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DOC EFP Staff Comments and Recommendations PUC Docket E002/TL-11-223 Page 6 period, Mr. Michael Kuruvilla Kallivayalil submitted four alternative substation locations (Finding 47). EFP Staff Analysis. Xcel Energy acquired the 16 acre parcel in 1989 and the existing 69 kV substation, with a fenced area of approximately 0.1 acres, has been in operation since 1990. In acquiring a larger parcel than needed for the actual substation location in a developing area it would appear that Xcel Energy was demonstrating prudent future planning. The actual developable area of the parcel is limited by the presence of wetlands on the site. Xcel Energy has designed the footprint of the replacement substation in a manner that minimizes impacts to wetlands and allows that MPCA noise standards to nearby receptors can be met with the addition of 14 to 16 foot noise walls around the transformer location. The Project is proposed to ensure a more robust transmission system in the west metro area. Because of the development and growth of the west metro, there is a relative paucity of undeveloped sites removed from residential development of the size that Xcel Energy would want to develop a 115 kV substation. The alternative substation sites proposed during scoping were reviewed by EFP staff prior to staff's recommendation to the Deputy Commissioner of the Department. Although no routes for the additional transmission to the alternate substation sites were developed, it appears that the alternate sites would require approximately 800 to 4,900 feet of additional double circuit 115 kV transmission line compared to Xcel Energy's proposed route. Because the proposed substation sites were all located east of Xcel Energy's Transmission Line 0831, it is probable, though not certain, that transmission to these substations would also follow a route along U.S. Highway 12 as does the Project. In addition to the transmission line, development of a new substation site would also require re-location of two existing electric distribution lines in, resulting in impacts to new landowners in addition to those affected by the transmission line. In reviewing alternative substation sites EFP staff did not identify anything to suggest that a new substation location would have great potential for a project with fewer impacts, but rather a shift the burden to a new unidentified set of landowners. The developed site of the replacement substation is much larger, 1.2 acres, than the present 0.1 acre site and the concern of neighborhood residents at the change is very understandable. EFP staff proposes a process for public comment on the substation mitigation plan as discussed below. Substation Mitigation. Residents of the Huntington Farm neighborhood and the city of Orono have identified visual and noise impacts from the replacement substation as a primary concern. The replacement substation will be substantially larger than the existing substation, a fenced area of approximately 1.2 acres compared to the existing 0.1 acre fenced site. Xcel Energy prepared a Noise Assessment evaluating noise impacts from installing a new transformer at the replacement substation and a possible additional transformer that may be added at some point in the future. Xcel Energy's submittals provided some initial proposals to screen the substation from views from homes to the west and south and from travelers along Hennepin County Road 6 through use of berms and vegetation. The city of Orono has requested that Xcel Energy develop a landscaping plan using a combination of berms and vegetative screening to minimize impacts to area residents and travelers along Hennepin County Road 6 and Orchard Park Road.