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GreenbergTraurig

William A. Hurst Tel 518.689.1400


Fax 518.689.1499 hurstw@gtlaw.com

October 29,2013

VIA ELECTRONIC SERVICE


Hon. Eleanor Stein Administrative Law Judge NYS Department of Public Service Three Empire State Plaza, 3'd Floor Albany, New York 12223
Re:

Case I2-T-0248 -- Application of New York State Electric & Gas Corporation for a Certificate of Environmental Compatibility and Public Need for the Construction of the "Columbia County Transmission Project," Approximately 11.1 Miles of 115 Kilovolt Trartsmission Lines and related facilities in the Towns of Chatham, Ghent, and Stockport, in
Columbia County.

Dear Judge Stein:

Protect Ghent, Inc. ("PG") submits this correspondence to identify alternative routes and/or route segments. PG believes that all of the alternatives identified herein will satisff applicable reliability criteria and address the single contingency by bringing a new sowce into NYSEG's Mechanicville Division for use in the event of a forced outage of the existing Churchtown to Craryville 115 kV transmission line. PG believes that all of these alternatives are reasonable.l Proposed Alternative I - Valkin Substation to Klinekill Substation Along New and Existing Rights of \ilay The record shows that NYSEG had selected a Valkin to Klinekill option from among several other options that were under consideration, and that NYSEG included a Valkin to Klinekill option in its 2009 rate case. NYSEG claims to have rejected this altemative on the ground that National Grid refused to allow the interconnection, although NYSEG presented no documents or other proof as part of its direct case showing that to be the case. The record shows that as of December 2010, National Grid had left the decision whether or not to pursue the
See Tyminskiv. Public Service Commission,33 N.Y.2d 156, 159-60 (1975) ("The Legislature recognized ' that the commission must be given the basic information necessary to evaluate the advantages and drawbacks of both the proposed facility and any reasonable alternatives. Accordingly, in addition to the impact study on the primary proposal, the applicant must supply a description of alternatives, a description of the comparative merits and detriments of each location, and a statement of the reasons why the primary proposal was deemed best suited for the facility. [The Legislature mandated] that the applicant produce descriptions of reasonable alternatives, and an explanation of why the alternatives were unsatisfactory."). ALB 1726197v1

. ATTORNEYS AT LAW T WWW,GTLAW COM 54 State Street ! 6th Ftoor r ALbany, NY 12207 . Tel 5]8 89.]400 I Fax 518 89.1499
GREENBERG TRAURIG, LLP

Hon. Eleanor Stein October 29,2013 Page2

Valkin to Klinekill alternative to NYSEG, which refused to do so for reasons that are not set forth on the record. Nor has NYSEG presented information comparing the cost and effectiveness of a Valkin to Klinekill alternative to NYSEG's preferred alternative. In other words, NYSEG has not ca:ried its burden of proof to demonstrate that a Valkin to Klinekill option is unreasonable. PG believes that it is a reasonable alternative, as evidenced by, among other things, NYSEG's inclusion of this option in its rate case.
The alternative route would begin at the existing Valkin Substation, located just north of the intersection of Maple Lane and Fordham Road in Valatie, NY. Exiting the rear of the Substation, the alternative route would follow Maple Lane South for approximately 5,300 feet, until it reaches the intersection with Route 9, where the route would turn south for approximately 500 feet to the edge of an existing agricultural field. The alternative route would then turn easterly, along the edge of the agricultural field for approximately 1,400 feet, to the intersection with State Farm Road. From the intersection with State Farm Road, the alternative route would turn northeasterly for approximately 2,100 feet through an undeveloped area until it intersects an existing transmission line right of way running generally north/south at that point.
The alternative route would then follow the existing transmission line right of way north, then northeasterly, for approximately 7,200 feet until it intersects with an existing CSX right of way, at a point where Route 203 crosses the CSX right of way. The CSX right of way leads south to a point adjacent to the Klinekill Substation. From that point, the Valkin to Klinekill alternative would turn westerly, through what appears to be a gravel pit ot mine, until it reaches the Klinekill substation.

1.5 miles of new

This alternative is approximately 8.5 miles in length and would require slightly more than right of way. See Exhibit "A."

Substation suffers from irremediable congestion, then the same alternative route pertains, but with double circuiting.

If the Valkin

Proposed Alternative 2 - Second Churchtown to Craryville 115 kV Line

PG's analyses show that the construction and operation of a second Churchtown to Craryville 115 kV transmission line satisfies all applicable reliability criteria. This alternative would entail the construction and operation of a second set of transmission structures in the exiting Churcthtown to Craryville right of way (widened as necessary). In so doing, this alternative would furnish the redundancy called for by applicable reliability criteria. See Figure 2-2 of the Application for the location of the Churchtown to Craryville line.

ALB 1726197v1
GREENBERG TRAURIG, LLP

ATTORNEYS AT LAW

WWW.GTLAWCOM

Hon. Eleanor Stein October 29,2013


Page 3

Proposed Alternative 3

34.5 kV Alternative

PG continues to support the 34.5 kV alternative originally advanced by the Town of Ghent and submits that NYSEG has not ca:ried its burden of demonstrating that the Town's 34.5 kV alternative, which is different from the 34.5 kV alternative reviewed and rejected by NYSEG, is unreasonable. PG continues to study the optimal configuration of a 34.5 kV altemative.

If there are any questions regarding


undersigned at any time.

the above, please do not hesitate to contact the

Respectfu lly submitted,

GREENBERG TRAURIG, LLP /s 'Wi[[nmA.lturst V/illiam A. Hurst


cc:

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