HomeMy WebLinkAbout1.0 ApplicationCOST OF COMPLIANCE
WITH GOVERNMENTAL REGULATION
COLORADO -UTE ELECTRIC ASSOCIATION, INC.
April 30, 1982
Table of Contents
Page No.
I. Introduction 1
II. General Description of Colorado -Ute 2
III. Overview of Study Elements
A. Objectives and Scope of Study
B. Conclusions of the Study
IV. Methodology of Study
A. Steam Generation
B. Transmission Lines
C. Pollution Control Removal Systems
D. Cost of Rate Regulations Stemming
from Public Utility Regulatory
Policies Act
5
14
V. Summary 21
I. Introduction
During 1978, Colorado-Ute Electric Association, Inc., devel-
oped a study of the costs of compliance with governmental, regula-
tions, primarily in the environmental area. That study was con-
ducted for use in sworn testimony of Colorado-Ute witnesses before
the Colorado Public Utilities Commission in its 1978 rate case.
It was also used to provide information to legislative committees
and other regulatory bodies. The study was not intended for the
purpose of passing judgment on governmental regulations as being
"necessary" or "unnecessary," but rather to identify the cost to
Colorado-Ute of regulatory compliance and ultimately, the cost to
the consumers supplied by Colorado-Ute.
This report is an update of the 1978 study, and is expanded
to cover more of Colorado-Ute's operations and experience. It
also addresses the anticipated costs imposed by regulation
stemming from the Public Utility Regulatory Policies Act of 1978.
II. General Description of Colorado -Ute
Colorado -Ute Electric Association, Inc., is a public utility
operating in the state of Colorado and headquartered in Montrose,
Colorado. Colorado -Ute operates as a non-profit, member -owned
cooperative and is principally engaged in the business of pro-
viding wholesale electric service to its fourteen member distribu-
tion cooperative associations.
Colorado-Ute's fourteen members are locally -owned consumer
cooperatives that are principally engaged in the business of pro-
viding retail electric service to their consumer members. In gen-
eral, the membership of these cooperatives is composed of residen-
tial, agricultural, recreational, commercial and industrial con-
sumers within the cooperatives' retail service area. The member
cooperatives supply their member consumers' load requirements
through bulk purchases of power and energy from Colorado -Ute. The
retail service areas of Colorado-Ute's member distribution cooper-
atives encompass approximately one-half of the land area within
the state of Colorado, including all or a portion of 49 of the
state of Colorado's 63 counties. Colorado -Ute and its fourteen
members together constitute the second largest electric utility
system in the state of Colorado in number of consumers served and
annual energy sales to consumers.
In order to meet its members' load requirements, Colorado -Ute
supplies power and energy from its own generating resources and
-2-
from purchases from other power supply entities. Colorado -Ute
presently owns and operates the following electric generating
capacity:
Colorado -Ute Electric Association, Inc.
Electric Generating Units
Net
Capacity
(MW)
1. Craig Unit 1 119
2. Craig Unit 2 119
3. Hayden Unit 1 175
4. Hayden Unit 2 131(1)
5. Nucla Units 1,2,3 30
6. Bullock Units 1,2 10
7. Tacoma and Ames Various Units 11
Hayden Station, Craig Station, Nucla Station, and Bullock
Station are coal-fired steam electric generation plants and Tacoma
and Ames Stations are hydroelectric generation plants. A third
400 mw coal-fired steam electric generating unit is now under
construction at Craig Station. This unit will be owned entirely
by Colorado -Ute and is scheduled to be in commercial operation by
the end of 1983.
Colorado -Ute currently plans to construct a coal-fired steam
generating unit at a new site near Grand Junction, Colorado. This
(1) On January 1, 1982 Colorado -Ute recaptured 30% of the net
capacity of Hayden Unit No. 2 making Colorado-Ute's share 131 mw
or 50% of the unit. However, during the time frame of this study,
Colorado -Ute had only a 20% share of Hayden Unit No. 2 or 52 mw.
The costs of compliance with governmental regulation for Hayden
Unit No. 2 represent only the costs associated with the 20%
share.
-3-
will be a 500 mw unit and is currently scheduled for commercial
operation in 1988.
Colorado -Ute delivers power and energy to its fourteen
members over its own transmission system and over the intercon-
nected high voltage transmission systems of other power supply
entities pursuant to the contractual terms of a variety of inter-
connection, wheeling and displacement arrangements. Colorado-
Ute's transmission system consists of approximately 1,162 miles of
high voltage transmission lines and 49 substations.
- 4-
III. Overview of Study Elements
A. Objectives and Scope of Study
The objectives of this study are as follows:
1. To examine and quantify the capital and operating costs
of compliance with governmental regulation where directly
ascertainable.
2. To compare these costs with total costs.
3. To discuss anticipated costs related to Public Utility
Regulatory Policies Act of 1978.
Colorado -Ute was able to ascertain the total of direct costs
of compliance with governmental regulation with respect to oper-
ating and capital costs in the area of coal-fired steam electric
generation. This is the area where governmental regulation has
had the greatest impact upon the costs of operation for Colorado -
Ute. Colorado -Ute has so far not been impacted greatly in the
areas of hydroelectric operating costs and has not had any direct
experience in the construction of major hydroelectric generation
facilities.
In the area of transmission system costs, Colorado -Ute was
not able to quantify the total costs of compliance with govern-
mental regulations due to the time limitations of the study, the
number of projects and the sheer bulk of the data that would have
to be analyzed. The analysis of regulatory costs in the trans-
mission area was again limited to examples of recent transmission
-5-
line construction. Costs associated with existing commitments to
preserving aesthetics on facilities in service have been
quantified.
The Public Utility Regulatory Policies Act (PURPA) of 1978
generally exempted small utilities and wholesale utilities from
its various provisions. However, PURPA regulations are generally
implemented through State regulatory agencies. In the case of the
State of Colorado, the Public Utilities Commission has determined
that the promotional and incentive rate designs and load manage-
ment principles set forth in PURPA should be implemented regard-
less of the exemptions in PURPA.
Colorado -Ute is interconnected to power systems in 14 Western
states and is also a member of the Inland Power Pool. Because of.
this situation and other favorable conditions, Colorado -Ute has
been able to institute a resource management program, which is a
much more effective tool to reduce costs than attempting to manip-
ulate demand through rate design. Our resource management program
in turn has enabled us to offer a unit price wholesale rate based
on a flat energy charge per kwh.
Colorado -Ute is able to eliminate the traditional demand
charge because Colorado-Ute's resources are base -loaded coal-fired
generating units. Colorado -Ute, because of its base -loaded gener-
ation, does not have to rely upon peaking units fueled by high-
priced oil and gas to meet peak loads, as many other utilities do.
-6-
Therefore, we believe that a mandate of incentive rates and load
management for the Colorado -Ute system is misguided, contrary to
the financial and rate design goals of Colorado -Ute and its mem-
bers, and would result in added and unnecessary costs. An estimate
of these additional costs has been developed based upon known in-
dustry experience and current vendor prices for meters and
equipment.
The Public Utilities Commission of the State of Colorado has
also expressed confidence that small power producer and cogenerator
developments could and should become a significant component of
utility resource plans. Our studies indicate that there are cur-
rently no cost effective small power producer or cogenerator poten-
tials in the service area. In the future, some possibilities may
emerge. To assume, however, that they will emerge would be an un-
warranted and costly risk in resource planning. No attempt has
been made to estimate costs associated with this aspect of the
PURPA influence.
It should be noted that the regulatory costs used in this
study represent only directly identifiable major cost components.
No attempt has been made to quantify those regulatory costs that
are paid by Colorado -Ute indirectly and therefore cannot be defin-
itely ascertained. For example, the study does not include, among
others, the following major indirect cost items:
1. Regulatory costs hidden in the price of materials used in
generating plant construction, such as steel and cement.
-7-
2. Reclamation and other regulatory costs included in the
price of fuel purchased by Colorado -Ute, unless passed on
directly to Colorado -Ute.
The study also does not include those direct regulatory costs
that consist of a multitude of small items, or where the costs are
known to exist but the amounts are somewhat speculative. The
following are examples of this category of regulatory costs
excluded from the study:
1. OSHA regulations requiring safety devices, imposing
operating limitations, and similar items.
2. Public Utilities Commission fees, hearing costs,
reporting requirements, and added financing costs.
3. Federal Energy Regulatory Commission reporting
requirements.
4. Local building permits and zoning restrictions.
5. Cost of continuous analysis of new regulations to
determine applicability to Colorado-Ute's business.
The above lists of excluded regulatory costs are only repre-
sentative of the many items that could properly be included if the
data were available and could be reasonably analyzed. Because of
these exclusions, the results of this study are, we believe, quite
conservative.
B. Conclusions of the Study
1. Steam Generation
The study concludes that the direct identifiable annual cost
of compliance with governmental regulations during the period of
this study amounted to 38.4 percent of the total cost of produc-
tion at steam generation plants, up from 35 percent in 1978. The
-8-
following is a tabulation of such costs by generating unit as a
percentage of the total cost of production.
Costs of Compliance with Governmental Regulation
(Percent of total production cost)
Craig Unit 1
Craig Unit 2
Hayden Unit 1
Hayden Unit 2
Nucla Station
Bullock Station
Average
34%
36%
51%
36%
30%
45%
38%
During 1981 these costs totaled $29 million of which $12
million related to the financing cost of pollution control equip-
ment and $16 million related to the operation and maintenance and
electric. power needed to operate the equipment. From these num-
bers, it is a reasonable inference that if all direct and indirect
regulatory costs were included, the cost of compliance with gov-
ernmental regulations would amount to at least half the total cost
of generating electric power by Colorado -Ute.
Schedules 1 and 2 set forth the summary of costs involved.
Supporting schedules 3 through 11 show a details of the cost
factors.
2. Transmission
Costs of transmission facilities recently constructed have
been affected tremendously by regulatory compliance. Increased
-9-
costs have been incurred directly as a result of regulatory re-
quirements and indirectly from inflationary increases which have
resulted from regulatory caused delays.
One of the projects analyzed was the Poncha-San Luis 230 kv
line which was placed in service in 1981, approximately 8 years
late. The cost of constructing this line was $10.7 million in-
cluding costs for direct regulatory stipulations of approximately
$1.5 million. Inflation during 4 years of regulatory delays is
estimated to represent another $3.4 million of the cost. Also in-
cluded in the cost is $4.1 million resulting from changes in the
original project scope and further delays brought about as a
result of actions by the permitting agencies. The total cost of
regulatory compliance associated with this project is estimated to
be 85 percent of the final cost. This means that Colorado -Ute
ended up spending more than six times as much as was originally
planned due to governmental regulations.
As another example, the Wolcott -Malta 230 kv transmission
line project has been delayed 6 years by federal and local agency
action and inactions. The project is currently under construction,
with final costs estimated to be $21.6 million. On this project,
direct regulatory costs are estimated to be $4.2 million. Infla-
tion during 5 years of regulatory delays is estimated to be
another $5.3 million. An additional cost of approximately $1.8
million has resulted from changes in the project scope and
-10-
associated delays which were imposed by permitting agencies. The
total cost of regulatory compliance associated with this project
is estimated to be 53 percent of the final cost.
Figure 1 is a graphic illustration of the increases in trans-
mission costs for the Poncha-San Luis 230 kv line due to govern-
mental regulations. Schedules 12 and 13 detail the above con-
struction costs for the Poncha-San Luis 230 kv and the Wolcott -
Malta 230 kv projects, respectively.
3. Rate Regulation Costs
At the present time it appears that the pressures of infla-
tion may be lessening. Although interest rates are presently
high, they are expected to come down in line with inflation.
Colorado-Ute's costs and, therefore, rates now reflect extensive
environmental protection equipment and efforts. Rates in the
future could therefore be expected to stabilize. However, there
is a new force at work which we believe will drive up costs and
rates with absolutely no increase in productivity or improved
environmental conditions. These costs will result from so called
"rate reform" activities which stem from the Public Utility Regu-
latory Policies Act of 1978. As evidenced by recent regulatory
decisions in the area of rate design, these experiments will in-
volve promotional rates, new metering systems, load research pro-
grams and load controllers, all of which will be very expensive.
The purported benefits, even if the economic theories are correct,
are a decade away. Today's customer must bear the cost, which we
-11-
FIGURE 1
Poncha-San Luis 230 kV
Transmission Line Construction Cost
51,860,000
55,050.000
59,150.000
fr
s10.700.000
BASE COST
1973
DELAYED COST
1977
PERMITTING COST AS -BUILT COST
1981 1981
DELAY represents the increases in labor and material
costs from 1973 to 1977 due to regulatory delays.
PERMITTING represents
material costs due to
imposed by permitting
resulting delays.
the increased labor and
changes in project scope
agencies, along with the
DIRECT REGULATORY represents the increased labor
and material costs directly related to regulatory
compliance.
-12-
estimate to be approximately $260 per customer. The $260 trans-
lates into an annual operating cost of 3.9 mills per kwh or 10
percent of total operating costs for Colorado -Ute. It should be
emphasized that no hard evidence exists that these consumer expen-
ditures will result in any benefits whatsoever. Schedule 14 sets
forth a summary of the cost estimates resulting from rate
regulations.
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IV. Methodology of Study
A. Steam Generation
In the area of cost of compliance for governmental regula-
tion with respect to steam generation plants, Colorado -Ute
examined for the twelve month period ending December 31, 1981 the
following cost components:
1. Labor and associated payroll overheads
2. Fuel expense
3. Materials and supplieb and other costs
4. Additional power costs
5. Fixed costs on pollution control equipment
a. Depreciation
b. Property Taxes
c. Interest Expense
d. Property Insurance
6. Administrative and general expense
Labor and associated payroll overhead expenses represent the
cost of plant operations and maintenance personnel that are spe-
cifically assignable to the operations, maintenance and testing
requirements of pollution control equipment. Also included were
estimates of the cost of supervision of these functions by plant
supervisory personnel.
Fuel
expenses represent the portion of Colorado-Ute's fuel
expense that was directly attributable to environmental taxes or
-14-
legislation at the time this study was prepared. These costs
include:
1. Reclamation costs, if specifically passed on to
Colorado -Ute
2. Colorado Severance taxes
3. Federal Reclamation costs
4. Federal Black Lung taxes
5. Environmental costs
Materials and supplies and other costs represent the direct
costs of materials, supplies and replacement parts issued on a
routine basis and other expenses associated with the operation,
maintenance and testing requirements of the pollution control
equipment.
Additional power costs represent a pro rata estimate of the
cost of capacity lost in the generation station by the addition of
pollution control equipment plus the cost of energy needed to
operate the equipment.
Depreciation, property tax, interest expense and property
insurance represent the fixed costs that are associated with
the pollution control equipment installed. The pollution control
equipment represented major component systems that Colorado -Ute
installed or retrofitted to existing plant in order to comply with
government regulation. These facilities are briefly summarized in
Section C, "Summary of Pollution Control Removal Systems."
-15-
Administrative and general costs represent the administrative
costs associated with the operation and maintenance of pollution
control equipment installed and compliance with directly identi-
fiable regulatory requirements.
B. Transmission Lines
In the area of analysis of the impact of government regula-
tion on construction of transmission facilities, the principal
result of these regulations has been to delay projects, change
project design, and lengthen the time period required for con-
struction, which increases the cost of construction due to infla-
tion and interest charges during construction. The regulations
that most affect Colorado -Ute are federal regulations with regard
to:
1. Line routing
2. Right-of-way clearing
3. Permitting
4. Preparation of additional studies
5. Requirements for additional hearings
Colorado-Ute's transmission system is particularly affected
by federal requirements because most of the land in Western Colo-
rado is federally owned and subject to the Bureau of Land Manage-
ment or United States Forest Service control.
-16-
Changes in requirements for routing transmission line corri-
dors away from existing highway corridors so as to hide transmis-
sion lines from public view require the use of special construc-
tion equipment, particularly in mountainous terrain. In most
cases, this requires special overland vehicles or the use of heli-
copters for construction. The Bureau of Land Management and
Forest Service limit the amount of access roads that can be con-
structed. Where right-of-way clearing is required, clear cutting
may not be permitted. New regulations require feathering tech-
niques which may involve landscaping and special cutting for dis-
tances up to 800 feet on either side of the center line. These
kinds of costs can be directly identified. Costs of delays must
be estimated to account for inflation.
Two new stipulations from federal agencies have come clearly
to light since the 1978 report. One is that of prebuilding future
line capacity so as to minimize or avoid future projects and
therefore environmental impacts. The second is major changes in
project scope, including longer lines, higher voltages and higher
costs simply to avoid geographic areas which are considered sensi-
tive or even of undetermined status by permitting agencies. These
costs have been specifically identified in the two comprehensive
examples of this study.
Colorado -Ute has also been able to identify some consider-
able expenses incurred to preserve aesthetics. These include
-17-
visual enhancements such as screening of facilities with
vegetation and camouflaging transmission lines. As of the end of
1981, Colorado -Ute has spent a total of $3.8 million dollars in
"aesthetic costs". The effect of this capital cost outlay has
been to increase Colorado-Ute's transmission system fixed costs
(Depreciation, Taxes and Interest) by $320,000 annually.
C. Pollution Control Removal Systems
The following is a brief summary of the major components of
pollution control systems that Colorado -Ute had installed for
Hayden Station, Craig Station, Nucla Station and Bullock Station
which were analyzed for the purposes of this study.
Hayden Station
1. Hotside electrostatic precipitators
2. Flyash and bottom ash removal systems
3. Ash hauling equipment and disposal site
(to the extent not required for operational purposes)
4. Waste water concentration system including holding ponds
and evaporation ponds
5. Coal yard drain ponds
6. Ambient air monitoring systems
7. Nitrous oxide reduction boiler design on Unit 2
8. Increased stack height on Unit 2 for better dispersal of
emissions
Craig Station Units 1 and 2
1. Hotside electrostatic precipitators
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2. Sulfur dioxide removal system
3. Flyash and bottom ash removal systems (to the extent not
required for operational purposes)
4. Ash and sludge hauling equipment and disposal site
5. Increased stack height for better dispersal of
emissions
6. Nitrous oxide reduction boiler design
7. Fugitive dust suppression systems at various
plant site locations
S. Waste water concentration system including
holding ponds and evaporation ponds
9. Coal yard drain pool
10. Sewage and plant waste drain system
11. Ambient air monitoring system
Nucla Station
1. Fabric filter baghouse collection system
2. Ash hauling equipment and disposal site (to the extent
not required for operational purposes)
3. Cooling tower system
4. Evaporation ponds and holding ponds
5. Water piping modifications for elimination of thermal and
water discharge pollution
Bullock Station
1. Fabric filter baghouse collection system
2. Ash hauling equipment and disposal site
(to the extent not required for operational purposes)
3. Evaporation ponds
4. Modification of drain piping to eliminate waste discharge
pollution
-19-
D. Cost of Rate Regulations Stemming from
Public Utility Regulatory Policies Act
In the State of Colorado, the Public Utilities Commission has
unilaterally determined that load management is a cost effective
course for regulated electric utilities to follow. Load manage-
ment embodies incentive or promotional rates, load control by the
customer, and load control by the utilities. Cost estimates have
been prepared in the following areas:
1. Load research program - A study of the customer load
characteristics to develop data upon which the design for
a load management program can be based.
2. Promotional or incentive rates - The metering and oper-
ating aspects of applying complex rate structures such as
demand/energy or time of use rates.
3.. Customer load control - In response to a demand or time
of use rate, it is assumed that customers with high lev-
els of electricity use would purchase and install a load
control device. The device would be a necessary measure
of preservation so as to maintain monthly bills at an
affordable level. The load controller simply gives the
residential or commercial customer the ability to exploit
a demand rate structure just as the larger industrial
customers do. The customer can react "correctly" to the
rate design to achieve the supposed savings inherent in
the rate structure. There is no assurance, however, that
such steps taken by consumers in response to a rate
structure will necessarily be rational if the structure
is too complex for the general public to understand.
4. Utility load control - The hardware and operating aspects
of applying interruptible rates to the residential class
of customers.
-20-
V. Summary
One of Colorado-Ute's basic policies has been a full
commitment to the protection of the environment. Colorado -Ute
believes that economic growth and environmental protection can be
compatible. However, it is Colorado-Ute's position that the
effects of governmental regulation need to be balanced reasonably
against costs. Colorado -Ute has an obligation to the member
consumers that it supplies to keep all costs, including the cost
of environmental protection, as low as possible.
Colorado -Ute is greatly concerned that the present costs of
compliance with governmental regulations may be only the tip of
the iceberg. New governmental regulations or modifications of
existing governmental regulations are being promulgated every
year. The seemingly innocuous provisions of the Public Utility
Regulatory Policies Act (PURPA) are a good example in the case of
Colorado -Ute. The spin-off costs from PURPA are totally
unnecessary, unproductive and, in Colorado-Ute's case, counter to
the rate design philosophy of Colorado -Ute and its members. Yet,
the ideas and concepts are being applied to Colorado -Ute by the
State regulators even though the Federal regulations exempted
small systems and wholesale operations.
-21-
Schedule 1
Colorado -Ute Electric Association, Inc.
Comparison of Costs of Compliance with Existing Governmental
Regulations to Total Production Costs for All Steam Generating Stations
Twelve Months Ended December 31, 1981
($1,000)
Cost of
Compliance Total
With Governmental Production
Regulations Costs
Operations and Maintenance
Labor $ 2,172 $ 6,208
Fuel Costs 3,909 21,349
Materials Supplies and Other Expenses 2,443 6,197
Additional Power and Energy 7,071
Total 15,595 33,754
Fixed Costs
Depreciation 5,039 10,341
Taxes 1,096 3,177
Interest 5,742 23,955
Insurance 400 1,334
Total 12,2/1 38,807
Subtotal 27,8/2 72,561
Administrative and General Expense
Total Production Costs
1,131
$29,003
2,943
$75,504
Cost of Compliance to Total Production Costs $29,003/$75,504 = $38.41%
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COLORADO—UTE ELECTRIC ASSOCIATION, INC.
Comparative Analysis of Construction Costs
Poncha—San Luis 230 kv Line
Construction
Engineering
Right—of—Way Procurement
Legal Costs (4)
Environmental Analysis
Interest During Construction
Total
1973
Normal
Construction
Costs
$ 1,364,000
103,000
110,000
44,000
0
16,000
$ 1,637,000
Costs directly attributed to Regulation
1981 Actual Cost
1981 Normal Construction Cost
Cost of Regulation
Costs attributed to changes in project scope
due to permitting
1981 Normal Construction Cost
1977 Normal Construction Cost
Cost of Permitting
Costs attributed
1977 Normal
1973 Normal
Cost of Delays
to Delays
Construction Cost
Construction Cost
1977
Normal
Construction
Costs(1)
$ 4,039,200
359,200
205,300
51,300
0
400,100
5,055,100
$10,698,300
9,152,300
$ 1,546,000
$ 9,152,300
5,055,100
$ 4,097,200
$ 5,055,100
1,637,000
$ 3,418,100
1981
Normal
Construction
Costs(2)
$ 7,160,300
850,000
280,000
12,000
0
850,000
$ 9,152,300
Schedule 12
1981
Actual
Costs(3)
$ 8,325,000
931,700
281,800
12,500
55,300
1,092,000
$.10,698,300
(1) Differences between 1977 and 1973 normal costs are due to inflation costs as a result
of regulatory delays.
(2) Differences between 1981 and 1977 normal costs are due to changes in project scope
necessitated by permitting requirements and to the resulting delays.
(3) 1981 actual costs include normal construction costs and all direct regulatory
compliance costs.
(4) 1981 normal and actual Legal Costs include only contracted legal services. Other
Legal Costs are included in Right—of—Way Procurement.
COLORADO -UTE ELECTRIC ASSOCIATION, INC.
Comparative Analysis of Construction Costs
Wolcott -Malta 230/345 kv Line
Construction
Engineering
Right -of -Way Procurement
Legal Costs (4)
Environmental Analysis
1976
Normal
Construction
Costs
$ 8,284,160
877,800
460,000
140,920
0
Interest During Construction 553,320
Total
$ 10,316,200
Costs directly attributed to Regulation
1982 Actual Cost
1982 Normal Construction Cost
Cost of Regulation
Costs attributed
1982 Normal
1977 Normal
Costs of Delays
to Delays
Construction Cost
Construction Cost
Costs attributed to changes in project scope
due to permitting
1977 Normal Construction Cost
1976 Normal Construction Cost
Cost of Permitting
1977
Normal
Construction
Costs(1)
$10,409,200
602,660
92,580
39,840
0
958,420
$12,102,700
$21,639,700
17,392,700
$ 4,247,000
$17,392,700
12,102,700
$ 5,290,000
$12,102,700
10,316,200
$ 1,786,500
1982
Normal
Construction
Costs(2)
$12,017,600
1,853,100
150,000
40,000
0
3,332,000
$17,392,700
Schedule 13
1982
Actual
Costs(3)
$14,667,800
2,481,900
400,000
45,000
0
4,045,000
$21,639,700
(1) Differences between 1977 and 1976 normal costs are due to changes in project scope
necessitated by permitting requirements and to the resulting delays.
(2) Differences between 1982 and 1977 normal costs are due to inflation costs as a result
of regulatory delays.
(3) 1982 actual costs include normal construction costs and all direct regulatory
compliance costs.
(4) 1977 and 1982 normal Legal Costs and 1982 actual Legal Costs include only contracted
legal services. Other Legal Costs are included in Right -of -Way Procurement.
Schedule 14
Page 1 of 5
LOAD MANAGEMENT
This schedule sets forth an estimate of costs to be incurred by
Colorado -Ute, its members, and, in turn, the retail customers, should
a program of load management be required for the residential and
commercial classes of customers. Such a program would include incen-
tive or promotional rates and direct load control, i.e., demand rates,
time of use rates, seasonal rates, and interruptible rates, as well as
load control devices (customer owned or utility owned).
I. ESTIMATED COST OF A COLORADO -UTE LOAD SAMPLING
PROGRAM FOR THE FOURTEEN MEMBER SYSTEMS
A. Capital Costs
Metering Equipment
4500 Recording Pulse Meters @ $900 each
installed $4,050,000
450 Spare Reserve Recording Pulse Meters
@ $550 each 247,500
Total Metering Equipment $4,297,500
Translation Equipment
Basic Hardware Package $ 170,000
Supporting Software 70,000
Total Translation Equipment $ 240,000
Total Capital Costs $4,537,500
B. Annual Operating Costs
Labor Costs
Field Personnel (28) 58,240 hr.
@ $10.27/hr. $ 598,120
Translator Operator (4) 8,320 hr.
@ $7.68/hr. 63,900
Load Analysts (6) @ $20,000/yr. $ 120,000
Subtotal 782,020
Payroll Overheads @ 40% 312,810
Total Labor $1,094,830
Transportation Expense 504,000 miles @ $.35/mi.
Operating and Maintenance Materials and Supplies
Administrative & General Overhead 30% of Total Labor
Depreciation $4,537,500 x 6%
Taxes $4,537,500 x 19.2429% x 0.04887
Interest $4,537,500 x 13.5%
Total Annual Costs
176,400
214,500
328,450
272,250
42,670
612,560
$2,741,660
Page 2 of 5
II. PROMOTIONAL OR INCENTIVE RATE STRUCTURES
A. Capital Costs
70,000 existing kwh meters modified to record demand
and energy use in selected time periods @ $200 each $14,000,000
7,000 spare meters for member inventory @ $150 each $ 1,050,000
Total Capital Costs $15,050,000
B. Annual Operating Costs
Labor, operating and maintenance, and administrative and general
expense is assumed to be greater than existing expenses due to
increased complexity and customer reaction. The following
extimates are therefore increases over current expenses.
Labor Costs:
Accounting (14) 29,120 hr. @ $10.00/hr. $ 291,200
Customer Service (14) $20,000/yr. 280,000
Subtotal $ 571,200
Payroll Overheads at 40% 228,480
TOTAL LABOR
$ 799,680
Transportation Expense 140,000 miles @ $ 49,000
$.35/mi.
Operating and Maintenance Materials and Supplies
$5/meter $ 350,000
Administrative and General Overhead
30% of Total Labor
Depreciation $ 15,050,000 x 6%
Taxes $ 15,050,000 x 19.2429% x .04887
Interest $ 15,050,000 x 13.5%
Total Annual Costs
$ 239,900
$ 903,000
$ 141,530
$ 2,031,750
$ 4,514,860
Page 3 of 5
III. CUSTOMER LOAD CONTROL
A. Capital Costs
Cost to residential customers using electricity for space heating.
30,000 controllers @ $650 per controller installed
(Represents a cost to be incurred by the customers)
$19,500,000
B. Operating and Maintenance Costs
The customer load controllers presently available are primarily
solid state electronic devices for which operation and
maintenance costs should be minimal. However, one service call
per year per device would amount to perhaps $40 per year and
with the industry in its infancy only one service call per year
is definitely conservative.
30,000 controllers @ $40 $ 1,200,000
Page 4 of 5
IV. UTILITY DIRECT LOAD CONTROL
ASSOCIATED WITH INTERRUPTIBLE RATES
A. Capital Costs
Estimated cost of a Colorado -Ute load control program for the
fourteen member system. The system would employ the. Colorado -Ute
microwave communication system and would give the Colorado -Ute
dispatch control over the interruptible load on the member systems.
Transmitter Stations
Master Radio Controller $ 28,000
14 VHF Transmitters, 300 watts @ $11,500 each 161,000
14 VHF Antennas @ $4,500 each 63,000
Inventory, parts, installation costs 33% 83,160
Total Transmitter Costs $ 335,160
Excludes cost of Colorado-Ute's communication
system capacity dedicated to load control
program.
Receiver/Relay Devices
30,000 Devices, one per residential space heat
customer at $100 each installed $3,000,000
Inventory and Parts 10%, 3,000 at $85 each $ 255,000
Total Receiver/Relay Equipment $3,255,000
Total Capital Costs $3,590,160
B. Annual Operating Costs
Labor Costs
Engineer (1) $24,000/yr.
Technician (2) 4160 hr. @ $10.27/hr.
Subtotal
Payroll Overheads @ 40%
Total Labor
Transportation Expense 100,000 miles @ $.35/mi
$ 24,000
42,720
66,720
26,690
Operating and Maintenance Materials and Supplies
Administrative & General Overhead 30% of Total Labor
Depreciation $3,590,160 x 6%
Taxes $3,590,160 x 19.2429% x 0.04887
Interest $3,590,160 x 13.5%
$ 93,410
35,000
20,000
28,020
215,410
33,760
484,670
Total Annual Costs $ 910,270
Page 5 of 5
V. SUMMARY OF COSTS FOR LOAD MANAGEMENT
Capital Annual
Activity Costs*1 Costs*2
Load Research $ 4,537,500 $ 2,741,660
Demand and Time of Use Rates $15,050,000 $ 4,514,860
Customer Load Controller $19,500,000 $ 1,200,000
Utility Load 'Control and
Interruptible Rates $ 3,590,160 $ 910,270
•
Total $42,677,660 $ 9,366,790
Cost per kwh in 1981 .392t/kwh
Cost per customer in 1981 $259 $56.81
* 1 Expressed in 1982 dollars
* 2 Annual carrying costs based upon 13.5% interest
Colorado -Ute Electric Association, Inc.
P. 0. Box 1149
Montrose, Colorado 81402
Telephone (303) 2494501 TWX 910-929-6924
January 11, 1982
HAND CARRIED
y Valasquez, Chairman
Garfield unty Board of Commissioners
P. 0. Box 64
Glenwood Springs, CQ_,81602
Dear Mr. Valasquez:
Application for Special Use Permit
Proposed Rifle -Battlement Mesa 138 kv Transmission Line
By letter dated October 20, 1981, Colorado -Ute made applica-
tion to Garfield County for a Special Use Permit for a proposed
138 kv transmission line from Rifle to Battlement Mesa. This
application has been placed on the agenda for the January 11, 1982
meeting of the Garfield County Planning Commission.
This letter is to withdraw Colorado-Ute's permit application.
As a result of discussions with Public Service Company of Colorado
(PSCC), Colorado -Ute now intends to provide service to its member
Holy Cross Electric Association in the Battlement Mesa area from a
new substation tapping the existing PSCC 230 kv transmission line
in the Parachute area. The reasons for this change and other
proposed joint Colorado-Ute/PSCC plans in Garfield County, will be
discussed by Mr. Raymond E. Keith, Manager of Power System and
Ecomonic Planning, at the January llth Planning Commission
meeting.
Since Colorado -Ute is withdrawing its application, I request
a refund of the $500 permit fee. If Garfield County has already
incurred significant expenses in processing our application,
please refund the unused portion.
If there are any further questions regarding the withdrawal
of this application after the January 11, 1982 meeting, please let
me know.
JRM/dcm
cc:
Flaven Cerise
Jim Drinkhouse
LD -his Farrar
Dave Howard, PSCC
Edward Grange, HCEA
Very truly yours,
e 44elti„e_o
John R. McNeill, Manager
Right -of -Way & Land Acquisition
GARFIELD COUNTY
PLANNING DEPARTMENT
GLENWOOD SPRINGS, COLORADO 81601
2014 BLAKE AVENUE
December 30, 1981
Mary Chapman
Colorado -Ute Electric Association
Box 1149
Montrose, CO 81401
PHONE 945-8212
RE: Rifle -Battlement Mesa 138kv Transmission Line Special Use Permit
Application
Dear Mary:
As indicated in previous conversations with you, the agenda for
the Garfield County Planning Commission has been such that we
are unable to hear Colorado-Ute's proposal until the Planning
Commission's first January meeting. For that reason, we are
asking Colorado -Ute to approve a 60 -day extension to accommodate
Garfield County's review. process. In the case that Colorado -
Ute is unable to agree to such a time extension, the Garfield
County Planning Department would be unable to recommend approval
of the Colorado -Ute proposal.
Please let me hear from you in regard to this request. A copy
of the Planning Commission',s January agenda will be forthcoming
shortly.
Sincerely,
Terry L. Bowman
Assistant Planner
TLB/lw
November 20, 1981
public Service Company CoRomeo
P.O. BOX 840 • DENVER, COLORADO 80201
Board of County Commissioners
Garfield County
P. 0. Box 640
Glenwood Springs, CO 81601
Gentlemen:
tROMOISE
Public Service Company of Colorado filed an application for a Special Use
Permit with the Garfield County Planning Office on November 10, 1981. The
application requests a Special Use Permit for the electric transmission and
substation system to serve the oil shale developments north of the town of
Parachute, Colorado. The planned facilities will include a 230,000 volt
transmission system and the associated substations and switching stations
required for the delivery of power to the various load centers.
The required electrical service will be provided by the Company's existing
230,000 volt Cameo -Rifle transmission line. This line will be extended to
the proposed Parachute Substation. Parachute Substation will provide the
bulk transmission facilities for the oil shale loads as well as tranfor-
mation facilities to augment the Company's local distribution system
capacity north of Interstate 70 in and around the town of Parachute. The
remaining proposed facilities include a 230,000 volt transmission line
from Parachute Substation to Wheeler Substation to Pyramid Switching
Station, from Pyramid Switching Station to Bench Substation, from Pyramid
Switching Station to Davis Switching Station, and from Davis Switching
Station to the Colony Project Plataeu Substation and to the Colony Project
Bench Substation.
Subject to the granting of the Special Use Permit, the Company will complete
the negotiations to acquire the substation sites and transmission line
easements, and required crossing permits. Public Service Company of
Colorado is a public utility authorized by State statutes to acquire pro-
perty by eminent domain (C.R.S. 1973: 38-5-105). Should negotiations
through normal procedures be unsuccessful, the Company will institute an
action in eminent domain for the purposes of acquiring the required land
rights. Preliminary discussions with the landowners indicate that such
actions will not be necessary.
Sincerely yours,
David K. Howard, Supervisor, Land Use
Electric Engineering Land Department
jc
` �I nl jAi y� Iii. 1 ` �'':
11 if,
;;•V2 19P1 III
Cl'I --1,7j.. ! COUNTY ("0.W1,.
CLAYCOMB
ENGINEERING
ASSOCIATES, INC.
November 18, 1981
Garfield County Planning Department
2014 Blake Avenue
Glenwood Springs, Colorado 81601
Attention: Mr. Davis Farrar
NODI 9 !9a
Uco
Re: Col -Ute 138KV Rifle - Battlement Mesa Transmission Line
and PSCC Upgrading of Ramsey Gulch Substation.
Job No. 1832.002
Gentlemen:
As the consulting engineers for the Bookcliff PUD, we feel there
is a real need to consolidate all utilities within the Rifle area.
Enclosed please find a copy of the approved sketch plan by the
City of Rifle and sheets 1 and 2 of a boundary survey showing all
existing utility easements across our property.
As shown on the enclosed development plan, our clients are willing
to dedicate a new 100' right-of-way easement to Col -Ute in ex-
change for abandonment of the existing 100' right-of-way and
relocation of the 69KV transmission line. It is both physically
and economically feasible for Col -Ute to place their proposed
138KV line and White River Electric Association's 69KV line
onto a common double wooden "H" frame.
We are actively pursuing relocation onto Lot PP approximating
the bottom of the bluff and south of Lots JJ, KK and II. There
will be sufficient access to this easement as we will be willing
to provide access points through our residential lots (LL, MM,
SS, and TT) and industrial lots (KK, JJ, II).
Another utility problem associated with the Bookcliff PUD involves
Public Service Company of Colorado (PSCC). PSCC is in need of
upgrading their Ramsey Gulch substation to provide service to the
Rifle area. As now located, between commercial lots UU and WW,
we do not feel the enlargement of this facility in its present
location is in the best interest of the City of Rifle, Garfield
County or the Bookcliff PUD.
SUITE 207 VILLAGE PLAZA GLENWOOI) SPRI NGS, COLORADO 81601 303.945.8676
Garfield County Planning Department
November 18, 1981
Page 2
The City of Rifle has passed a resolution to insure the develop-
ment of a regional shopping center in this vicinity within the
next three years. That fact, along with the proposed 80' right-
of-way for County Road 346 makes the existing site decidedly
unfavorable for an increase in size.
As agents for the owners of the Bookcliff PUD, we feel an
upgrade in PSCC Rifle substation should be looked at as a
viable alternative. We are also prepared to sell all or a
portion of Lot FF in our industrial area adjacent to Col -Ute
as an alternate site.
As you can see on both maps transmitted herein, Col -Ute, PSCC,
Holy Cross, Mountain Bell and Cascade Natural Gas traverse our
site. With the removal of the Ramsey Gulch substation to
another site, the PSCC line meandering across the project
could be relocated to a more advantageous position for access
and maintenance, into an easement we would dedicate along
County Road 346.
Since both PSCC and HCEA will be providing electric service
to our development, I feel Garfield County can take an active
step towards the consolidation of utilities by recommending
the relocation of Holy Cross and PSCC into common easements
where applicable.
I will be attending the public hearings for Planning and Zoning
Commission and County Commissioners. Hopefully, by working
together, we can achieve a solution to the benefit of all
parties involved.
Any questions you have may be directed to me at Claycomb Engineer-
ing.
Ernest J. Fregg .o, P.E.
Project Manager
EJF/vsg
cc: Don Macy, Cambridge Rifle Properties
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Glenwood Springs Resource Area
P.O. Box 1009
Glenwood Springs, CO 81602
November 5, 1981
Davis Farrar
Garfield County Planning Dept.
2014 Blake Ave.
Glenwood Springs, CO 81601
Dear Davis:
IN REPLY REFER TO
2850
2880
7-162
The following comments are provided in response to your request for comments
on the draft zone district definition of utilities.
Powerlines
By using a definition of electric lines based partially on voltage, and
partially on use, the definition between a transmission line and a
distribution line has become unclear. The definitions overlap, so that
a 138 kV double circuit H -frame structure providing loop feed service to
several industrial consumers becomes a distribution line, while a short,
single pole 115 kV line circumventing a town becomes a transmission line.
The former becomes a use by right, the latter a special use.
The impacts of a powerline are directly related to structure type, size,
and location. Regardless of its purpose in providing for industrial or
residential consumers, the impact of a 115 kV "transmission" line is the
same as a 115 kV "distribution" line. We would recommend the following:
a) Take out the voltage requirements in the definitions of electric
transmission lines and distribution lines.
b) Include under special uses:
All electric transmission lines 115 kV and above
All electric distribution lines 115 kV and above
c) Include under uses by right:
All electric distribution lines less than 115 kV
All electric transmission lines less than 115 kV
An alternative solution, though less flexible, would be to define all
powerlines of 115 kV voltage or above as transmission lines, and all
powerlines less than 115 kV as distribution lines. Provided that all
115 kV and above powerlines are included under special uses, we feel
that all uses have been properly designated.
GARFIELD COUNTY
PLANNING DEPARTMENT
GLENWOOD SPRINGS, COLORADO 01601
2014 BLAKE AVENUE PHONE 945-8212
November 5, 1981
George Vonesh, Jr.
Public Service Company of Colorado
550 15th Street
Denver, CO 80202
Dear Mr. Vonesh,
Garfield County has recently received application from
Colorado Ute for construction of a 138 KV transmission line
from Rifle to Parachute, Colorado. This county is very
concerned over proliferation of transmission lines which could
result from oil shale development.
We are aware that Public Service Company has a 215 KV "H"
frame transmission line on the south side of the Colorado River
from Rifle to Parachute. We would like to know if Public
Service would be interested in sharing the existing facility
with Colorado Ute for service to Parachute/Battlement Mesa.
We would also like to know if a 138 KV line could be hung on the
existing structures and what modifications would have to be
made to the structures to accommodate an additional line.
We will be requesting all utility companies with proposals
in the county to take a serious look at long range consolidation
of transmission facilities and sizing of facilities so they may
be upgraded to meet future power demands. We are very willing
to work with all of the utility companies to see that their needs
are met as well as the county's.
If you have any comments or concerns, please feel free to
contact this office.
Sincerely,
DSF/lw
Davis S. Farrar
Planner
GARFIELD COUNTY Board of County Commissioners
P.O. Box 640 Glenwood Springs, Colorado 81601 Telephone (303) 945-9158
FLAVEN J. CERISE JIM DRINKHOUSE LARRY VELASQUEZ
November 5, 1981
James Summers
Public Utilities Commission
State Services Building
1525 Sherman Street
Denver, CO 80203
Dear Sirs:
We are writing to inform you that Garfield County has recently
received application from Colorado Ute to construct a 138 KV
power transmission line from Rifle to Parachute, Colorado.
This county requires a special use permit which includes a
public hearing prior to the initiation of any construction of this
type of facility. The County Planning Department is in the process
of reviewing the application and no action has been taken at this time.
It is anticipated that the application will be reviewed by the County
Planning Commission early in December with a public hearing to
follow shortly thereafter.
Garfield County is seriously concerned over proliferation of
power transmission lines. There is a great potential for a
proliferation of transmission lines here as a result of oil shale
development. The County, through its special use review, will require
consolidation of lines and sharing of facilities where possible and
where reliability will not be impaired.
We request that the P.U.C. refrain from taking action on this
proposal until the County has completed its review process. We would like
to work with the P.U.C. to share information or answer questions. We
appreciate this opportunity to relay our concerns. If you have any
questions or comments, please contact this Board.
Sincerely,
Larry Velasquez
Chairman, Board of County Commissioners
Pipelines
Some high pressure wells may not require pumping or compressor stations
for a considerable distance from the well head. Would such a line still
be a gathering line? We would suggest that you do not use loop stress as
a limitation. The impacts of a pipeline are more closely related to the
length and width of a right-of-way (though these factors are dependent
upon the purpose and size of a pipeline). If the definition could be tied
more closely to the purpose or use of the pipeline, the delineation would
be clearer. We feel that all pipeline uses have been properly designated
as special uses or uses by right.
All other definitions appear to us to be clear and easily understood. It is
apparent that someone has put a considerable amount of effort into this
project, and we very much appreciate the work that has gone into coordination
and cooperation with all concerned parties. Thanks for the opportunity to
comment. If we can be of further assistance, please contact us.
Sincerely,
\JA\q
for___.)
Al red W. Wright
Area Manager
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TO ALL INTERESTED PERSONS, FIRMS OR CORPORATIONS:
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Colorado -Ute Electric Association, Inc.
P. 0. Box 1149
Montrosc, Colorado 81402
Telephone (303) 249-4501
Ms. Terry L. Bowman, Assistant Planner
Garfield County Planning Department
2014 Blake
Glenwood Springs, CO 81601
Dear Ms. Bowman:
TWX 910-929-6924
October 26 7'1.981
Rifle -Battlement Mesa 138 kv Transmission Line
Garfield County - Special Use Application
OCT271,9
6.
ktio
Neil Marsh and I appreciated the chance to visit with you
on Tuesday, and to present Colorado-Ute's Special Use Applica-
tion for the proposed Rifle -Battlement Mesa 138 kv Line.
It is our understanding that you will schedule a hearing
date, possibly by the end of this week. <it is our further
understanding that the utility siting guidelines that are
currently being drafted by the Garfield County Planning
Staff will not be applied to Colorado-Ute's Special Use Permit
Application
t I look forward to working with you over the months to come.
gij
1(." y
�j f I can provide any assistance, please do not hesitate to
call.
Very truly yours,
iUc iiihlapmcvyk.
Mary M. Chapman
Community Relations Specialist
MMC/dcm
�e.2)5c_
Colorado -Ute Electric Association, Inc.
P. 0. Box 1149
Montrose, Colorado 81402
Telephone (303) 249-4501 TWX 910-929-6924
October 20, 1981
HAND CARRIED
Mr. Larry Valasquez, Chairman
Garfield County Board of Commissioners
P. O. Box 640
Glenwood Springs, CO 81602
Dear Mr. Valasquez:
Application for Special Use Permit
Proposed Rifle -Battlement Mesa 138 kv Transmission Line
Colorado -Ute Electric Association, Inc. (Colorado -Ute) is a
rural electric generation and transmission cooperative associa-
tion, owned by and serving the total electric power needs of its
fourteen retail distribution cooperative members. One of
Colorado-Ute's member systems, Holy Cross Electric Association,
Inc. (Holy Cross) will be serving the new Town of Battlement Mesa.
In order to fulfill its statutory and contractual responsibilities
to meet the electrical needs of Holy Cross, Colorado Ute proposes
to construct a 138 kilovolt transmission line between Rifle and
Battlement Mesa and a 138-25 kilovolt Substation at Battlement
Mesa. This letter transmits Colorado Ute's Special Use Permit
Application for this transmission line and substation.
These facilities are needed for the following reasons:
1. Holy Cross presently serves the Battlement Mesa area by a
25 kilovolt distribution line originating at Colorado-
Ute's Rifle Substation. Development now underway at
Battlement Mesa will increase the loading on Holy Cross'
existing facilities such that they will be near or at
capacity during the winter of 1982. Completion of the
proposed transmission line will allow Holy Cross to meet
its increased electric loading requirements.
Mr. Larry Valasquez
-2- October 20, 1981
2. Alternatives to the proposed line, including constructing
additional distribution lines, or tapping the Public
Service Company of Colorado (Public Service) 230 kilovolt
line have been considered. Multiple distribution
circuits would be required to equal the capacity of the
proposed 138 kilovolt line. Energy losses are generally
much higher on lines of lesser voltage. Because of the
higher cost of a 230 kilovolt -25 kilovolt stepdown sub-
station, it is not practical to connect to the existing
230 kilovolt line every few miles to serve intervening
loads. Further, Public Service may uprate their existing
230 kilovolt line for 345 kilovolt operation, which would
further increase the cost of adding such substations.
Presently, there is no subtransmission system in the
115/138 kilovolt range between Rifle and Battlement Mesa.
Construction of the proposed line will make it possible
to create a subtransmission system to serve the Battle-
ment Mesa area, as well as other loads that may require
service, such as the proposed Rifle Ski Area.
In addition, the proposed 138 kilovolt line is capable of
providing a backup source of electrical power in the
area. Uprating of the Public Service 230 kilovolt line
would probably require that it be temporarily removed
from service. If interconnected to the Public Service
system, the proposed 138 kilovolt line could serve the
area while this work is being done.
3. The established subtransmission voltage in northwestern
Colorado is 138 kilovolts. The Western Area Power
Administration established a 138 kilovolt transmission
lines in northwestern Colorado in the early 1960's.
Shortly thereafter, Colorado -Ute constructed a subtrans-
mission system from Hayden to Montrose which has the
capability to operate at 138 kilovolts. The Hayden -
Rifle portion of this line is currently operated at 138
kilovolts including a major substation at Rifle. In
order to increase its transmission system capacity,
Colorado -Ute plans to operate the Rifle -Grand Junction
portion (presently operated at 115 kilovolts) at 138
kilovolts in the near future. Furthermore, a number of
additions to this system are in the planning and devel-
opment stages. The White River Electric Association,
Inc. (White River) recently completed a 138 kilovolt
line to the C -b oil shale tract from the Meeker Switch-
ing Station. The Moon Lake Electric Association is
serving the C -a oil shale track at 138 kilovolts. The
proposed RiEle-Battlement Mesa 138 kilovolt line would be
Mr. Larry Valasquez
-3- October 20, 1981
an important link in a system capable of serving new
loads in the Garfield and Mesa County areas west of
Rifle.
Reasons for proposal are set forth in more detail in the
enclosed impact statement for the proposed transmission line,
entitled Borrower's Environmental Report.
Two (2) copies of the Borrower's Environmental Report, which
include vicinity maps are enclosed, in compliance with Section
5.03.07 of the Garfield County Zoning Resolution. In addition, in
compliance with Section 9.03.01 of the Resolution, one set of USGS
quad sheets assembled on cardboard backing with a clear mylar
overlay attached, showing the route of the proposed line, the
names of the owners of the property crossed by the line, and other
features, is also enclosed. For your convenience, four blue -line
prints made from the mylar map are enclosed as well. The line
route is depicted as precisely as possible at this time.
Landowner negotiations may result in some minor rerouting. You
will be promptly notified of any change which may affect a new
property owner.
Also enclosed is an address list of the affected owners, a
completed application form for a special use 'permit for the
proposed 138 kilovolt line including a practical description of
the proposed route, and Colorado-Ute's check number 127954 dated
October 6, 1981, in the amount of $500.00, as required by Section
9.03.02 of the zoning resolution.
Please let me know if further information is required or de-
sired. I will be calling the Garfield County Planning Department
soon to discuss whether a meeting to review this application is
desired.
JRM/dcm
Enclosure
cc:
ven Cerise
Jim Drinkhouse
Davis Farrar
(w/o enc)
11
Very truly yours,
ohn R. McNeill, Manager
Right -of -Way & Land Acquisition
SPECIAL USE PERMIT
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Practical Description
COLORADO -UTE ELECTRIC ASSOCIATION, INC.
Proposed Rifle -Battlement Mesa 138 kv
Transmission Line
The proposed transmission line lies south of the Colorado River
and Interstate Highway and connects the existing Colorado -Ute
Rifle Substation to a new proposed Battlement Mesa Substation
south of Parachute, Colorado. Total length of the proposed line
is approximately 18 miles. The proposed line is more specifically
described as follows:
A 125 foot wide right-of-way and the area necessary to locate guy
wires beginning at the existing Colorado -Ute Rifle Substation
located in the SW1/4 SE1/4 of Section 14, Township 6 South, Range
93 West, 6th P.M., Garfield County, Colorado, THENCE southerly
approximately one-half mile into Section 23, THENCE Southwesterly
through the W1/2 of Section 23, Section 22, the S1/2 of Section
21, the NW1/4 of Section 28, the N1/2 of Section 29, Section 30,
Township 6 South, Range 93 West, THENCE continuing Southwesterly
through the S1/2 of Section 25, SW1/4 of Section 26, Section 35,
NW1/4 of Section 36, SW1/4 of Section 34, Township 6 South, Range
94 West, THENCE continuing Southwesterly through Section 3, SE1/4
of Section 4, Section 9, Section 8, Section 7, Township 7 South,
Range 94 West, THENCE continuing Westerly through Section 12,
Section 11, Southwesterly through the NW1/4 of Section 14, Section
15, SEI/4 of Section 16, Section 21, Section 20, Section 19,
Township 7 South, Range 95 West, THENCE continuing Westerly into
and terminating near the center of Section 24, Township 7 South,
Range 96 West.
RIFLE -BATTLEMENT 138 kv TRANSMISSION LINE
Landowners
1. Cambridge Rifle Properties
2. Loren Jewell and
Alvina M. Jewell
0547 352 Road
Rifle, CO 81650
625-2588
3. Grass Mesa Ranch
P. 0. Box 1599
Aspen, CO 81612
4. Pierce Mangu.rian
7101 Road 117
12. Milton Oliver Roots
11491 Ham Lane
Lodi, CA 95240
13. Wayne Payton
1820 Iroquois Road
Pueblo, CO 81001
14. George Gardner and
Sharon J. Gardner
1236 302 Road
Parachute, CO 81635
285-7648
Glenwood Springs, CO 81601
5. Verner Donn Mead and
Elma M. Mead
212 Glendale Drive
Hot Springs, AZ 71901
6. Felix S. Sefcovic
6516 County Road 301
Parachute, CO 81635
625-1918
7. Merlin T. Wagner and
Brenda F. Wagner
P. 0. Box 1472
Pascagula, MS 39567
8. John Colin Clem and
Joseph H. Clem
2862 310 Road, Box 30
Parachute, CO 81635
285-7613
9. Morrisania Ranch
Donald R. Burtrand and
Elizabeth Burtrand
0268 338 Road
Parachute, CO 81635
285-7685
10. Lena Blanche Wehr
Rt. #1, Box 17
Parachute, CO 81635
11. Kenneth G. Hagen and
Christee M. Hagen
7825 Kimberly St.
Commerce City, CO 8022
287-0827
15. Skyline Oil Corp.
2000 University Club Bldg.
Salt Lake City, UT 84111
16. Mona G. Gardner
0134 County Road 303, Box 16
Parachute, CO 81635
285-7604
17. Tosco and Battlement
Mesa Corp.
c/o Exxon Corp.
P. O. Box 53
Houston, TX 77001
18. Cache Creek Venture
P. O. Box 2694
Grand Junction, CO 81502
19. Rifle Ski Corp.
P. O. Box 472
Rifle, CO 81650
625-1533
20. John W. Savage
1122 293 Road
Rifle, CO 81650
625-1673
21. Brown Rifle Ranch Co.
2100 Colorado State
Bank Bldg.
16th & Broadway
Denver, CO 80202
WORKING PAPER
RESTRUCTURED RIFLE -SAN JUAN 345 -KV TRANSMISSION LINE
NORTHERN SECTION
1. INTRODUCTION
In February 1982, the Colorado Public Utilities Commission
(PUC) denied Colorado-Ute's application for a Certificate of
Public Convenience and
transmission line from
Necessity for a double -circuit 345-kv
Rifle, Colorado,
Based on recommendations by the PUC and
posed project was restructured, adding a
Service Company of Colorado), a new load
to San Juan, New Mexico.
other parties, the pro -
new participant (Public
center (Grand Junction),
and reducing the size of the line to single -circuit 345 kv. In
light of the restructured project, Colorado -Ute reevaluated the
alternative corridors in the northern section of the line and
eliminated from additional study the original proposed corridor,
the Rifle -North Fork -Delta -Montrose Alternative. Two other gen-
eral corridors (including eight specific corridors) for the
northern section were retained for detailed evaluation.
The purpose of this working paper is to describe and document
Colorado-Ute's preliminary screening of the general corridors for
the northern section of the proposed restructured line. The prep-
aration of this paper was recommended by the Glenwood Springs
Resource Area of the Bureau of Land Management.
-1-
2. HISTORY
The following information on the proposed Rifle -San Juan Line
clarifies certain proiect constraints and their implications with
regard to corridor selection in Mesa, Garfield, and Delta
Counties.
The Rifle -San Juan Proiect was originally proposed as a
double -circuit 345-kv transmission line to extend from Rifle to
San Juan, New Mexico. It was to be iointly owned by Colorado -Ute
and the Western Area Power Administration (Western). In February
1982, the PUC denied approval of the proiect. One of the apparent
concerns was that the northern section of the line, as it was
originally proposed, did not pass near the arowina electrical
loads in the Parachute and Grand Junction areas.
Based on a PUC request for coordinated planning among elec-
tric utilities in Garfield, Mesa, and Delta Counties (copy
attached) and the Commission's subsequent denial of a Certificate
of Public Convenience and Necessity, Colorado -Ute, Western, and
Public Service Company of Colorado (PSCo) developed a new plan.
On August 6, 1982, Colorado -Ute filed this plan with the PUC in
the form of an application seeking a Certificate of Public Conven-
ience and Necessity for a restructured, single -circuit Rifle -San
Juan Line. The segment of the line between Rifle and Grand Junc-
tion would be iointly owned by Colorado -Ute, PSCo, and Western,
-2-
with Colorado -Ute and Western each paying 37 1/2% of the cost, and
PSCo, the remaining 25%. For the remainder of the line, Colorado -
Ute and Western would each pay half of the cost. The new line
would satisfy Colorado-Ute's needs for bulk electrical transmis-
sion to its southwestern Colorado members, PSCo's needs for addi-
tional transmission capacity to its Grand Junction load center,
and Western's need for additional regional bulk transmission
capacity. PSCo's existing 230-kv line between Rifle and Grand
Junction would remain in place, serving as the Colorado River
Valley's suhtransmission system.
-3-
3. ROUTING CONSTRAINTS
Numerous constraints are weighed
transmission lines. Some of the more
to determine the routing of
important factors are:
1. The utilities participating in the line and their respec-
tive needs;
2. The locations of the load centers which must be
connected;
3. The need to develop an integrated, efficient, and reli-
able transmission network;
4. The minimization of both capital and operatina costs,
aenerally done by minimizing line length and avoiding
areas which require special, expensive enaineerina,
design, and construction; and
5. The need to avoid or minimize adverse impacts on land use
and the environment.
The relative importance attached to each constraint depends
on the unique situation of each
of PSCo as a participant in the
line. For example, the addition
Rifle -San Juan 345-kv line prosect
has added a new load center and caused the proiect to be reevalu-
ated with additional consideration being given to PSCo's needs. A
revision of the corridor analysis for the northern section of the
line has resulted. A summary of the analysis is presented in the
next section.
-4-
4. CORRIDOR AND ROUTE SELECTION
Three corridors for the northern section of the proposed line
were studied in the 1981 Environmental Analysis prepared for the
proposed double -circuit line. The first corridor generally
paralleled the Western 230-kv line from Rifle to the North Fork
area and then went west to Delta and south to Montrose. It was
Colorado-Ute's preferred corridor in the original application.
The second corridor generally followed the Colorado River Valley
between Rifle and Grand Junction and then proceeded south to Delta
and Montrose parallel to Colorado-Ute's existing 115-kv line. It
is Colorado-Ute's present preferred alternative. The third
corridor generally followed Colorado-Ute's 115-kv line for its
entire length between Rifle and Montrose, proceeding south from
Rifle, west through Collbran to Grand Junction, and then south to
Delta and Montrose. Colorado -Ute has never considered it a
preferred route.
Upon PUC denial of the original project and the subsequent
development of a new transmission plan for the area, the three
original corridors were reevaluated in light of new project
constraints. The evaluation resulted in a decision to eliminate
the original preferred corridor from further consideration. The
two remaining corridors will be analyzed further in the Supplement
to the Environmental Analysis and the Supplemental Draft
Environmental Impact Statement (SDEIS).
-5-
GENERAL CORRIDOR A: ELIMINATED FROM FURTHER STUDY
Rifle -North Fork -Delta -Montrose
plus Delta -Grand Junction Extension
General Corridor A extends south from Rifle to the Paonia
area, generally paralleling the Western 230-kv line. From Paonia
the line extends west to Delta and then south to Montrose.
Several specific variations were considered in the 1981
Environmental Analysis, although all of them were contained in the
general corridor described above.
Corridor A was Colorado-Ute's preferred corridor in the orig-
inal proposal for the double -circuit Rifle -San Juan Line,
primarily because it was the most direct route between the Rifle
and North Fork load centers. At that time, PSCo was not a
participant in the project, so there was no need for the line to
be routed to the Grand Junction area.
In order to avoid a proliferation or duplication of transmis-
sion facilities in northwestern Colorado, the Public Utilities
Commission, in September 1981, indicated that future proposals for
facilities in Rio Blanco, Garfield, Mesa, and Delta Counties must
demonstrate a "coordinated plan among all utilities which will
provide service to all Colorado ratepayers at the lowest possible
cost." In addition, the PUC Hearing Examiner and other parties
have noted the need to coordinate the Rifle -San Juan line with
PSCo service needs in the Grand Junction area. Therefore, PSCo
became a participant in the Rifle -San Juan proiect and assisted
Colorado -Ute and Western in developing a new plan, which was sub-
mitted to the PUC in August 1982. The need to serve PSCo's load
-6-
in the Grand Junction and Colorado River Valley areas became a
major constraint in routing the northern section of the proposed
line.
Implementing the Corridor A alternative would require that a
new line be constructed from either Rifle or Delta to Grand
Junction, in order to meet PSCo's need to serve the Grand Junction
area. The line likely would be 230 kv. Simply extending PSCo's
existing Rifle -Cameo 230-kv line into Grand Junction is an
unacceptable alternative because it is a radial line and would not
provide for a second method of transmitting power to Grand
Junction.
An extension from Delta, at approximately 26 miles and $6
million, would be shorter and cheaper than an extension from
Rifle. However, it would not allow for connection of possible
future oil shale loads in the Colorado River Valley, as would a
line from Rifle to Grand Junction.
Corridor A is approximately 30-40 miles longer than Corridors
B and C and would cause considerable additional environmental
impacts. See Table 1 for a comparison of the three corridors.
Corridor A would cross more than twice as much prime farmland than
either Corridor B or C. It would also cross nearly twice as much
irrigated cropland as Corridor B, though less than Corridor C.
Two more river crossings and at least three more highway crossings
would be necessary for Corridor A. In addition, Corridor A would
require establishing nearly 10 more miles of new transmission line
corridor than Corridor B, and would cross 20 more miles of
conifer -aspen vegetation than either other alternative.
-7-
Table 1
RIFLE -SAN JUAN 345-kv TRANSMISSION LINE
NORTHERN SECTION
GENERAL CORRIDOR COMPARISON
(Miles)
General Corridor A* General Corridor B General Corridor C
Total Length 145.1
Vegetation
Conifer -Aspen
Pinon-Juniper
Saltbrush-Greasewood
Mountain Shrub
Sagebrush -Grassland
Barren
Agricultural Land Use
Prime Farmland
Irrigated Cropland
Nonirrigated Cropland
Wildlife
21.5
27.7
45.9
4.5
5.7
11.6
15.4
2.7
Mule Deer and Elk Fawning 14.2
and Calving Areas
Mule Deer and Elk Critical 25.8
Winter Range
Bald Eagle Concentration Areas 38.6
107.5 116.8
1.0
54.9
30.3
4.3
4.6
8.9
3.5
17.6
40.0
39.6
lisual Absorption Capacity
Low 123.2 91.4
Medium 18.5 11.1
High 3.4 5.0
;rosion Hazaro
1.5
25.0
30.3
20.3
2.5
4.6
26.9
5.7
5.8
42.9
23.1
105.5
11.3
Low 64.2 38.9 38.1
Medium 80.9 68.6 78.7
High --
teclamation Potential
Poor 26.2 31.3 31.9
Fair 84.9 53.6 78.8
Good 34.0 22.6 6.1
,ength of New Corridor Established 44.1 36.7 --
Liver Crossings 3 1** 1
Iighway Crossings 6 2** 3
*Includes 345-kv line from Rifle -North Fork -Delta -Montrose, plus 230-kv line from
Delta -Grand Junction.
**Assumes route south of the Colorado River.
In light of the considerably longer length of Corridor A, the
resultant greater environmental impact, and the reduced capability
of serving PSCo's needs in the Grand Junction area, Corridor A has
been eliminated from further detailed consideration.
-9-
GENERAL CORRIDOR B
Rifle -Grand Junction -Delta -Montrose
General Corridor B extends from Rifle to Grand Junction
generally parallel to the Colorado River, and then from Grand
Junction to Delta to Montrose along Colorado-Ute's existing 115-kv
line. Several specific corridors within this general corridor
satisfy the constraints identified for this project, as listed in
Section 3 of this Working Paper. This Corridor enables
a substa-
tion site in Grand Junction; thus Public Service Company's needs
can be met without building another transmission line. This
alternative also satisfies the PUC's requirement for a coordinated
system.
In
addition, General Corridor B allows for a
connection of PSCo's 230-kv system with the Rifle -San
line at several points along the Colorado River, such
direct
Juan 345-kv
as Parachute,
DeBeque, or Cameo, negating the need for additional lengthy trans-
mission lines. Such connections may be desirable in the future if
oil shale loads grow. A general environmental comparison of
Corridor B with the other corridors is presented in Table 1.
Colorado -Ute therefore designated General Corridor B for
further study in the Supplement to the Environmental Analysis and
SDEIS. Through discussions with BLM and other affected parties,
Colorado -Ute has indentified 4 specific corridors within the
General Corridor B for detailed study. The section extending from
Grand Junction to Delta to Montrose is the same in all cases.
-10-
The four specific corridors are:
1. Parallel the PSCo 230-kv line its entire length to south
of Cameo, then proceed south to the intersection with the
Colorado -Ute Collbran-Grand Junction 138/115-kv line and
parallel that line to Grand Junction;
2. Proceed west from the Rifle Substation, cross the
Colorado River and I-70 west of Rifle and parallel I-70
on its north side to lust east of DeBeque, cross 1-70 and
the river again and follow Specific Corridor 1 for the
rest of the line;
3. Proceed southwest from the Rifle Substation at the base
of the foothills lust north of the white River National
Forest until Battlement Mesa, from which point the line
would parallel the PSCo 230 line and proceed the same as
Specific Corridor 1; and
4. Proceed southwest from the Rifle Substation at the base
of the foothills just north of the White River National
Forest to south of DeBeque, where the line would loin the
PSCo 230 line and proceed the same as Specific Corridor 1.
One other alternative corridor, continuing north of the Colorado
River west of DeBeque and into PSCo's Cameo Generating Station, was
determined not feasible. Routing around DeBeque and its adioininq
farmlands would be difficult and lengthy. The high terrain lust
-11-
north of DeBeque Canyon is extremely rugged and has very little
access. BLM's Little Bookcliffs Wilderness Study Area effectively
blocks a transmission corridor approach to Cameo from the north.
For these reasons, this specific corridor was eliminated from
further study.
Each of these four corridors will be fully addressed in the
Supplement to the Environmental Analysis and the SDEIS. The
approach to the analysis is discussed in Section 5 of this Working
Paper.
-12-
GENERAL CORRIDOR C
Rifle-Collbran-Grand Junction -Delta -Montrose
General Corridor C proceeds south from the Rifle Substation
generally paralleling the Colorado -Ute 138/115-kv line through
Collbran to Grand Junction, and then the 115-kv line south to
Delta and Montrose.
This general corridor meets the constraints for routing the
Rifle -San Juan Line. It serves the same load centers as the
Corridor B; it generally avoids environmental constraints, and
parallels existing lines for its entire length. On the surface,
it has two drawbacks; it is about 10 miles (10%) longer than
General Corridor B and it would not allow a direct connection of
PSCo's 230-kv line with the 345-kv line in the Colorado River
Valley without lengthy additional transmission lines. At some
time PSCo may desire to link the 345-kv and 230-kv systems at
Parachute or DeBeque to support the oil shale loads which are now
served solely by the 230-kv system. However, since it meets the
present constraints for the Rifle -San Juan Line, General Corridor
C is retained as an alternative for full analysis in the Supple-
ment to the Environmental Analysis and the SDEIS. A general
environmental comparison of Corridor C and the other corridors is
presented in Table 1.
-13-
Four specific corridors within this general corridor are
investigated in the Supplement to the Environmental Analysis and
Draft EIS. They are all very similar, the only difference being
the way they proceed south after exiting the Rifle Substation.
Each would follow either the existing Colorado -Ute 138/115-kv line
or the existing Western 230-kv line; the variations are determined
by how far the route would parallel one or the other of the
existing lines. Once turning to the west,
Colorado -Ute 138/115-kv line past Collbran
then the Colorado -Ute 115-kv line south to
-14-
all would parallel the
to Grand Junction, and
Delta and Montrose.
5. ANALYSIS
For the Supplement to the Environmental Analysis and the
SDEIS, the environmental information is being organized into a set
of environmental profiles which indicate:
o construction and maintenance limitations
o erosion hazards
o reclamation potential
o geologic hazard potential
o vegetative communities
o threatened and endangered fauna
o large mammals
o human resources
o cultural resources
o visual absorption capacity
o visual sensitivity
c land ownership
o mineral resource areas
o agricultural areas
o commercial forests
o recreational resources
o adjacent existing lines
o adjacent highways
-15-
These profiles have recently been completed. The information
is being analyzed using an impact evaluation methodology designed
to evaluate the advantages and disadvantages of each corridor.
The method is an adaptation of a similar procedure used by the
U.S. Bureau of Land Management (Richfield, Utah District) in the
Moon Lake Proiect. The methodology allows numerical values to be
derived for the overall potential impact along each route. The
impact scores which result are then used to make direct compari-
sons of parameters between alternative corridors. Once these
analyses have been performed, other factors such as engineering
constraints, costs, public, and agency input, will be incorporated
into the decision-making process and a preferred corridor will be
selected.
-16-
^t ..•-
- PU"oMISSIO,N
ai11D__oar;.•nen(drRzgulatbiy CZencies
`r_.v F.7:e.Ser:•ite5c.•ildi-� r� .
1523 Sherman Street "
Denver, Colorado 80203
:,-•.03.13 3 it -en
-r-Y• , ..
J a V
TATE OF -11,,,C,1 29.
:,mac.••
John J. Bugas, General Manager • .•
-
Colorado -Ute Electric Association, Inc.
P. 0.• Box 1149 _
Montrose, CO 81401
Dear Mr. Bubas:
Richard D. Lamm.
Governor .
WeUineton L Webb,
:. Eaeculi,e Dire^.or
....
comAissioNEas:
• Edvihe S. bluer,
▪ Daniel F- Muse
L Duane Woodard
-[ Harn & Cailiean. p -
Executive Secretary .
Adminlnraiion ()03) 364
Transportation (1031 ese
Fixed U:ihties {303) 86E -
Counsel (303) :So -3R5
As you know, the Commission has had a continuing concern with the construction
requirements of its utilities, particularly as they are impacted by the energy
related developments in the western Colorado Counties of Rio Blanco, Garfield,
Mesa and Delta. ' . . . .
It appears that there exists the possibility of uncoordinated planning for constrt
tion of electric facilities in these counties. This potential problem is a matter
of great concern to the Commission as duplication of facilities, and therefore
expenditures for construction, would create a burden for existing ratepayers.
Therefore, the Commission is requesting that the management of the utilities
• operating in these particular counties of.. Western Colorado file applications for._^
Certificates of Public Convenience and Necessity for all generation, and for any
transmission lines or transmission substations built in these counties. -.Applica-
tions should be filed for new construction or for the upgrading or Uprating of
existing facilities, for initial or -possible ultimate operation at a voltage level
of,115 KV or greater. •The Commission will review these applications with the
utmost care for.a demonstrated coordinated plan among all utilities which will
. provide service to all Colorado electric ratepayers at the lowest possible cost.
Very truly yours,
EDYTHE sJJP1iLLER, CHAIRWOMAN
O:•NIDE t. MUSE, CO MiSSIGNER
L. DUANE WOODARD, COMMISSIONER
•
CC: Rio Blanco County Comalissioners
Garfield County Commissioners
tee