Excel & Minnesota Department of Commerence

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M Plan and Profile Guidance for Transmission Lines, issued by the Department in 2012,3 provides further detail on how Plan and Profile documents are to be submitted. Among other guidelines, permittees are directed to provide copies that are signed and dated by a professional engineer. The intent of this requirement is to ensure that structures are placed in locations consistent with project design. In its June 21St filing,Xcel Energy has explained that the mistake was the result of confusion resulting from multiple sets of location coordinates. Apparently this particular structure was staked and constructed using coordinates resulting from a preliminary location, rather than the coordinates from the location shown on the plan and profile.According to the filing of May 8, 2013,the error was not noted until a clearance issue with GRE's 69 kV line was identified. As a result of the mistake, Xcel Energy failed to comply with the requirement in Section 4.1 of the Site Permit that the permittee notify the Commission of changes from the plan and profile filed with the Commission. To reduce the likelihood of a similar incident in future construction,Xcel Energy states that the company has implemented new control procedures including exclusive naming conventions for each set of coordinates to better differentiate final coordinates and additional QA/QC reviews by multiple groups to verify construction coordinates are consistent with locations shown on the plan and profile. The June 21st filing introduced four possible remedies for the mistake: I. Moving structure 076-4 to the location shown on the plan and profile filed with the Commission; 2. Leave structure 076-4 in its current location and lower the insulators on the GRE 69 kV line to create adequate clearance between the 115 and 69 kV lines; 3. Request that GRE discontinue use of the 69 kV line; or 4. Leave structure 076-4 in its current location and add two additional tangent structures just outside the substation to lift the conductors to create adequate clearance between the 115 and 69 kV lines. After reviewing the options internally and with landowners from Huntington Farm Home Owners' Association, Xcel Energy states that its preferred option is to move the structure to the location shown on the plan and profile. EFP Discussion and Recommendation Although this failure to comply with the condition of the permit appears to have been inadvertent,EFP staff finds the inattention to details such as structure location very troubling. EFP staff's understanding is that the signed plan and profile drawings are used in the field to ensure that the Project is built according to an approved plan. A difference of 120 feet between the constructed location and the planned location does appear to be the type of discrepancy that should be, if not prevented, at least discovered in a cursory"eyeball" inspection of the plan and profile drawings during the construction or cleanup process. EFP staff notes that the structure in question, 076-4, was already in place when Xcel Energy provided an explanation for an 3 Minnesota Department of Commerce,Plan and Profile Guidance for Transmission Lines,June 2012, http://mn.gov/commerce/energvfacil ities/documents/Plan%20and•%20Profi le%20Guidance%2 006142012.pdf