NPPD Reply to R-Project Email for FWS

From: Kent, Thomas J.

Sent: Wednesday, February 18, 2015 2:15 PM

To: 'robert_harms@fws.gov'

Cc: Citta Jr., Joseph L.; Hostetler, Bonnie J.; Linder, Larry D.; Jenniges, James J.; 'mike.fritz@nebraska.gov'; 'michelle.koch@nebraska.gov'; 'eliza_hines@fws.gov'; Holthe, Craig L.; Harding, Mary A- Board Member

Subject: South Alternative for the R-Project

Mr. Harms:

This e-mail is written in response to your e-mail dated February 13, 2015, wherein the U.S. Fish and Wildlife Service (Service) requested Nebraska Public Power District (NPPD) to review a new South Alternate Route for the R-Project. While NPPD appreciates the Service’s input regarding environmental concerns, the South Alternative Route that you described is not a feasible alternative for the R-Project because it does not satisfy the project’s purpose and need. Thus, NPPD intends to continue preparing its Habitat Conservation Plan based on the final route selected on January 20, 2015.

The need for the R-Project transmission line was identified by Southwest Power Pool (SPP) in its Integrated Transmission Plan. SPP, which NPPD is a member of, is a regional transmission organization that is governed by the Federal Energy Regulatory Commission to ensure that adequate transmission capacity is planned for, and reliable operation of the transmission system is provided in the nine-state SPP region, which includes Nebraska.

SPP issued a series of Notifications to Construct beginning in April 2012, wherein NPPD was ultimately notified to construct the following approved Network Upgrades: Build approximately 76 miles of new 345 kV transmission line from NPPD’s Gerald Gentleman Station north to the Cherry County area to connect to a new substation adjacent to NPPD’s existing substation east of Thedford, and then proceed east with approximately 146 miles of new 345 kV transmission line to connect to a second new substation to be sited near the existing Western Area Power Administration (WAPA) 345 kV transmission line in the Holt/Antelope/Wheeler County area. SPP ordered NPPD to construct these new facilities to meet the following needs: (1) enhance transmission system reliability by providing parallel paths for key contingencies in Nebraska; (2) relieve congestion from existing lines; and (3) provide opportunities for additional renewable energy generation.

NPPD’s initial study area was developed in the shape of a large “L” in order to meet the needs and benefits to the network upgrades that NPPD was ordered to construct by SPP. The study area was developed to go north from Gerald Gentleman Station to the Cherry County area, and then east to connect to the WAPA line. In developing the study area, corridors, and potential line routes, NPPD considered:

• the location of section, half section, and township lines;
  
• number of homes;
  
• exclusion areas, such as existing homes, airports, and public buildings;,
  
• minimization of property bi-sections;
  
• maximization of the use of existing access roads and corridors;
  
• crossing of river bottoms at perpendicular crossings or at existing bridges;
  crossing of river bottoms at perpendicular crossings or at existing bridges;
  
• the influences of existing wetlands;
  
• potential for ABB occurrence;
  
• avoidance of crossing other existing transmission lines, especially 345 kV transmission lines;
  
• the length of potential lines, which would increase impacts to more people;
  
• the need for larger areas to site substations along the route;
  
• topography; and
  
• congestion around NPPD’s existing Gerald Gentleman Station.
  

The study area was sufficiently expansive to allow NPPD to identify locations of alternate routes within the study area that would enable NPPD to meet the requirements of the SPP Order to Construct, while minimizing impacts to landowners.

NPPD has spent approximately two and a half years completing a comprehensive process to identify the final route that was announced by NPPD on January 20, 2015. During this exhaustive process, NPPD: (1) conducted 26 open houses and meetings with the public; (2) held eight public hearings in eight different counties; (3) consulted with local, state, and federal government officials, including the Service, the Nebraska Department of Roads, the State Historical Society, the Nebraska Game and Parks Commission, and the U.S. Army Corps of Engineers; and (4) accepted and analyzed more than 2,500 comments received during the routing process. In total, nearly 1,800 individuals attended the various open houses and hearings.

Determination of the final route was based on established line-routing criteria, which included more than 50 criteria, including proximity to occupied residences, towns, villages, and other amenities; the impact to farming and ranching operations; land use and environmental considerations; and engineering and construction criteria. Selecting a final line route that meets the project’s purpose and need while minimizing overall impacts is a careful balancing act of all of these criteria.

The South Alternate Route proposed by the Service angles through the central part of Nebraska, but does not meet one of the major requirements of the SPP Order to Construct facilities because it does not extend north of NPPD’s Gerald Gentleman Station to Thedford. After two and a half years of work, this project is not in the early stages of development, either in NPPD’s construction project itself, nor in the process the Service and NPPD are working on with respect to the development of the Habitat Conservation Plan and the Environmental Impact Statement.

Since the final route was announced in January of 2015, after the extensive process used by NPPD and described above, no additional routes for the R-Project Transmission Line will be considered for evaluation.

Thomas J. Kent, PE

Vice President & Chief Operating Officer

Nebraska Public Power District