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Testimony in Support of Senate File 716 Western Plymouth Neighborhood Alliance March 12, 2013

Plymouth area residents are grateful for Senator Terri Bonoffs leadership and the bipartisan collaboration of co-authors Senators Rest, Limmer and Osmek and Representative Sara Anderson, the author of a House companion to Senate File 716. Senate File 716 would protect Plymouth area residents, property values and wetlands in the Minnehaha Creek Watershed District from harm that would be caused by construction of an unnecessary high voltage 115 kilovolt (kV) transmission line to meet local distribution needs. Summary of Issues: 1. Xcel Energys proposed Hollydale high voltage transmission line is not needed. There is a feasible and available alternative (A2) that would meet Plymouth and Medina area distribution needs by providing a new substation and underground, low-voltage distribution feeders. 2. Xcel Energys proposed Hollydale high voltage transmission line through a densely populated suburban community would have serious adverse effects on residential homes, quality of life and property values. 3. The proposed high voltage transmission line would have significant adverse effects on natural resources, crossing thousands of feet of wetlands and flood plains and requiring construction of an estimated 16 power line poles in high value wetlands. 4. The adverse impacts of a high voltage transmission line in the Plymouth and Medina communities could be avoided by selection of the A2 low-voltage distribution alternative. 5. Senate File 716 is critical to make sure that an unnecessary high voltage power line is not built in the suburban residential communities of Plymouth and Medina.

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1. Xcel Energys proposed Hollydale high voltage transmission line is not needed. There is a feasible and available alternative (A2) that would meet Plymouth and Medina area distribution needs by providing a new substation and underground, low-voltage distribution feeders. Xcel Energy Plymouth Load Serving Study (November 2010) A2 meets the various criteria by which Planning Engineers compared each alternative. With respect to System Performance, A2 installs additional substation transformer capacity at one new location which is a greater distance than the substation under A1 from the identified load center in the Focused Study Area. As a result, A2 requires longer feeder circuits than A1 to serve load, and therefore, is subject to greater exposure to conditions that could lead to line failures. With respect to Operability, similar to A1 [the high voltage alternative preferred by Xcel], A2 is an extension of the existing distribution system and provides for a large number of standard options that could be quickly implemented under contingency conditions. Pre-filed Expert Testimony of Electrical Engineer Emmanuel Day for Western Plymouth Neighborhood Association (February 15, 2013) I studied the Certificate of Need Application and the studies performed by Xcel Energy that are contained in Appendix B1 and B2 of the Application to develop an opinion on whether the Hollydale 115 kV transmission line analyzed in these studies was really needed. After studying this material, I concluded that the electrical system in the Plymouth and Medina area did need some improvements to serve future load, but that the need for reliable electric power through the 2030 planning horizon reflected in the Appendix B studies could be met by implementing Alternative A2. Alternative A2 includes construction of a new perimeter substation near the Interstate 494 corridor, which would connect with existing Great River Energy 115 kV transmission lines, and would require additional 13.8 kV feeder lines from that new perimeter substation. The fundamental difference between the Hollydale alternative that Xcel proposes to build and Alternative A2 is that Alternative A2 meets existing and forecasted distribution needs in the focused study areas where Xcel Energy forecasted load growth without constructing eight or more miles of new 115 kV transmission line through highly populated neighborhoods of Plymouth, Minnesota. Minnesota Department of Commerce, Environmental Report Hollydale 115 kV Transmission Project (February 2013) Distribution Alternative -- A distribution alternative to the Hollydale Project is available and is feasible to construct.

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2. Constructing Xcel Energys proposed Hollydale high voltage transmission line through a densely populated suburban community would have serious adverse effects on residential homes, quality of life and property values. On Xcel Energys preferred route for the Hollydale 115 kV project, there are at least 62 homes within 50 feet and 289 homes within 200 feet of the high voltage transmission line center line. The following chart was provided by Applicant in Response to Western Plymouth Neighborhood Alliance (Alliance) Route Permit Information Request (IR) No. 4:

Dayna Murray, Realtor with Keller Williams Premier, voted Best Realtor for 2013 in Plymouth, Minnetonka, Wayzata and Maple Grove, Public Testimony on March 6, 2013. Whether or not there is scientific evidence that power lines are hazardous or not doesnt matter. The public perceives it as a risk and therefore their perception becomes reality for someone trying to sell a house. Days on market are increased and price is decreased. I spoke with the other top four agents in our office. Their responses were very similar. Basically, they all moaned and then shared that they had all sold homes with power lines but that they had taken longer to sell and received less money. Most said on average that the homes sold 10-15% lower. I did look at a small sample of homes along the power line area of Kady [St. Michael, MN]. The average days on market for the homes backing up to the power lines was 203. The average days on market for the other properties in that same area which were not backing up to the power lines was 43. Statistically, we know that the longer a home is on the market, the lower the price. Alan Napier, Public Testimony on March 6, 2013 (Paraphrase) Analysis of property tax records to determine property values of homes adjacent to the proposed high voltage transmission line showed that in the Plymouth area, east of Brockton, 263 homes had an aggregate value of $80.75 million. If property values were reduced 14% as a result of proximity to the power line, local property values would be hurt to the tune of $11.3 million. If all of the homes along the line were considered, total property values would be approximately $100 million and losses $14 million. An overhead high voltage line would harm aesthetics with 90-foot industrial-style metal poles, cut and remove trees (photos attached), and create buzzing noise and magnetic field health risks.

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3. The proposed high voltage transmission line would have significant adverse effects on natural resources, crossing thousands of feet of wetlands and flood plains and requiring construction of an estimated 16 power line poles in high value wetlands. Applicants Response to Alliance Certificate of Need (CON) IR No. 19 summarized land cover and the number of poles that would be placed on sensitive land uses:

Pre-filed Expert Testimony of Benjamin Carlson, Arrowhead Environmental Consulting, for Western Plymouth Neighborhood Association (February 15, 2013) My overall assessment was that the transmission project affected a number of significant water resources. The Hollydale transmission line would cross approximately 11,800 lineal feet of wetlands. Approximately 6,100 feet of these crossings have no adjacent road access. The Hollydale transmission line would cross approximately 4,700 feet of wetlands within the Minnehaha Creek Watershed District. Approximately 4,050 feet of the MCWD crossings would be within the higher value wetlands classified as Preserve or Manage 1. The Hollydale transmission line would cross approximately 2,560 of wetlands listed in the Minnesota Department of Natural Resources Public Waters Inventory. The Hollydale transmission line would cross approximately 5,300 feet of FEMA 100year floodplain. The Hollydale transmission line would cross approximately 3,650 feet of agricultural crop lands. Based on the information provided by Xcel Energy, of the 128 total poles planned for the Hollydale project, approximately thirty-five percent (45 poles) are located in sensitive water resources or on agricultural crop lands. (map is attached) Barry Altman, Public Testimony on March 17, 2013 (photos are attached) Our neighborhood is bounded on the north by a wetland area with several ponds full of wildlife. Aside from the wide array of birds and squirrels we have a variety of ducks. Several hatch their young on our ponds every year. Egrets are commonly seen in our wetlands. Our pond is host to a Muskrat family. The Red Foxes are always a treat as are the deer that come through our back yard. The wild turkeys and pheasants are often seen running through our property. The Hollydale 115kV Power Line will traverse these wetlands.

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4. The adverse impacts of a high voltage transmission line in the Plymouth and Medina communities could be avoided by selection of the A2 low-voltage distribution alternative. Pre-filed Expert Testimony of Benjamin Carlson, Arrowhead Environmental Consulting, for Western Plymouth Neighborhood Association (February 15, 2013) My assessment is that the proposed Hollydale transmission project has a number of potentially significant impacts on wetlands and water resources, particularly in the western portion of the project, from the Medina substation to the Hollydale substation. If it is feasible to avoid this type of impact on natural resources through selection of an alternative, I believe it would be desirable to do so. Alternative A2 would avoid most if not all of the impacts on agricultural crop lands, wetlands and water resources that would result from the Hollydale transmission line project. Dayna Murray, Realtor with Keller Williams Premier, voted Best Realtor for 2013 in Plymouth, Minnetonka, Wayzata and Maple Grove, Public Testimony on March 6, 2013. As for underground power lines, Ive never even considered any aesthetic or health risk with underground lines. As a Realtor, I have never had any buyer ask any question regarding the power boxes that sit in the front yards of some of the homes. That is a nonissue.

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5. Senate File 716 is critical to make sure that an unnecessary high voltage power line is not built in the suburban residential communities of Plymouth and Medina. There is unanimous community opposition to building a 115 kV power line if the facts show that a low-voltage distribution alternative can provide reliable energy to the Plymouth area. Plymouth City Council unanimously adopted Resolution No. 2012-251 on August 14, 2012: BE IT RESOLVED that the Plymouth City Council urges the Public Utilities Commission to refer the Certificate of Need proceeding for the Hollydale Transmission Line Project, Docket No. CN-12-113, for a contested-case hearing to allow for a full fact-finding hearing to determine if there are other low-voltage alternatives that can provide reliable energy to the Plymouth community. Public testimony at hearings on March 6 and March 7, 2013 unanimously supported a lowvoltage (13.8 kV) distribution alternative as a feasible and prudent alternative to a 115 kV high voltage transmission line in the Plymouth and Medina area. Unless SF 716 is enacted, there is a very real possibility that Xcel Energy will proceed with a route permit for a high voltage 115 kV transmission line, even if the weight of the evidence supports a low-voltage distribution alternative to meet energy needs. On February 27, 2013, Applicants asked Administrative Law Judge Eric Lipman to delay certificate of need hearings until the legislation is acted upon by the Governor or until it becomes apparent that a route over 10 miles in length may be selected by the Commission. Judge Lipman determined that both certificate of need and route proceedings should be continued pending legislative action. In response to questions by citizens in public hearings on March 7, 2013, Xcel Energy stated that if the legislature doesnt change the law, they will proceed with the 115 kV power line if a route is chosen that is less than the 10 miles long. Xcel Energy would use the transmission rider in Minn. Stat. 216B, Subd. 7b to recover costs for a suburban 115 kV high voltage line, but could not use the rider for a low-voltage alternative. Xcel Energy will seek cost recovery for the purchase of the Great River Energy 69 kV line as well as the construction of the proposed 115 kV line through a transmission cost recovery rider filing. (Applicants Response to Alliance CON IR No. 3) Because Alternative A2 is an alternative that does not meet the criteria for being granted a Certificate of Need by the Minnesota Public Utilities Commission, it would not be eligible for inclusion in the Northern State Power Companys Transmission Cost Recovery rider and instead would be recovered through inclusion in the Northern State Power Companys base retail rates. (Applicants Supp. Response to Alliance CON IR No. 12).

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Existing Residential-Scale 69 kV Power Line on Wooden Poles

Example of Proposed Commercial-Industrial Scale 115 kV Power Line on Metal Poles

Applicants' Response to Alliance Info. Request No. 12 Changes in Trees and Shrubs with 115 kV Line

Orchard Lane facing south CURRENT CONDITIONS*

Orchard Lane facing south FUTURE CONDITIONS*

*Note: Photographs were provided by Minnesota Department of Commerce. This photograph representation was completed using Adobe PhotoShop/Illustrator and is not spatially referenced. The photographs are not meant to be an exact representation of future conditions.

Hollydale CON - Carlson Direct - Schedule 11

3/11/13

Walnut Grove Pond

Wetland Area

10

Barry Altman

CON Hearing 03/2013

Walnut Grove Pond

Wetland Area

11

Barry Altman

CON Hearing 03/2013

Altman CON Hearing 03/13

3/11/13

Walnut Grove Pond

Wetland Area

12

Barry Altman

CON Hearing 03/2013

Walnut Grove Pond

Wetland Area

13

Barry Altman

CON Hearing 03/2013

Altman CON Hearing 03/13

3/11/13

Walnut Grove Pond

Wetland Area

14

Barry Altman

CON Hearing 03/2013

Altman CON Hearing 03/13

Hollydale Transmission Line Crossings Analysis Arrowhead Environmental Consulting (AEC)

Hollydale CON - Exhibit from Carlson Direct Testimony

PWI ID 27-603W 27-602W 27-601W 27-461W

Feet 650 620 580 710

NWI (Cowardin) PEMF PEMCd PEMCd PEMC/PEMF PEMCd, PSS1/EMC, PFO1Cd PEMCd, PEMFd PEMCd PEMCd PEMC, PUBF PEMA PEMCd PFO1Cd PEMC PEMBd/PEMCd PEMCd PEMCd PEMCd PEMCd/PSS1Cd PEMC/PFO1C PEMCd, PFO/SS1Cd, PEM/SS1Cd PEMCd

Feet 380 1260 255 710 1270 500 575 415 430 105 310 190 205 450 310 990 475 780 150 1485 550

MCWD (Classification) Manage 1 Preserve Manage 3 Manage 3 Manage 2 Manage 1 Manage 1 Manage 1 Manage 1 Manage 3 Manage 1

Feet 1405 145 90 50 445 265 970 430 770 65 65

Floodplain 100 -YR 100 -YR 100 -YR 100 -YR 100 -YR 100 -YR (3) 100 -YR 100 -YR 100 -YR 100 -YR

Feet 550 110 580 350 520 320 1590 405 735 140

Ag Field Crossing (Feet) Wetland no road access Feet 1220 PEMCd 505 1945 PEMC/PUBF 430 480 PEMCd 310 PFO1Cd 190 PEMC 205 PEMB/Cd 450 PEMCd 310 PEMCd 990 PEMCd 475 PEMCd/PSS1Cd 780 PEMCd, PFO/SS1Cd, PEM/SS1Cd 1485

AEC Barr

2560 NA

11795 11894
Preserve Manage 1 Manage 2 Manage 3

4700 NA
145 3905 445 205

5300 4564

3645 3769

6130 5596

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