,Jason Marks...,Jason Marks Attorney at Law 1011 Third Street NW Albuquerque, NM 87102 July 5, 2019 Ms. Melanie Sandoval Bureau Chief, Records Bureau NM Public Regulation Commission

,Jason MarksAttorney at Law1011 Third Street NWAlbuquerque, NM 87102

July 5, 2019

Ms. Melanie SandovalBureau Chief, Records BureauNM Public Regulation Commission1120 Paseo de PeraltaSanta Fe, NM 87501

Re:

Voice: (505) 385-4435Fax: (505) 359-3245

[email protected]

NLED !N OF!q. CE OF

Application for Approval of Right of WayWidth

Dear Ms. Sandovah

Attached please find an original plus five copies for filing of the Application forDetermination of Right of Way Width for the Great Divide Gen-Tie, and a check for the$25.00 filing fee required by NMSA § 62-13-2(B).

Please open a new docket for this Complaint and file the enclosed document therein.

Th nk you much, and best regards,

Jas(Att{

n Marksvney for Applicant Scout Clean Energy, LLC

BEFORE THE NEW MEXICO PUBLIC REGULATION COMMISSION

IN THE MATTER OF THE APPLICATIONOF GREAT DIVIDE WIND FARM, LLC FORDETERMINATION OF RIGHT-OF-WAYWIDTH FOR THE GREAT DIVIDE GEN-TIE,

GREAT DIVIDE WIND FARM, LLC,

Applicant.

)))))))))

APPLICATION FOR DETERMINATION OF RIGHT-OF-WAYWIDTH FOR THE GREAT DIVIDE GEN-TIE

COMES NOW Great Divide Wind Farm, LLC, Applicant, by and through undersigned

counsel, with its Application for Determination of Right-of-Way Width for the Great Divide

Gen-Tie, and supporting testimony. This Application is brought pursuant to NMSA 1978 § 62-

9-3.2, providing that a determination of right-of-way width shall be obtained from the New

Mexico Public Regulation Commission (NMPRC) prior to the construction of electrical

transmission requiring a fight-of-way width in excess of 100 feet.

The Great Divide Gen-Tie is a transmission line rated at 345 kV that will connect the

Great Divide Wind Farm 2 (GDW2) and Great Divide Wind Farm 3 (GDW3), from a common

collection point, to a point on the existing 345 kV line between E1 Paso Electric Company’s

(EPE) Hidalgo and Luna substations approximately 16 miles northeast of the city of Lordsburg,

Grant County, NM. The line is approximately two miles in length.

Applicant has determined through engineering studies that a right-of-way width of 180

feet is required for the Great Divide Gen-Tie, and applies for approval of such a right-of-way

width. Because the Gen-Tie is not being constructed in connection with, or to transmit

electricity from, a generating plant capable of operation at a capacity equal or greater than 300

megawatts, location control for the line is not required pursuant to NMSA § 62-9-3(B).

This Application provides a summary below, along with further details in accompanying

testimonies and exhibits, regarding the Applicant, the Great Divide Wind Farm projects, the

Great Divide Gen-Tie, the requirements of the ROW width statutes, the Great Divide Gen-Tie’s

compliance with the ROW width statute, and other matters related to this Application.

PROJECT BACKGROUND

1. Scout Clean Energy, LLC (Scout) is a Delaware limited liability company. Scout

has wind projects under development in 11 states, representing 4,045 MW of energy production.

Scout is the project developer and owner of Great Divide Wind Farm, LLC, Great Divide Wind

Farm 2, LLC, and Great Divide Wind Farm 3, LLC. Great Divide Wind Farm, LLC, Great

Divide Wind Farm 2 LLC, and Great Divide Wind Farm 3 LLC are each organized as Delaware

limited liability companies; and registered as a foreign limited liability company with the New

Mexico Secretary of State.

2. Great Divide Wind Farm, LLC is the overall project development company. It

will be the owner the Great Divide Gen-Tie, and it is the holder of the leases required to develop

the wind projects and the Gen-Tie.

3. The GDW2 and GDW3 projects are located on separate sites, approximately one

mile apart, in Grant County, NM, approximately 16 miles northeast of Lordsburg, NM. Under

the working engineering design, each project consists of 19 wind turbines, each rated at 4.2 MW,

for a total of 79.8 MW maximum output. The proposed equipment in this design case are

manufactured by Senvion. The turbines are to be installed at a terminal voltage of 0.580 kV.

This initial voltage is immediately stepped up to 34.5 kV, and delivered to underground collector

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lines. A single 345/34.5 kV main transformer will then step up the collector voltage to the 345

kV EPE Transmission System voltage, and an overhead transmission line which is the Great

Divide Gen-Tie will connect the projects to a new 345kV substation at a tap on the 345kV EPE

Hidalgo-Luna transmission line.

4. Applicant will have all land rights required for the two wind projects and the

Great Divide Gen-Tie by virtue of four private landowner Wind Energy Lease and Easement

Agreements that have been executed, and a long-term wind energy lease with the New Mexico

State Land Office which was negotiated and released for bids, and then awarded to Great Divide

Wind Farm, LLC on July 1, 2019. Applicant has completed initial project design and initiated

environmental studies and permitting for each Great Divide Wind project.

5. The GDW2 and GDW3 wind farms are planned to be constructed in 2020. The

Great Divide Gen-Tie is planned to be constructed in 2020.

THE GREAT DIVIDE GEN-TIE

6. The Great Divide Gen-Tie is a 345kV gen-tie line of approximately 2.1 miles that

will run from the common point of collection for the GDW2 and GDW3 wind farms to a point

on the existing 345 kV line between E1 Paso Electric Company’s (EPE) Hidalgo and Luna

substations, where a new substation will be constructed. It is configured as a single pole single

circuit. The line will run southeast in a single line.

7. The proposed location for the Gen-Tie is shown in Exhibit RK-2 to the Direct

Testimony of Robert "Bob" Karsted, which is submitted with this Application.

8. The 180’ right-of-way width requested for the Gen-Tie, over the 2.1 miles of the

line, results in a corridor containing approximately 46 acres. The Gen-Tie will be located on the

Land made available under the State Land Office Lease as well as on private lands leased from

the Hudson Cattle Company and the "96 Ranch."

RIGHT OF WAY WIDTH

9. Applicant requests a 180-foot ROW width for its approximately 2.1 -mile long

Gen-Tie Line. This width is required for compliance with electric and safety codes, for

construction and maintenance logistics, and route design flexibility over local terrain features.

Applicant requests the Commission’s ROW width determination pursuant to NMSA 1978, §62-

9-3.2 for the 180-foot ROW width.

10. New Mexico’s ROW width statute provides:

Unless otherwise agreed to by the parties, no person shall begin theconstruction of any transmission line requiring a width for fight of way ofgreater than one hundred feet without first obtaining from the commissiona determination of the necessary fight-of-way width to construct andmaintain the transmission line. Construction does not include acquisitionof rights of way, preparation of surveys or ordering of equipment.

NMSA 1978, 8 62-9-3.2(A). The ROW width statute requires applications to contain, in writing,

all information required for the Commission to make its determination, and to set forth the facts

involved. NMSA 1978, 8 62-9-3.2(C). The statute also requires the applicant to cause notice of

the time and place of hearing on the application to be given to any owner of "property to be

taken" and to any person in actual occupancy of such property. Notice shall be given by first

class mail at least 20 days before the time set for heating, and the applicant shall file proof of

notice on or before the hearing. NMSA 1978, 8 62-9-3.2(D). The statute further provides the

Commission shall act upon the application, after public hearing, within six months of the date the

application was filed, and failure to do so is deemed to be approval of the application. NMSA

1978, 88 62-9-3.2(E) & (F).

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11. The ROW corridor for the Gen-Tie Line encompasses approximately 46 acres,

which will be on the Land obtained through the State Land Office Lease which has been awarded

to Applicant, and land leased from Hudson Cattle Company and the owners of the 96 Ranch.

12. The Gen-Tie facilities will be located on lands for which Applicant has obtained

all needed land rights, therefore all underlying landowners agree to the ROW and no land will be

"taken" without landowner agreement. All affected landowners therefore have notice of the Gen-

Tie project and have consented thereto. Nevertheless, to the extent required by law, Applicant

requests the Commission’s approval of the requested ROW width pursuant to NMSA 1978, § 62-

9-3.2.

THE RIGHT OF WAY DETERMINATION SHOULD BE APPROVED

13. As explained more fully below and in the testimonies and exhibits that support

this Application, the 180-foot ROW width is necessary for the Great Divide Gen-Tie to connect

the Great Divide wind projects to EPE’s transmission line at the new substation.

14. The ROW width statute, NMSA 1978, Section 62-9-3.2, requires Commission

approval of ROW widths greater than 100 feet "unless otherwise agreed to by the parties." As

explained in the Direct Testimony of Robert "Bob" Karsted, the Gen-Tie Line will be located

entirely on private and state land for which Applicant has obtained necessary land rights. The

Direct Testimony of Robert Millies and accompanying exhibits demonstrate that a ROW width

of 180 feet is necessary to provide sufficient space for variation in design while addressing

electrical safety code requirements and construction and operational considerations according to

industry standard practice.

WITNESSES ~

15. The Application is supported by the direct testimony of two witnesses, as follows:

Robert "Bob" Karsted:

Robert Millies:

Project overview and background, land-ownerapprovals

Engineering design and need for 180’ ROW.

PROCEDURAL MATTERS

16. The Right-of-Way Width statute requires that an applicant provide notice of the

hearing to "to any owner of property proposed to be taken and, if applicable, to the person in

actual occupancy of the property." Applicant will provide such persons with required notice.

Notice to other persons, including the general public is not required.

17. Applicant requests that the Commission assign the matter to a hearing examiner

and cause a public hearing to be timely held on the Application.

WHEREFORE, for the foregoing reasons, Great Divide Wind Farm, LLC respectfully

requests the Commission grant the requested ROW width determination to the extent required by

law after a public hearing.

DATED July 5, 2019

submitted,

MARKS LAW, LLCMarks

101 Third St. NWAlbuquerque, NM 87102505-385-4435lawoffice@j asonmarks.comAttorney for Applicant

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IN THE MATTER OF THE APPLICATIONOF GREAT DIVIDE W1ND FARM, LLC FORDETERMINATION OF RIGHT-OF-WAYWIDTH FOR THE GREAT DIVIDE GEN-TIE,


Applicant.

)))))))))

JUL - 5. ~rJl’:+J

CERTIFICATE OF SERVICE

On this 5 day of July 2019, I did serve the Application of Great Divide Wind Farm, LLC, andprefiled direct testimony of Robert Millies and Robert "Bob" Karsted on the following personsvia the email addresses shown.

Bradford Borman

Jack Sidler

[email protected]

[email protected]

Jas¢ n Marks101 Third St. NWAlffuquerque, NM 87102

Attorney for Applicant

7




Applicant.

)))))))))

Case No.

FILED ~N OFFICE OF

JUL -.~3 ~.~tNM PUBLIC ~Eq! iLAT[ON COM, I’~

DIRECT TESTIMONY OF ROBERT "BOB" KARSTED

ON BEHALF OF GREAT DIVIDE WIND FARM, LLC

July 5, 2019

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INTRODUCTION

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CASE NO. 19- -UTDIRECT TESTIMONY OF ROBERT "BOB" KARSTED

PLEASE STATE YOUR NAME, POSITION, AND BUSINESS ADDRESS.

My name is Robert "Bob" Karsted. I am employed by Scout Clean Energy, LLC as a

project developer. My business address is 4865 Sterling Dr., Suite 200, Boulder, CO

80301.

Ao

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ON WHOSE BEHALF ARE YOU TESTIFYING?

I am submitting this testimony on behalf of Great Divide Wind Farm, LLC, in support of

its Application for Determination of Right-of-Way Width for the Great Divide Gen-Tie.

PLEASE DESCRIBE YOUR

PROFESSIONAL EXPERIENCE

EDUCATIONAL BACKGROUND AND

My education includes the following degrees all earned from the University of Colorado

at Boulder: Bachelor of Arts (Political Science); Master of Arts (Journalism and Mass

Communication); and Master of Science (Telecommunications).

My professional experience covers several industries (print joumalisrn!magazines;

telecommunications, law firms and wind energy development companies) though my

various positions with my previous employers mainly focuses on project management,

and since 2005, real property.

HAVE YOU PREVIOUSLY PROVIDED TESTIMONY IN A PROCEEDING

BEFORE THE NMPRC OR OTHER STATE COMMISSION?

No, I have not previously provided testimony in a proceeding before the NMPRC or

other state commission

Oo WHAT IS THE PURPOSE OF YOUR TESTIMONY?

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The purpose of my testimony is to (1) provide background information on the Great

Divide Wind Farm projects and the Great Divide Gen-Tie and (2) explain the property

ownership for the Gen-Tie corridor, and the approvals Great Divide Wind Farm, LLC has

obtained from the land owners.

V~-IAT EXHIBITS DO YOU SPONSOR AS PART OF YOUR TESTIMONY?

I sponsor Exhibit RK-1, which is my resume; and Exhibit RK-2, which shows the

location of the wind projects and the Gen-Tie.

WERE EXHIBITS RK-1 AND RK-2 PREPARED BY YOU OR UNDER YOUR

SUPERVISION?

Yes.

ARE EXHIBITS RK-I AND RK-2 TRUE AND CORRECT COPIES OF THE

DOCUMENTS YOU DESCRIBE IN YOUR TESTIMONY?

Yes.

BACKGROUND INFORMATION ON THE GREAT-DIVIDE WIND PROJECTS

Q. CAN YOU PROVIDE BACKGROUND INFORMATION ON SCOUT CLEAN

ENERGY?

Scout Clean Energy, LLC (Scout) is a Delaware limited liability company. Scout has

wind projects under development in 11 states, representing 4,045 MW of energy

production. Scout is the owner of Great Divide Wind Farm, LLC, Great Divide Wind

Farm 2, LLC and Great Divide Wind Farm 3, LLC.

CAN YOU PROVIDE BACKGROUND INFORMATION ON THE GREAT

DIVIDE WIND PROJECTS?

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Great Divide Wind Farm, LLC, Great Divide Wind Farm 2, LLC, and Great Divide Wind

Farm 3, LLC are each organized as Delaware limited liability companies, and registered

as foreign limited liability companies with the New Mexico Secretary of State. Great

Divide Wind Farm, LLC (the Applicant) is the overall project development company,

which will be the owner of the Great Divide Gen-Tie. Great Divide Wind Farm 2, LLC

("GDW2") and Great Divide Wind Farm 3, LLC ("GDW3") are the project development

companies for the two individual wind projects.

The GDW2 and GDW3 projects are located on separate sites, approximately one mile

apart, in Grant County, NM, approximately 16 miles northeast of Lordsburg, NM. Under

the working engineering design, each project consists of 19 wind turbines, each rated at

4.2 MW, for a total of 79.8 MW maximum output. The proposed equipment in this

design case are manufactured by Senvion. The turbines are to be installed at a terminal

voltage of 0.580 kV. This initial voltage is immediately stepped up to 34.5 kV, and

delivered to underground collector lines. A single 345/34.5 kV main transformer will

then step up the collector voltage to the 345 kV EPE Transmission System voltage, and

an overhead transmission line which is the Great Divide Gen-Tie will connect the

projects to a point on the existing 345 kV line between E1 Paso Electric Company’s

(EPE) Hidalgo and Luna substations approximately 16 miles northeast of the city of

Lordsburg, Grant County, NM, where a new substation will be constructed..

Great Divide Wind Farm, LLC has obtained all land rights required for the two wind

projects and the Great Divide Gen-Tie by virtue of four private landowner Wind Energy

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Lease and Easement Agreements which have been executed, and a long-term wind

energy lease with the New Mexico State Lands Office which has been negotiated, bid

upon and awarded to Great Divide Wind Farm, LLC. Great Divide Wind Farm, LLC has

completed initial project design and initiated environmental studies and permitting for

each Great Divide Wind project.

The GDW2 and GDW3 wind farms are planned to be constructed in 2020. The Great

Divide Gen-Tie is planned to be constructed in 2020.

LAND OWNERSHIP AND AGREEMENTS FOR THE GREAT-DIVIDE GEN-TIE CORRIDOR

Q. PLEASE EXPLAIN THE OWNERSHIP OF THE LAND THAT THE GEN-TIE

WILL CROSS

A. The wind turbines and collector infrastructure will be located on land leased from the

New Mexico State Land Office, and on private land owned by Hudson Cattle Company,

LLC ("Hudson Ranch"); White Horse, LLC and Troy Ohio Center, LLC, who are the

owners of the "96 Ranch"; the Stewart Ranch; and the C-Bar Ranch. The location of the

Gen-Tie and other improvements in relation to land ownership is shown in Exhibit RK-2.

The Gen-Tie will be located on land leased from the State Land Office, the Hudson

Ranch, and the 96 Ranch.

White Horse, LLC and Troy Ohio Center, LLC, the owners of the 96 Ranch, are Indiana

limited liability companies, whose address is: White Horse, LLC and Troy Ohio, LLC,

C/O 96 Ranch, 300 Meridian, Suite 1100, Indianapolis, IN 46204, Attn: Bill Shank.

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Hudson Cattle Company, LLC, is a New Mexico limited liability company whose address

is Hudson Cattle Company, LLC, Leldon W. Hudson, President, 7530 Keeler Rd.,

Deming, NM 88030.

HAS GREAT DIVIDE WIND FARM, LLC OBTAINED THE RIGHT TO CROSS

THE LANDS OF THE 96 RANCH?

Yes. Great Divide Wind Farm, LLC has executed a Wind Energy Lease and Easement

Agreement ("Lease") with White Horse, LLC and Troy Ohio Center, LLC, which are the

owners of the "96 Ranch" in Grant County, NM. The executed Lease is for

approximately 2,077.50 acres of land, for a term of up to 40 years.

WHAT DOES THAT LEASE PROVIDE WITH RESPECT TO RIGHT OF WAY

WIDTH?

The 96 Ranch Lease grants the lessee exclusive rights to use any part of the leased

premises for transmission lines as necessary to develop the wind projects. Specifically,

the Lease provides that lessee has "the exclusive right to erect, construct, reconstruct,

replace, relocate, remove, operate, maintain and use ....over and across the Property, in

connection with Windpower Facilities... a line or lines of towers, with such wires and

cables as may be suspended therefrom...for the transmission of electrical energy ... and

all necessary and proper foundations, guy wires, footings, crossarms and other appliances

fixtures for use with said towers." The Lease does not specify right of way width, or

restrict the width of the transmission corridors.

HAS GREAT DIVIDE WIND FARM, LLC OBTAINED THE RIGHT TO CROSS

THE LANDS OF THE HUDSON CATTLE COMPANY, LLC?

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Yes. Great Divide Wind Farm, LLC has executed a Wind Energy Lease and Easement

Agreement ("Lease") with Hudson Cattle Company, LLC. The executed Lease is for

approximately 5,720 acres of land, for a term of up to 43 years, including an operational

term of up to 35 years, plus up to eight years for development and construction.

WHAT DOES THAT LEASE PROVIDE WITH RESPECT TO RIGHT OF WAY

WIDTH?

The Hudson Lease grants the lessee exclusive rights to use any part of the leased

premises for transmission lines as necessary to develop the wind projects. Specifically,

the Lease provides that lessee has "the exclusive right to erect, construct, reconstruct,

replace, relocate, remove, operate, maintain and use ....over and across the Property, in

connection with Windpower Facilities... a line or lines of towers, with such wires and

cables as may be suspended therefrom...for the transmission of electrical energy.., and

all necessary and proper foundations, guy wires, footings, crossarms and other appliances

fixtures for use with said towers." The Lease does not specify right of way width, or

restrict the width of the transmission corridors.

HOW HAS GREAT DIVIDE WIND FARM, LLC OBTAINED THE RIGHT TO

CROSS THE LAND UNDER CONTROL OF THE STATE LAND OFFICE?

Great Divide Wind Farm, LLC and the State Land Office (SLO) negotiated a form of

lease that provides Great Divide Wind Farm, LLC with all the rights needed on state

lands to develop the wind projects and the Gen-Tie. The SLO requires that all long-term

leases be put out to bid before they may be finalized. On July 1, 2019, Great Divide

Wind Farm, LLC was awarded the lease it negotiated with the SLO, after it had been

released for public bids.

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WHAT DOES THAT AGREEMENT PROVIDE WITH RESPECT TO RIGHT OF

WAY WIDTH?

The form of lease that was negotiated with the SLO and has been awarded to Great

Divide Wind Farm, LLC grants the rights to use the leased Land for Wind Energy

Development, which includes the right to use the Land for construction and use of

facilities for the "collection, distribution, transmission, and Delivery of the electrical

energy (whether such lcctricity is produced on or off the Land)." The SLO form of

Lease does not restrict the lessec’s use for transmission facilities to a particular corridor

within the demised Land.

EVEN THOUGH GREAT DIVIDE WIND FARM, LLC HAS OBTAINED

CONSENTS FOR THE RIGHT OF WAY WIDTH REQUESTED FROM THE

PROPERTY OWNERS, WILL GREAT DIVIDE WIND FARM, LLC COMPLY

WITH THE STATUTORY NOTICE REQUIREMENTS?

Yes.

RIGHT OF WAY WIDTH REQUEST

Q. WHAT RIGHT OF WAY WIDTH

REQUESTING FOR THE GEN-TIE?

IS GREAT DIVIDE WIND FARM, LLC

Great Divide Wind Farm, LLC is requesting the New Mexico Public Regulation

Commission to approve a right of way width of 180 feet for the Great Divide Gen-Tie.

This is the width established by the engineers that Great Divide Wind Farm, LLC has

engaged. This width will also provide sufficient space for the construction and

maintenance of the Gen-Tie.

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HOW MUCH TOTAL AREA WILL BE REQUIRED FOR THE RIGHT OF WAY

CORRIDOR WHICH IS BEING REQUESTED?

I have calculated that a right of way corridor of 180’ for a line that is approximately 2.1

miles in length will create a right of corridor of approximately 46 acres.

CONCLUSION.

Q.

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DO YOU HAVE ANY REQUESTS OR RECOMMENDATIONS FOR THE

COMMISSION?

I recommend and request that the Commission approve a right-of-way width of 180’ for

the Great Divide Gen-Tie, which is the width established by the engineers Great Divide

Wind Farm, LLC has engaged.

DOES THIS CONCLUDE YOUR TESTIMONY AT THIS TIME?

Yes, it does.

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1N THE MATTER OF THE APPLICATIONOF GREAT DIVIDE WIND FARM, LLC FORDETERMINATION OF RIGHT-OF-WAYWIDTH FOR THE GREAT DIVIDE GEN-TIE,


Applicant.

)))))))))

VERIFICATION

Case No. 19-

STATE OF COLORADO

COUNTY OF BOULDER

}}

ROBERT "BOB" KARSTED, first being sworn on his oath, states:

I am the witness identified in the preceding direct testimony. I have read the direct testimony andam familiar with the contents. Based upon my personal knowledge, the facts stated in the directtestimony are true. In addition, in my judgment and based upon my professional experience, theopinions and conclusions stated in the direct testimony are true, valid, and accurate.

ROBERT "BOB" KARSTED

SUBSCRIBED AND SWORN TO before me on this 2 day of July, 2019 by Robert "Bob"

I NOTARY ~ I| STATE OF COLORADO |

My commission expires:

Exhibit RK-1, Page 1 of 2

Robert K. Karsted3256 Billington Drive, Erie, Colorado 80516

303-499-9998 (h) 303-520-9177 (m) [email protected]

As an experienced project manager, real estate and contracts paralegal, I offer excellent written and verbalcommunication and interpersonal skills, a demonstrated ability to work in self-directed workenvironments, accountability for high quality work product, and a business-oriented approach to problem-solving. I bring proven skills in providing a wide of legal and corporate operational support, preparingand drafting legal documents, managing multiple time sensitive deadlines and delivering superior servicein dynamic environments. I am able to prioritize matters and multi-task, as well as facilitate the flow ofinformation to senior management and attorneys, project developers and business managers,governmental agencies, clients and other stakeholders. I enjoy working independently, as well as part ofa team, and in liaising between multiple groups. I have a "can do" attitude and the ability to work wellunder pressure, adapt to change, meet deadlines and within budget.


Scout Clean Energy LLCProject Manager / Developer¯

Boulder, Colorado 10/2017 - present

Develop mid- to late-stage wind energy generation projectsResponsible for site control and lease negotiations, title and survey review, obtaining all necessarypermits and agreements with local and state agenciesCo-lead cross-functional development teams consisting of electrical and civil engineers,meteorologists and business analysts

NexCore Companies LPMoye White LLPParalegal (Real Estate)¯

¯

¯

¯

¯

¯

¯

Denver, ColoradoDenver, Colorado

11/2016 - 10/20178/2014 - 11/2016

Review commercial real estate contracts, prepare closing and critical dates checklistsTitle and survey reviewDraft consents, assignments, resolutions and amendments, prepare and file financing statementsPrepare title objection letters and closing instruction lettersCoordinate with title companies and opposing counsel for closingsPrepare contract closing documents, review and revise title company closing documentsFormation, qualification and dissolution of business entities, filing of annual compliance reports

j uwi Wind, LLC Boulder, Colorado 4/2011 - 7/2014Paralegal (Real Estate)¯ Draft, prepare and review commercial contracts and agreements (land leases, amendments, notices,

easements (access, construction, wind, cable) and licenses, crossing agreements, neighbor and mettower agreements, subordination and non-disturbance agreements, estoppels, deeds, assignments,certificates, releases, non-disclosure, consulting and service agreements)

¯ Review and analyze title commitments, surveys and plats¯ Conduct due diligence and assist with the acquisition and/or disposition of wind farm assets to/from

project portfolio; lease and title curative, preparation of lease abstracts¯ Coordinate and negotiate with landowners, easements holders, lenders and other wind development

companies in order to execute easements and leases, consents and crossing agreements, subordinationand non-disturbance agreements, and non-disclosure agreements respectively

Exhibit RK-1, Page 2 of 2

Robert Karsted page 2

¯ Manage and track land related expenses (lease and easement payments, title company and other 3rdparty invoices)

¯ Collaborate with GIS analyst and construction manager to prepare maps, exhibits and legaldescriptions for easements, licenses and other agreements, and asset manager regarding landownerand vendor payments

¯ Contribute to the development, implementation and maintenance of landowner lease and contractsdatabase; responsible for abstracting lease terms and obligations, preparation of rent schedules

¯ Responsible for all land lease related efforts in the successful development, financing andconstruction of a 30 MW wind farm in Nobles County, MN, and 4 wind farms (totaling 24 MW) inNova Scotia, Canada

Senn Visciano Canges P.C. Denver, Colorado 1/2005 - 3/2011Paralegal (Transactional / Real Estate / Special District)¯ Prepare and revise legal documents (commercial purchase and sale agreements, form-based contracts,

operating agreements, corporate resolutions and certificates, notices, assignments, deeds, and othertransaction related documents), coordinate execution between parties and ensure return of documents

¯ Review and analyze title commitments, surveys and plats¯ Review contracts, prepare closing and critical dates checklists¯ Research permitted land uses and restrictions for commercial, residential and industrial developments¯ Work with surveyors and planners to create subdivision plats, draft and review general notes,

reservations and grants of easement, drive plat map through acceptance and approval process¯ Assemble documentation and bills of sale for final acceptance of public improvements by

governmental entities¯ Formation and qualification of business entities and filing of annual compliance reports¯ Extensive contact with title companies, government agencies, land use departments and lenders¯ Assist corporate clients buy and/or sell real property in transactions valued between $1 million - $100

million, including the Wildhorse Meadows residential development in Steamboat Springs, CO, andthe acquisition and annexation of land for wind turbine manufacturing facilities in Brighton, Windsorand Pueblo, CO

¯ Assist wind energy client create two urban renewal areas and obtain tax incremental financing foreligible development expenses worth over $250 million ~

¯ Assist lender clients close mezzanine financing loans valued between $5 million - $80 million¯ Responsible for the formation of three metropolitan districts, including the conduct of mail ballot

elections verified by the Secretary of State’s Office

EDUCATION

Denver Career College (f.k.a. Denver Paralegal Institute), Thornton, Colorado¯ ABA-accredited Paralegal Certificate

University of Colorado, Boulder, Colorado¯ Master of Science - Telecommunications

Emphasis: Public Policy and Network Architecture¯ Master of Arts - Journalism & Mass Communication

Emphasis: Mass Communication Research¯ Bachelor of Arts - Political Science




Applicant.

))))))))

DIRECT TESTIMONY OF ROBERT MILLIES

ON BEHALF OF GREAT DIVIDE WIND FARM, LLC

July 5, 2019

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CASE NO. 19- -UTDIRECT TESTIMONY OF ROBERT MILLIES

INTRODUCTION

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PLEASE STATE YOUR NAME, POSITION, AND BUSINESS ADDRESS.

My name is Robert Millies. My

Commonwealth Associates, Inc.

Jackson, M149202.

position is Associate Director of Engineering at

My business address is 2700 West Argyle Street,

ON WHOSE BEHALF ARE YOU TESTIFYING?

I am submitting this testimony on behalf of Great Divide Wind Farm, LLC, in support of

its Application for Determination of Right-of-Way Width for the Great Divide Gen-Tie.

PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND


I graduated from Hillsdale College with a Physics and Biology Major and from Michigan

State University with a Masters Degree in Structural Engineering. I have 27 years of

engineering experience. I am licensed as a Professional Engineer in the states of Indiana,

Louisiana, Michigan, Minnesota, Missouri, North Dakota, Nebraska, New Hampshire,

New Jersey, New Mexico, Pennsylvania, Utah, Vermont, and Wisconsin. I have worked

for Commonwealth Associates in the transmission line design industry for nearly 22

years.

HAVE YOU PREVIOUSLY PROVIDED TESTIMONY IN A PROCEEDING

BEFORE THE NMPRC OR OTHER STATE COMMISSION?

Yes I have provided testimony for PSE&G in New Jersey in 2009 in regards to a new

double circuit 230kV/500kV 54 mile transmission line.

Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?

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The purpose of my testimony is to (1) provide background information about the

engineering for the Great Divide Gen-Tie and (2) provide information to support the

necessity for a 180’ right of way (ROW) width for the Gen-Tie.

WHAT EXHIBITS 1)O YOU SPONSOR AS PART OF YOUR TESTIMONY?

I sponsor Exhibit RM-1, which is my resume, Exhibit RM-2 which is my Right of Way

Requirement Report, and Exhibits RM-3 and RM-4, which are drawings showing typical

ROW cross-sections.

WERE EXHIBITS RM-1, RM-2, RM-3 AND RM-4 2 PREPARED BY YOU OR

UNDER YOUR SUPERVISION?

Yes.

ARE EXHIBITS RM-1, RM-2, RM-3 AND RM-4 2 TRUE AND CORRECT

COPIES OF THE DOCUMENTS YOU DESCRIBE IN YOUR TESTIMONY?

Yes.

BACKGROUND INFORMATION ON THE GREAT-DIVIDE GEN-TIE

Q. PLEASE DESCRIBE THE GREATE DIVIDE GEN-TIE LINE

A. The Great Divide Gen-Tie is a 345kV gen-tie line of approximately 2.25 miles that will

run from the common point of collection for the GDW2 and GDW3 wind farms to a point

on the existing 345 kV line between E1 Paso Electric Company’s (EPE) Hidalgo and

Luna substations approximately 16 miles northeast of the city of Lordsburg, Grant

County, NM. It is configured as a single circuit. The line will run southeast in a single

line.

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CAN YOU EXPLAIN WHY THE GEN-TIE LINE HAS BEEN ENGINEERED TO

OPERATE AT 345 KV?

345 kV is the voltage of the existing EPE line to which the Great Divide Wind project

will be connected. The Gen-Tie must match the voltage made available at point of

5 interconnection substation.

6 Q. CAN YOU EXPLAIN WHY THE GEN-TIE LINE HAS BEEN ENGINEERED AS

7 A SINGLE-CIRCUIT?

8 A. A single circuit 345 kV line is all that is necessary to deliver energy produced by

9 proposed wind farm.

10 Row WIDTH EVALUATION.

11 Q. PLEASE EXPLAIN THE PURPOSE OF YOUR ROW WIDTH EVALUATION.

12 A. The purpose of my evaluation was to determine the ROW widths that would ensure

13 safety, minimize landowner impact, provide adequate space in which to work, and allow

14 flexibility during detailed design of the 345 kV Gen-Tie Line proposed by Scout.

15 National Electrical Safety Code ("NESC") and industry best practices were used as the

16 basis for determining the necessary ROW widths.

17 Q. PLEASE EXPLAIN THE BASIC DESIGN CONDITIONS YOU EVALUATED.

18 A. We evaluated two primary design conditions to determine the required ROW width. The

19 first condition uses a 6 pounds per square foot ("psf’) wind (approximately a 48 mile per

20 hour wind) acting perpendicular to the conductor at a 60 degree ambient temperature, as

21 provided in NESC § 234.C. 1.b. The second condition uses a 100 miles per hour ("mph")

22 wind speed (25.6 psf wind) at a 60 degree ambient temperature, reflecting the extreme

23 wind condition expected to be used for line design. Under these conditions, we evaluated

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structure configuration and conductor offset from the centerline of the Gen-Tie Line,

structure deflection, conductor displacement and horizontal clearance requirements to

obtain components necessary to determine the overall ROW width

HOW DO SPAN LENGTH AND STRUCTURE CONFIGURATION AFFECT

ROW WIDTH?

Structure configuration and spacing help determine allowable span lengths when

designing a transmission line. As the span length increases, the minimum ROW width

needed also increases due to greater conductor sag and displacement under a wind

condition. We understand Scout wishes to retain flexibility for determining structure

locations so that landowner preferences and potential avoidance of resources (i.e.

wetlands) are taken into consideration. We performed the ROW width calculations shown

in Exhibit RM-2, the supporting ROW width report, for maximum span lengths of 1350

feet for the H-frame configuration and 1500 feet for the steel mono-pole transmission

structure configurations

DID YOU TAKE OTHER CONSIDERATIONS INTO ACCOUNT?

Yes. Line constructability, and maintenance and operations also affect ROW width and

are considered in the design phase. These factors were considered along with ROW

widths associated with projects of similar proposed construction. The ROW width of 180

ft is consistent with other similar projects as well as being supported by the project

specific calculations presented.

HOW DO CONSTRUCTION, OPERATIONS AND MAINTENANCE AFFECT

THE NECESSARY ROW WIDTH?

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The ROW width must be large enough to move construction and maintenance equipment

along the Gen-Tie Corridor. Large cranes used to erect the Gen-Tie Line structures are

typically the controlling factor. In this case, the recommended 180 foot ROW will be

adequate for access and operations purposes. Considering the terrain of the Gen-Tie

Corridor, we did not identify any extraordinary issues for construction, maintenance or

operations.

WHAT DID YOU CONCLUDE WAS THE REQUIRED ROW WIDTH?

As described in my written report which is Exhibit RM-2, we determined a ROW width

of 180 feet is necessary for the Great Divide Gen-Tie Line.

WHAT WERE THE RESULTS OF YOUR CALCULATIONS FOR DIFFERENT

SPAN LENGTH AND STRUCTURE CONFIGURATIONS?

Our calculations and results are shown in the ROW width written report and provide a

summary of the results, and detailed calculations. We analyzed an H-frame structure

configuration with maximum span lengths of 1350 feet as well as a steel mono-pole

structure configuration with maximum span lengths of 1500 feet. Our calculations

demonstrate that a ROW width of 180 feet is necessary.

CONCLUSION.

Q. BASED ON YOUR ANALYSIS, WHAT IS THE NECESSARY ROW WIDTH?

A. I recommend a ROW width of 180 feet as shown in Exhibit RM-2, the ROW width report

and supporting Exhibits RM-3 and RM-4. This will provide sufficient ROW width for

variation in design while addressing electrical safety code requirements and construction

and operational considerations according to industry best practice.

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DOES THIS CONCLUDE YOUR TESTIMONY AT THIS TIME?

Yes, it does.




Applicant.

)))))))))

Case No. 19-

VERIFICATION

STATE OF MICHIGAN

COUNTY OF JACKSON

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ROBERT MILLIES, first being swom on his oath, states:

I am the witness identified in the preceding direct testimony. I have read the direct testimony andam familiar with the contents. Based upon my personal knowledge, the facts stated in the directtestimony are true. In addition, in my judgment and based upon my professional experience, theopinions and c.onc)usions stated in the direct testimony are true, valid, and accurate.

ROBER~r MILLIES

SUBSCRIBED AND SWORN TO before me on this 2 day of July, 2019 by Robert Millies.

My commission expires:

JAMES J. AIELLONOTARY PUBLIC - MICHIGAN

JACKSON COUN’D/ACTING IN THE COUNTY OF :~$o ~MY COMMISSION EXPIRES NOV. 4, 2024

Exl

ROBERT J. MILLIES, P.E.Associate Director of Engineering, Transmission and Distribution

QUALIFICATIONS SUMMARYMr. Millies has 21 years of experience directly related to: the design of overhead and underground electricaltransmission lines; long-span river crossings; analysis and design of wood, concrete, and steel transmissionstructures and various associated foundations; field inspection of existing towers; preparation of constructiondrawings; and development of specifications for transmission and distribution projects. His background alsoincludes the analysis, design, and management of various industrial civil projects, as well as the analysis anddesign of hydraulic and hydrological facilities. Mr. Millies’ management responsibilities include supervising astaff of engineers, designers, and CADD operators. He is currently serving as Chair of the IEEE TransmissionLine Design and Construction Working Group.

EMPLOYMENT HISTORY1997-Pres.

1995-1997

1992-1995

Commonwealth Associates Inc.Jackson, MichiganUnited States Army Corps of EngineersDetroit, MichiganEngineering Services, International PaperShreveport, Louisiana

REPRESENTATIVE PROJECTSPennsylvania Power & Light (PPL EU)Hosensack-Quarry South: Project manager for the Hosensack-Quarry South project (currently in design)involving the rebuild of approximately 20 miles of 69/138 kV transmission line as well as a temporary line for theElliot Heights tap segment. Scope includes the design of custom steel poles along with LD poles, supportingpermitting and environmental activities, support at public open house meetings, support CWOS task andresponsibility for geo-technical activities.

Blooming Grove Development Project: Transmission design manager for approximately 22 miles of 69/138kV rebuild. Completed the conceptual design of three segments related to this project as well as supportingenvironmental and permitting activities, base maps of the segments, geo-technical investigations, developCWOS and field reviews.

Shickshinny 500kV Switchyard: Project manager for the 500 kV tap design (currently in design) from the existingSusquehanna-Lackawanna 500 kV line into this new switchyard.

Otter Creek-Conastone 230 kV: Acting as owner’s engineer to review the project design.

1 I Robert J, Millies, Commonwealth

Exhibit RM-1, Page 2 of 4Great River Energy (GRE)Provide engineering services and design packages for approximately 20 transmission line projects. ConductedNERC compliance work for approximately 1200 miles of transmission lines ranging from 115 kV to 500 kV.

Public Service Electric and Gas (PSE&G)Project Manager for a double-circuit, 500 kV transmission line from the Delaware Water Gap NationalRecreation Area to the Roseland Substation in northeastern New Jersey. This line segment is approximately44-miles-long and utilizes both self-supporting, double-circuit, steel poles and lattice towers on caisson, rockanchor, and pile foundations. Provided preliminary and final drawings for permits, meetings, and constructionbidding, cost and construction schedules, expert testimony for permitting, final structure and foundation design,and final construction packages. Developed supplier bid packages and assisted in the bid process. Visitedsuppliers and inspected their operation, witnessed steel pole arm test, inspected prototype lattice towers, andwitnessed full scale tower tests in Spain and India.

EntergyKaiser-Algiers "Phase Raising": Project Manager for this 230/115 kV, double-circuit Mississippi River crossing"Phase Raising" project in New Orleans, Louisiana. The objective was to raise the two bottom phases on442-foot-tall towers to allow cruise ships to safely pass under the circuits during high-water conditions.Designed two new arms, analyzed the towers, and designed the reinforcement of existing members per theanalysis. Assisted the construction contractor with the rigging and lifting procedures. Observed constructionand answered questions on-site. Climbed the towers several times to observe the rigging and to obtainmeasurements.

VELCOProject Manager for a new 54-mile, 345 kV transmission line in Vermont. The project involved review of currentVELCO standards/criteria and development of project design criteria. Project challenges included designinga new 345 kV line efficiently, despite rugged, mountainous terrain, severe side hill issues, and uplift problemsalong steep terrain. Provided temporary line design to allow construction of two new 345 kV substations.Transmission line staff worked closely with substation staff to cover all aspects of the substation andtransmission line design deliverables.

Project Manager for a 54-mile 345 kV project in Vermont paralleling an existing 345 kV line in mountainous rightof way. This line utilized mostly H-frame structures with a few self-supporting steel poles. Provided preliminaryand final drawings for permits, meetings, and construction bidding, cost and construction schedules, finalstructure and foundation designs, and final construction packages.

American Transmission Company (ATC)Project Manager for a new 66-mile, double-circuit, and 138 kV, steel pole transmission line in northernWisconsin, which included the design of a temporary 138 kV wood pole line to keep existing substationsenergized. Designed various foundation types due to shallow rock in the northern portion of the line. Highquality engineering work products that were provided enabled the construction contractor to build the linewithout requiring additional engineering input. Provided project management services for an additional 20projects.

Northeast Utilities and National GridProject Manager for a 345 kV routing feasibility study for these two utilities in New England. Evaluatedapproximately 480 miles for a new 345 kV transmission line. Identified environmental and engineeringconstraints, developed a corridor analysis procedure, and prepared various overhead and undergroundtransmission cost estimates, segment maps, and right-of-way cross-section detail drawings showing feasibility.

Robert J. Mitties, P.E. Commonwealth

EDUCATION1992 MS, Structural Engineering, Michigan State University1989 BS, Physics and Biology, Hillsdale College

Exhibit RM-1, Page 3 of 4

REGISTRATION¯ Professional Engineer in Indiana, Louisiana, Michigan, Minnesota, Missouri, North Dakota, Nebraska, New

Hampshire, New Jersey, New Mexico, Pennsylvania, Utah, Vermont, and Wisconsin

PROFESSIONAL AFFILIATIONS AND AWARDS¯ Institute of Electrical and Electronics Engineers (IEEE): Chair, Transmission Line Design and Construction

Working Group¯ National Society of Professional Engineers¯ Michigan Society of Professional Engineers¯ American Society of Civil Engineers¯ American Institute of Steel Construction

3 I Robert J. Millies, P.E. Commonwealth

Exhibit RM-1, Page 4 of 4ADDITIONAL PROJECTS (INTERNAL USE ONLY)Salt River ProjectProject Manager responsible for resolving 500 kV tower erection problems on the 500 kV Hassayampatransmission line, reviewing structure details and foundations details, and proposing alternatives to correct thesituation.

M&A ElectriclTennessee Valley AuthorityProject Engineer for a 161 kV long span crossing of the Mississippi River in Missouri. Assisted in the designto strengthen the existing 350-foot suspension towers and anchor towers, the design of a special conductor,and observation of conductor and hardware testing. Assisted with engineering issues during construction, fromthe field. Climbed a 350-foot suspension tower during construction for measurements and observation of thereconductoring.

Xcel EnergyProject Manager for the design of a double-circuit, 115 kV underground system in Bloomington, Minnesota, nearthe Mall of America. The design utilized 3000 kcmil XLPE cable with fiber.

Red Rock Roger’s Lake: Project Manager for the 115 kV project, which involved the reconductoring of anexisting 6.5-mile, 115 kV transmission utilizing ACSS conductor, OPGW, and new double-circuit, galvanizedsteel poles.

Hydro Lane-T-Corners: Project Engineer for the 115 kV project involving the design of a new 33-mile, double-circuit, steel pole line. Utilized vibratory foundations in sandy soil areas to expedite construction.

Pennsylvania Power and LightSteel City-Quarry Double Circuit: Project Manager for the 230 kV project. Designed an approximately three-quarter-mile-long, 230 kV transmission system to interconnect a new IPP substation to an existing 230 kVtransmission line.

Calpine CorporationProject Engineer for several proposed cogeneration projects within the state of California. Analyzed thefeasibility of new and existing transmission line routes to connect the power generation to the existingtransmission grid. Provided conceptual design information and drawings.

MEAG PowerPerformed structural analysis of wood, concrete, and steel transmission structures in Georgia. Preparedconstruction drawings, material lists, and specifications for bid packages and then evaluated the submitted bids.Prepared close-out reports for finished projects. Conducted field inspection of transmission line structures forinstallation of fiber communication lines in place of shield wire.

Northern States Power CompanyPerformed structural analysis of wood, concrete, and steel transmission structures in Minnesota. Performedfield inspection of transmission line structures to be reconductored with a larger conductor.

Pennsylvania Power & LightSteel City-Hosensack: Project Manager for the 500 kV project. The work involved the design of four 500 kVstructures for tie-ins to a new 500 kV substation at Hosensack and a new IPP substation at Steel City.

4 I Robert J, Millies, P,E. Commonwealth

GREAT DIVIDE WIND FARM345 KV TRANSMISSION LINE

RIGHT-OF-WAY REQUIREMENTRev. 2019-06-10

1. Line Description

The proposed 345,000 volt (345 kV) transmission line is associated with the Great Divide WindFarm planned to be developed on land northeast of Lordsburg in southwest New Mexico. Theline is expected to be approximately 2.25 miles in length and will deliver energy produced bythe wind farm to the planned Point of Interconnection (POI) with E1 Paso Electric at a plannedsubstation located along their existing Luna to Hidalgo 345 kV line.

The transmission line in general will utilize either wood 2-pole H-frame structures (depicted onExhibit RM-3) or tubular steel mono-pole structures (depicted on Exhibit RM-4). The structuretype will be selected during the final design.

This Right-of-Way (ROW) width requirement has been prepared in a good faith effort to allowfor the future construction of either of the two structure types described above with assumedtypical span lengths and conductor type expected to be appropriate for this project.

2. Right-of-Way Considerations

When determining ROW width for a transmission line, the following items are considered:¯ the type of structure(s) used,¯ the separation of the phases (horizontal and/or vertical phase spacing),¯ the maximum expected length between structures (span),¯ the amount of sag of the conductor in assumed maximum span,¯ the total horizontal displacement (blowout) of the conductors under various wind

conditions,¯ any deflection in the structure and/or swing in conductor supporting insulator assembly

under various wind conditions,¯ the desired clearance from the displaced conductor position to the edge of ROW.

The above items, in general, are used to establish the width of the ROW corridor for atransmission line. Also, this type of transmission line design is typically adequate to provideaccess for the construction and maintenance of the transmission line along the ROW. However,there are areas where additional temporary or special easements or land use agreements may beneeded for construction or special guy anchoring outside the primary ROW corridor. Theseinclude but may not be limited to such things as guy and anchor easements at turning angles inthe line, temporary work pads for equipment engaged in the wire pulling and tensioning at selectpoints along the line, and areas where through access along the line and within the ROW isobstructed or restricted during construction, maintenance and inspection patrols.

While utilities and transmission line owners differ in their approach to determining ROWwidths, many have established a practice of analyzing two primary design conditions related tostructure and conductor displacement under design wind loads.

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One condition is to determine the blowout of the conductor when displaced by a 6 pound persquare-foot wind (6 psf wind) along with the National Electrical Safety Code (NESC)required horizontal clearance to buildings or other facilities that may be located anywherealong the edge of the ROW. The conductor displacement under this wind condition togetherwith the NESC building clearance (which for a 345 kV line at altitude up to 6300 fi is 14.3 fi)determines the ROW width for this condition. The 6 psfwind equates to a wind velocity ofapproximately 48 mph.

The second condition is to determine the total blowout and conductor displacement associatedwith the extreme wind condition the line is to be designed for regarding strength and size ROWto keep the conductor contained inside while including perhaps a few feet to cover contingencyand/or electrical strike distance (which for a 345 kV line is approximately 3 fi). For this project,an extreme wind condition of 100 mph is anticipated to be considered for strength and equatesto approximately 25.6 psf.

For the typical long spans anticipated for this project, the conductor blowout (sag anddisplacement of the conductor at mid-span) under the 25.6 psfwind condition will govern overthe 6 psf wind condition and therefore the proposed ROW width will be based on the 25.6 psfwind condition.

3. Conductor and Sag

An Alternating Current (AC) transmission line consists of 3 electrical phases. The conductorfor each of the 3 phases on this transmission line is expected to consist of a pair of AluminumConductor Steel Reinforced (ACSR) wires. ACSR conductors are available in a variety of sizesand strandings each with different electrical and physical properties. The type anticipated forthis project is a 795 kcmil 26/7 ACSR code named "Drake". This conductor has 26 strands ofaluminum supported on a 7 strand steel core. The weight per foot is 1.094 lbs/fi and it has anoverall diameter of 1.108 inches. The rated tensile strength is 31,500 lbs.

Span lengths for this line (distance between structures) are expected to vary but be limited to amaximum of 1350 ft for the wood H-frame type structure depicted in Exhibit RM-3 andmaximum of 1500 ft for the steel mono-pole type structure depicted in Exhibit RM-4. Anaverage span for this transmission line, described in technical terms as the Ruling Span, isassumed to be 1100 ft. For compliance with NESC tension limits while also accounting forperformance and avoiding Aeolian vibration by having conductor strung too tightly, a controltension is established for design. For this line and the ROW requirement calculation, the 795ACSR Drake has been assumed to have a tension of 6,000 lbs at 60 degrees F Initial loadcondition no wind with Ruling Span assumed at 1100 ft. The tension at 60 degrees F with 100mph wind would be approximately 12,000 lbs.

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Using the control tension at NESC Heavy as specified and using a Ruling Span of 1100 fi, thesag of a 795 ACSR Drake under the 25.6 psf extreme wind condition would be approximately35 ft. The amount of sag in the maximum assumed span under the same 25.6 psf condition isdetermined by the following equation.

where,SRS = Sag at Ruling SpanRS = Ruling SpanLmax = Maximum SpanSmax= Sag at Maximum Span

L2maxSRS * RS2~ = Sm~

Sag in the maximum 1350 fl span assumed for the wood H-flame depicted on Exhibit RW-1,is therefore:

1350235.~= 52.7ft.11002

Sag in the maximum 1500 fl span assumed for the steel mono-pole depicted on Exhibit RW-2,is therefore: ft.

1500235 * ~ = 65.1 ft.11002

4. ROW Width Calculation

As stated previously in Section 2, the ROW width is determined by considering the followingcomponents.

ROW width = 2*(W+D+S+B+C) where

W = Structure Width (distance from centerline of structure to outside conductor)

D = Structure Deflection (negligible for a braced H-flame, 10%+/- of attachment heightfor mono-pole steel)

S = Insulator Swing (assumed to be same angle as conductor blowout on H-frame, noneon mono-pole steel because of the braced assembly configuration) length of insulatoron H-frame is 12 fl

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B = Horizontal Blowout of conductor under 25.6 psfwind (same on both structure types)

C = Clearance desired between conductor and edge of ROW = 3 fi

The conductor is fixed at the end of the braced insulator on the mono-pole type structure butflee to swing on the H-frame. The angle it swings under the 25.6 psfwind is assumed to be thesame as that calculated for the conductor which is found as follows.

= tan-1 (~) whereAngleH = horizontal force on conductor due to a 25.6 psfwind= 25.6" 1.108/12 = 2.364 lbs/fi (1.108 is diameter of conductor in inches)

V = 1.094 lbs/ft

-1 2.364Angle = tan (~) = 65.2 degrees

For the H-frame type structure depicted on Exhibit RM-3, the components and are as follows.

W= 27’D=I’S = sin(65.2)*12 = 10.9’B = sin(65.2)*52.7 = 47.9’C=3’ROW = 2*(W+D+S+B+C) = 179.6’

For the Mono-pole type structure depicted on Exhibit RM-4, the components and are as follows.

W=12’D=15’S = 0’ (The braced insulator system is fixed)B = sin(65.2)*65.1 = 59.1’C--3’ROW = 2*(W+D+S+B+C) = 178.2’

5. Recommended ROW Requirement

Assuming the same twin-bundled 795 kcmil ACSR Drake conductor is used for either of the 2options for structure type presented on Exhibits RM-3 and RM-4, a ROW width of 180 ft isdeemed appropriate and able to contain expected blowout with maximum spans anticipated upto 1350 ft for the wood H-frame structure type and up to 1500 ft for the steel mono-pole.

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××

WIRE ATREST

WIRE BLOWOUTDISPLACED UNDER WIND

WIRE SAGGENERALLY AT

MID-SPAN

"0

1/2 ROW+l- 1/2 ROW+I-

RIGHT OF WAY (ROW)0NIDTH AS DESCRIBED IN NOTES)

HORIZON’r/v,.CLEARANCEFO~ 100 MPHWIND = ~F’I"

AMERICAN ENERGY, INC.

GREAT DWIDE NM 345 KV LINE

R/W WIDTH REQUIREMENTJWN JWN RJM SINGLE POLE STEEL ORDRN DSGN CKD APPD WOOD H-FRAME

CAI JOB NUMBER0340.00,18

DRAWING NO. REV

A ISSUED FOR STATE APPLICATION 6/10/lgRE~ DESCRIPTION DATE

STRUCTURE SHOWNWITH EXTREME WIND

DEFLECTION

1/2 ROW+/-

¯ WIRE BLOWOUT¯ ¯¯ ~DISPLACED UNDER WIND

CLEARANCEFOR 100 MPHWIND = 3FT

1/2 ROW+/-

RIGHT OF WAY (ROW)(WIDTH AS DESCRIBED IN NOTES)

AMERICAN ENERGY, INC.

GREAT DMDE NM 345 KV LINE

RJW WIDTH REQUIREMENTSINGLE POLE STEEL OR

WOOD H-FRAMEISSUED FOR STATE APPLICATION 6/10/19 JWN JWN RJM

DESCRIPTION DATE DRN DSGN CKD APPD

Documents

,Jason Marks...,Jason Marks Attorney at Law 1011 Third Street NW Albuquerque, NM 87102 July 5, 2019 Ms. Melanie Sandoval Bureau Chief, Records Bureau NM Public Regulation Commission