Response to CAI Comments

SE Metro Transmission Project

Red Rock – Wilson Double Circuit

115 kV Transmission Line

Prepared by David Schoengold

MSB Energy Associates

April 5, 2001

Commonwealth Associates filed two sets of comments on the report we prepared – both in the form of letters to Mayor Tiffany of Sunfish Lake. One letter was from March 21, 2001, and the other was from April 2, 2001. This response is to those comments, and is keyed to those comments. We have not necessarily answered every point in the comment letters – just those we felt are most important.

March 21, 2001 Letter

· CAI makes a number of points in response to our concern as to whether they can be considered independent. All of the points they raise are valid; however, they do not really address the question of independence. There is no way to judge CAI’s independence, because we cannot be privy to their thinking. The Steering Committee and others will just have to use their judgement on this issue.

· CAI claims that double contingency planning is appropriate for the Twin Cities metropolitan area. A close reading of CAI’s comments makes it clear that some utilities use double contingency planning and some use single contingency. They did not suggest that there is a predominance of double contingency planning, and the fact that they did not do so suggests to me that single contingency planning is probably the predominant choice. This issue does not have a right or wrong answer. The question is whether the greater cost and environmental impact of double contingency is justified by the benefits. Everything else being equal, multiple contingency planning is more reliable than single contingency, but everything else is not equal.

· CAI says that their review of routes was limited because of the instructions they were given. Exactly. The limitation was built into the process from the beginning, and this limitation reduces the value of CAI’s report.

· CAI claims that the conceptual design of the proposed line precludes upgrading to higher voltage without having to, essentially, rebuild the entire line. If the line is built to the conceptual design, this is a valid point and would eliminate the possibility of a “stealth” upgrade to a higher voltage.

· CAI states that they are not expert in the question of the impact of EMF fields and that this area should be the responsibility of others who are more expert. We agree that the question of EMF fields needs much more attention than the CAI report was able to provide.

· CAI claims that their EMF estimates vary with the distance to the structures and thus are not underestimates. We agree that the EMF strength varies with the distance, but point out that there are some structures identified which are very close to the line. We do not believe that the report makes clear enough that certain structures are impacted by very high EMF.

· CAI claims that use of a one meter height for calculating EMF is standard in the industry. This may be true, but does not address the point that actual exposure for many structures will be at heights much closer to the lines than one meter above the ground.

· CAI claims that magnetic field exposures from appliances are often as high as the calculated levels. This may be true, but appliances are not generally run round the clock.

· CAI claims that adding the second line to the existing line will reduce the level of EMF. We do not disagree.

April 2, 2001 Letter

· CAI claims that load growth in the area has been high and the use of the forecasts in the report are justified. CAI also acknowledges that it has not done an independent forecast. We also have not done an independent forecast, but rather noted what appeared to be large increases in the forecasts compared to recent forecasts. The Steering Committee and other planning bodies will have to make the judgement as to whether the recent forecast increases are justified.

· CAI claims that the analytical approach used was the same general approach which Xcel/NSP has used for years and, thus, is not related to the new competitive market for electricity. However, they go on to state that transmission system upgrades are important in order to support a move to more competitive markets. We do not believe the CAI comment really addresses the issue we raised.

· CAI acknowledges that the analytical basis of their report was a short-term review which did not look at the longer term needs of the area. They state that this was the scope of their intended services. The point we made was that transmission planning requires a longer term outlook. CAI has not addressed our concern.