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I I 2.4 Certificate of Need A Certificate of Need ("CON") is not required for the Project because it is not classified as a large energy facility under Minn. Stat. §§ 216B.243 and 216B.2421, subd. 2(3). While the Project is a HVTL with a capacity of 100 kV or more,it is not more than 10 miles long in Minnesota and it does not cross a state line. Therefore, a CON is not required. See Minn. Stat. §§ 216B.2421, subd. 2(3) and 216B.243. 2.5 Route Permit,Alternative Permitting Process The Minnesota Power Plant Siting Act ("PPSA") provides that no person may construct a HVTL without a Route Permit from the Commission. Minn. Stat. § 216E.03, subd. 2. Under the PPSA,an HVTL includes a transmission line that is 100 kV or more and is greater than 1,500 feet in length. Minn. Stat. § 216E.01, subd. 4. The proposed new 115 kV transmission line is an HVTL greater than 1,500 feet in length and, therefore, a Route Permit is required from the Commission prior to construction. The Project qualifies for review under the Alternative Permitting Process authorized by Minn. Stat. § 216E.04, subd. 2(3), and Minn. R. 7850.2800, Subp. 1(C) (establishing alternative process for HVTLs between 100 and 200 kilovolts). Accordingly, Xcel Energy is following the provisions of the Alternative Permitting Process outlined in Minn. R. 7850.2800 to 7850.3900 for this Project. 2.6 Notice to Commission Xcel Energy notified the Commission on March 17, 2011, by letter (mailed and electronically filed) that Xcel Energy intended to use the Alternative Permitting Process for the Project. This letter complies with the requirement of Minn. R. 7850.2800, Subp. 2, to notify the Commission of this election at least 10 days prior to submitting an application for a Route Permit. A copy of the letter is attached in Appendix A. 1 Orono Project June 7,2011 MPUC Docket No. E002/TL-11-223 8