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The project is a 0-0-0-Plan, however, for homeowners and Orono residents, who will pay the price for a project that benefits others. We would submit that, as a matter of good public policy, the better solution is a 5-5-5 Plan. That is one in which Xcel vigorously pursues every alternative to placing an ill-suited,visually abusive, and risky substation and high-voltage transmission lines in the backyards of homeowners, and imperiling precious wetlands. If potential alternatives are diligently explored and no other alternative does, in fact, exist, every effort MUST be made to ensure that precious wetlands are protected, and the impact on homeowners and residents are mitigated to the greatest extent possible, and to our satisfaction. Those should be the paramount objectives, not resolving Xcel's problems quickly, cheaply and easily. If the cost of the project increases, so be it. Pass on the cost to all those users who receive the benefit of the improvements, or let the shareholders and executives share in the costs. Xcel should keep its own monkey. Here are some of our specific concerns: • Xcel has not demonstrated an urgent,compelling need to justify expansion of the substation. Given state of the economy now and for many years to come, the argument that the substation is required to accommodate growth in the western suburbs is not convincing. If there is no urgent, compelling need, the project should not be pursued at this time. • Representatives of Xcel have admitted that Xcel did not explore alternative sites for location of the substation. Consistent with its 9-9-9 Plan, Xcel has chosen this site out of concern for its own costs and convenience, rather than demonstrating due regard for nearby homeowners or for residents of the city of Orono who have an interest in enforcement of the city's comprehensive plan. Although the EA examines alternative routes from the existing substation, it does not explore alternative sites for the substation. It should. A paramount consideration should be location of a site that has the least impact on any residential neighborhood and does not desecrate wetlands. • In discussing alternative routes, the EA makes a puzzling statement that selecting one of the alternate routes would have an additional impact on new landowners. Why would the impact on new landowners be more compelling that the impact on existing landowners? Who are these new landowners? Developers? Do they have that much influence over the process? Or is this just more 9-9-9? • The proposed project is not consistent with the city of Orono's comprehensive plan. In a letter dated August 22, 2011, from Lili Tod MacMillan, mayor of Orono, the city expressed its "critical concerns", and the city's interest in"protecting natural vistas without manmade intrusions". While the proposed use of the site may be a permissible use under applicable zoning laws, that does not mean the facility itself may be constructed in a fashion that is not consistent with the city's comprehensive plan or without due regard for other stakeholders. • The EA also does not take into consideration another stakeholder: Minnesota taxpayers, whose millions of dollars were spent to improve and beautify Highway 12, 3