 2007 (see Exhibit Petitioners KJ-14). 10 11 3.9 Windham 12 Q41. Please discuss the Project upgrades in the Town of Windham. 13 A41. The proposed upgrade in Windham is an approximately 5.3-mile portion of the 14 51-mile, 345 kV transmission line between Vernon and Cavendish. 15 16 Q42. Have you reviewed the Windham Town plan? 17 A42. Yes. Excerpts are attached as Exhibit Petitioners TOU-10. Q43. Please identify sections of the Windham Town Plan that relate to the siting of 18 19 20 electric transmission facilities. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 22 of 37 1 A43. The Windham Town Plan under the heading of “Prospective Situation” for public 2 utilities, states, “All utility construction must be contained in existing corridors.” 3 (Windham Town Plan at 16.) 4 5 Q44. Have the Petitioners considered recommendations of the Windham Planning 6 Commission and Selectboard and the land conservation measures contained in the 7 Windham Town Plan, if any? 8 A44. 9 Yes. The proposed line will be constructed entirely within an existing right of way. There are no land conservation measures in the Windham Town Plan. 10 11 As described in the testimony of Mr. Johnson, the Windham Selectboard and 12 Planning Commission were provided with Project plans on June 1, 2007, and 13 VELCO staff met with Selectboard members on August 13, 2007 to discuss the 14 Project in more detail. As of October 29, 2007 neither body recommended 15 changes to the Project as designed. Should the Selectboard or Planning 16 Commission provide recommendations after that date, VELCO and CVPS will 17 consider them and provide them to the Board and all parties. 18 19 20 3.10 Q45. Andover Please discuss the Project upgrades in the Town of Andover. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 23 of 37 1 A45. 2 The proposed upgrade in Andover is an approximately 4.1-mile portion of the 51mile, 345 kV transmission line between Vernon and Cavendish. 3 4 Q46. Have you reviewed the Andover Town Plan? 5 A46. Yes. Excerpts are attached as Exhibit Petitioners TOU-11. Q47. Please identify sections of the Andover Town Plan that relate to the siting of 6 7 8 9 electric transmission facilities. A47. One of the goals of the Andover Town Plan is to “accommodate the necessity of 10 [electrical facilities and transmission lines] while minimizing the economic, 11 aesthetic and environmental impact on the town.” (Andover Town Plan at 9.) 12 13 Q48. Have the Petitioners considered the recommendations of the Andover Planning 14 Commission and Selectboard and the land conservation measures contained in the 15 Andover Town Plan, if any? 16 A48. Yes. The Petitioners have designed the Project to optimize the use of the existing 17 utility corridor in Andover, which will minimize economic, aesthetic, and 18 environmental impacts. In addition, the Project’s environmental and aesthetic 19 reports and testimony of Mr. Stamatov address strategies regarding the avoidance 20 and minimization of aesthetic and environmental impacts. The Andover Town 21 Plan does not contain any land conservation measures. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 24 of 37 1 2 As described in the testimony of Mr. Johnson, the Andover Selectboard and 3 Planning Commission were provided with Project plans on June 1, 2007, and the 4 Selectboard discussed the project at its meeting of August 13, 2007. As of 5 October 29, 2007 neither body recommended changes to the Project as designed. 6 Should the Selectboard or Planning Commission provide recommendations after 7 that date, VELCO and CVPS will consider them and provide them to the Board 8 and all parties. 9 10 3.11 Chester 11 Q49. Please discuss the Project upgrades in the Town of Chester. 12 A49. The proposed upgrade in Chester is an approximately 5.2-mile portion of the 51- 13 mile, 345 kV transmission line between Vernon and Cavendish. 14 15 Q50. Have you reviewed the Chester Town Plan? 16 A50. Yes. Excerpts are attached as Exhibit Petitioners TOU-12. Q51. Please identify sections of the Chester Town Plan that relate to the siting of 17 18 19 20 21 electric transmission facilities. A51. The Plan’s Utilities and Facilities section contains several Electric Utilities Policies. Policies that appear applicable to transmission lines include: Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 25 of 37 1 “Provide residents with safe, effective and efficient utility service.” 2 “New utility lines should be placed along existing corridors whenever possible; 3 4 multipurpose use of utility corridors is encouraged.” 5 “Aesthetic and natural resource impacts should be considered when placing utility lines.” 6 7 (Chester Town Plan at 31-32.) “Promote underground electric lines where possible and practical.” 8 9 Q52. Have the Petitioners considered the recommendations of the Chester Planning 10 Commission and Selectboard and the land conservation measures contained in the 11 Chester Town Plan, if any? 12 A52. Yes. The Petitioners have designed the Project to optimize the use of the existing 13 utility corridor in Chester. In addition, the Project’s environmental and aesthetic 14 reports and testimony of Mr. Stamatov address strategies regarding the avoidance 15 and minimization of natural resource and aesthetic impacts. Particularly in light 16 of the existing transmission corridor and the design considerations regarding 17 aesthetics and environmental impacts, it is neither necessary nor practical to place 18 the proposed transmission line underground in Chester. The Chester Town Plan 19 does not contain any land conservation measures. 20 Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 26 of 37 1 As described in the testimony of Mr. Johnson, the Chester Selectboard and 2 Planning Commission were provided with Project plans on June 1, 2007, and 3 VELCO has been working with municipal officials to schedule a joint meeting to 4 discuss the Project in more detail. As of October 29, 2007 neither body 5 recommended changes to the Project as designed. However, Petitioners expect 6 that both bodies will be afforded ample time to respond to recent design changes 7 and make recommendations, including time beyond the filing of the Petition if 8 necessary. VELCO and CVPS will consider any such recommendations and 9 provide them to the Board and all parties. 10 11 3.12 Ludlow 12 Q53. Please discuss the Project upgrades in the Town of Ludlow. 13 A53. The proposed upgrade touches the southeast corner of Ludlow as the line crosses 14 from Chester into Cavendish. 15 16 Q54. Have you reviewed the Ludlow Town plan? 17 A54. Yes. Excerpts are attached as Exhibit Petitioners TOU-13. Q55. Please identify sections of the Ludlow Town Plan that relate to the siting of 18 19 20 electric transmission facilities. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 27 of 37 1 A55. The Electrical Services goals and implementation sections of the Ludlow Town 2 Plan include statements that the placement of electric lines and facilities should be 3 evaluated for health, safety and aesthetic concerns, and that the use of existing 4 infrastructure and services should be encouraged. (Ludlow Town Plan at 6-3.) 5 The Plan also encourages efforts to improve efficiency and reduce peak demands. 6 (Ludlow Town Plan at 6-2 and 6-3.) 7 8 Q56. 9 Commission and Selectboard and the land conservation measures contained in the 10 11 Have the Petitioners considered the recommendations of the Ludlow Planning Ludlow Town Plan, if any? A56. Yes. As described in the testimony of Mr. LaForest and Mr. Diebold the Project 12 is a component of a larger planning process which includes extensive efforts to 13 improve efficiency and reduce peak demands. The Petitioners have designed the 14 Project to optimize the use of the existing utility rights of way in an around 15 Ludlow. In addition, the Project’s environmental and aesthetic reports and 16 testimony of Mr. Stamatov address strategies regarding the avoidance and 17 minimization of environmental and aesthetic impacts. The Ludlow Town Plan 18 does not contain any land conservation measures. 19 20 As described in the testimony of Mr. Johnson, the Ludlow Selectboard and 21 Planning Commission were provided with Project plans on June 1, 2007, and Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 28 of 37 1 VELCO staff met with the Planning Commission and Town Manager on August 2 21, 2007 to discuss the Project in more detail. As of October 29, 2007 neither 3 body recommended changes to the Project as designed. Should the Selectboard or 4 Planning Commission provide recommendations after that date, VELCO and 5 CVPS will consider them and provide them to the Board and all parties. 6 7 3.13 Cavendish 8 Q57. Please discuss the Project upgrades in the Town of Cavendish. 9 A57. The proposed upgrades in Cavendish are an expansion of VELCO’s Coolidge 10 substation and an approximately 5.5-mile portion of the 51-mile, 345 kV 11 transmission line between Vernon and Cavendish. 12 13 Q58. Have you reviewed the Cavendish Town plan? 14 A58. Yes. Excerpts are attached as Exhibit Petitioners TOU-14. Q59. Please identify recommendations in the Cavendish Town Plan that relate to the 15 16 17 18 siting of electric transmission facilities. A59. 19 20 21 The Plan’s Utilities and Facilities section contains several Electric Utilities Policies. Policies that appear applicable to transmission lines include: “New utility lines should be placed along existing corridors whenever possible; multipurpose use of utility corridors is encouraged.” Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 29 of 37 1 2 3 “The location or relocation shall not have a negative impact upon aesthetic and natural resources.” 4 “The town encourages the installation of underground utility lines for new construction.” (Cavendish Town Plan at 23.) 5 6 Q60. Have the Petitioners considered the recommendations of the Cavendish Planning 7 Commission and Selectboard and the land conservation measures contained in the 8 Cavendish Town Plan, if any? 9 A60. Yes. The Petitioners have designed the Project to optimize the use of the existing 10 utility corridor in Cavendish. In addition, the Project’s environmental and 11 aesthetic reports and testimony of Mr. Stamatov address strategies regarding the 12 avoidance and minimization of natural resource and aesthetic impacts. 13 Particularly in light of the existing transmission corridor and the design 14 considerations regarding aesthetics and environmental impacts, it is neither 15 necessary nor practical to place the proposed transmission line underground in 16 Cavendish. The Cavendish Town Plan does not contain any land conservation 17 measures. 18 19 As described in the testimony of Mr. Johnson, the Cavendish Selectboard and 20 Planning Commission were provided with Project plans on June 1, 2007, and 21 VELCO staff met with members of the Selectboard and Planning Commission on Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 30 of 37 1 August 13, 2007 to discuss the Project in more detail. In addition, Town Manager 2 Richard Svec was a member of the Community Working Group. As of October 3 29, 2007 neither body recommended changes to the Project as designed. Should 4 the Selectboard or Planning Commission provide recommendations after that 5 date, VELCO and CVPS will consider them and provide them to the Board and 6 all parties. 7 8 3.14 Windham Regional Commission 9 Q61. Have you reviewed the Windham Regional Plan? 10 A61. Yes. Excerpts are attached as Exhibit Petitioners TOU-15. Q62. Please identify sections of the Windham Regional Plan that relate to the siting of 11 12 13 14 electric transmission facilities. A62. The Windham Regional Plan identifies the Southern Loop as an important 15 regional consideration and acknowledges that CVPS and VELCO have 16 undertaken a major planning project that is focused on identifying and 17 implementing needed improvements to the Southern Loop area. (Windham 18 Regional Plan at 46.) 19 20 The Windham Regional Plan places the Southern Loop in the context of other 21 components of the New England power system which are “older and less robust Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 31 of 37 1 than in some parts of the U.S.” (Windham Regional Plan at 46.) Energy policies 2 include the following: 3 With regard to all energy generation, transmission and distribution 4 projects: 5 Adhere to a high environmental standard that includes avoiding 6 negative environmental impacts to the extent possible and 7 adequately minimizing and mitigating those that cannot be 8 avoided; 9 Conduct thorough and proper studies and analyses of all 10 anticipated socioeconomic and environmental impacts, both 11 positive and negative; 12 13 Adequately address all areas of concern regarding proposed developments; and 14 Effectively and adequately address all issues related to facility 15 operation and reliability, recognizing that in some instances they 16 are inextricably intertwined with public health and safety concerns. 17 With regard to new or improved energy transmission or distribution 18 facilities: 19 20 Prefer and select existing transmission and distribution corridors over creation of new corridors; Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 32 of 37 1 2 Avoid extension of energy transmission or distribution facilities into or through Resource Lands; and 3 Avoid extension or alteration of energy transmission or distribution 4 facilities in any manner that would significantly impact Resource 5 Lands or significantly diminish important natural resource values. 6 Avoid extension of energy transmission or distribution facilities, or other 7 utility services into or through Resource Lands, or near them in a manner 8 that significantly reduces their resource values. (Windham Regional Plan 9 at 47.) 10 11 12 For areas identified as “Rural Lands” the Plan’s Land Use policies include: 13 14 Avoid extension of roads, energy transmission or distribution facilities, or other utility services into or through Resource Lands. Construct corridors for new energy transmission or distribution facilities 15 only when needed, and then only within or adjacent to existing operational 16 energy transmission facility corridors to the maximum extent possible. 17 Minimize their visual impact on ridgelines, slopes and open areas, and 18 avoid important natural and historic resources. (Windham Regional Plan 19 at 32.) 20 Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 33 of 37 1 Q63. 2 3 Have the Petitioners considered the recommendations of the WRC and the land conservation measures contained in the Windham Regional Plan, if any? A63. Yes. The Project is the primary product of the planning process mentioned in the 4 Plan and is designed to improve reliability in the area of the Southern Loop. The 5 Petitioners have thoroughly analyzed the environmental and socioeconomic 6 aspects of transmission planning. 7 8 The Project is located almost entirely within Rural Lands, according to the Plan’s 9 Proposed Land Use map, including a significant area identified as Resource 10 Lands. The Project will be located almost entirely within an existing operational 11 transmission right of way, adjacent to an existing VELCO transmission facility. 12 The proposed Newfane substation and associated connecting loop will be built in 13 and adjacent to an existing CVPS transmission line, and was proposed only when 14 necessary, after making significant investments in efficiency and load 15 management. As explained in the Project’s environmental and aesthetic reports 16 and testimony of Mr. Stamatov, the Project has been designed to avoid and 17 minimize impacts on natural and aesthetic resources. 18 19 Because Resource Lands occupy nearly half the land area of the Region, and 20 because the Project was designed to make use of an existing operational 21 transmission right of way rather than create a new corridor, extension of the Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 34 of 37 1 proposed line through Resource Lands cannot be avoided. The Project design 2 nonetheless avoids any reduction in the resource value of these areas, and meets 3 the overall goals for transmission planning and construction expressed in the Plan. 4 5 As described in the testimony of Mr. Johnson, the Windham Regional 6 Commission was provided with Project plans on June 1, 2007. In addition, 7 Executive Director Jim Matteau was a member of the Community Working 8 Group. As of September 26, 2007 the Windham Regional Commission had not 9 recommended changes to the Project as designed. However, given recent design 10 changes in the towns of Dummerston and Newfane, Petitioners expect that the 11 Windham Regional Commission will be afforded ample time to respond to the 12 changes and make recommendations, including time beyond the filing of the 13 Petition if necessary. VELCO and CVPS will consider any such 14 recommendations and provide them to the Board and all parties. 15 16 3.15 Southern Windsor County Regional Planning Commission 17 Q64. Have you reviewed the Southern Windsor County 2003 Regional Plan? 18 A64. Yes. Excerpts are attached as Exhibit Petitioners TOU-16. Q65. Please identify sections of the Southern Windsor County 2003 Regional Plan that 19 20 21 relate to the siting of electric transmission facilities. Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 35 of 37 1 A65. The Southern Windsor County 2003 Regional Plan states that efficient 2 infrastructure adequate to support economic or other growth should be created 3 prior to development. (Southern Windsor County 2003 Regional Plan at 8.) 4 5 The Plan includes a goal to “direct the placement of transmission lines to support 6 designated village, commercial and industrial development.” (Southern Windsor 7 County 2003 Regional Plan at 29.) Like many of the town plans identified above, 8 the Plan also prefers that transmission and distribution facilities be built in 9 existing corridors. Policies include: “Location and expansion of utilities and 10 facilities should occur in areas best able to serve the public interest with the 11 fewest negative side effects”; and “Multipurpose use of existing utility corridors 12 and placement of new lines or extension in existing corridors is encouraged 13 wherever possible.” (Southern Windsor County 2003 Regional Plan at 29-30.) 14 15 Q66. Have the Petitioners considered the recommendations of the Southern Windsor 16 County Regional Planning Commission, and the land conservation measures 17 contained in the Southern Windsor County 2003 Regional Plan, if any? 18 A66. Yes. Consistent with the Southern Windsor County 2003 Regional Plan, the 19 Project is designed to improve the electric transmission system, making the 20 electric infrastructure system more dependable and supporting local and regional 21 land use planning and development efforts. The Project includes the use of Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 36 of 37 1 existing transmission corridors in the Region. In addition, the Project has been 2 designed to minimize potential negative side effects of construction, as explained 3 in the environmental and aesthetic reports and testimony of Mr. Damiano and Mr. 4 Buscher. 5 6 As described in the testimony of Mr. Johnson, the Southern Windsor County 7 Regional Planning Commission was provided with Project plans on June 1, 2007. 8 In addition, Executive Director Tom Kennedy was a member of the Community 9 Working Group. The Southern Windsor County Regional Planning Commission 10 indicated its support of the Project in its letter dated September 20, 2007 (see 11 Exhibit Petitioners KJ-14). 12 13 14 4. Q67. Conclusion In summary, will the Project interfere with the orderly development of the region 15 with due consideration to the recommendations of the municipal and regional 16 planning commissions and the municipal legislative bodies, and the land 17 conservation measures contained in local and regional plans? 18 A67. No. Most of the Project elements are located within relatively remote rural areas 19 of southern Vermont, where their impacts are more expected and acceptable than 20 they may be in some residential areas. See In re: Petition of Blittersdorf, CPG 21 NM-11 at 17. (“… barns, silos, farm machinery, tall telephone poles and other Southern Loop Project, PSB Docket No._____ Prefiled Testimony of Timothy Upton November 8, 2007 Page 37 of 37 1 large working structures with moderate noise impacts are more common in a rural 2 environment than in a residential area.”) Also, nearly all of the Project elements 3 are located within an existing utility corridor, reflecting the clear preference of 4 local and regional planning commissions along the entire corridor, as well as 5 previous Board decisions. See Petition of Vermont Electric Power Company, Inc. 6 and Green Mountain Power Corporation, Docket No. 6860, Order of 01/28/05 at 7 203 (“The effects of the proposed Project on the orderly development of the 8 region are limited by the use of existing transmission corridors and existing 9 substation locations for the vast majority of the Project.”) The proposed 10 substation, while not an expansion of an existing substation site, is located 11 directly adjacent to an existing transmission corridor. Its location was chosen in 12 order to avoid locally identified conflicts with municipal land use planning efforts 13 in Dummerston, and by placing the facility in an existing gravel pit, the 14 Petitioners have avoided new conflicts in the town of Newfane. 15 16 Q68. Does this conclude your testimony at this time? 17 A68. Yes, it does.