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HomeMy WebLinkAbout20193043.tiffLAND USE APPLICATION SUMMARY SHEET Planner: Chris Gathman Case Number: USR18-0100 Hearing Date: June 18, 2019 Applicant: Public Service Company of Colorado, do Larry Claxton Address: 1800 Larimer Street, Suite 400, Denver, Colorado 80202 Request: A Site Specific Development Plan and Use by Special Review Permit for A Major Facility of a Public Utility (One (1) 230 kV Transmission line extending approximately 10.4 miles, one (1) new substation (Graham Creek) and upgrades to an existing substation Western Area Power Administration (WAPA) Ault Substation in the A (Agricultural) Zone District. Legal Description: Transmission line to be located in Sections 2, 3, 4, 5, 6, 10, 15, 22, 26, 27 and 35 T7N R66W of the 6th P.M. Weld County Colorado Location: Transmission Line is in two Sections: Segment 1 runs from the WAPA Ault Substation located south of County Road 86 and east of County Road 25 to the proposed Husky Substation (within the Town Limits of Ault). The Husky Substation will be located east of County Road 33 and south of County Road 86. Segment 2 runs from the Husky Substation site (east of County Road 33 and south of County Road 86) to the proposed Graham Creek Substation site located east of and adjacent to County Road 33 and approximately 1/2 mile north of County Road 74. Parcel Numbers: Multiple Size of Parcel: Transmission Line: N/A Graham Creek Substation site: +/- 11 acres POSSIBLE ISSUES SUMMARIZED FROM APPLICATION MATERIALS The criteria for review of this Special Review Permit is listed in Chapter 21 of the Weld County Code The Department of Planning Services' staff has received responses with comments from the following agencies: • • • Weld County Department of Public Works, referral dated May 22, 2019 Colorado Department of Transportation, referral dated October 24, 2018 Weld County Department of Public Health and Environment, referral dated October 30, 2018 Federation Aviation Administration, referral dated October 4, 2018 Town of Eaton, referral form and response dated May 20, 2019 New Cache La Poudre Irrigating Company, referral dated November 5, 2018 Weld County Office of Emergency Management, referral dated October 4, 2018 Water Supply and Storage Company, referral letter from Sara J.L. Irby - Fischer, Brown, Bartlett USR18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 1 • • • • • • & Gunn dated November 1, 2018 The Pierce Lateral Ditch Company, referral letter from Sara J.L. Irby - Fischer, Brown, Bartlett & Gunn dated November 1, 2018 The Collins Lateral Ditch Company, referral dated from Sara J.L. Irby - Fischer, Brown, Bartlett & Gunn dated November 1, 2018 New Cache La Poudre Irrigation Company, referral from Sara J.L. Irby - Fischer, Brown, Bartlett & Gunn dated November 1, 2018 SRC Energy, referral dated October 4, 2018 Larimer & Weld Irrigation Company, referral dated October 31, 2018 and referral letter dated November 1, 2018 Mead Lateral, referral dated November 16, 2018 The Department of Planning Services' staff has received responses without comments from the following agencies: • Weld County Zoning Compliance, referral dated April 25, 2019 • Public Safety Wireless Communications Manager, referral dated April 30, 2019 • RE -2 School District, referral dated October 8, 2018 • RE -9 School District, referral dated May 19, 2019 • Weld County Sheriff's Office, referral dated October 15, 2018 • Town of Pierce, referral dated May 22, 2019 • North Weld County Water District, referral dated May 20, 2019 • Western Area Power Administration (WAPA), referral dated May 13, 2019 • PDC Energy, referral dated April 30, 2019 The Department of Planning Services' staff has not received responses from the following agencies: Colorado Parks & Wildlife History Colorado US Army Corps of Engineers Town of Severance Farm Services Administration Ault Fire Protection District Eaton Fire Protection District • North Weld County Water District • Comcast • Century Link • Atmos Energy • Bayswater Exploration & Production • Extraction Oil & Gas • Great Western Operating Company • Noble Energy • Snyder Oil • Petit Lateral • Leaf Waste Ditch • Eaton Ditch • Graham Seep Ditch • Greeley Soil Conservation District • Great Western Railroad U5R18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 2 SPECIAL REVIEW PERMIT ADMINISTRATIVE REVIEW Planner: C. Gathman Case Number: USR18-0100 Hearing Date: June 18, 2019 Applicant: Public Service Company of Colorado, do Larry Claxton Address: 1800 Larimer Street, Suite 400, Denver, Colorado 80202 Request: A Site Specific Development Plan and Use by Special Review Permit for A Major Facility of a Public Utility (One (1) 230 kV Transmission line extending approximately 10.4 miles, one (1) new substation (Graham Creek) and upgrades to an existing substation (WAPA Ault Substation) in the A (Agricultural) Zone District. Legal Description: Transmission line to be located in Sections 2, 3, 4, 5, 6, 10, 15, 22, 26, 27 and 35 T7N R66W of the 6th P.M. Weld County Colorado Location: Transmission Line is in two Sections: Segment 1 runs from the WAPA Ault Substation located south of County Road 86 and east of County Road 25 to the proposed Husky Substation (within the Town Limits of Ault). The Husky Substation will be located east of County Road 33 and south of County Road 86. Segment 2 runs from the Husky Substation site (east of County Road 33 and south of County Road 86) to the proposed Graham Creek Substation site located east of and adjacent to County Road 33 and approximately 1/2 mile north of County Road 74. Parcel Numbers: Multiple Size of Parcel: Transmission Line: N/A Graham Creek Substation site: +/- 11 acres Narrative: The applicant is proposing a new electric transmission line and substation in Weld County. The proposed overall project consists of a new overhead, double -circuit 230 kV transmission lines and two new substations (one of which will be in the Town of Ault). The proposed transmission line will be approximately 10.4 miles in length. The transmission line will be in two (2) segments. The transmission line is proposed to originate at the (Western Area Power Administration) WAPA (located just to the west of County Road 27 between County Roads 84 and 86) and will run to the proposed Graham Creek Substation located west of and adjacent to County Road 33 and approximately 1/2 mile north of County Road 74. The transmission line will be constructed using double -circuit, single -pole self-supporting steel structures. The structures will range in height from 80 to 130 feet. U5R18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 3 The new substation proposed is the Graham Creek substation is located east of and adjacent to County Road 33 and south of County Road 76. The applicant is proposing to purchase the substation site (the site is approximately 11 acres in size) and is applying for a recorded exemption for the substation site in conjunction with this application. The Graham Creek substation would replace the existing Eaton substation which is located entirely within the municipal limits of the Town of Eaton and is immediately adjacent to existing residential development. The application indicates the primary objective of the project is to replace the existing, antiquated and non-standard 44kV power system in northern Weld County. The project is designed to increase safety, reliability, load -serving capability and generation accommodation (including the towns of Ault and Eaton). Note: The applicant originally applied for a 21 -mile transmission line in three segments that would extend from the WAPA to the Graham Creek substation to the Cloverly Substation approximately 1/2 mile south of County Road 66 and east of County Road 43. This application has been revised to include the 10.4 -mile segment. This is a stand-alone application. Before submitting the revised application, the applicant indicated that if approved, they would proceed with building the 10.4 -mile segment and Graham Creek substation. They would proceed regardless of whether a transmission line extension from the Graham Creek substation to the Cloverly substation is ever applied for, reviewed and approved. Referral agencies who commented on areas within this 10.4 -mile segment (under the original application) are listed in this recommendation in addition to referral comments that have been subsequently received. If or when the applicant decides to apply for an extension from the Graham Creek substation to the Cloverly substation — it will be reviewed under a separate 1041 application. THE DEPARTMENT OF PLANNING SERVICES' STAFF RECOMMENDS THAT THIS REQUEST BE APPROVED FOR THE FOLLOWING REASONS: 1. The submitted materials are in compliance with the application requirements of Chapter 21 of the Weld County Code 2. It is the opinion of the Department of Planning Services' staff that the applicant has shown compliance with Section 21-3-340. A of the Weld County Code, as follows: Section 21-3-340.A.1 — The health, welfare and safety of the citizens of the County will be protected and served. The application indicates that the proposed transmission system will replace the existing aging 44kV infrastructure with higher voltage facilities. The existing system is one of the oldest transmission assets owned by Public Service of Colorado (dating to the early 1900s). The application indicates that Public Service has and will continue to have safety and reliability issues with the existing 44kV transmission system resulting in power interruptions and reduced reliability. Section 21 -3 -340.A.2 -The natural and socio-economic environment of the County will be protected and enhanced. The proposed transmission line and substation will result in more reliable power and greater power generation capacity for the region and for agricultural, residential, commercial and industrial uses. The proposed transmission line and substation will not cross or be located within a floodplain. The application has provided avoidance and mitigation measures to protect wildlife species and habitats. The applicant conducted a transmission and substation routing and siting study and determined a preferred route location that reduces impacts to existing cropland and irrigated cropland structures as much as possible while avoiding existing residences and oil and gas facilities to the extent practicable. Section 21-3-340.A.3 -- All reasonable alternatives to the proposed action, including use of existing rights -of -way and joint use of rights -of -way wherever uses are compatible, have been adequately assessed and the proposed action is compatible with and represents the best interests of the people of the County and represents a fair and reasonable utilization of resources in the impact area. U5R18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 4 Transmission line and substation alternatives were evaluated to address the project needs. The applicant has presented a transmission routing and substation siting study with the application. The application indicates that potential routes were studied from January 2016 to May 2018 to identify substation sites and to also identify a preferred route between substations that minimized impacts to the greatest extent practicable. During this process opportunity areas (most desirable), sensitive areas and constraint areas (least desirable) where identified for different land use types, natural resources and engineering criteria in an opportunities and constraints matrix. For example, agricultural land uses were ranked from rangeland/uncultivated (most desirable) to cultivated lands (less desirable) to center pivot and drip irrigation systems. Potential substation sites and transmission routes were contemplated and then defined using the opportunities and constraints matrix to the extent possible. In addition to the opportunities and constraints matrix the location of preliminary substation sites and where determined by the ability to cost effectively connect substations and serve load centers. Three (3) public meetings were held: 10/25/2017 in Ault, 1/24/2018 and 5/16/2018 in Eaton. The purpose of these meetings was to introduce the project, aid in refining the evaluation criteria in the Siting study, refine transmission route alternatives through community comments and to identify additional issues that permit applications should address. A total of twelve (12) people attended the 10/25 meeting, seventy-three (73) people attended the 1/24 meeting and fifty-eight (58) people attended the 5/16 meeting. Comments were submitted via hardy copy, e -mails and electronically. Primary concerns and comments were identified including (but not limited to) proximity to residences, health and safety, noise and land use. Through the review of community plans (comp plans), future land use maps and public input criteria category were identified to evaluate potential impacts of the project. Within each category measurable parameters where determined to allow a comparison of alternative routes and substations to each other. For example, in the transmission corridor evaluation criteria for agricultural lands factors such as number of pivot irrigation systems potentially affected by the project and number of transmission structures through cultivated land. A total of six (6) substation sites where evaluated near the town of Eaton and the Graham Creek substation site was decided as the preferred site. The Graham Creek substation site has a lower number of residences in proximity to it (within 0.25 miles), is outside of the floodplain, will not be near existing oil and gas production facilities and the layout of the site will allow for the existing pivot onsite to keep operating. Once the substation sites and alternative transmission routes were evaluated to meet electrical system needs while considering land use and environmental factors, including: Avoid removal of residences; Minimize the number of pivot and drip irrigation systems potentially affected; Minimize distance through established residential areas and proximity to individual residences A total of three (3) alternative routes were evaluated for the WAPA Ault substation to Husky substation section and three (3) alternatives for the Husky substation to Graham Creek Substation section. WAPA Ault substation to Husky Substation: The applicant is proposing the preferred alternative because based on the evaluation criteria it has the lowest impact on agricultural lands and has fewer residences within 0.25 mile of the transmission line. Husky Substation to Graham Creek Substation: VSR18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 5 The applicant is proposing the preferred alternative because it has the lowest number of residences both within 0.25 mile and within 200 feet of the transmission route. The alternatives have similar evaluations levels when it comes to distance through cultivated irrigated land. The transmission corridor shown is 500 -feet wide to allow for site adjustment of the transmission line within the corridor where needed. Section 21 -3 -340.A.4 --A satisfactory program to mitigate and minimize adverse impacts has been presented. The applicant developed criteria to evaluate impacts upon existing or planned agricultural, Commercial/Industrial and residential uses and natural resources. These criteria (in addition to engineering criteria such as the ability to connect substations and serve load centers) were used to review alternative substation locations and alternative power line locations. The applicant utilized these criteria to evaluate and select the preferred substation and transmission line. Additionally, the applicant has proposed environmental protection measures to mitigate impacts during construction including reseeding areas disturbed during construction and requiring that no construction activities occur when soil is too wet to adequate support equipment and vehicles. Section 21 -3 -340.A.5 --The nature and location or expansion of the facility complies with all applicable provisions of the master plan of this County, and other applicable regional, metropolitan, state and national plans. Section 23-3-40 A P. Goal 1 states: "Promote efficient and cost-effective delivery of public facilities and services." The proposed substation and transmission lines will result in more reliable electricity for existing development and additional capacity for future development. Section 23-3-40 B. P. Goal 2 states: "Require adequate facilities and services to assure the health, safety and welfare of the present and future residents of the County."The proposed facilities will provide more reliable electricity and additional electrical capacity. Section 22-6-20 A. ECON.Policy 1.3 states: "Maintain and improve basic County services and infrastructure, in order to ensure that the County is a viable candidate for attracting businesses, labor and capital." The proposed facilities would provide electrical capacity and viability for future business and labor opportunities. Section 22-2-40 UD.Goal 5. States: "The County and municipalities should strive to coordinate urban land use planning in cooperative planning areas, including such items as development policies and standards, zoning, street and highway construction, open space, public infrastructure and other matters associated with urban development." The Town of Eaton, in their referral dated May 20, 2019 is opposes this request. The referral response states that the location of the Graham Creek substation will increase the likelihood that transmission lines are paces on the west and south side of Eaton undermining the Town's efforts and impeding its growth potential. It states that the failure to include the transmission line segment from the Graham Creek Substation to the Cloverly Substation (north of the Greeley -Weld Airport) in this application makes this project not operative or functional. Additionally, the Town of Eaton states that they would prefer the Graham Creek #3 alternative (located adjacent to the southeastern boundary of Eaton) as it is near of existing industrial uses and would blend in with the surrounding area. Eaton states that the difference between the Graham Creek #3 and Graham Creek #1 alternative is too slight to support the long-term decision as to where to locate the Graham Creek substation. The applicant has indicated that (if approved) they would construct the proposed transmission line segments and the Graham Creek substation. It is a stand-alone application and is not contingent upon application or approval of any future transmission line segments. USR18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 6 The proposed transmission line route and proposed Graham Creek substation are located outside of the Cooperative Planning Agreement boundary between Weld County and the Town of Eaton. The proposed Graham Creek substation is located approximately 0.75 mile to the west of the municipal boundaries of the Town of Eaton and the Eaton Area Community Center. The proposed preferred transmission line route is located 0.5 miles to the east of the municipal limits of Eaton and the Eaton Area Community Center. The preferred transmission line route and Graham Creek Substation are also located 0.5 and 0.75 miles west of and outside of the 2018 Comprehensive Plan land use map for the Town of Eaton. The proposed substation site is located approximately 100 -feet to the north of the Great Western Trail. Because of the proximity of the substation to the trail and community center, a condition of approval is attached requiring a screening plan to be submitted and approved for the Graham Creek substation component. Section 21-3-340.A.6 --The nature and location or expansion of the facility does not unduly or unreasonably impact existing community services. The proposed transmission line and substation will not unduly or unreasonably impact community services. No referral comments have been received from the Ault and Eaton Fire Protection Districts regarding this application. Section 21 -3 -340.A.7 --The nature and location or expansion of the facility will not create an expansion of the demand for government services beyond the reasonable capacity of the community or region to provide such services, as determined by the Board of County Commissioners. The proposed USR is meant to upgrade an outdated and unreliable electrical transmission system with a newer system better capable to handle the existing electrical load and future growth in the region. Section 21-3-340.A.8-- The facility site or expansion area is not in an area with general meteorological and climatological conditions which would unreasonably interfere with or obstruct normal operations and maintenance. The proposed powerline and substation are proposed to replace an existing aging power infrastructure in the same area. The general meteorological and climatological conditions are consistent with this area of Northern Colorado and will not unreasonably interfere with or obstruct normal operations and maintenance. Section 21 -3 -340.A.9 --The nature and location of the facility or expansion will not adversely affect the water rights of any upstream, downstream or agricultural users, adjacent communities or other water users. No long-term use of water will be required for the on -going operation of the transmission line or substations. The application indicates that water utilized during construction of the project (for foundations and dust control) will be brought in from off -site sources (from a private well owned by a construction water company or by municipality). Section 21 -3 -340.A.10 --Adequate water supplies are available for facility needs. The substation and transmission line facilities are unmanned. Bottled water and screened portable toilets will be provided during construction. Section 21-3-340.A.11— The nature and location of the facility or expansion will not unduly interfere with existing easements, rights -of -way, other utilities, canals, mineral claims or roads. A letter was received from Fischer, Brown, Bartlett and Gunn, PC dated 11/1/2018 on behalf of Collins Lateral, Pierce Lateral Ditch and Larimer County Canal (New Cache La Poudre — Greeley No. 2 is also mentioned but is not crossed by this proposed transmission line according to County records and application materials). This letter requests that any encroachment within the ditches and ditch easements shall not be allowed without the ditch's prior written permission. A condition of approval is attached requiring an agreement or other acceptable form of authorization if any transmission structure and/or construction easements encroach into ditch rights -of -way. USR18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 7 Section 21 -3 -340.A.12 --Adequate electric, gas, telephone, water, sewage and other utilities exist or shall be developed to service the site. This is an unmanned facility. Section 21 -3 -340.A.13 -The nature and location for expansion of the facility will not unduly interfere with any significant wildlife habitat or adversely affect any endangered wildlife species, unique natural resource or historic landmark within the impact area. A biological reconnaissance survey of the WAPA Ault substation was conducted in December 2017 and a raptor nest survey report was conducted in 2016. Also, an inventory of cultural resources was conducted. The application states that no designated or high -quality habitat areas will be impacted by the project. A pre -construction nest survey for raptors and other avian species would be conducted no sooner no more than one week prior to disturbance. If any nests are observed pre -construction surveys and monitoring would be coordinated with Colorado Parks and Wildlife and U.S. Fish and Wildlife Service. The application indicates should previously unknown historic/prehistoric sites or artifacts be encountered during construction, all land altering at the location will be suspended until the proper authorities are notified and appropriate measures taken to assure compliance with the National Historic Preservation Act and enabling legislation. No referral response has been received from Colorado Parks and Wildlife and History Colorado regarding this application. Section 21-3-340.A.14 — The nature and location or expansion of the facility, including expected growth and development related to the operation and provision of service, will not significantly deteriorate water or air quality in the impact area. Prior to construction, a Storm Water Permit for Construction Activities (SWMP) permit will be obtained from the Colorado Department of Public Health and Environment (CDPHE) and best management practices (BMPs) to minimize impacts to surface and groundwater. Project construction is anticipated to last 24 to 36 months. Air pollutants generated are anticipated to be short-term and minimized by the small scale of the construction (excavating foundations for the substation and transmission structures). Air pollutants would be minimized through dust suppression measures and proper maintenance of construction vehicles. Section 21-3-340.A.15 — The geological and topographic features of the site are adequate for all construction, clearing, grading, drainage, vegetation and other needs of the facility construction or expansion. The proposed facility is not located within a geologic hazard area. The transmission structures and substation will be designed to accommodate the geotechnical and soil conditions in the area. Section 21-3-340.A.16 — The existing water quality of affected state waters will not be degraded below state and federal standards or established baseline levels. The applicant will submit a SWMP plan for the proposed facilities. BMPs will be implemented to prevent contaminants from construction activities (including fuel, cement, refuse) from flowing into water courses and underground water sources. Water and eroded materials from construction activities shall be prevented from entering streams or watercourses by constructing barriers, bypass channels or other acceptable methods. Section 21-3-340.A.17 — The proposed project will not have a significantly adverse net effect on the capacities or functioning of streams, lakes and reservoirs in the impact area, nor on the permeability, volume, recharge capability and depth of aquifers in the impact area. The proposed transmission line and substation will not result in any direct discharge and disturbance to any streams, lakes or reservoirs. USR18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 8 Section 21-3-340.A.18 — The benefits of the proposed developments outweigh the losses of any natural resources or reduction of productivity of agricultural lands as a result of the proposed development. The application indicates that the 230kV transmission facility will replace the existing aging 44kV infrastructure with higher voltage facilities. The existing system is one of the oldest transmission assets owned by Public Service of Colorado (dating to the early 1900s). The application indicates that Public Service has and will continue to have safety and reliability issues with the existing 44kV transmission system resulting in power interruptions and reduced reliability for the area. The area that this transmission line serves has grown extensively (and continues to grow) and the upgraded transmission line will result in a more reliable and safe power source for the region. The applicant has presented a transmission routing and substation siting study with the application. The application indicates that potential routes were studied from January 2016 to May 2018 to identify substation sites and to also identify a preferred route between substations that minimized impacts to the greatest extent practicable. During this process opportunity areas (most desirable), sensitive areas and constraint areas (least desirable) where identified for different land use types, natural resources and engineering criteria in an opportunities and constraints matrix. For example, agricultural land uses were ranked from rangeland/uncultivated (most desirable) to cultivated lands (less desirable) to center pivot and drip irrigation systems. Potential substation sites and transmission routes were contemplated and then defined using the opportunities and constraints matrix to the extent possible. In addition to the opportunities and constraints matrix the location of preliminary substation sites and were determined by the ability to connect substations and serve load centers. A letter of objection was received regarding the proposed preferred route from the WAPA substation to the proposed Husky substation. The letter dated May 21, 2019, from Fischer, Bartlett, Brown and Gunn P.C. on behalf of Keith Amen asserts that the proposed transmission line will impact and potentially disable (without extensive modifications) the existing irrigation system on the property and impact irrigation supply to the Meisner property to the south. A total of three proposed transmission line were evaluated for this WAPA to Husky transmission line segment. The preferred transmission line route is identified as having the least amount of structures crossing cultivated land (along the edge of a property boundary). The evaluation also indicated that the number of residences between 200-0.25 miles of the proposed transmission line is considerably less for the preferred alternative (7) than the for the other two alternatives (16 and 22 respectively). The proposed Graham Creek substation is located on a non -irrigated corner of an irrigated agricultural parcel. Section 21-3-340.A.19 — The applicant has obtained or will obtain all property rights, permits and approvals necessary for the proposed project, including surface, mineral and water rights and easements for drainage, disposal, utilities, access, etc. If the applicant has not obtained all necessary property rights, permits and approvals, the Board may, at its discretion, grant the permit conditioned upon completion of the acquisition of such rights prior to issuance of a zoning or building permit by the County. Transmission line crossing agreements and ditch crossing agreements (if applicable) are required as a condition of approval for this case. Section 21-3-340.A.20 — The proposed project (nonlinear facilities) will not present an unreasonable risk of exposure to or release of toxic or hazardous substances within the impact area. The determination of effects of the project shall include the following considerations: The means by which outdoor storage facilities for fuel, raw materials, equipment and related items are adequately enclosed by a fence or wall. VSR18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 9 The likelihood of hazardous materials or wastes being moved off the site by natural causes or forces. Containment of inflammable or explosive liquids, solids or gases. This criterion is not applicable to the transmission line as it is a linear facility. The substation will does not include the storage of toxic or hazardous substances. Section 21-3-340.A.21 — The scope and nature of the proposed project will not unnecessarily duplicate existing services within the County. The proposed transmission line and substation will not duplicate existing services in the county. The applicant proposes to replace an aging, unreliable electric transmission system with a newer system more able to cope with existing demand and handle future growth. Section 21-3-340.A.22 — If the purpose and need for the proposed project are to meet the needs of an increasing population within the County, the area and community development plans and population trends demonstrate clearly a need for such development. The proposed USR will upgrade the existing electrical transmission system in the region that dates to the early 1900's. The region has experienced considerable population growth since the transmission line was originally built. The application indicates that Public Service has and will continue to have safety and reliability issues with the existing 44kV transmission system resulting in power interruptions and reduced reliability. This recommendation for One (1) 230 kV Transmission line extending approximately 10.4 miles, one (1) new substation (Graham Creek) and upgrades to an existing substation (WAPA Ault Substation) a is based, in part, upon a review of the application materials submitted by the applicant, other relevant information regarding the request, and responses from referral entities. The Department of Planning Services' staff recommendation for approval is conditional upon the following: 1. Prior to recording the map: A. A Road Maintenance Agreement is required at this location. Road maintenance includes, but is not limited to, dust control and damage repair to specified haul routes. (Department of Public Works) B. A Final Drainage Report and Certification of Compliance stamped and signed by a Professional Engineer registered in the State of Colorado is required for the Graham Creek Substation portion of this USR. (Department of Public Works) C. If applicable, the applicant shall submit a recorded copy of any agreement signed by all of the owners of the property crossed by the access. The access shall be for ingress, egress, utilities and shall be referenced on the USR map by the Weld County Clerk and Recorder's Reception number. (Department of Public Works) D. A copy of the signed and recorded (construction and post -construction) easement agreements (or other acceptable authorization from property owners) shall be submitted to the Department of Planning Services. (Department of Planning Services) E. A copy of signed and recorded ditch crossing agreements (or other acceptable authorization) from ditch rights -of -way encroached upon by the transmission line towers or construction easements shall be provided to the Department of Planning Services. (Department of Planning Services) F. A screening plan shall be submitted and approved by the Department of Planning Services for the Graham Creek substation site. The Screening Plan shall consist of USR18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 10 solid opaque fencing and/or solid vegetative screening. If landscaping is proposed, an irrigation plan shall be submitted for review and approval by the Department of Planning Services. (Department of Planning Services) 2. The map shall be amended to delineate the following: 1. All sheets of the map shall be labeled USR18-0100. (Department of Planning Services) 2. The map shall be prepared in accordance with Section 23-2-260.D of the Weld County Code. (Department of Planning Services) 3. The attached Development Standards. (Department of Planning Services) 4. The final location of the permanent 100 to 150 -foot transmission line easement with dimension of permanent right-of-way, property ownership, parcel number, all easements of record, and all physical encumbrances. (Department of Planning Services) 5. County Road 27 is an unmaintained section line right-of-way. The applicant shall verify and delineate on the map the unmaintained right-of-way and the documents creating the right-of-way. All setbacks shall be measured from the edge of right-of- way. This road is not maintained by Weld County. Any unmaintained road needs to be located/identified in relationship to the right-of-way. Show and label the section line Right -of -Way as "CR 27 Section Line Right-of-way, not County maintained". (Department of Public Works) 6. County Roads 31 and 86 are gravel roads and are designated on the Weld County Functional Classification Map as local roads which require 60 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the future and existing rights -of -way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) 7. County Road 29 in this location is designated on the Weld County Functional Classification Map as an arterial road which in this location requires 100 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the existing right-of-way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) 8. County Road 33 is a paved road and is designated on the Weld County Functional Classification Map as a collector road which require 80 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the existing rights -of -way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) 9. County Road 84 is a gravel road and is designated on the Weld County Functional Classification Map as a local road which requires 60 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the existing right-of-way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) 10. County Road 78 and 80 are unmaintained section line rights -of -way at the locations impacted by the project's alignment. The applicant shall verify and delineate on the map the unmaintained rights -of -way and the documents creating the rights -of -way. All setbacks shall be measured from the edge of right-of-way. These roads are not USR18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 11 maintained by Weld County. Any unmaintained road needs to be located/identified in relationship to the right-of-way. Show and label the section line Rights -of -Way as "CR 78 Section Line Right-of-way, not County maintained" or "CR 80 Section Line Right-of-way, not County maintained" as appropriate. (Department of Public Works) 11. County Road 39 is a paved road and is designated on the Weld County Functional Classification Map as a local road which requires 60 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the existing right-of-way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) 12. Show and label the approved access locations, approved access width and the appropriate turning radii on the site plan. The applicant must obtain an access permit in the approved location(s) prior to construction. (Department of Public Works) 13. If applicable, show the approved Colorado Department of Transportation (CDOT) access(es) on the site plan and label with the approved access permit number. (Department of Public Works) 14. If applicable, show and label the entrance gate. An access approach that is gated shall be designed so that the longest vehicle (including trailers) using the access can completely clear the traveled way when the gate is closed. In no event, shall the distance from the gate to the edge of the traveled surface be less than 35 feet. (Department of Public Works) 15. If applicable, show and label a 30 -ft minimum access and utility easement to provide legal access to the parcel on the site plan. (Department of Public Works) 16. The applicant shall show and label the accepted drainage features and drainage flow arrows. Stormwater ponds should be labeled as "Stormwater Detention, No - Build or Storage Area" and shall include the calculated volume. (Department of Public Works) 17. Show and label the parking and traffic circulation flow arrows showing how the traffic moves around the property. (Department of Public Works) 2. Prior to construction: A. The approved accesses and tracking control shall be constructed prior to construction of the transmission lines and substations. (Department of Public Works) B. The applicant shall submit evidence of a right-of-way permit for any work that may be required in the right-of-way and/or a special transport permit for any oversized or overweight vehicles that may access the construction sites. (Department of Public Works) C. If more than one (1) acre is to be disturbed, a Weld County Grading Permit will be required. (Department of Public Works) 3. Prior to Operation: A. The applicant shall develop an Emergency Action and Safety Plan with the Office of Emergency Management and the Fire District. The plan shall be reviewed on an annual basis by the Facility operator, the Fire District and the Weld County Office of Emergency U5R18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 12 Management. Submit evidence of acceptance to the Department of Planning Services. (Department of Planning Services) 4. The applicant shall submit one (1) electronic (.pdf) copy of the map for preliminary approval to the Weld County Department of Planning Services. (Department of Planning Services) 5. Upon completion of Conditions of Approval numbers 1. above the applicant shall submit a Mylar map along with all other documentation required as Conditions of Approval. The Mylar map shall be recorded in the office of the Weld County Clerk and Recorder by Department of Planning Services' Staff. The map shall be prepared in accordance with the requirements of Section 23-2-390 of the Weld County Code. The Mylar map and additional requirements shall be submitted within one hundred twenty (120) days from the date of the Board of County Commissioners resolution. The applicant shall be responsible for paying the recording fee. (Department of Planning Services) 6. In accordance with Weld County Code Ordinance 2005-7 approved June 1, 2005, should the map not be recorded within the required one hundred twenty (120) days from the date the Board of County Commissioners Resolution was signed a $50.00 recording continuance charge may be added for each additional 3 -month period. 7. The Department of Planning Services respectively requests the surveyor provide a digital copy of this Use by Special Review. Acceptable CAD formats are .dwg, .dxf, and .dgn (Microstation); acceptable GIS formats are ArcView shapefiles, Arclnfo Coverages and Arclnfo Export files format type is .e00. The preferred format for Images is .tif (Group 4). (Group 6 is not acceptable). This digitalfilemaybesenttomaps@co.weld.co.us. (Department of Planning Services) 8. The Use by Special Review is not perfected until the Conditions of Approval are completed and the map is recorded. Activity shall not occur, nor shall any building or electrical permits be issued on the property, until the Use by Special Review map is ready to be recorded in the office of the Weld County Clerk and Recorder or the applicant has been approved for an early release agreement. (Department of Planning Services) USR18-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 13 SITE SPECIFIC DEVELOPMENT PLAN SPECIAL REVIEW PERMIT DEVELOPMENT STANDARDS Public Service Company of Colorado USR18-0100 1. A Site -Specific Development Plan And Special Review Permit for a Major Facility of a Public Utility - One (1) 230 kV Transmission line extending approximately 10.4 miles, one (1) new substation (Graham Creek) and upgrades to an existing substation (WAPA Ault Substation) in the A (Agricultural) Zone District. (Department of Planning Services) 2. Approval of this plan may create a vested property right pursuant to Section 23-8-10 of the Weld County Code. (Department of Planning Services) 3. The property owner or operator shall provide written evidence of an approved Emergency Action and Safety Plan on or before March 151h of any given year signed by representatives for the Fire District and the Weld County Office of Emergency Management to the Department of Planning Services. (Department of Planning Services) 4. The property owner shall control noxious weeds on the site. (Department of Public Works) 5. The access on the site shall be maintained to mitigate any impacts to the public road including damages and/or off -site tracking. (Department of Public Works) 6. There shall be no parking or staging of vehicles on public roads. On -site parking shall be utilized. (Department of Public Works) 7. Any work that may occupy and or encroach upon any County rights -of -way or easement shall acquire an approved Right -of -Way Use Permit prior to commencement. (Department of Public Works) 8. The Property Owner shall comply with all requirements provided in the executed Road Maintenance Agreement. (Department of Public Works) 9. Access(es) may be along unmaintained County right-of-way and maintenance of the right-of-way will not be the responsibility of Weld County. (Department of Public Works) 10. The historical flow patterns and runoff amounts on the site will be maintained. (Department of Public Works) 11. Weld County is not responsible for the maintenance of onsite drainage related features. (Department of Public Works) 12. All liquid and solid wastes (as defined in the Solid Wastes Disposal Sites and Facilities Act, 30-20-100.5, C.R.S.) shall be stored and removed for final disposal in a manner that protects against surface and groundwater contamination. (Department of Public Health and Environment) 11. No permanent disposal of wastes shall be permitted at this site. This is not meant to include those wastes specifically excluded from the definition of a solid waste in the Solid Wastes Disposal Sites and Facilities Act, 30-20-100.5, C.R.S. (Department of Public Health and Environment) 115818-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 14 12. Waste materials shall be handled, stored, and disposed in a manner that controls fugitive dust, fugitive particulate emissions, blowing debris, and other potential nuisance conditions. The facility shall operate in accordance with Chapter 14, Article 1 of the Weld County Code. (Department of Public Health and Environment) 13. Fugitive dust and fugitive particulate emissions shall be controlled throughout the duration of construction of the transmission line and until ground cover is established. Uses on the substation property shall comply with the Colorado Air Quality Commission's air quality regulations. (Department of Public Health and Environment) 14. The applicant shall submit an Air Pollution Emission Notice (A.P.E.N.) and Emissions Permit Application and obtain a permit from the Air Pollution Control Division, Colorado Department of Public Health and Environment, as applicable. (Department of Public Health and Environment) 15. During construction, adequate toilet facilities and handwashing units shall be provided. Portable toilets are acceptable. Portable toilets shall be serviced by a cleaner licensed in Weld County and shall contain hand sanitizers. (Department of Public Health and Environment) 16. Environmental Protection Measures for Construction Projects, as identified in the application, shall be adhered to. (Department of Public Health and Environment) 17. The facility shall adhere to the maximum permissible noise levels allowed in the Residential Zone as delineated in 25-12-103 C.R.S. (Department of Public Health and Environment) 18. The operation shall comply with all applicable rules and regulations of the State and Federal agencies and the Weld County Code. (Department of Public Health and Environment) 19. Building Permits issued on the proposed lots will be required to adhere to the fee structure of the County -wide Road Impact Fee Program. (Department of Planning Services) 20 Building Permits issued on the proposed lots, will be required to adhere to the fee structure of the County Facility Fee and Drainage Impact Fee Programs. (Department of Planning Services) 21. The property owner or operator shall be responsible for complying with the Design Standards of Section 23-2-240, Weld County Code. (Department of Planning Services) 22. The property owner or operator shall be responsible for complying with the Operation Standards of Section 23-2-250, Weld County Code. (Department of Planning Services) 23. Necessary personnel from the Weld County Departments of Planning Services, Public Works, and Public Health and Environment shall be granted access onto the property at any reasonable time in order to ensure the activities carried out on the property comply with the Conditions of Approval and Development Standards stated herein and all applicable Weld County regulations. (Department of Planning Services) 24. The Use by Special Review area shall be limited to the plans shown hereon and governed by the foregoing standards and all applicable Weld County regulations. Substantial changes from the plans or Development Standards as shown or stated shall require the approval of an amendment of the Permit by the Weld County Board of County Commissioners before such changes from the plans or Development Standards are permitted. Any other changes shall be filed in the office of the Department of Planning Services. (Department of Planning Services) 115818-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 15 25. The property owner or operator shall be responsible for complying with all of the foregoing Development Standards. Noncompliance with any of the foregoing Development Standards may be reason for revocation of the Permit by the Board of County Commissioners. (Department of Planning Services) 26. RIGHT TO EXTRACT MINERAL RESOURCES STATEMENT: Weld County has some of the most abundant mineral resources, including, but not limited to, sand and gravel, oil, natural gas, and coal. Under title 34 of the Colorado Revised Statutes, minerals are vital resources because (a) the state's commercial mineral deposits are essential to the state's economy; (b) the populous counties of the state face a critical shortage of such deposits; and (c) such deposits should be extracted according to a rational plan, calculated to avoid waste of such deposits and cause the least practicable disruption of the ecology and quality of life of the citizens of the populous counties of the state. Mineral resource locations are widespread throughout the County and person moving into these areas must recognize the various impacts associated with this development. Often times, mineral resource sites are fixed to their geographical and geophysical locations. Moreover, these resources are protected property rights and mineral owners should be afforded the opportunity to extract the mineral resource. 27. WELD COUNTY'S RIGHT TO FARM: Weld County is one of the most productive agricultural counties in the United States, typically ranking in the top ten counties in the country in total market value of agricultural products sold. The rural areas of Weld County may be open and spacious, but they are intensively used for agriculture. Persons moving into a rural area must recognize and accept there are drawbacks, including conflicts with long-standing agricultural practices and a lower level of services than in town. Along with the drawbacks come the incentives which attract urban dwellers to relocate to rural areas: open views, spaciousness, wildlife, lack of city noise and congestion, and the rural atmosphere and way of life. Without neighboring farms, those features which attract urban dwellers to rural Weld County would quickly be gone forever. Agricultural users of the land should not be expected to change their long-established agricultural practices to accommodate the intrusions of urban users into a rural area. Well -run agricultural activities will generate off -site impacts, including noise from tractors and equipment; slow -moving farm vehicles on rural roads; dust from animal pens, field work, harvest and gravel roads; odor from animal confinement, silage and manure; smoke from ditch burning; flies and mosquitoes; hunting and trapping activities; shooting sports, legal hazing of nuisance wildlife; and the use of pesticides and fertilizers in the fields, including the use of aerial spraying. It is common practice for agricultural producers to utilize an accumulation of agricultural machinery and supplies to assist in their agricultural operations. A concentration of miscellaneous agricultural materials often produces a visual disparity between rural and urban areas of the County. Section 35-3.5- 102, C.R.S., provides that an agricultural operation shall not be found to be a public or private nuisance if the agricultural operation alleged to be a nuisance employs methods or practices that are commonly or reasonably associated with agricultural production. Water has been, and continues to be, the lifeline for the agricultural community. It is unrealistic to assume that ditches and reservoirs may simply be moved "out of the way" of residential development. When moving to the County, property owners and residents must realize they cannot take water from irrigation ditches, lakes, or other structures, unless they have an adjudicated right to the water. Weld County covers a land area of approximately four thousand (4,000) square miles in size (twice the size of the State of Delaware) with more than three thousand seven hundred (3,700) miles of state and County roads outside of municipalities. The sheer magnitude of the area to be 115818-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 16 served stretches available resources. Law enforcement is based on responses to complaints more than on patrols of the County, and the distances which must be traveled may delay all emergency responses, including law enforcement, ambulance, and fire. Fire protection is usually provided by volunteers who must leave their jobs and families to respond to emergencies. County gravel roads, no matter how often they are bladed, will not provide the same kind of surface expected from a paved road. Snow removal priorities mean that roads from subdivisions to arterials may not be cleared for several days after a major snowstorm. Services in rural areas, in many cases, will not be equivalent to municipal services. Rural dwellers must, by necessity, be more self-sufficient than urban dwellers. People are exposed to different hazards in the County than in an urban or suburban setting. Farm equipment and oil field equipment, ponds and irrigation ditches, electrical power for pumps and center pivot operations, high speed traffic, sandburs, puncture vines, territorial farm dogs and livestock, and open burning present real threats. Controlling children's activities is important, not only for their safety, but also for the protection of the farmer's livelihood. 115818-0100- Northern Colorado Area Plan: 230kV Transmission line/substation project, page 17 May 31, 2019 DEPARTMENT OF PLANNING SERVICES 1555 N 17th AVE GREELEY, CO 80631 WEBSITE: www.weldgov.com E-MAIL: cgathman@weldgov.com PHONE: (970) 400-3537 FAX: (970) 304-6498 CLAXTON LARRY 1800 LARIMER ST STE 400 DENVER, CO 80202 Subject: USR18-0100 - A SITE SPECIFIC DEVELOPMENT PLAN AND SPECIAL REVIEW PERMIT FOR A MAJOR FACILITY OF A PUBLIC UTILITY (ONE (1) 230kV TRANSMISSION LINE EXTENDING APPROXIMATELY 10.4 MILES, ONE (1) NEW SUBSTATION (GRAHAM CREEK) AND UPGRADES TO AN EXISTING SUBSTATION (WAPA AULT SUBSTATION) IN THE A (AGRICULTURAL) ZONE DISTRICT. APPLICANT IS AMENDING THE ORIGINAL APPLICATION THAT WAS ORIGINALLY SUBMITTED UNDER THE SAME CASE NUMBER. THE ORIGINAL REQUEST READ (ONE (1) 230 kV TRANSMISSION LINE EXTEND 21 MILES, ONE (1) NEW SUBSTATION (GRAHAM CREEK) AND UPGRADES TO AN EXISTING SUBSTATION (WAPA SUBSTATION) IN THE A (AGRICULTURAL) ZONE DISTRICT. On parcel(s) of land described as: THE TRANSMISSION LINE IS TO BE LOCATED IN SECTIONS 2, 3, 4, 5, 6, 10, 15, 22, 26, 27 AND 35, T7N, R66W OF THE 6TH P.M., WELD COUNTY, COLORADO. of the 6th P.M., Weld County, Colorado. Dear Applicants: I have scheduled a meeting with the Weld County Planning Commission on June 18, 2019, at 12:30 p.m. A subsequent hearing with the Board of County Commissioners will be held on July 24, 2019 at 10:00 a.m. Both hearings will be held in the Hearing Room, Weld County Administration Building, 1150 O Street, Greeley, Colorado. It is recommended that you and/or a representative be in attendance to answer any questions the Planning Commission members or Board of County Commissioners may have. Colorado Revised Statute, C.R.S.24-65.5-103 (adopted as part of H.B.01-1088) requires notification of all mineral estate owners 30 days prior to any public hearing. The applicant needs to provide the Weld County Planning Department with written certification indicating the above requirement has been met. A representative from the Department of Planning Services will be out to the property a minimum of ten days prior to the hearing to post a sign adjacent to and visible from a publicly maintained road right-of-way which identifies the hearing time, date, and location. In the event the property is not adjacent to a publicly maintained road right-of-way, one sign will be posted in the most prominent place on the property and a second sign posted at the point at which the driveway (access drive) intersects a publicly maintained road right-of-way. The Department of Planning Services' staff will make a recommendation concerning this application to the Weld County Planning Commission and will be included in the staff report one week prior to the scheduled Planning Commission hearing. You may view the staff report at www.weldcountyplanninqcases.orq d co u ntypl a n n i n g cases. orq Page 2 of 2 If you have any questions concerning this matter, please call. Respectfully, Chris Gathman Planner DEPARTMENT OF PLANNING SERVICES 1555 N 17th AVE GREELEY, CO 80631 WEBSITE: www.weldgov.com E-MAIL: cgathman@weldgov.com PHONE: (970) 400-3537 FAX: (970) 304-6498 April 23, 2019 CLAXTON LARRY 1800 LARIMER ST STE 400 DENVER, CO 80202 Subject: USR18-0100 - A SITE SPECIFIC DEVELOPMENT PLAN AND SPECIAL REVIEW PERMIT FOR A MAJOR FACILITY OF A PUBLIC UTILITY (ONE (1) 230kV TRANSMISSION LINE EXTENDING APPROXIMATELY 10.4 MILES, ONE (1) NEW SUBSTATION (GRAHAM CREEK) AND UPGRADES TO AN EXISTING SUBSTATION (WAPA AULT SUBSTATION) IN THE A (AGRICULTURAL) ZONE DISTRICT. APPLICANT IS AMENDING THE ORIGINAL APPLICATION THAT WAS ORIGINALLY SUBMITTED UNDER THE SAME CASE NUMBER. THE ORIGINAL REQUEST READ (ONE (1) 230 kV TRANSMISSION LINE EXTEND 21 MILES, ONE (1) NEW SUBSTATION (GRAHAM CREEK) AND UPGRADES TO AN EXISTING SUBSTATION (WAPA SUBSTATION) IN THE A (AGRICULTURAL) ZONE DISTRICT. On parcel(s) of land described as: The Transmission line is to be located in Sections 2, 3, 4, 5, 6, 10, 15, 22, 26, 27 and 35, T7N, R66W of the 6th P.M., Weld County, Colorado. Dear Applicants: Your application and related materials for the request described above are complete and in order at this time. I will schedule a meeting with you at the end of the review period to discuss the referral comments received by our office. It is the policy of Weld County to refer an application of this nature to any town or municipality lying within three miles of the property in question or if the property under consideration is located within the comprehensive planning area of a town or municipality. Therefore, our office has forwarded a copy of the submitted materials to the following Planning Departments for their review and comments: Ault at Phone Number 970-834-2844 Eaton at Phone Number 970-454-3338 Severance at Phone Number 970-686-1218 Pierce at Phone Number 970-834-2851 It is recommended that you contact the listed Planning Departments for information regarding their process and to answer any questions that might arise with respect to your application. If you have any questions concerning this matter, please call. Respectfully, Chris Gathman Planner r_siA 'Or Energy Northern Colorado Area Plan 2.30k1V Tra nsm ission/ ubsta tion Project Appendix Summary of PSCo's Responses to the Comment Letters Xcel Energy® March 29, 2019 Amended Section 1041 Permit Application Appendix I: Summary of PSCo's Responses to Referral Agency and Landowner Comment Letters Introduction In preparation for public hearings on the Amended Section 1041 Permit application, PSCo's responses to referral agency and landowner comment letters are described below and have also been incorporated into the Amended 1041 Application. A►s described in the Project Description, PSCo has amended the Application to limit the scope to the following components: • Upgrades to the WAPA Ault Substation; • A 230kV-capable transmission line from the WAPA Ault Substation to the Husky Substation (permitted separately by the Town of Ault); and • A 230kV-capable transmission line from the Husky Substation to the Graham Creek Substation. • A new Graham Creek Substation west of the Town of Eaton; The Section 1041 Permit Application remains unchanged for these Project components. The 230kV-capable transmission line connecting the new Graham Creek Substation to an interconnection point near the existing Cloverly Substation has been removed from the original Section1041 Permit Application (August 10, 2018) and will be submitted separately following a good faith effort by PSCo to expand the siting area and continue to identify other routes and evaluate them against the current preferred alternative. PSCo has conducted extensive landowner outreach efforts to site the preferred transmission line and substations, as demonstrated in the Siting Study that is included as Appendix B of this Amended 1041 Application. PSCo respectfully requests that the Weld County Planning Commission and Board of County Commissioners review and approve the Amended 1041 Permit Application. Comment Letters Weld County and PSCo received a total of 20 comment letters on Section 1041 Permit Application that was determined to be complete by County staff on September 24, 2018. In response to these comments, PSCo limited the scope of the Project through an amended application. Table 1 lists the comment letters applicable to the Amended Section 1041 Application, those out of scope, and those with no comments. A total of three comment letters were related to the Amended Application, exclusively. Three comment letters are now out of the scope of the Amended Application and will be addressed in a subsequent application, exclusively. Nine comment letters related to both the Amended Section 1041 Application and the out of scope transmission segment between Graham Creek and Cloverly Tap. Five letters found no conflict with their interests and offered no comments. 1 Xcel Energy® Table 1 Comment Letters Received March 29, 2019 Name/Organization Amended Section Application (WAPA Graham �� 1041 Ault to Creek) Out of Scope (Graham Creek to Cloverly Tap) No Comments City of Thornton X Town of Eaton X X Town of Pierce X Weld County School District RE -2 X Weld County Sheriff Department X Weld County Zoning Department X Weld County Environmental Health Services X X Weld Floodplains County Department of Planning Services - Weld County Public Works Department X X Office of Emergency Management X X Colorado Department of Transportation (CDOT) X X The Lateral Company, Company, Bartlett, Water Ditch & Supply Company, and as Gunn, represented New PC and Storage Company, Collins Lateral Cache la Poudre by Fischer, Ditch Irrigating Brown, Pierce X X Mead Lateral Ditch Company, Fischer, Brown, Bartlett, 2018 as represented & Gunn, PC. by November 16, X X Larimer and Weld Irrigation Company X X Public Safety Wireless Communications X SRC Energy X Harold and Carol Long X Michael and Sandy Gantz X X Petrocco attorney Farms, as represented by Maria Petrocco, X Federal Aviation Administration (FAA) X Provided below is a summary of the comment letters and PSCo's responses. Comments from Municipalities 1. City of Thornton. December 3, 2010. Comment: The City of Thornton agrees with the need for the Project. Thornton proposes that the transmission route be located east of Hwy 85 near the Town of Eaton to reduce impacts to Thornton's most productive agricultural lands. Response: A comprehensive siting study was conducted to inform selection of the proposed transmission routes and substation locations. The corridors and sites with the least agricultural, residential, industrial/commercial, recreational, institutional, and natural and cultural resource impacts and greatest engineering advantages were identified as preferred. The City of Thornton owns properties along the WAPA Ault to Husky Substation preferred corridor. Thornton does not own properties south of the Town of Eaton, and would not be affected by the Graham Creek to Cloverly Tap segment. Nevertheless, 2 Xcel Energy® March 29, 2019 PSCo has committed to further study for Graham Creek to Cloverly Tap segment, including additional routes located east of Hwy 85 as well as potential modifications to the overall system design. 2. Town of Eaton. October 12 and November 1, 2018. Comment: The Town of Eaton objects to the proposed transmission line routing and the siting of the Graham Creek Substation for various reasons. Eaton favors an alternative transmission route that continues east on County Road 78 and south between County Road 41 and County Road 43. Eaton prefers the Graham Creek 3 Substation location over the proposed Graham Creek 1 Substation. Response: PSCo understands the Town's concerns and has consulted with the Mayor, Town Board, and Town Administration regularly, including holding two public meetings in the Town. Their feedback was influential in PSCo's decision to limit the scope of the Amended Application. As noted above, PSCo has committed to further study of the Graham Creek to Cloverly Tap, which will include additional evaluation of transmission line routes located east of Highway 85 in consultation with the Town of Eaton. Comments from Weld County Departments and Organizations 1. Weld County Environmental Health Services. October 30, 2018. Comment: Weld County Environmental Health Services supports the proposal with a commitment to the following Development Standards: PSCo accepts and commits to comply with all the Development Standards requested below. More specific response are provided, as appropriate, to each Development Standard. a. All liquid and solid wastes (as defined in the Solid Wastes Disposal Sites and Facilities Act, 30 20 100.5, C.R.S.) shall be stored and removed for final disposal in a manner that protects against surface and groundwater contamination. Response: See Section 1041 Permit Application, Section 21-3-330.B.5.g:"Enclosed containment will be provided for all trash. All construction waste, including trash and litter, garbage, other solid waste, petroleum products, and other potentially hazardous materials will be removed from the site and transported to a disposal facility authorized to accept such materials. There would be no significant amount of hazardous materials stored in the Project area." b. No permanent disposal of wastes shall be permitted at this site. This is not meant to include those wastes specifically excluded from the definition of a solid waste in the Solid Wastes Disposal Sites and Facilities Act, 30 20 100.5, C.R.S. Response: See response to item a (above). c. Waste materials shall be handled, stored, and disposed in a manner that controls fugitive dust, fugitive particulate emissions, blowing debris, and other potential nuisance conditions. The facility shall operate in accordance with Chapter 14, Article 1 of the Weld County Code. Response: See Section 1041 Permit Application, Section 21-3-330.B.12, Air and Water Pollution Impacts and Control Alternatives: "Construction activities associated with the Project would generate less than significant amounts of particulate matter from soil disturbances and diesel - 3 Xcel Energy® March 29, 2019 powered equipment, and less than significant amounts of carbon monoxide and the precursor pollutants to ozone formation from tailpipe emissions. Any air pollutants generated would be widely dispersed across the siting area, short-term in duration, and minimized by the small scale of construction operations for the substation, and excavating foundations for transmission structures. Air pollutants also would be minimized through implementation of dust suppression and proper vehicle maintenance." d. Fugitive dust and fugitive particulate emissions shall be controlled throughout the duration of construction of the transmission line and until ground cover is established. Uses on the substation property shall comply with the Colorado Air Quality Commission's air quality regulations. Response: See response to item c (above). e. The applicant shall submit an Air Pollution Emission Notice (A.P.E.N.) and Emissions Permit Application and obtain a permit from the Air Pollution Control Division, Colorado Department of Public Health and Environment, as applicable. Response: See Section 1041 Permit Application, Section 21-3-330.B.12, Air and Water Pollution Impacts and Control Alternatives: "No long-term impacts to air quality are anticipated from the project." PSCo will submit for and comply with emissions permits and regulations, as applicable to the project. f. During construction, adequate toilet facilities and handwashing units shall be provided. Portable toilets are acceptable. Portable toilets shall be serviced by a cleaner licensed in Weld County and shall contain hand sanitizers. Response: See USR Questionnaire, Environmental Health Questions. "During construction, bottled water and portable toilets would be located on site. During operations, the facilities will not be staffed and a sewage disposal system is not required." g. Environmental Protection Measures for Construction Projects, as identified in the application, shall be adhered to. Response: PSCo will adhere to the environmental protection measures for construction projects, as identified in the 1041 permit application. h. The facility shall adhere to the maximum permissible noise levels allowed in the Residential Zone as delineated in 25 12 103 C.R.S. Response: 25 12 103 C.R.S. states acceptable noise limits for residential areas 50 to 55 db(A). See 1041 permit application, Section 21-3-330.B.15, Hydrologic, Atmospheric, Geologic, Pedologic, Biotic, Visual, and Noise Impacts. "The Project would be constructed and maintained in accordance with Colorado Revised Statutes 25-12-101 et seq. (Noise Abatement) and Article IX, Section 14-9-10 et seq. of the Weld County Code. The audible noise in fair weather conditions would be negligible at the edge of the 115kV ROW and below 20 dBA at the edge of the 230kV ROW." 4 Xcel Energy® March 29, 2019 i. The operation shall comply with all applicable rules and regulations of the State and Federal agencies and the Weld County Code. Response: PSCo will comply with all applicable rules and regulations of the State and Federal agencies and the Weld County Code. 2. Weld County Department of Planning Services - Floodplains. November 5, 2018. Comment: Weld County Department of Planning Services - Floodplains states that a floodplain permit would be required for any construction that occurs within a floodplain. Response: No regulatory floodplains are crossed by the preferred transmission line route. In any event, PSCo will comply with all applicable regulations and will obtain a floodplain permit should any construction occur within a floodplain. 3. Weld County Public Works Department. October 31, 2018. Comment: The Weld County Public Works Department provides 20 Conditions of Approval and 8 Development Standards that the project must comply with. See below for specific requirements and PSCo responses. Response: PSCo accepts and commits to compliance with all the Conditions of Approval and Development Standards identified below. More specific response are provided, as appropriate, to each condition or standard. CONDITIONS OF APPROVAL A. A Road Maintenance Agreement is required at this location. Road maintenance includes, but is not limited to dust control and damage repair to specified haul routes. (Department of Public Works) Response: See Section 1041 Permit Application, Section 21.3-330.D, List of Future Permits and Plans. PSCo will submit a Road Maintenance Agreement for the project to the Weld County Department of Public Works. B. A Final Drainage Report and Certification of Compliance stamped and signed by a Professional Engineer registered in the State of Colorado is required for the Graham Creek Substation portion of this USR. (Department of Public Works) Response: See Section 1041 Permit Application, Section 21-3-330.D, List of Future Permits and Plans PSCo will submit a final Drainage Report and Certification of Compliance for the Graham Creek Substation to the Weld County Department of Public Works. C. If applicable, the applicant shall submit a recorded copy of any agreement signed by all of the owners of the property crossed by the access. The access shall be for ingress, egress, utilities and shall be referenced on the USR map by the Weld County Clerk and Recorder's Reception number. (Department of Public Works) Response: PSCo will submit recorded copies of landowner easement agreements for the project to the Weld County Department of Public Works prior to construction activities. D. The plan shall be amended to delineate the following: 5 Xcel Energy® March 29, 2019 1. County Road 27 is an unmaintained section line right-of-way. The applicant shall verify and delineate on the map the unmaintained right-of-way► and the documents creating the right-of-way. All setbacks shall be measured from the edge of right-of-way. This road is not maintained by Weld County. Any unmaintained road needs to be located/identified in relationship to the right-of- way. Show and label the section line Right -of -Way as "CR 27 Section Line Right-of-way, not County maintained". (Department of Public Works) Response: PSCo will verify and delineate the CR 27 unmaintained right-of-way on the final ROW Transmission Plats, as described above. PSCo will work with Public Works to identify how to site the transmission line easement adjacent to unmaintained rights -of -way as shown on Attachment 2. 2. County Roads 31, 41, 72, and 86 are gravel roads and are designated on the Weld County Functional Classification Map as local roads which require 60 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the future and existing rights -of -way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) Response: PSCo will delineate future and existing rights -of -way for CR 31, CR 41, CR 72, and CR 86 on the final ROW Transmission Plats, as described above. PSCo will work with Public Works to identify how to site the transmission line easement adjacent to future and existing rights - of -way as shown on Attachment 2. 3. County Road 29 in this location is designated on the Weld County Functional Classification Map as an arterial road which in this location requires 100 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the existing right-of-way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) Response: PSCo will delineate CR 29 and the existing right-of-way on the final ROW Transmission Plats, as described above. 4. County Roads 33, 35, 37, 43, and 66 are paved roads and are designated on the Weld County Functional Classification Map as collector roads which require 80 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the existing rights -of -way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) Response: PSCo will delineate existing rights -of -way for CR 33, CR 35, CR 37, CR 43, and CR 66 on the final ROW Transmission Plats, as described above. 5. County Road 84 is a gravel road and is designated on the Weld County Functional Classification Map as a local road which requires 60 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the existing right-of-way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) Response: PSCo will delineate existing rights -of -way for CR 84 on the final ROW Transmission Plats, as described above. County Road 80 is an unmaintained section line right-of-way. The applicant shall verify and delineate on the map the unmaintained right-of-way and the documents creating the right-of-way. All setbacks shall be measured from the edge of right-of-way. This road is not maintained by Weld County. Any unmaintained road needs to be located/identified in relationship to the right-of- way. Show and label the section line Right -of -Way as "CR 80 Section Line Right-of-way, not County maintained". (Department of Public Works) 6 Xcel Energy® March 29, 2019 Response: PSCo will verify and delineate the CR 80 unmaintained right-of-way on the final ROW Transmission Plats, as described above. 7. County Road 78 has no right-of-way between County Road 31 and halfway between County Road 33 and County Road 35. County Road 76 is a gravel road west of County Road 33 and is a paved road east of County Road 33. It is designated on the Weld County Functional Classification Map (Code Ordinance 2017-01) as a(n) local road, which requires 60 feet of right-of-way. The applicant shall delineate on the site map or plat the future and existing right-of-way and the physical location of the road. If the right-of-way cannot be verified it shall be dedicated. Pursuant to the definition of setback in the Weld County Code, Chapter 23, Article III, Section 23-3- 50, the required setback is measured from the future right-of-way line. Be aware that physical roadways may not be centered in the right-of-way. This road is maintained by Weld County. Response: PSCo will delineate the future and existing rights -of -way for CR 78 and CR 76 on the final ROW Transmission Plats, as described above. 8. County Road 74 is a paved road and is designated on the Weld County Functional Classification Map as a arterial road which requires 140 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the existing right-of-way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) Response: PSCo will delineate the existing right-of-way for CR 74 on the final ROW Transmission Plats, as described above. 9. County Road 39 is a paved road and is designated on the Weld County Functional Classification Map as a local road which requires 60 feet of right-of-way at full buildout. The applicant shall delineate on the site plan the existing right-of-way. All setbacks shall be measured from the edge of right-of-way. This road is maintained by Weld County. (Department of Public Works) Response: PSCo will delineate the existing right-of-way for CR 39 on the final ROW Transmission Plats, as described above. 10. County Road 70 is a gravel road from County Road 31 to County Road 37, paved from County Road 37 to Highway 85, and gravel from Highway 85 to County Road 41. It is designated on the Weld County Functional Classification Map (Code Ordinance 2017-01) as a(n) local road, which requires 60 feet of right-of-way. The applicant shall delineate on the site plan and existing right-of- way at full buildout. If the right-of-way cannot be verified it shall be dedicated. All setbacks shall be measured from the edge of right-of-way. Be aware that physical roadways may not be centered in the right-of-way. This road is maintained by Weld County. Response: PSCo will delineate the existing right-of-way for CR 70 on the final ROW Transmission Plats, as described above. 11. Show and label the approved access locations, approved access width and the appropriate turning radii on the site plan. The applicant must obtain an access permit in the approved location(s) prior to construction. (Department of Public Works) Response: Access locations, width, and appropriate turning radii are presented on the Revised Graham Creek Substation Plot Plans in Appendix A, Maps 12a and 12b. PSCo will obtain an access permit for applicable locations prior to construction. 12. If applicable, show the approved Colorado Department of Transportation (CDOT) access(es) on the site plan and label with the approved access permit number. (Department of Public Works) 7 Xcel Energy® March 29, 2019 Response: PSCo will obtain an approved CDOT access permit for this location and the permit number will be included on the Final ROW Transmission Plats. 13. If applicable, show and label the entrance gate. An access approach that is gated shall be designed so that the longest vehicle (including trailers) using the access can completely clear the traveled way when the gate is closed. In no event, shall the distance from the gate to the edge of the traveled surface be less than 35 feet. (Department of Public Works) Response: The entrance gate for the Graham Creek Substation is included on the Revised Graham Creek Substation Plot Plans in Appendix A, Maps 12a and 12b. The access approach will be gated and designed to accommodate the longest vehicles accessing the site; including compliance with the 35 feet standard stated above. 14. If applicable, show and label a 30 foot minimum access and utility easement to provide legal access to the parcel on the site plan. (Department of Public Works) Response: PSCo has included a 30 foot minimum access and utility easement on the Revised Graham Creek Substation Plot Plans in Appendix A, Maps 12a and 12b. 15. The applicant shall show and label the accepted drainage features and drainage flow arrows. Stormwater ponds should be labeled as "Stormwater Detention, No -Build or Storage Area" and shall include the calculated volume. (Department of Public Works) Response: PSCo has presented drainage features and drainage flow arrows on the Revised Graham Creek Substation Plot Plans in Appendix A, Maps 12a and 12b. Stormwater ponds will be labelled as described above and will include the calculated volume. 16. Show and label the parking and traffic circulation flow arrows showing how the traffic moves around the property. (Department of Public Works) Response: PSCo has presented the parking and traffic circulation flow arrows on the Revised Graham Creek Substation Plot Plans in Appendix A, Maps 12a and 12b. Prior to Construction: 1. The approved accesses and tracking control shall be constructed prior to construction of the transmission lines and substations. (Department of Public Works) Response: PSCo will prioritize construction of accesses and tracking control prior to construction of the transmission lines and substations. 2. The applicant shall submit evidence of a right-of-way permit for any work that may be required in the right-of-way and/or a special transport permit for any oversized or overweight vehicles that may access the construction sites. (Department of Public Works) Response: PSCo will submit evidence of a right-of-way permit for any work that may be required in the right-of-way and/or a special transport permit for any oversized or overweight vehicles that may access the construction sites. 3. If more than one (1) acre is to be disturbed, a Weld County Grading Permit will be required. (Department of Public Works) Response: See Section 1041 Permit Application, Section 21-3-330.D, List of Future Permits and Plans. PSCO will comply with all applicable Weld County Grading Permit requirements. 8 Xcel Energy® DEVELOPMENT STANDARDS March 29, 2019 1. The property owner shall control noxious weeds on the site. (Department of Public Works) Response: See Section 1041 Permit Application, Section 21-3-330.B.7.c, Discussion of Impacts on Additional Resources, Including Significant Environmentally Sensitive Factors. "The potential for the introduction and/or spread of noxious weeds will be minimized by implementing BMPs such as ensuring construction equipment is cleaned, using weed -free seed mixes and controlling noxious weeds within the ROW and substation areas. The potential for the introduction and/or spread of invasive non-native species (including noxious weeds) will be minimized by the implementation of BMPs during the construction period and reclamation efforts." 2. The access on the site shall be maintained to mitigate any impacts to the public road including damages and/or off -site tracking. (Department of Public Works) Response: A Road Maintenance Agreement will be developed and implemented to mitigate potential impacts to public roads in Weld County. 3. There shall be no parking or staging of vehicles on public roads. On -site parking shall be utilized. (Department of Public Works) Response: No vehicles will be parked or staged on public roads. 4. Any work that may occupy and or encroach upon any County rights -of -way or easement shall acquire an approved Right -of -Way Use Permit prior to commencement. (Department of Public Works) Response: See Section 1041 Permit Application, Section 21-3-330.D, List of Future Permits and Plan "PSCo will obtain applicable Right -of -Way Use Permits from the Weld County Department of Public Works prior to construction." 5. The Property Owner shall comply with all requirements provided in the executed Road Maintenance Agreement. (Department of Public Works) Response: PSCo will comply with all requirements provided in the executed Road Maintenance Agreement. 6. Access(es) may be along unmaintained County right-of-way and maintenance of the right-of-way will not be the responsibility of Weld County. (Department of Public Works) Response: Comment noted. 7. The historical flow patterns and runoff amounts on the site will be maintained. (Department of Public Works) Response: PSCo will maintain the historical flow patterns and runoff amounts on the project site. 8. Weld County is not responsible for the maintenance of onsite drainage related features. (Department of Public Works) Response: Comment noted. Comments from Agencies 9 Xcel Energy® 1. Office of Emergency Management. October 4, 2018. March 29, 2019 Comment: The Office of Emergency Management states that the Emergency Plan included with the 1041 permit application should list local emergency responders. Response: PSCo will provide applicable contact information for local emergency responders. 2. Colorado Department of Transportation (CDOT). October 24, 2018. Comment: CDOT states that PSCo is required to obtain necessary utility permits and access permits for entry onto state highway property. Response: PSCo will obtain all necessary CDOT utility and access permits for construction of the project. Comments from Ditch Companies 1. The Water Supply and Storage Company, Pierce Lateral Ditch Company, Collins Lateral Ditch Company, and New Cache la Poudre Irrigating Company, as represented by Fischer, Brown, Bartlett, & Gunn, PC. November 1, 2018. Comment: The four ditch companies, as represented by their attorney, object to the project without an executed crossing agreement. Response: PSCo will work closely with ditch and irrigation companies to assure that the project does not interfere with operation and maintenance activities. Any crossing of a ditch or location of structures within a ditch ROW will not occur without written approval of the ditch company. 2. Mead Lateral Ditch Company, as represented by Fischer, Brown, Bartlett, & Gunn, PC. November 16, 2018. Comment: The Mead Lateral Ditch Company, as represented by their attorney, objects to the Project without an executed crossing agreement. Response: PSCo will work closely with ditch and irrigation companies to assure that the Project does not interfere with ditch operation and maintenance activities. No crossing of a ditch or location of structures within a ditch ROW willoccur without written approval of the ditch company. 3. Larimer and Weld Irrigation Company. November 1, 2018. Comment: The Larimer and Weld Irrigation Company states that structures must be placed outside of their ROW and must not interfere with operation and maintenance of the ditch. They also note that impacts to agricultural lands must be adequately mitigated. Response: PSCo will work closely with ditch and irrigation companies to assure that the Project does not interfere with ditch operation and maintenance activities. No crossing of a ditch or location of structures within a ditch ROW will occur without written approval of the ditch company. Comments from Private Citizens 1. Harold and Carol Long. December 3, 2018. 10 Xcel Energy® March 29, 2019 Comment: Mr. and Mrs. Long are concerned about effects from the Project on their property values, visual impacts, and agricultural operations. Their property is located within the Husky Substation to Graham Creek Substation transmission line corridor. Response: PSCO will work with landowners to microsite the transmission facilities and related easement to minimize the need for removing trees and reduce negative effects on agricultural operations. Typical examples of how PSCo will work to avoid such conflicts are shown in Attachment 2. 2. Michael and Sandy Gantz. January 29, 2019. Comment: Mr. and Mrs. Gantz are concerned about effects from the Project on their agricultural operations. They prefer that transmission lines are located as far from Ault, Eaton, and Lucerne municipal limits as possible. Response: PSCO will work with landowners to microsite the transmission facilities and easement to minimize negative impacts on agricultural operations. Typical examples of how PSCo will work to avoid conflicts are shown in Attachment 2. Out of Scope Comments Provided below is a summary and PSCo's responses to the comment letters that pertain to the Graham Creek Substation to Cloverly Tap segment that has been removed from the Amended Section 1041 Permit Application. 1. SRC Energy. October 4, 2018. Comment: SRC Energy expressed concern with potential effects from the Project on their existing and planned well drilling or operations. Weld County approval of the Project should be conditioned on avoiding these conflicts. Response: In a meeting with SRC Energy on March 18, 2019, PSCo presented the approach to the Amended Application. SRC Energy stated that the Amended Application does not affect any of their company interests. They offered to submit a new letter on support of the Amended Application at the public hearings. If SRC Energy interests are located in the Graham Creek Substation to Cloverly Tap corridor, PSCo will work with SRC Energy pursuant to CRS 24-65.6-101 et seq., The Notification of Surface Development Statute, in order to avoid conflicts with their drilling and operations. Typical examples of how PSCo will work to avoid conflicts are shown in the Section 1041 Permit Application, Figures 4 and 5. 2. Petrocco Farms, as represented by Maria Petrocco, attorney. November 27, 2018. Comment: Petrocco Farms voiced a number of concerns with the Project, including equipment height, potential for electrocution, flood and pivot irrigation constraints, aerial spraying, and potential radio interference with agricultural operations. Their property is located within the Graham Creek Substation to Cloverly Tap corridor. Response: PSCo will evaluate additional transmission line routing opportunities between Graham Creek to Cloverly Tap in order to avoid or minimize the concerns identified by Petrocco Farms. In addition, 11 Xcel Energy® March 29, 2019 PSCO will work with all landowners to microsite the transmission facilities and easement to minimize negative impacts on agricultural operations. Typical examples of how PSCo will work to avoid conflicts are shown in the Section 1041 Permit Application. 3. Federal Aviation Administration (FAA). October 4, 2018. Comment: FAA stated that Form 7460-1 should be filed with the FAA if the transmission line is located within 20,000 feet of a public runway and breaks the 100:1 plane. The only public runway in the siting area is affected by the Graham Creek to Cloverly Tap segment, which is now out of scope. Response: PSCo will submit form 7460-1 if the route ultimately identified as the preferred Graham Creek to Cloverly Tap route meets the criteria cited above. PSCo will work closely with FAA to assure that the Project is in compliance with all applicable guidance and requirements. 12 Hello