Alberta Electric System Operator, AltaLink Management Ltd ...€¦ · Decision 2013-369: Alberta...

Decision 2013-369

Alberta Electric System Operator, AltaLink Management Ltd. and ENMAX Power Corporation Foothills Area Transmission Development October 7, 2013

The Alberta Utilities Commission

Decision 2013-369: Alberta Electric System Operator, AltaLink Management Ltd. and

ENMAX Power Corporation

Foothills Area Transmission Development

Applications No. 1608620, No. 1608642, No. 1608637, No. 1608643, No. 1608649,

No. 1608846, No. 1608861 and No. 1608862

Proceeding ID No. 2001

October 7, 2013

Published by


Fifth Avenue Place, Fourth Floor, 425 First Street S.W.

Calgary, Alberta

T2P 3L8

Telephone: 403-592-8845

Fax: 403-592-4406

Website: www.auc.ab.ca

http://www.auc.ab.ca/

Contents

1 Introduction and background .............................................................................................. 1 1.1 The Foothills Area Transmission Development applications ........................................ 4

1.1.1 Two AESO need applications ........................................................................... 4 1.1.1.1 FATD need Application No. 1608620 ................................................. 4 1.1.1.2 Amendment to the SATR NID Application No. 1608846 .................. 5

1.1.2 Four facility applications associated with the FATD NID ............................... 6 1.1.2.1 AltaLink Application No. 1608642 – Langdon to Janet ...................... 6 1.1.2.2 AltaLink Application No. 1608637 – north Foothills transmission

development ...................................................................................................... 6 1.1.2.3 AltaLink Application No. 1608643 – Foothills 138-kV transmission

development ...................................................................................................... 7

1.1.2.4 ENMAX Application No. 1608649 ..................................................... 7

1.1.3 Two facility applications associated with the SATR NID amendment ............ 7 1.1.3.1 AltaLink Application No. 1608861 – south Foothills transmission

development ...................................................................................................... 7 1.1.3.2 AltaLink Application No. 1608862 – Windy Flats 138S substation

and line reconfiguration .................................................................................... 8 1.2 Process for new transmission and legislative framework .............................................. 8

1.2.1 Need applications .............................................................................................. 9

1.2.2 Facility applications ........................................................................................ 10 1.2.3 Other requirements.......................................................................................... 13

2 The AESO’s need applications .......................................................................................... 13 2.1 Assessment of the need to expand the transmission system in southern Alberta ........ 14

2.1.1 Views of the AESO ......................................................................................... 14 2.1.1.1 Application No. 1608620 – FATD NID ............................................ 14

2.1.1.2 Amendment to the SATR NID .......................................................... 16 2.1.2 Views of the Diagonal group .......................................................................... 17 2.1.3 Views of Phyllis Robertson ............................................................................ 17

2.1.4 Views of Industrial Power Consumers Association of Alberta (IPCAA)....... 17

2.1.5 Views of Benign Energy Canada II Inc. (Benign Energy) ............................. 18 2.1.6 Views of TransAlta Corporation (TransAlta) ................................................. 18 2.1.7 Views of ENMAX Green Power Inc. (EGPI) and ENMAX Shepard Inc. (ESI)

......................................................................................................................... 19 2.1.8 Commission findings ...................................................................................... 19

2.1.8.1 Application No. 1608620 – FATD NID ............................................ 19 2.1.8.2 Amendment to the SATR NID .......................................................... 20

2.2 Reasonableness of the proposed technical solutions .................................................... 20 2.2.1 Views of the AESO ......................................................................................... 21

2.2.1.1 FATD NID ......................................................................................... 21 2.2.1.2 Amendment to the SATR NID .......................................................... 26

2.2.2 Views of AltaLink........................................................................................... 30

2.2.3 Views of the Diagonal group .......................................................................... 32 2.2.4 Views of Phyllis Robertson ............................................................................ 39 2.2.5 Views of IPCAA ............................................................................................. 40

2.2.5.1 FATD NID ......................................................................................... 40 2.2.5.2 Amendment to the SATR NID .......................................................... 41

ii • AUC Decision 2013-369 (October 7, 2013)

2.2.6 Views of TransCanada Energy Ltd. (TransCanada) ....................................... 42

2.2.7 Views of Ronald and Laurie Conner .............................................................. 43 2.2.8 Views of Powerex Corp. (Powerex) ............................................................... 43 2.2.9 Commission findings ...................................................................................... 45

3 Criteria and route siting principles ................................................................................... 57 3.1 AltaLink’s routing methodology .................................................................................. 57

3.1.1 Preliminary siting stage................................................................................... 58 3.1.1.1 Preliminary routings .......................................................................... 66

3.1.2 Detailed siting stage ........................................................................................ 69

3.1.3 Final siting stage ............................................................................................. 74

4 Consultation ......................................................................................................................... 79 4.1 Views of AltaLink ........................................................................................................ 80

4.1.1 Group and personal consultation .................................................................... 81 4.1.2 Aboriginal consultation ................................................................................... 82 4.1.3 AltaLink response to intervener consultation concerns .................................. 82

4.2 Views of the interveners............................................................................................... 83 4.2.1 Langdon to Janet application .......................................................................... 83

4.2.2 North Foothills and Foothills 138-kV applications ........................................ 84 4.2.3 South Foothills and Windy Flats 138-kV applications ................................... 85

4.3 Views of ENMAX ....................................................................................................... 85

4.4 Commission findings ................................................................................................... 85

5 Environment ........................................................................................................................ 87 5.1 Introduction .................................................................................................................. 87 5.2 Application No. 1608642 – Langdon to Janet ............................................................. 90

5.3 Application No. 1608637 – north Foothills transmission development ...................... 91 5.4 Application No. 1608643 – Foothills 138-kV transmission development ................... 94

5.5 Application No. 1608861 – south Foothills transmission development ...................... 95 5.6 Application No. 1608862 – Windy Flats 138S substation and line reconfiguration ... 96 5.7 Application No. 1608649 – ENMAX application........................................................ 97

6 Electrical considerations .................................................................................................... 97 6.1 Views of the applicant .................................................................................................. 97 6.2 Views of the interveners............................................................................................... 99 6.3 Commission findings ................................................................................................... 99

7 AltaLink Application No. 1608642 – Langdon to Janet ................................................ 101 7.1 Preferred and alternate route selection ....................................................................... 101

7.2 Views of AltaLink ...................................................................................................... 102 7.3 Views of the interveners............................................................................................. 104

7.3.1 Interveners on the preferred route ................................................................. 104 7.3.2 Interveners on the alternate route .................................................................. 108 7.3.3 Intervener objecting to preferred route variant ............................................. 110

7.4 Commission findings ................................................................................................. 111

8 AltaLink Application No. 1608637 - north Foothills transmission development ........ 112 8.1 The preferred and stakeholder-proposed Foothills substation site selection ............. 112

AUC Decision 2013-369 (October 7, 2013) • iii

8.1.1 Introduction ................................................................................................... 112

8.1.2 Views of AltaLink......................................................................................... 113 8.1.3 Views of the interveners ............................................................................... 115 8.1.4 Commission findings .................................................................................... 119

8.2 The preferred and alternate 240-kV transmission routes ........................................... 120 8.2.1 Introduction ................................................................................................... 120 8.2.2 Interveners along the north Foothills line routes .......................................... 123 8.2.3 Views of AltaLink......................................................................................... 124 8.2.4 Views of the interveners ............................................................................... 129

8.2.5 Commission findings .................................................................................... 132 8.3 Tower structure options at the Bow River crossing ................................................... 135

8.3.1 Introduction ................................................................................................... 135 8.3.2 Interveners in the Bow River crossing portion ............................................. 136

8.3.3 Views of AltaLink......................................................................................... 136 8.3.4 Views of interveners ..................................................................................... 137

8.3.5 Commission findings .................................................................................... 138

9 AltaLink Application No. 1608643 Foothills 138-kV transmission development ....... 139 9.1 The preferred and alternate routes.............................................................................. 139 9.2 Views of AltaLink ...................................................................................................... 142 9.3 Views of the interveners............................................................................................. 144


10 AltaLink Applications No. 1608861 and No. 1608862 - South Foothills and Windy Flats

138-kV transmission developments ......................................................................................... 149 10.1 Introduction ................................................................................................................ 149

10.1.1 The preferred and alternate substation sites ................................................ 149 10.1.2 The preferred and alternate transmission line routes .................................. 149

10.1.3 Other project components ........................................................................... 151 10.2 Preferred versus alternate route .................................................................................. 154

10.2.1 Views of AltaLink ....................................................................................... 154

10.2.2 Views of interveners.................................................................................... 158 10.3 Hybrid A versus Hybrid B ......................................................................................... 162

10.3.1 Views of AltaLink ....................................................................................... 162 10.3.2 Views of the interveners .............................................................................. 164

10.4 Preferred versus Hybrid B .......................................................................................... 164 10.4.1 Views of AltaLink ....................................................................................... 164

10.5 Commission findings ................................................................................................. 166 10.5.1 Preferred versus alternate route ................................................................... 166 10.5.2 Hybrid A route versus Hybrid B route ........................................................ 167 10.5.3 Preferred route versus Hybrid B route ........................................................ 167 10.5.4 Preferred route versus CERC route ............................................................. 168

10.5.5 Windy Flats 138S substation ....................................................................... 170

11 ENMAX Application No. 1608649 ................................................................................... 171 11.1 Discussion .................................................................................................................. 171


iv • AUC Decision 2013-369 (October 7, 2013)

12 Decision .............................................................................................................................. 172

Appendix A: Proceeding participants who have registered a statement of intent to

participate ........................................................................................................ 175

Appendix B: Oral hearing ........................................................................................................ 180

Appendix C: Abbreviations ..................................................................................................... 183

Appendix D: Process meeting Decision 2012-360 .................................................................. 186

List of tables

Table 1. AltaLink open houses for the north Foothills project ........................................... 81

Table 2. Proximity to residence comparison between the preferred route and the

alternate route ......................................................................................................... 103

Table 3. Siting comparison between the preferred site and alternate site ....................... 114

Table 4. Comparison between the preferred route and north alternate route ................ 125

Table 5. Comparison between the preferred route and Frank Lake alternate route ..... 128

Table 6. Comparison of the preferred and alternate routes .............................................. 142

Table 7. Project assessment metrics for the preferred and alternate routes ................... 154

Table 8. Incremental residential impacts ............................................................................ 155

Table 9. Project assessment metrics for the hybrid routes ................................................ 163

Table 10. Project assessment metrics for the south portion of the preferred and alternate

routes ........................................................................................................................ 165

AUC Decision 2013-369 (October 7, 2013) • v

List of figures

Figure 1 – Overall project map ....................................................................................................... 2 Figure 2 – Transmission system in 2014 following completion of the East Calgary NID, plus

proposed transmission developments ......................................................................... 22

Figure 3 – AESO 138-kV alternatives in the High River area ..................................................... 25 Figure 4 – Windy Flats configuration ........................................................................................... 26 Figure 5 – Grid Power Fidler to Langdon proposal ...................................................................... 35 Figure 6 – Grid Power proposal – Langdon termination .............................................................. 36 Figure 7 – Grid Power proposal – Fidler termination ................................................................... 37

Figure 8 – Grid Power 911L at 138-kV ........................................................................................ 39 Figure 9 – North Foothills project Study Area (with Preliminary Routes) ................................... 59

Figure 10 – South Foothills project study area (with preliminary routes) .................................... 61 Figure 11 – Langdon to Janet study area (with preliminary routes) ............................................. 63 Figure 12 – 138-kV study area in the High River – Okotoks area ............................................... 65 Figure 13 – Preliminary routes for the 434L/646L line ................................................................ 67

Figure 14 – Component B – proposed routing for the 646L Line ................................................ 68 Figure 15 – Substation target areas ............................................................................................... 70 Figure 16 – North Foothills project preferred and alternate routes .............................................. 75

Figure 17 – South Foothills project preferred and alternate routes .............................................. 76 Figure 18 – Langdon to Janet preferred and alternate routes ........................................................ 77

Figure 19 – Foothills 138-kV project preferred and alternate routes............................................ 78 Figure 20 – AltaLink’s staged environmental approach ............................................................... 88 Figure 21 – Langdon to Janet project area map .......................................................................... 101

Figure 22 – Preferred route/route variant for entering the Langdon and Crossings substations 102

Figure 23 – Frank Lake environmentally significant area and important bird area .................... 117 Figure 24 – North Foothills route options................................................................................... 121 Figure 25 – Alternate Foothills substation .................................................................................. 123

Figure 26 – Cross-section drawings of structure options at Bow River crossing ....................... 135 Figure 27 – Foothills 138-kV route options ................................................................................ 139

Figure 28 – Alternate route segment near Foothills substation .................................................. 140 Figure 29 – Foothills 237S substation preferred and alternate locations .................................... 141 Figure 30 – Phyllis Robertson’s property location ..................................................................... 146 Figure 31 – South Foothills project preferred and alternate routes ............................................ 150

Figure 32 – Terminate 603L into Windy Flats 138S substation ................................................. 152 Figure 33 – Terminate 608L into Windy Flats 138S substation ................................................. 153

AUC Decision 2013-369 (October 7, 2013) • 1


Calgary, Alberta

Decision 2013-369

Alberta Electric System Operator, Applications No. 1608620, No. 1608642,

AltaLink Management Ltd. and No. 1608637, No. 16808643, No. 1608649,

ENMAX Power Corporation No. 1608846, No. 1608861 and No. 1608862

Foothills Area Transmission Development Proceeding ID No. 2001

1 Introduction and background

1. The Alberta Electric System Operator (AESO) filed an application with the

Alberta Utilities Commission (AUC or the Commission) on July 5, 2012, for approval of a needs

identification document (NID) to expand the transmission system in the vicinities of southeast

Calgary, Okotoks and High River. This NID application was registered as Application

No. 1608620 and is referred to in this decision as the Foothills Area Transmission Development

(FATD) need application, or the FATD NID.

2. AltaLink Management Ltd. (AltaLink) filed three facility applications on July 12, 2012,

requesting approval to construct and operate various transmission facilities to meet part of the

need described in the AESO’s FATD need application. The applications were registered as

Applications No. 1608642, No. 1608643 and No. 1608637. ENMAX Power Corporation

(ENMAX) also filed one facility application on July 13, 2012, requesting approval to alter and

operate some of its existing substations to meet the remainder of the need described in the

AESO’s FATD need application. The application was registered as Application No. 1608649.

3. The AESO filed a second application with the AUC on September 21, 2012, for approval

to amend the Southern Alberta Transmission Reinforcement (SATR) NID approval, which

involves the re-termination of a proposed line to a new Windy Flats 138S substation from the

existing Peigan 59S substation in the area southwest of Fort Macleod. This application was

registered as Application No. 1608846 and is referred to in this decision as the SATR NID

amendment.

4. AltaLink subsequently filed two facility applications on September 25, 2012, requesting

approval to construct and operate various transmission facilities to meet the need described in the

AESO’s SATR NID amendment. These applications were registered as Applications

No. 1608861 and No. 1608862.

5. These eight applications were considered jointly by the Commission and designated as

the Foothills Area Transmission Development Proceeding ID No. 2001. The total estimated

project cost for the above applications is approximately $827 million within +20/-10% accuracy.

The following map provides an overview of the facilities proposed in this proceeding.

Alberta Electric System Operator, AltaLink Management Ltd. Foothills Area Transmission Development and ENMAX Power Corporation

2 • AUC Decision 2013-369 (October 7, 2013)

CLARESHOLM

NANTON

VULCAN

GRANUM

STAVELY

FORT

MACLEOD

LITTLE BOW

RIVERCLEAR

LAKEWILLOW

CREEK

T.16

R.24W.4MR.26

22X22X

R.27W.4M.R.28

T.19

T.20

T.21

T.22

R.29

HIGH RIVER

BLACKIE

OKOTOKS

CALGARY

791

797

2

2

552

2

2

783

7

2A

23

23

799

BOW

547

RIVER

FRANK

LAKE

THIRD

LAKE

1201L

552

2A

1201L

HIGHWOOD RIVER

SHEEP

RIVER

CANAL T.23

560 LANGDON

SHEPARD

2

2

3

3

2

533

534

529

520

R.25

23

T.18

T.17

T.15

T.14

T.13

T.12

T.11

T.10

T.9

T.8

Figure 1 – Overall project map



6. The facilities proposed by AltaLink include approximately 200 kilometres of contiguous

transmission lines connecting southeast Calgary to the High River area and to the Fort Macleod

area, and approximately 18 kilometres of transmission line connecting southeast Calgary

eastward to the Langdon area.

7. The Commission issued notice of the applications and of a process meeting for the five

Foothills Area Transmission Development applications on August 28, 2012. The notice provided

the date of and location for the process meeting and a preliminary schedule of the process steps

for the Foothills Area Transmission Development applications. It was published in the

Calgary Herald, Calgary Sun and Okotoks Western Wheel newspapers on September 5, 2012, in

the Chestermere Anchor newspaper on September 6, 2012, and in the High River Times

newspaper on September 7, 2012. It was also mailed directly to all landowners, residents and

other interested parties residing within 800 metres of the edge of the transmission line

right-of-way and substation site boundary for the preferred and alternate routes and sites and all

route options, and delivered to all residences and addresses in the project area by way of a

general postal code drop.

8. The process meeting, scheduled for October 17, 2012, was cancelled because three

additional applications were filed by the AESO and AltaLink between September 21, and

September 25, 2012, which related to the first five Foothills Area Transmission Development

applications by virtue of the proposed Foothills 237S substation. The meeting was cancelled to

give potentially directly and adversely affected parties time to participate in the proceeding.

9. The Commission issued a revised notice of applications and process meeting for the eight

Foothills Area Transmission Development applications on October 19, 2012.1 The notice

provided the revised date and location of the process meeting, and an updated preliminary

schedule of the process steps for the Foothills Area Transmission Development applications.

10. A process meeting was held on November 26, 2012, at the Heritage Inn Hotel &

Convention Centre in High River before Commission member Anne Michaud. The goal of the

process meeting was to establish a schedule and process to fairly and effectively consider the

Foothills Area Transmission Development applications.

11. The Commission issued Decision 2012-3602 with respect to the process meeting on

December 24, 2012. In that decision, the Commission listed the issues it considered to be

relevant to the proceeding, ruled on standing, and set a schedule and process for the

Foothills Area Transmission Development applications.

1 The revised notice was published in the High River Times and Rockyview Weekly newspapers on

October 30, 2012, in the Calgary Herald, Calgary Sun, Okotoks Western Wheel, Nanton News, Vulcan

Advocate, Pincher Creek Echo, Claresholm Local Press and Fort Macleod Gazette newspapers on

October 31, 2012, and in the Chestermere Anchor newspaper on November 2, 2012. It was also mailed directly

to all landowners, residents and other interested parties residing within 800 metres of the edge of the

transmission line right-of-way and substation site boundary for the preferred and alternate routes and sites and

all route options, and delivered to all residences and addresses in the project area by way of a general postal

code drop. 2 Decision 2012-360: Alberta Electric System Operator, AltaLink Management Ltd., ENMAX Power

Corporation, Foothills Area Transmission Development – Process Meeting Decision, Applications

No. 1608620, No. 1608642, No. 1608637, No. 1608643, No. 1608649, No. 1608846, No. 1608861 and

No. 1608862, Proceeding ID No. 2001, December 24, 2012.

http://www.auc.ab.ca/applications/decisions/Decisions/2012/2012-360.pdf



12. AltaLink filed amendments to its facility applications on December 21, 2012. The

Commission issued a notice of amendments to the facility applications for the Foothills Area

Transmission Development applications on January 4, 2013.3

13. AltaLink filed a second amendment to one of its facility applications on March 8, 2013.

14. The Commission issued a notice of hearing for the Foothills Area Transmission

Development applications on March 15, 2013, which noted the March 8, 2013 amendments.4

15. The Commission deemed the applications complete on April 10, 2013.

16. The Commission also held three information sessions, between September 24, 2012, and

November 13, 2012, in High River, Indus and Claresholm. Notification of the information

sessions was provided in the notice of applications and the revised notice of applications.

17. The hearing commenced on Tuesday, May 14, 2013, at the Heritage Inn Hotel &

Convention Centre in High River before Commission member and panel chair Anne Michaud,

Commission member Neil Jamieson and acting Commission member Patrick Brennan. The

hearing concluded on May 30, 2013, at the AUC’s hearing room in Calgary.

18. The Commission deemed the record for this proceeding closed on July 12, 2013.

1.1 The Foothills Area Transmission Development applications

1.1.1 Two AESO need applications

1.1.1.1 FATD need Application No. 1608620

19. The AESO stated that the need for transmission reinforcement in the vicinities of

southeast Calgary, Okotoks and High River is driven predominantly by the future load growth,

insufficient transmission capacity to allow wind generation flow from southern Alberta to the

load centres, and increasing interest in gas-fired generation in the south Calgary and High River

areas. The AESO added that the transmission system constraints could occur as early as 2014.

20. The FATD need application proposed the following major 240-kilovolt (kV)

components:

a 240/138-kV Foothills 237S substation located in the vicinity of High River, including

two 240/138-kV 400-megavolt-ampere (MVA) transformers

3 The notice of amendments was published in the Calgary Herald, Calgary Sun and Okotoks Western Wheel

newspapers on January 9, 2013, and in the High River Times and Chestermere Anchor newspapers on

January 11, 2013; it was mailed directly to all landowners, residents and other interested parties residing within

800 metres of the edge of the transmission line right-of-way and substation site boundary who may be directly

and adversely affected by the amendments. In addition, the notice was delivered to all residences and addresses

in the project area by way of a general postal code drop. 4 The notice of hearing was published in the High River Times and Rockyview Weekly newspapers on

March 26, 2013, in the Calgary Herald, Calgary Sun, Okotoks Western Wheel, Nanton News, Vulcan Advocate,

Pincher Creek Echo, Claresholm Local Press and Fort Macleod Gazette newspapers on March 27, 2013, and in

the Chestermere Anchor on March 28, 2013; it was mailed directly to all landowners, residents and other

interested parties residing within 800 metres of the edge of the transmission line right-of-way and substation site

boundary for the preferred and alternate routes and sites and all route and site options, and was also delivered to

all residences and addresses in the project area by way of a general postal code drop.



a double-circuit 240-kV transmission line between Janet 74S and Langdon 102S

substations, with an approximate summer rating of 800 MVA per circuit

a double-circuit 240-kV transmission line between ENMAX No. 65 and Foothills 237S

substations, with an approximate summer rating of 600 MVA per circuit

a 240-kV transmission line 1109L between ENMAX No. 25 and No. 65 substations by

reusing portions of transmission line 850L, with an approximate summer rating of 490 MVA.

a double-circuit 240-kV transmission line between East Calgary 5S and Langdon 102S

substations by connecting transmission lines 936L and 937L to transmission lines 1077L

and 917L, with an approximate summer rating of 490 MVA per circuit

termination of the 985L line at Janet 74S substation

21. The FATD need application proposed the following major 138-kV components:

a 138-kV transmission line between Foothills 237S and High River 65S substations, with

an approximate summer rating of 260 MVA

a 138-kV transmission line between Foothills 237S and Okotoks 678S substations, with

an approximate summer rating of 260 MVA

reconfiguration of the 850L line between Okotoks 678S and Carseland 525S substations

by using portions of some existing transmission lines and new line segments

discontinued operation of some portions of existing transmission lines which would not

be reused

1.1.1.2 Amendment to the SATR NID Application No. 1608846

22. The SATR NID Approval No. U2011-115,5 issued by the Commission on June 7, 2011,

includes a new double-circuit 240-kV transmission line from Peigan 59S substation to a future

Foothills substation to be located in south Calgary and a static var compensation addition at the

Peigan 59S substation. The AESO’s amendment to this approval sought to re-terminate the new

double-circuit transmission line to a new Windy Flats 138S substation from the existing Peigan 59S

substation and other associated transmission facilities. The AESO stated that the amendment is

driven by a risk to the in-service date for the original approval which arises from work on federal

lands and project cost reduction associated with the Windy Flats option, identified by AltaLink.

23. The amendment proposed to replace the developments associated with Peigan 59S

substation in the approval with the following Windy Flats configurations:

a Windy Flats 138S substation east of Peigan 59S substation, including one 240/138-kV

400 MVA transformer and two shunt reactors

a double-circuit 240-kV transmission line with a maximum 50 per cent series

compensation from Windy Flats 138S substation to Foothills 237S substation

a double-circuit 240-kV transmission line connecting Windy Flats 138S substation to the

967L/968L line via an in and out scheme

5 Approval U2011-115, Alberta Electric System Operator, Southern Alberta Transmission Reinforcement,

Application Nos. 1606564 and 16056526, proceeding ID No. 748, June 7, 2011.

http://www.auc.ab.ca/applications/orders/utility-orders/Utility%20Orders/2011/U2011-115.pdf



a new single-circuit 138-kV transmission line connecting Windy Flats 138S substation

with the 603L line

a new single-circuit 138-kV transmission line connecting Windy Flats 138S substation

with the 608L line

1.1.2 Four facility applications associated with the FATD NID

1.1.2.1 AltaLink Application No. 1608642 – Langdon to Janet

24. The Langdon to Janet project application is comprised of five major components:

construction of approximately 18 kilometres of double-circuit 240-kV transmission line

1064L/1065L from Langdon 102S substation to Janet 74S substation

modification of transmission line 1080L/850L between the ENMAX No. 25 substation

and Janet 74S substation

re-termination of transmission line 936L/937L between the Crossings 511S substation,

and East Calgary 5S substation

expansion of the Janet 74S substation site to install new 240-kV circuit breakers, and

rearrange terminations for several 240-kV transmission lines

expansion of the Crossings 511S substation to add four new 240-kV circuit breakers

25. AltaLink amended this application on March 8, 2013, to relocate four turning structures

of the1064/1065L line, located in the southeast quarter of Section 18, Township 23, Range 28,

west of the Fourth Meridian.

1.1.2.2 AltaLink Application No. 1608637 – north Foothills transmission development

26. The north Foothills transmission development application is comprised of four major

components:

construction of new 240-kV Foothills 237S substation, located in the northwest quarter of

Section 35, Township 18, Range 28, west of the Fourth Meridian

construction of approximately 51 kilometres of double-circuit 240-kV 1106L/1107L line

from Foothills 237S substation to ENMAX No. 65 substation

relocation of the 911L/850L line south of ENMAX No. 65 substation

relocation of a segment of the 850L line onto triple-circuit structures of the 106L/1107L

line

27. AltaLink amended this application on December 21, 2012, to include an alternate

Foothills 237S substation site located in the northwest quarter of Section 8, Township 19,

Range 27, west of the Fourth Meridian. Consequently, the associated 1106L/1107L line route

would be shifted from the preferred Foothills substation site to the alternate Foothills substation

site.



1.1.2.3 AltaLink Application No. 1608643 – Foothills 138-kV transmission development

28. The Foothills 138-kV transmission development application is comprised of five major

components:

addition of a new 138-kV switchyard with two new 240/138-kV transformers in the

Foothills 237S substation

construction of a new 138-kV 646L line from the Foothills 237S substation to

Okotoks 678S substation

construction of a new 138-kV 434L line from Foothills 237S substation

to High River 65S substation; the 434L line would be constructed on double-circuit

towers with the 646L line

alterations to High River 65S substation, the Okotoks 678S substation, the 727L line, the

911L line and the 850L line to facilitate the construction of the 646L line

salvage of the portion of the 727L line between Janet 74S substation and Okotoks 678S

substation

29. AltaLink amended this application on December 21, 2012, to include an additional

138-kV route associated with the alternate Foothills 237S substation site.

30. AltaLink amended this application again on March 8, 2013, to add an additional structure

near the confluence of the 727L and 727AL lines in the southeast quarter of Section 2,

Township 20, Range 29, west of the Fourth Meridian.

1.1.2.4 ENMAX Application No. 1608649

31. The ENMAX application is comprised of four major components:

addition of two 240-kV circuit breakers at ENMAX No. 65 substation

termination of the 1106L line, 1107L line and 1109L line at ENMAX No. 65 substation

termination of the 1109L line and 985L line at ENMAX No. 25 substation

disconnection of the 911L line at ENMAX No. 65 substation

1.1.3 Two facility applications associated with the SATR NID amendment

1.1.3.1 AltaLink Application No. 1608861 – south Foothills transmission development

32. The south Foothills transmission development application is comprised of seven major

components:

construction of a new 240-kV Windy Flats 138S substation located southwest of

Fort McLeod including circuit breakers, reactors and associated equipment

modifications to the existing double-circuit 240-kV 967L/968L line to terminate the

967L/968L line at Windy Flats 138S substation

installation of two additional 240-kV circuit breakers at the Foothills 237S substation



construction of approximately 120 kilometres of double-circuit 240-kV 1037L/1038L

line from the Windy Flats 138S substation to the Foothills 237S substation

construction of a new series capacitor station SC1 266S to provide series compensation

for the proposed double-circuit 240-kV 1037L/1038L line

modification to the portion of 138-kV transmission line 197L just outside of

Stavely 349S substation to provide safe clearance to accommodate the cross-over of the

proposed double-circuit 1037L/1038L line to the preferred site location of capacitor

station SC1 266S

relocation of four sections of the 240-kV 911L line slightly away from the right-of-way

so that the double-circuit 240-kV 1037L/1038L line could be constructed on those

sections of the existing alignment of the 911L line

33. AltaLink amended this application on December 21, 2012, to include additional routes

for the new 1037L/1038L line, due to the inclusion of an alternate Foothills 237S substation site.

These additional routes shift the start point from the preferred Foothills substation site to the

alternate Foothills substation site.

1.1.3.2 AltaLink Application No. 1608862 – Windy Flats 138S substation and line

reconfiguration

34. The Windy Flats 138S substation and line reconfiguration application is comprised of

four major components:

construction of new 138-kV substation equipment at the Windy Flats 138S substation to

include one 138/240-kV 400-MVA transformer, circuit breakers and associated

equipment

connection of the existing 138-kV 603L line to the Windy Flats 138S substation by using

a portion of the existing 603AL line in series with a new 138-kV transmission line

connection of the existing 138-kV 608L line to the Windy Flats 138S substation by using

a portion of existing transmission line 608L in series with a new 138-kV transmission

line

installation of airbreaks on the 608L and 608AL lines for isolation and reliability

purposes

1.2 Process for new transmission and legislative framework

35. Two approvals from the Commission are required to build new transmission in Alberta,

other than critical transmission infrastructure. The first is an approval of the need for expansion

or enhancement to the system pursuant to Section 34 of the Electric Utilities Act. The second is a

permit to construct and a licence to operate a transmission line pursuant to sections 14 and 15 of

the Hydro and Electric Energy Act.

36. Under the Electric Utilities Act, the Alberta Electric System Operator (AESO), in its

capacity as the Independent System Operator (ISO), is responsible for preparing a document

called a needs identification document. The needs identification document describes the need for

new transmission and proposes a transmission solution to meet that need (this is also referred to

as a need application). The AESO files the need application with the Commission for approval,



pursuant to Section 34 of the Electric Utilities Act. When making a decision on a contested need

application, in accordance with subsection 34(3) of the Electric Utilities Act, the Commission

may approve the needs identification document, refer the needs identification document back to

the AESO with directions or suggestions for changes or additions, or refuse to approve the needs

identification document.

37. Facility applications are prepared by a transmission facility owner assigned by the AESO.

When considering an application for a transmission facility, the Commission must consider

whether the proposed transmission line is in the public interest having regard to the social and

economic effects of the transmission line and the effect of the transmission line on the

environment, pursuant to Section 17 of the Alberta Utilities Commission Act.

1.2.1 Need applications

38. Section 33 of the Electric Utilities Act states in part:

33(1) The Independent System Operator must forecast the needs of Alberta and develop

plans for the transmission system to provide efficient, reliable and non-discriminatory

system access service and the timely implementation of required transmission system

expansions and enhancements.

39. Section 34 of the Electric Utilities Act states in part:

34(1) When the Independent System Operator determines that an expansion or

enhancement of the capability of the transmission system is or may be required to meet

the needs of Alberta and is in the public interest, the Independent System Operator must

prepare and submit to the Commission for approval a needs identification document that

(a) describes the constraint or condition affecting the operation or performance of

the transmission system and indicates the means by which or the manner in

which the constraint or condition could be alleviated,

(b) describes a need for improved efficiency of the transmission system, including

means to reduce losses on the interconnected electric system, or

(c) describes a need to respond to requests for system access service.

(2) On its own initiative or in response to views expressed by the Commission, the

Independent System Operator may amend a needs identification document submitted to

the Commission for approval.

40. Section 11 of the Transmission Regulation, which describes the information that the

AESO must include in a need application, specifies that it must include an assessment of current

transmission capacity; load and generation forecasts; studies and analysis that identify the timing

and nature of the need for new transmission; and a technical and economic comparison of the

technical solutions considered by the AESO to address the need identified. Section 11 also

requires a need application to state which technical solution the AESO preferred.

41. Section 38 of the Transmission Regulation describes what principles and matters the

Commission must have regard for when deciding upon a need application. Subsection 38(e)

requires the Commission to consider the AESO's assessment of the need to be correct unless an



interested person satisfies the Commission that the assessment is technically deficient, or that

approval of the need application would not be in the public interest. Subsection 38(e) states:

38 When considering whether to approve a needs identification document under

section 34(3) of the Act the Commission must:

…

(e) consider the ISO’s assessment of the need to be correct unless an interested

person satisfies the Commission that

(i) the ISO’s assessment of the need is technically deficient, or

(ii) to approve the needs identification document would not be in the public

interest.

42. The first need application considered by the Commission's predecessor, the Alberta

Energy and Utilities Board (EUB or the Board), was for 240-kilovolt transmission upgrades

between Pincher Creek and Lethbridge. The Board described the needs assessment process as

follows:

It is the Board's view that section 34 contemplates a two-stage consideration of a NID. In

the first stage, the Board must determine whether an expansion or enhancement of the

capability of the transmission system is necessary to alleviate constraint, improve

efficiency, or respond to a request for system access.

If it is determined that expansion or enhancement of the system is required to address

constraint, inefficiency, system access requests, or any combination thereof, the Board

must then assess, in the second stage, whether enhancement or expansion measures

proposed by AESO are reasonable and in the public interest.6

43. The Commission has consistently followed this approach when deciding upon need

applications.7

1.2.2 Facility applications

44. Under Section 35 of the Electric Utilities Act, the AESO may direct, at the time of

preparing a needs identification document, after filing a needs identification document, or after

receiving an approval of a needs application, a transmission facility owner to submit a

transmission facility proposal to meet the need identified. In this case, the AESO directed

AltaLink and ENMAX, respectively, to prepare the above-mentioned facility applications. The

applications were filed under sections 14 and 15 of the Hydro and Electric Energy Act, which

state:

14(1) No person shall construct a transmission line or any part of a transmission line

unless the person is the holder of a permit issued by the Commission.

6 EUB Decision 2004-087, Southwest Alberta 240-kV Transmission System Development Addendum to

Decision 2004-075, Application No. 1340849, October 14, 2004, pages 13-14. 7 EUB Decision 2005-049: Alberta Electric System Operator Needs Identification Document Application

Southwest Alberta 240-kV Transmission System Development Pincher Creek – Lethbridge Area, page 5; AUC

Decision 2009-126: Alberta Electric System Operator, Needs Identification Document Application Southern

Alberta Transmission System Reinforcement, Application No. 1600862, Proceeding ID No. 171, September 8,

2009, page 1; Decision 2010-188: Alberta Electric System Operator, Needs Identification Document

Application Hanna Region Transmission System Development, Application No. 1605359, Proceeding ID

No. 278, April 29, 2010, page 3.



(2) No person shall make a significant extension or alteration of a transmission line

unless the Commission has amended the person’s permit or issued a new permit to cover

the extension or alteration.

(3) Repealed 2007 cA-37.2 s82(14).

(4) This section does not preclude a person proposing to apply for a permit or the

person’s agents from

(a) entering on any Crown or other land lying in the intended route of the

transmission line to make surveys or examinations, or

(b) negotiating for the acquisition of interests in land that may be required for the

transmission line.

15 No person shall operate a transmission line unless the person is the holder of a

subsisting licence to operate the transmission line, issued by the Commission.

45. Section 15.1 of the Hydro and Electric Energy Act states that the Commission, in

considering a facility application, shall take into account a certification by the AESO. It states:

15.1 When the Commission is considering an application for an approval, permit or

licence under this Part in respect of a transmission line or part of a transmission line that

has the potential to meet a need identified in a needs identification document that has

been approved by the Commission under section 34(1) of the Electric Utilities Act, the

Commission shall take into account a certification by the Independent System Operator

that the technical aspects of the application meet the requirements set out in the needs

identification document.

46. The Commission may combine a need application and a facility application which

pertains to the need application pursuant to Section 15.4 of the Hydro and Electric Energy Act.

47. In making its decision on a facility application, the Commission must consider whether

the project is in the public interest. Section 17 of the Alberta Utilities Commission Act reads in

part:

17(1) Where the Commission conducts a hearing or other proceeding on an application to

construct or operate a …transmission line under the Hydro and Electric Energy Act… it

shall, in addition to any other matters it may or must consider in conducting the hearing

or other proceeding, give consideration to whether construction or operation of the

proposed… transmission line is in the public interest, having regard to the social and

economic effects of the …line …and the effects of the…… line …on the environment.

48. Regarding the interpretation of “public interest”, the Commission is mindful of

Decision 2009-028,8 which states:

…The Commission recognizes that there is no universal definition of what comprises the

“public interest” and that its meaning cannot be derived from strictly objective measures.

The Commission acknowledges that the ultimate determination of whether a particular

project is in the “public interest” will largely be dictated by the circumstances of each

transmission facility application.

8 Decision 2009-028: AltaLink Management Ltd. – Transmission Line from Pincher Creek to Lethbridge,

Application No. 1521942, Proceeding ID No. 19, March 10, 2009.




In the Commission's view, assessment of the public interest requires it to balance the

benefits associated with upgrades to the transmission system with the associated impacts,

having regard to the legislative framework for transmission development in Alberta. This

exercise necessarily requires the Commission to weigh impacts that will be experienced

on a provincial basis, such as improved system performance, reliability, and access with

specific routing impacts upon those individuals or families that reside or own land along

a proposed transmission route as well as other users of the land that may be affected. This

approach is consistent with the EUB's historical position that the public interest standard

will generally be met by an activity that benefits the segment of the public to which the

legislation is aimed, while at the same time minimizing, or mitigating to an acceptable

degree, the potential adverse impacts on more discrete parts of the community.

When assessing whether AltaLink's proposed route is in the public interest, the

Commission must weigh the benefits with the site specific impacts that will be

experienced by landowners and residents along the proposed route as well as others that

may be impacted. The Commission understands that these impacts are real and may be

significant. Transmission towers are large structures that may obscure scenery, impact

agricultural operations, and may have an influence on land use and development plans.

The Commission expects transmission facility owners to take all reasonable steps to

avoid such impacts but acknowledges that despite the use of sound routing and planning

practices such impacts are sometimes truly unavoidable given the nature of transmission

lines. Where such impacts are truly unavoidable, the Commission expects that the

Applicant would explore all reasonable steps to mitigate those impacts.9

49. The Commission has consistently applied this interpretation of "public interest".

50. The Commission may approve, approve with conditions, or deny a facility application.

Section 19 of the Hydro and Electric Energy Act states:

19(1) On an application for an approval, permit or licence under this Part, or for an

amendment of an approval, permit or licence, the Commission may grant the approval,

permit, licence or amendment subject to any terms and conditions that it prescribes or

may deny the application.

(1.1) Notwithstanding subsection (1), the Commission shall not refuse an approval of a

transmission line or part of a transmission line designated as critical transmission

infrastructure as defined in the Electric Utilities Act on the basis that, in its opinion, it

does not meet the needs of Alberta.

(2) Without restricting the generality of subsection (1), the Commission may do one or

more of the following:

(a) require changes in the plans and specifications of a hydro development, power

plant or transmission line;

(b) require changes in the location of a hydro development, power plant or

transmission line;

(c) prescribe a date before which the construction of, or operation of, the hydro

development, power plant or transmission line must commence;

9 Decision 2009-028, paragraphs 32, 33 and 35.



(d) prescribe the location and route of the transmission line as precisely as it

considers suitable;

(e) prescribe the location of the right of way of the transmission line and the

relationship of its boundaries to the transmission line or any part of the

transmission line.

1.2.3 Other requirements

51. Applications must meet the informational and other requirements set out in AUC

Rule 007: Applications for Power Plants, Substations, Transmission Lines and Industrial System

Designations (AUC Rule 007). Applicants must provide technical and functional specifications,

environmental information including noise assessments, information on public consultation,

route selection criteria and the cost of a proposed project.

52. In addition, applicants must seek the requisite approvals under other applicable provincial

or federal legislation.

2 The AESO’s need applications

53. This section discusses the AESO’s two need applications, including the views of the

applicants and interested parties, and the Commission findings on the evidence related to the two

applications. The parties who objected to or had concerns with the need applications and

provided evidence are listed below:

the Diagonal group

Phyllis Robertson

Industrial Power Customers Association of Alberta

Benign Energy Canada II Inc.

TransAlta Corporation

ENMAX Green Power Inc.

ENMAX Shepard Inc.

TransCanada Energy Ltd.

Ronald and Laurie Conner

Powerex Corp.

54. Grid Power Development and Design Inc. (Grid Power) was hired by both the

Diagonal group and Phyllis Robertson to perform technical assessments of the AESO’s need

applications. Grid Power prepared a technical report on behalf of the Diagonal group to evaluate

some of the 240-kV components within the need applications and recommended a Fidler to

Langdon proposal. Further, Grid Power prepared a technical report on behalf of Mrs. Robertson

to evaluate the 138-kV components in the High River area proposed in the FATD NID and

recommended a 911L at 138-kV proposal.



2.1 Assessment of the need to expand the transmission system in southern Alberta

2.1.1 Views of the AESO

2.1.1.1 Application No. 1608620 – FATD NID

55. The AESO stated that the need for transmission reinforcement in the vicinities of

southeast Calgary, Okotoks and High River is driven by the forecasted load growth in the area,

integration of local gas-fired generation to the system and accommodation of the transfer of wind

generation from southern Alberta. The AESO forecasted that the load in the Calgary,

Strathmore/Blackie and High River planning areas will increase by approximately

450 megawatts (MW), or 25 per cent, by 2021; while the installed wind generation in Alberta is

forecasted to increase by approximately 1,600 MW, to a total of approximately 2,500 MW by

2019. The AESO further stated that the local gas-fired generation plants, with a combined

capacity exceeding 1,300 MW, had applied for system access service in or adjacent to the south

Calgary area for an in-service date as early as 2014.

56. The AESO’s system studies focused on the transmission system in south Calgary and the

High River planning area, which it collectively referred to as the study area, or south Calgary

area. The High River planning area includes the towns of Black Diamond, Turner Valley,

High River, Okotoks and the areas between these towns.

57. The AESO first identified transmission system reliability constraints in the south Calgary

area in its 2009 Long-term Transmission Plan. These reliability constraints include both thermal

overloads and voltage violations. The AESO confirmed these system constraints in its 2011

Long-term Transmission Plan.

58. The AESO reported that it conducted detailed system performance analyses and

developed a transmission system expansion plan, referred to as the 2011 Foothills Area

Transmission Development plan, in its 2011 engineering report. The 2011 FATD engineering

report assessed the existing transmission system in the study area based on the AESO’s 2009

Corporate Load Forecast (referred to as FC2009) and two generation scenarios (scenario A1 -

high northern generation development and scenario B5 - high southern generation development)

from its 2009 Long-term Transmission Plan. The 2011 FATD engineering report concluded that

the study area will experience several thermal overloads under normal and single-contingency

operating conditions in 2014, due to steady load growth, insufficient transmission capacity to

allow power flow from southern Alberta to the load centres, and insufficient transmission

capacity to integrate new local generation. It also concluded that there is a risk of voltage

collapse in the High River planning area following a single-contingency event during the

summer peak load condition due to the forecasted load growth in the area, and an inadequate

transmission supply connecting this area to the grid. The AESO noted that both thermal

overloads and voltage violations increase significantly by 2019.

59. The AESO updated its generation forecast in its 2011 Long-term Transmission Plan.

Subsequently, the AESO conducted sensitivity studies applying the updated generation forecast

in its 2011 FATD engineering report. The study results indicated to the AESO that the proposed

FATD plan is required in the second quarter of 2014.



60. The AESO performed one set of sensitivity studies in 2012 to determine whether the

69-kV transmission upgrades in south Calgary would affect the conclusions and

recommendations in the 2011 FATD engineering report. Originally, the AESO applied to

upgrade the 69-kV transmission system in south Calgary in its need Application No.1604960

(Proceeding ID No. 234). These proposed 69-kV transmission system upgrades were modelled in

the 2011 FATD engineering report; however, the AESO amended the need application in

April 2012. The need application was subsequently approved in Decision 2012-194.10 The

sensitivity studies performed by the AESO for Proceeding ID No. 234 replaced the originally-

proposed 69-kV transmission upgrades in south Calgary with the existing transmission system in

south Calgary. The AESO compared the results of the sensitivity studies with the results of the

2011 FATD engineering report and found that the conclusions of the assessment of the need in

the 2011 FATD engineering report would not be materially impacted if the 69-kV transmission

upgrades in south Calgary are not built.

61. Based on the AESO’s 2012 long-term outlook load and generation forecast, referred to as

the 2012LTO, the AESO performed a second set of sensitivity studies in 2012 (2012LTO and

high-voltage direct-current (HVDC) dispatch supplementary report) to determine whether the

2012LTO and the 2012LTO combined with various dispatch assumptions of the Western Alberta

Transmission Line (WATL) and the Eastern Alberta Transmission Line (EATL), referred to as

2012LTO+HVDC, will affect the conclusions and recommendations made in the 2011

engineering report. The summer peak load in Calgary, Strathmore/Blackie and High River area

was forecasted by the AESO to be 2,123 MW in 2019 in the 2012LTO, in comparison with

2,338 MW in the FC2009. The installed wind generation in Alberta by 2019 was forecasted to be

2,544 MW for the environmental scenario in the 2012LTO, in comparison with 4,488 MW for

scenario B5 - high southern generation in the AESO’s 2009 Long-term Transmission Plan.

According to the AESO, the results of these sensitivity studies confirmed the need assessment in

the 2011 FATD engineering report. The AESO indicated that the 2012LTO+HVDC scenario

showed an increase in the trend for the identified overloads as compared to those of the

2012LTO scenario.

62. Based on the above studies, the AESO stated that prior to the proposed transmission

development in the FATD NID, the transmission system throughout the south Calgary area

would be subject to line overloading, voltage violations and curtailment of generation output.

The AESO noted that such reliability criteria violations are not permitted under Alberta

Reliability Standards and would compromise the ability of the transmission system to reliably

serve load in the area. It further noted that such violations would constrain generation production

even under normal operating conditions, which would limit the AESO’s ability to provide system

access service in a manner that gives market participants a reasonable opportunity to exchange

electricity and ancillary services.

63. The AESO stated that its participant involvement program for the FATD need application

was conducted between November 2010 and June 2012. The AESO directed the transmission

facility owners, ENMAX and AltaLink, to assist in the conduct of the participant involvement

program. ENMAX, AltaLink and the AESO utilized various methods to notify occupants,

residents and landowners of the need for the project and held open houses between February and

November 2011. The AESO also consulted with the representatives of municipalities to discuss

10

AUC Decision 2012-194, Alberta Electric System Opreator, AltaLink Management Ltd., ENMAX Power

Corporaion, South Calgary 69-kV Transmission System Upgrade, Proceeding ID No. August 8, 2012.




and address any concerns. It consulted with the Town of High River, the Town of Okotoks, the

City of Calgary, the Municipal District (M.D.) of Foothills and the M.D. of Rocky View County,

as well as government agencies, organizations, industry companies, First Nations and Métis

Nations.

64. The AESO also publicized its intention to file the FATD need application in newspapers

within the project area.

2.1.1.2 Amendment to the SATR NID

65. The AESO stated that the proposed amendment does not change the need for the

enhancement of the capability of the transmission system described in the SATR NID. Instead, it

seeks to amend the approved technical solution to address that need, that is, the south termination

of the 240-kV 1037L/1038L line (911L line rebuild) at the new Windy Flats 138S substation,

instead of the existing Peigan 59S substation. Therefore, the AESO explained that no need

assessment on the existing transmission system was performed.

66. The AESO stated that the approved SATR milestone11 for the 911L line rebuild has been

met since 2010, and confirmed that the milestone continues to be met by the latest wind

generation forecasts.12 The AESO stated that there would be constraints on the existing 911L line

under normal operating conditions and added that it has a statutory obligation to ensure the

timely implementation of transmission system developments to alleviate the constraints so

market participants will not be adversely affected by the absence of reliable transmission system

access.

67. In February 2013, the AESO published the 2012 Long-term Outlook Update

(2012LTOU). In the 2012LTOU, there is approximately 1,560 MW of total wind generation in

Alberta by 2017. The AESO explained that the revised wind generation forecast in the

2012LTOU was only the base case scenario and that the environmentally-driven scenario

remains valid.

68. The AESO stated that there are 14 wind projects currently in the AESO’s interconnection

queue, most of them with proposed in-service dates between 2014 and 2016,13 and that the reason

that some of the wind project developers are not proceeding is the lack of transmission capacity.

The AESO stated that it would be unreasonable to expect wind developers to complete their

investments and then sit and wait for transmission access, and that it’s inappropriate for the

AESO to require that these investments be made before filing a NID for transmission system

development. It submitted that it has a statutory obligation to anticipate the timing and location

of future generation additions, and to ensure that transmission is available to meet these future

needs.

69. The AESO conducted a participant involvement program in respect of its SATR NID

amendment from November 2010 to September 2012. It notified and consulted, as necessary,

with all occupants, residents and landowners within 800 metres of the proposed development, as

well as government agencies, industry companies, First Nations, and Métis Nations.

11

NID Approval No. U2010-264, Alberta Electric System Operator, Southern Alberta Transmission System

Reinforcement with Finalized Milestones, July 19, 2010. 12

Exhibit 889.01, AESO reply argument, paragraph 11. 13

Exhibit 755.01, AESO project list.



2.1.2 Views of the Diagonal group

70. The Diagonal group stated that there is no urgency for the 911L line rebuild due to

changes in market conditions and the approval of major transmission facilities. The group added

that it respected the Commission’s direction in Decision 2012-360 that the application to amend

the SATR NID did not re-open the issue of the underlying need that the solution was designed to

address. The Diagonal group submitted that the report prepared by Grid Power, recommending

the move of the north and south termination points of the 911L line rebuild to Langdon and

Fidler substations respectively, did not question the underlying need for this line.14

2.1.3 Views of Phyllis Robertson

71. Despite having concerns with the proposed Foothills 138-kV development,

Phyllis Robertson acknowledged that the power system needs an upgrade.15 Grid Power was

retained by Mrs. Robertson. Grid Power acknowledged in its report that the AESO had justified

the need for additional load supply in the High River area on the basis of the AESO’s 2009 load

forecast and an assumed operating condition where all local generation is simultaneously

out-of-service. The report stated that system re-enforcements would be required in the five-plus

years time horizon for the High River regional system; although there is no immediate urgent

need, additional load supply capability would likely be required by 2017, and on this basis, it

recommended the acceptance of the AESO’s position that system improvements in the

High River area are required.

2.1.4 Views of Industrial Power Consumers Association of Alberta (IPCAA)

72. IPCAA questioned the need for the 911L line rebuild on the basis that the fundamental

conditions that justify the original SATR need have changed significantly since it was approved

in 2009.

73. IPCAA submitted that there is a 50 per cent reduction to the wind development forecast

in the AESO’s latest generation forecast. The original wind generation forecast in the SATR

ranged from 2,200 MW to 3,900 MW by 2017, which was driven by the anticipated economic

conditions of high natural gas prices and the ability to sell renewable energy credits to California.

However, IPCAA observed that the oversupply of natural gas in the North American market has

driven down the price leading to combined cycle plants having more economic merit than wind

generation. Further, IPCAA noted that California has altered its legislation on carbon dioxide

(CO2) offsets to encourage local green generation development, which contributed to a dramatic

drop in the wind development forecast. IPCAA noted that the AESO was now predicting only

1,352 MW of wind generation in southern Alberta by 2017, and 2,019 MW by 2022.16 Based on

the intended capacity of the planned stages of the SATR NID approval, IPCAA submitted that

Stage I is sufficient until 2017, and no decision should be made to initiate any construction of

Stage II until at least 2020.

74. IPCAA submitted that the SATR need was developed prior to the approval of the

two north to south high-voltage direct-current lines. With the addition of the two high-voltage

direct-current lines, it argued that the underlying bulk system configuration on which the original

14

Exhibit 896.01, Diagonal group reply argument, page 4, paragraph 15. 15

Exhibit 788.01, Revised opening statements from Phyllis Robertson, page 3, paragraph 15. 16

Exhibit 450.01, IPCAA Statement of intent to participate, page 2.




SATR need was based, has been radically altered. IPCAA anticipated that much of the southern

Alberta wind production could be transported through these high-voltage direct-current lines.

75. IPCAA argued that due to the dramatic changes of the wind generation forecast and bulk

system configuration, the in-service date for the 911L line rebuild is questionable. It contended

that it is a project built for generation congestion, not load supply reliability. IPCAA added that

the sense of urgency is artificial because there are methods of managing constraints that should

be considered, such as using dynamic thermal line ratings, proposed by the AESO in this

proceeding as the solution to address the issues raised by Powerex, or remedial action schemes,

as an interim measure to address congestion issues. IPCAA submitted that the Commission

should send back both need applications to the AESO and direct the AESO to re-examine its

in-service date.

76. IPCAA also submitted that the estimated cost for Stage I of the SATR has doubled since

the SATR NID was approved. Without the proper fixed cost contracts in place to ensure project

development accountability, there is no guarantee that the cost would not continue to rise as the

lines are built. It argued that the estimated $1.8 billion in capital cost to implement the SATR

need would represent significant savings for Alberta consumers, if the project is in fact no longer

needed.

2.1.5 Views of Benign Energy Canada II Inc. (Benign Energy)

77. Benign Energy supported the FATD project because the transmission system in southern

Alberta had been underbuilt for years. It explained that it is the holder of an AUC permit for the

construction and a licence to operate the Heritage wind farm, and submitted that the AESO

advised that only 100 MW of an approved total of 297 MW could be tied into the transmission

system. It noted that, along with other similar wind projects, the Heritage wind farm project

remained subject to significant transmission constraint in southern Alberta. It was also advised

by the AESO that the facility applications in the FATD project are required for its Heritage

project to transmit its electricity to the market.

78. Benign Energy submitted that construction of transmission lines and related substations

in the north and south Foothills applications are necessary to relieve a bottleneck of electricity

constraining generation in southern Alberta. In particular, it is anticipated that the Heritage

project will tie into the Fidler substation, which will eventually link to the Windy Flats 138S

substation for transmission to the proposed Foothills 237S substation and Janet 74S substation.

Benign Energy submitted that failure to approve the FATD applications would render it unable

to fully build the Heritage wind farm or would result in delays and modifications that will have

significant and adverse economic consequences.

2.1.6 Views of TransAlta Corporation (TransAlta)

79. TransAlta supported the AESO’s SATR NID amendment and associated facility

applications, and submitted that there are existing transmission constraints that are frequently

imposed on its wind generating facilities in the Pincher Creek area, even under normal operating

conditions. For example, it is currently experiencing constraints at its Ardenville, Blue Trail and

Soderglen wind generating facilities.



80. TransAlta explained that early in 2013, the AESO had notified it of the proposed

connection of a new wind aggregated generating facility, adding that the connection of this

project may introduce additional constraints which may occur under normal and abnormal

operating conditions. TransAlta stated that it was advised by the AESO that the proposed

double-circuit line from the Windy Flats substation to the Foothills substation planned for 2015

will remove the identified system constraints. TransAlta stated that the facilities in the south

Foothills project are urgently required and supports the earliest possible in-service date in order

to alleviate known constraints, which are directly and adversely impacting its generating

facilities.

2.1.7 Views of ENMAX Green Power Inc. (EGPI) and ENMAX Shepard Inc. (ESI)

81. Both EGPI and ESI are in support of the FATD NID application. EGPI is the parent

company of ESI, which owns the Shepard Energy Centre. They submitted that the Shepard

Energy Centre, the expected in-service date of which is January 1, 2015, needs the facilities

proposed in the FATD in order to deliver its full capacity to the grid in a timely manner.

2.1.8 Commission findings

2.1.8.1 Application No. 1608620 – FATD NID

82. As noted in paragraph 39, Section 34 of the Electric Utilities Act contemplates a

two-stage assessement of need applications. First, the Commisison considers whether an

expansion or enhancement of the existing transmission system is necessary to alleviate

constraint, improve efficiency or respond to a request for system access. Second, the

Commission considers if the AESO’s preferred alternative to address that need is reasonable and

in the public interest.

83. With respect to the first stage assessment of the FATD NID, the Commission observes

that no party disputed the AESO’s conclusion that there is a need to expand and enhance the

transmission systems in the vicinities of southeast Calgary, Okotoks and High River. To the

contrary, all of the parties recognized that some measures were required to address this need. The

real dispute amongst the parties relates to the means proposed by the AESO to address the

identified need, a topic that the Commission addresses in Section 2.2 below.

84. The Commission has reviewed the load and generation forecasts prepared by the AESO

in support of the NID and considers that those forecasts reflect recent changes in market

conditions and up-to-date information regarding future generation. Although the AESO’s future

wind generation forecast has dropped compared to earlier forecasts, it continues to forecast

2,544 MW of total installed wind generation by 2019 in its 2012LTO environmentally-driven

scenario. Likewise, the AESO continues to forecast load growth for the area, although at a more

modest pace than it previously predicted. The Commission is satisfied that the assumptions made

by the AESO in its load and generation forecasts are sound, and that the forecasts themselves are

reasonable.

85. The Commission is similarly satisfied that the power system planning studies, undertaken

by the AESO under various scenarios, support the AESO’s conclusion that there is a need to

expand or enhance the transmission system in the study area to avoid reliability constraints in the

southeast Calgary, Okotoks and High River areas.



86. The Commission also finds that sensitivity studies undertaken by the AESO confirm the

need to expand or enhance the transmission system in the study area. The Commission notes, in

that respect, that those studies appropriately took into account recent changes in system

configurations such as the WATL and EATL, and verified the need for upgrading the

transmission system in the study area. The Commission accepts the results of the sensitivity

study that while certain planned facilities such as the Foothills to Sarcee line could be delayed,

the system upgrades are required in the study area by 2014.

87. The Commission concludes that the AESO’s load and generation forecasts for the study

area are reasonable and concludes that there is a need to expand and enhance the transmission

system in the vicinities of southeast Calgary, Okotoks and High River. The Commission accepts

that the need for system reinforcement in the area is primarily driven by the need for facilitating

the transfer of wind generation from southern Alberta, interconnection of local gas-fired

generation and forecasted load growth.


88. While IPCAA questioned the ongoing validity of the SATR NID approval given changes

to market conditions since it was issued, the Commission finds that it is not an issue that it

should properly consider in this proceeding.

89. The AESO’s application to amend the SATR NID approval did not relate to the need to

expand or enhance the transmission system in southern Alberta. Rather, its amendment request

was specific to one element of the SATR NID approval, its preferred technical solution to

address the need for the 911L line rebuild. Because the AESO is not seeking to amend that

aspect of the SATR NID approval, and because the ongoing validity of that determination was

not raised in a subsequent application to review and vary the SATR NID approval, the

Commission finds that the concerns raised by IPCAA in this respect are not properly before it.

Notwithstanding the Commission’s conclusion that this element of the SATR NID approval is

not properly before it in this proceeding, the Commission is of the view that the need for the

911L line rebuild is consistent with the AESO’s finalized SATR milestones for staged

implementation approved by the Commission. Specifically, the Stage I construction milestone

for the 911L line rebuild approved by the Comission was 500 MW of generation forecast in

Pincher Creek and the Peigan region. In this proceeding, the AESO reiterated that this milestone

has been met since 2010, and continues to be met by the latest wind generation forecast.

90. Because it is the Commission’s view that its previous approval of the need to expand or

enhance the transmission system in southern Alberta continues to be in force, it is of the view

that the only issue raised by the SATR NID amendment is whether the technical solution (Windy

Flats configuration) proposed is the appropriate technical solution to meet that need. That issue is

discussed below.

2.2 Reasonableness of the proposed technical solutions

91. Because Grid Power’s Fidler to Langdon and 911L at 138-kV proposals in relation to the

technical solutions are intrinsically linked with the facility applications, the Commission is

addressing the Grid Power proposals in conjunction with the need applications.



2.2.1 Views of the AESO

2.2.1.1 FATD NID

240-kV system development

92. The AESO stated that reconfiguring, upgrading or rebuilding existing transmission lines

was preferred over transmission development options that required distinctly separate new

corridors to minimize land impacts and maximize the efficient use of existing rights-of-way. The

AESO added that a voltage conversion from 138-kV to 240-kV was also considered where

possible. Further, it stated that it employed an incremental approach to isolate, and subsequently

alleviate constraints and reliability violations caused by existing transmission lines to satisfy the

requirements of the Alberta Reliability Standards in the long-term. Except for the proposed

FATD plan, the AESO did not develop any other alternatives to the 240-kV transmission system

expansion plan.

93. The AESO explained that its 2011 FATD plan was derived from the its 2011 FATD

engineering report and was comprised of four development steps. Step one included

reinforcement of the 240-kV transmission path from the Langdon 102S substation to Janet 74S

substation to East Calgary 5S substation, which was applied for in the East Calgary transmission

system upgrades and the Shepard Energy Centre connection project, and approved in

Decision 2012-283.17 Steps two and three included all the transmission facilities applied for in

the FATD NID. Step four included possible future transmission upgrades. The major component

of the step four development was a new 240-kV double-circuit transmission line from Sarcee

42S substation to Foothills 237S substation.

94. The AESO explained that its 2012LTO and HVDC dispatch supplementary report

assumed the following system configurations:

FATD East configuration: includes steps one to three of the 2011 FATD plan

FATD East plus third-circuit configuration: includes steps one to three of the 2011 FATD

plan, as well as the new 138-kV circuits connecting the ENMAX No. 65 to No. 54 to

No. 41 substations

FATD full configuration: includes steps one to four of the 2011 FATD plan

95. The following figure, found in the FATD NID, illustrates the proposed 240-kV

transmission facilities in the AESO’s FATD NID:

17

Decision 2012-283, Alberta Electric System Operator, AltaLink Management Ltd., ENMAX Power

Corporation, East Calgary Transmission Project and Shepard Energy Centre Interconnection, Proceeding

No. 1229, November 1, 2012.




T

72

7L

72

7L

85

0L

911L

De-e

nerg

ized

1

03

7L

9

85

L

1109L (

old

8

50L @

24

0kV

)

10

03

L

10

38

L

1080L (

se

ctio

ns o

f 9

11

L)

Transmission System in 2014 following completion of the East Calgary

NID, plus Proposed Transmission Developments

Sarcee

East Calgary

5S

936L 937L

E

x Janet

x 42S 916L

SS-2 2.80L

SS-23

23.80L

74S

D

1064L

1065L

Note:

This diagram contains a

simplified representation of

the system configuration.

Technical detail has been

simplified for illustration

purposes. It does not

indicate geographical

locations of facilities. Some

existing substations and

circuits are not shown.

J

SS-25

I

F

Langdon

102S

C

Legend

Existing 138 kV

New 138 kV

Existing 240 kV SS-65

1106L

1107L

x

XXXX

New 240 kV

Join existing lines

Energized with FATD-East

New substation included in

FATD East NID

x 850L

H

G

B

Carseland

525S

De-energize 138 kV

De-energize 240 kV

Okotoks

678S

727AL

646L

L

FATD-East NID

o Magcan

142S K

A Foothills

237S

A Summary List Reference 434L

High River 65S

Figure 2 – Transmission system in 2014 following completion of the East Calgary NID, plus proposed transmission

developments



96. The AESO disagreed with Grid Power that the Fidler to Langdon proposal would offer

more system capability than the AESO’s FATD plan. The AESO pointed out that Grid Power

included the high-voltage direct-current lines in its analysis of its Fidler to Langdon proposal but

excluded them when evaluating the AESO’s proposal. The AESO explained that Grid Power

used WATL and EATL to alleviate overloads in the post-contingency period. Wind generation

was then increased in the post-contingency period by redispatching WATL and EATL, until one

or both of them reached their respective limits. The AESO concluded that such an approach

yields a higher total transfer capability (TTC) than is practically feasible for the operation of the

high-voltage direct-current lines. The AESO stated that its TTC analysis demonstrates that its

FATD plan provides significantly more TTC than the Fidler to Langdon proposal under all

options.18

97. According to the AESO, a TTC analysis is recognized as a test of transfer capability and

is not, in any event, a substitute for a full reliability assessment. It explained that the TTC

analysis may not accurately model future loads and generation because it simply assumes load

and generation are added at specific locations to stress specific transmission paths.

98. The AESO argued that it did not create the overload of the 936L/937L line for the Fidler

to Langdon proposal by dispatching WATL at zero MW. It noted that it is required to make

assumptions to support transmission system planning and it previously established a high-voltage

direct-current dispatch methodology for planning purposes. The AESO stated that it consistently

applied this methodology to model both the performance of the ENMAX No. 65 substation

termination proposed in the FATD plan and the Langdon termination proposed by Grid Power.

The AESO submitted that, from a long-term planning perspective, the ENMAX No. 65

substation termination is more robust than a Langdon termination because it satisfies the Alberta

Reliability Standards under a wider range of operating conditions and, therefore, avoids or delays

the need for future transmission system development.

99. The AESO stated that the Langdon termination would result in dependence upon the

Langdon substation and increase the number of major transmission lines terminating there from

eight to ten. It added that its FATD plan avoids this dependence by directing the power to

ENMAX No. 65 and Janet 74S substations, both of which directly serve the Calgary area load.

Rather than increasing the impact of a significant power supply disruption at either the Langdon

substation or in the corridors leading to the substation, the AESO explained that its proposal

ensures that the ENMAX No. 65 and Janet 74S substations would remain separately supplied in

the event of such a disruption.

100. The AESO testified that it had considered the option of having a new line from Fidler to

the load centre in the Calgary area during the initial stage of the development of the SATR need

application. However, the AESO stated that it discarded this option in the initial phase of the

SATR because of constructability and environmental issues. The AESO reiterated that it had not

changed its views since then.

101. Although the power from various generation sources flows on the single corridor between

Shepard Energy Centre and Janet 74S substation, the AESO submitted that terminating at

ENMAX No. 65 substation diversifies the system. Currently, most of the power supplying the

city of Calgary is transferred from the Langdon 102S to Janet 74S substations. ENMAX No. 65

18

Exhibit 721.0, AESO Reply Evidence, Appendix C, Attachment B, pages 8-9.



substation is close to the load centre in south Calgary. The AESO explained that terminating the

line at this substation helps to unload Janet 74S substation and spread the flows out more evenly

around Calgary. It further noted that terminating at ENMAX No. 65 substation assists with

operational flexibility because it is currently difficult for operators to plan maintenance around

these highly loaded lines.

102. The AESO further stated that creating diversity on the system is very important for the

long-term. It observed that as the city of Calgary continues to grow, its ENMAX No. 65

termination will provide strong supply sources to its surrounding area. The AESO explained that

it is also looking at a 240-kV loop around the west of the city in its long-term plan, which

requires diversity on the system.

103. The AESO stated that the Goose Lake to Chapel Rock project (the Chapel Rock project)

is not part of this proceeding.19 In response to the Grid Power submission that the proposed

Fidler termination would eliminate the need for the Chapel Rock project, the AESO stated that

the Grid Power proposal would not eliminate the need for the Chapel Rock project because its

cancellation would restrict wind development in southern Alberta due to limited capability of the

Milo to Langdon transmission line. The AESO added that additional transmission facilities

would be needed by 2022, if the Chapel Rock project was cancelled. The AESO added that the

cancellation would also prevent it from restoring the Alberta-British Columbia intertie path

rating because additional transmission facilities are required to do so. The AESO concluded that

the Fidler to Langdon proposal would not result in indirect cost savings of $342 million by going

south to Fidler because the Chapel Rock project is nonetheless required.

138-kV system development

104. The AESO identified three alternatives in developing the 138-kV transmission system

expansion plan to reinforce the existing local transmission system in the vicinity of High River

and Okotoks:

two single-circuit 138-kV transmission lines: one from Foothills 237S to Okotoks 678S

substation and one from Foothills 237S to High River 65S substation

a double-circuit 138-kV transmission line from Foothills 237S to High River 65S

substation and a new single-circuit 138-kV transmission line from Okotoks 678S to

High River 65S substation

a double-circuit 138-kV transmission line from Foothills 237S to Okotoks 678S

substation and a new single-circuit 138-kV transmission line from Okotoks 678S to

High River 65S substation

105. The AESO stated that all three alternatives meet the short-term and long-term need for

transmission system expansion between Foothills 237S, High River 65S and Okotoks 678S

substations and satisfy all reliability requirements in the long-term. It explained that based on the

information provided by AltaLink, alternative 1 was selected for the proposed 138-kV

development plan because, in comparison, alternatives 2 and 3 are higher in cost and land

impacts. The following figure illustrates the schematic configurations of the three alternatives:

19

The Goose Lake to Chapel Rock project is comprised of a new Chapel Rock 500/240-kV substation and

associated 240-kV transmission line. An application for this project was filed and registered as

Proceeding ID No. 2349.



727L

727L

727L

Alternative 1 (Preferred)

Alternative 2

Alternative 3

Okotoks

Magcan

Foothills

High River

Okotoks

Magcan

Foothills

High River

Okotoks

Magcan

Foothills

High River

Legend Note:

New 138 kV These diagrams contains a simplified representation of the system configuration. Technical detail has been simplified for illustration purposes. They do not

Existing 138 kV indicate geographical locations of facilities.

Figure 3 – AESO 138-kV alternatives in the High River area

106. The AESO stated that using the Foothills substation to supply the High River and

Okotoks areas would provide geographic separation from south Calgary. It explained that this

would provide long-term supply security for the High River area by enabling future expansion of

the 138-kV transmission system and operational flexibility for both the Calgary and High River

areas. The AESO stated that the Grid Power proposal of 911L at 138-kV would not result in

these benefits. The AESO also explained that its Foothills 138-kV plan would allow for the

salvage and removal of some existing transmission facilities that would no longer be needed after

the new facilities are in place.

107. The AESO stated that there is no evidentiary basis for the assertions made by Grid Power

that its 911L at 138-kV proposal would not require a third circuit out of ENMAX No. 65

substation. It argued that the Grid Power proposal would not result in cost savings of between

$115 and $130 million due to the avoidance of the third circuit because the third circuit is

required in both the AESO’s proposed 138-kV plan and in Grid Power’s proposal.

108. The AESO stated that the 911L at 138-kV proposal would cost more than the $2.5 million

claimed by Grid Power because additional transmission facilities would be required to enable the

Grid Power proposal to comply with reliability criteria and meet the needs of the High River area.

The AESO estimated that based on an association for the advancement of cost engineering class

level estimates between Class 5 (screening) and Class 4 (concept/feasibility), the total cost of

Grid Power’s proposal would be $60 million with an uncertainty range of -40% to +80%.



109. The AESO added that the 911L at 138-kV proposal would require the termination of

three 138-kV lines at ENMAX No. 65 substation and that this would fully utilize the three

remaining 138-kV bays designed to serve the south Calgary load. In addition, connecting the

350 MW Saddlebrook power plant to the 138-kV transmission system in High River would result

in reliability violations and is not a viable alternative.


110. The AESO amended one of the technical solutions in the SATR NID approval, namely

the 911L line rebuild. Instead of terminating the new double-circuit 240-kV 1037L/1038L line at

the existing Peigan 59S substation as approved previously (Peigan configuration), the AESO

proposed to move the south termination point to a new Windy Flats 138S substation (Windy

Flats configuration). The following figure in the AESO’s need amendment application illustrates

the proposed Windy Flats configuration.

Figure 4 – Windy Flats configuration



111. The AESO stated that while preparing detailed engineering and scheduling for the

proposed south Foothills application, AltaLink identified an in-service date risk arising from

work on federal lands required to upgrade the existing Peigan 59S substation, which had an

in-service date of 2014. Consequently, AltaLink proposed the development of a new 240/138-kV

substation east of Peigan 59S substation to serve as the southern termination point for the

proposed 1037L/1038L line and also provided to the AESO an order of magnitude cost

comparison between the two configurations.

112. The AESO performed steady state analyses to assess transmission system performance

for both the Peigan and Windy Flats configurations, assuming both summer peak load and light

load conditions in 2016. The study results concluded that both configurations would serve the

same functionality and meet the transmission system requirements.

113. Having considered the potential effects of delaying the new line if it were terminated at

the Peigan 59S substation, the reduced cost of terminating the line at the new Windy Flats

substation, and that the same technical functionality existed for both configurations, the

AESO proposed to amend the original need approval to request the construction of a new

Windy Flats 138S substation east of Peigan 59S substation and terminating the new

1037L/1038L line at this substation. The AESO indicated that the primary reason for the

amendment is that the Peigan 59S termination would not meet the in-service date. It clarified that

it had included AltaLink’s two cost estimates in the SATR NID amendment for the purposes of

describing the cost implications of the amendment and not for conducting a comparative

analysis.20

114. As discussed in Section 2.1.8.1, the AESO acknowledged that the wind generation

forecast has significantly changed since the SATR NID was approved and that it had conducted

sensitivity studies utilizing the updated generation and load forecasts. The AESO stated that the

approved SATR construction milestone for the 911L line rebuild has been met since 2010 and

confirmed that the milestone continues to be met by the latest wind generation forecasts.

115. The AESO testified that the timing for the 911L line rebuild is now critical. It is currently

experiencing constraints on the existing 911L line from an operational perspective.21 Starting

next year, there will be N-0 constraints under normal system operation. The AESO explained

that remedial action schemes, as suggested by IPCAA, is not an appropriate planning response to

address N-0 constraints, adding that such constraints would become increasingly severe as new

wind generation is connected to the transmission system in southern Alberta. Due to the earliest

achievable in-service date of Q3 2015 for the 911L line rebuild, it would not be in the public

interest to continue to delay the 911L line rebuild and constrain market participants in southern

Alberta.

116. The intertie between British Columbia and Alberta (referred to as path 1), is rated as

1,200 MW for imports from British Columbia to Alberta, and 1,000 MW for exports from

Alberta to British Columbia. Based on the AESO’s current operating policies and procedures

(OPP) 304 Alberta-BC interconnection transfer limits,22 the maximum British Columbia to

Alberta import and export capabilities are 780 MW and 800 MW, respectively. The AESO stated

20

Exhibit 550.01, AESO responses to IPCAA information requests, page 7. 21

Transcript, Volume 2, page 185, line 8. 22

AESO OPP 304 Alberta-BC Interconnection Transfer Limits, http://www.aeso.ca/downloads/OPP_304.pdf.

http://www.aeso.ca/downloads/OPP_304.pdf



that for the FATD planning studies, the existing Alberta-British Columbia intertie operational

limits as described in the AESO’s OPP 304 were assumed and tested to determine whether the

limits could be maintained over the range of generation and system conditions evaluated. It

concluded that the proposed FATD does not negatively impact the current operational limits of

the Alberta-British Columbia intertie.

117. The AESO concurred with Powerex that the main issue limiting the simultaneous wind

and imports is the overload on the proposed 240-kV line between the Goose Lake and proposed

Windy Flats substations after the outage of the Chapel Rock to Langdon 500-kV line, and

proposed two mitigation measures to address this issue:

Dynamic thermal line rating: to be placed on the 240-kV lines between Goose Lake and

Windy Flats substations.

Remedial action scheme: to trip the Alberta-British Columbia intertie for the outage of

the Chapel Rock to Langdon 500-kV line. This remedial action scheme will be armed

only at combination of high wind generation and high import conditions.

118. The AESO testified that it would ensure that it takes all necessary mitigation measures in

advance of the need. Based on the results of the market simulation tool, it concluded that with

the planned transmission system, no adverse impact on intertie capability is expected in 2017,

and that anticipated wind generation and in-merit imports in 2022 can be accommodated without

constraints in all but a few hours under normal system conditions. The AESO stated that the

timeline to install the dynamic thermal line rating is between 2017 and 2022; while the timeline

to install the remedial action scheme is 2022. If the need were to arise before 2017, it would be

prepared to move forward with the implementation of these measures. The dynamic thermal line

rating does not require acquisition of rights-of-way and it is a piece of equipment that must be

mounted on towers. With respect to a remedial action scheme, the AESO stated that it would

take a year at most to implement.

119. The AESO stated that the dispatch of WATL and EATL in a south to north direction

could alleviate potential path 1 curtailments caused by the 936L line (East Calgary 5S to

Langdon 102S substations) contingency under high wind and high import conditions.

120. The AESO concluded that the FATD will be a step towards restoring the Alberta-British

Columbia intertie capability and confirmed that the mitigation measures and the timing thereof

would be addressed as part of the intertie restoration program.

121. The AESO spoke of the many legislated duties it has as the transmission system planner,

including Section 15.1(2) of the Transmission Regulation, reproduced below:

…when considering the location of new transmission facilities or of enhancements or

upgrades to existing transmission facilities, the ISO must consider

(a) wire solutions that reduce or mitigate the right of way, corridor or other route

required, and

(b) maximize that efficient use of rights of way, corridors or other routes that already

contain or provide for utility or energy infrastructure.



122. The AESO provided the following examples of the legislative duties it must fulfill in

planning the transmission system.

plan the capability of the transmission system to meet the current and future needs of

market participants23

develop plans for the transmission system to provide efficient, reliable and

non-discriminatory system access service and the timely implementation of required

transmission system expansions and enhancements24

plan a transmission system that satisfies reliability standards25

take into consideration geographic separation for the purpose of ensuring reliability of the

transmission system26

plan a transmission system that is sufficiently robust so that 100 per cent of the time,

transmission of all anticipated in-merit electric energy can occur when all transmission

facilities are in-service27

make arrangements for the expansion or enhancement of the transmission system so that,

under normal operating conditions, all anticipated in-merit electricity can be dispatched

without constraint28

123. The AESO argued that it considered the use of existing infrastructure and right-of-way in

its planning process for the SATR need application and, consequently, proposed the 911L line

rebuild to terminate at the existing Peigan 59S substation. However, it became apparent during

the subsequent development process that the Peigan substation rebuild would not be available in

a timely manner to meet the needs of market participants. In order to meet this urgent need, the

AESO proposed the Windy Flats alternative.

124. The AESO recognized that the Peigan configuration might better serve the private

interest of the Conners, but that it must also have regard for the greater public interest, ensure the

timely implementation of transmission system enhancements to satisfy reliability standards, and

allow all in-merit electricity to be dispatched without constraint under normal operating

conditions. According to the AESO, there is no basis for the argument that the SATR NID

amendment has the effect of discriminating against the Conners or the Piikani First Nation. It

explained that the process for acquiring access to federal lands is different than the process for

acquiring access to lands that are subject to provincial jurisdiction. The potential for delay

associated with the Peigan substation upgrades on federal lands poses scheduling implications

and risks that are unacceptable to the AESO.

23

Electric Utilities Act, Section 17(i). 24

Electric Utilities Act, Section 33(1). 25

Transmission Regulation, Section 15(1)(a). 26

Transmission Regulation, Section 15.1(1). 27

Transmission Regulation, Section 15(1)(e)(i). 28

Transmission Regulation, Section 15(1)(f).



2.2.2 Views of AltaLink

125. With respect to Grid Power’s conceptual Fidler to Langdon route, AltaLink submitted

that the opinions of Mr. Trevor Cline, who authored the Grid Power report and testified at the

hearing on siting, costing and the social, economic and environmental effects of transmission

lines, must be given the same weight as those of a lay witness. AltaLink stated that Mr. Cline is

not an expert with respect to assessing land-use impacts or transmission line routing, adding that

the only projects in which Mr. Cline has had a role in siting as a project manager were in the

early 1990s and were minor in scale. AltaLink also stated that Mr. Cline did not have substantial

experience in transmission line costing, design, construction, or project management and had

never been involved in the construction of a project with terrain comparable to the land along the

conceptual Fidler to Langdon route. According to AltaLink, Mr. Cline had less relevant

experience with respect to transmission line design, construction methods, costing, and siting

than project managers working for transmission facility owners in Alberta today.

126. Although the Langdon termination is shorter, AltaLink submitted that the preferred route

to ENMAX No. 65 substation requires 66 fewer acres of right-of-way. It argued that Mr. Cline

did not consider the agricultural benefits associated with the triple-circuit monopoles and ignored

that the Langdon termination would mean the addition, rather than the replacement, of a line.

127. With respect to residential impacts, AltaLink submitted that only two residences within

150 metres would be closer to a transmission line than they are today along its preferred route, as

opposed to three such residences on the conceptual Fidler to Langdon route. Regarding

residences within 800 metres, AltaLink stated that there will be 28 on the preferred route, as

opposed to 22 along the conceptual Fidler to Langdon route.

128. AltaLink contended that Mr. Cline’s cost estimate for the Langdon termination was

simply based on average costs of the north Foothills line and did not account for angle or

dead-end structures, despite having a sharp turn and a termination at the Langdon 102S

substation’s west side. In its view, Mr. Cline has also double-counted a blended line cost.

129. AltaLink submitted that the Langdon termination would result in the congregation of

important substations in one geographical area, which does not align with the AESO’s preference

for geographical diversity by locating substations in different areas where opportune to do so.

AltaLink agreed with the AESO that the ENMAX No. 65 termination provides operational

flexibility because it will be easier for AltaLink to take line outages, or if such outages are not

possible, will mean that maintenance crews are working in less congested areas when

undertaking live line work.

130. AltaLink disagreed with Mr. Cline’s conclusion that his Fidler termination would

significantly reduce land-use impacts for both local residences and the environment, arguing that

he did not undertake any field studies or engage any experts when he drew a straight line on a

map and called it a “representative” or “conceptual” route. Further, Mr. Cline used the alternate

Fidler substation site, which was not approved in the recent Commission Decision 2013-177,29

for the Fidler project, and is approximately four kilometres from the preferred Fidler substation

site, approved by the Commission. Terminating at the approved Fidler substation site would

increase the distance assumed by Mr. Cline.

29

Decision 2013-177, Alberta Electric System Operator, AltaLink Management Ltd., Fidler 312S Substation

Transmission Project, Proceeding ID No. 2284, May 10, 2013.




131. AltaLink submitted that in contrast to Mr. Cline, it has direct experience with the social,

economic and host of other challenges that arise in exploring routing through the Porcupine

Hills. Both the Southwest 240-kV project and the initial work for the proposed Fidler to

Chapel Rock project included potential routes in the area. When such routes were suggested

within or close to the Porcupine Hills, AltaLink received an immediate and significant level of

stakeholder and general public opposition. AltaLink learned that routing in the Porcupine Hills

raises social and environmental concerns. People in and around that area are informed because

they place great value on the Porcupine Hills, not only from an environmental perspective, but

also from a recreational perspective, as well as for the preservation of the beauty of the hills.

132. According to AltaLink, Mr. Cline’s cost estimate for the Fidler termination is neither

realistic nor credible, contending that Mr. Cline did not know where the conceptual route would

exactly go, how long it would be, how it would be built, what structures would be used and

where, what construction techniques would be used, and so on. It argued that Mr. Cline made no

investigation into the constructability of the route and did no research or analysis on the potential

costs. Like the Langdon termination, Mr. Cline’s cost estimate for the Fidler termination is based

on a simplistic application of a per-kilometre average line cost of the south Foothills line (across

flat prairie on lattice towers) to the steep terrain and winding hills and valleys of the

Porcupine Hills, without any certainty with respect to the structures that would be used or the

challenges that would be encountered.

133. AltaLink submitted that the conceptual Fidler to Langdon route would encounter

construction challenges in the Porcupine Hills because it would zigzag all over the place. The

conceptual Fidler to Langdon route would require more than twice the heavy angles and

dead-end structures than the south Foothills line. In addition, most of the structures would have

to be modified because 38 per cent of the Fidler route crossing the Porcupine Hills would have

elevation changes greater than ten percent. Unlike building a line on the flat prairie as the south

Foothills line, graded roads would be required for access, construction and maintenance.

134. With respect to environmental impacts, AltaLink submitted that although an additional

Oldman River crossing can be avoided in the conceptual Fidler to Langdon route, this route

would involve approximately 44 transmission line crossings of the tributaries of the

Oldman River, most of which share similar environmental sensitivities as the Oldman River. In

addition, given the expected terrain constraints, a large number of access trails and watercourse

crossings would be required to gain access to the right-of-way for construction. AltaLink

considers the crossing of dozens of tributaries to have a higher, overall potential for impacts than

one crossing of a larger river. Although its preferred route for the south Foothills line passes

close to Mud Lake, there are two towers 173 metres and 146 metres away from the edge of

Mud Lake respectively. Further, although Mud Lake is within Environmentally Significant Area

291, it is not recognized as a significant breeding or staging area for water birds.

135. Stantec Consulting Ltd. (Stantec), AltaLink’s environmental expert, submitted that the

conceptual Fidler to Langdon route would have a much higher environmental effect. This route

encounters a much greater number of environmental resources than the south Foothills line.

While avoidance of some features may be possible during route refinement, other features (e.g.,

intact native grassland, steep slopes, headwater drainages) are widespread and cannot be avoided

completely. Many of these resources are highly sensitive to anthropogenic disturbances. Stantec

added that the environmental impacts which would result from the Fidler route, and on any

refined route near this route through the eastern Porcupine Hills, are expected to be much higher



than the south Foothills line and present much greater challenges for mitigation. Dr. Power of

Stantec gave an example of the Foothills’ rough fescue. Currently, there is no evidence that the

rough fescue grassland community can be restored and subsequently reclaimed.

136. AltaLink submitted that Mr. Cline had not established that the AESO’s technical solution

to terminate the south Foothills line at Windy Flats 138S substation is not in the public interest.

Due to the reverse onus with respect to need applications, interested parties must establish that

the AESO’s assessment of the need is technically deficient or that to approve the need

applications is not in the public interest. AltaLink submitted that in contrast, diverting the

proposed south Foothills transmission line to Fidler 312S substation would have greater

environmental effects, be challenging from a constructability perspective, have a greater cost and

would be highly contentious.

137. AltaLink stated that Grid Power’s 911L at 138-kV proposal is not devoid of impacts. The

911L line would nonetheless have to be re-terminated into the ENMAX No. 65 substation, which

would involve some construction activity adjacent to residential areas in Calgary. The proposal

would create issues with future terminations at the ENMAX No. 65 substation. AltaLink

explained that after the third 138-kV line is constructed into the substation, which the AESO is

proposing in 2014, the 138-kV portion of the substation will be full. Given the proximity to the

freeway and ring road, there is little or no room to expand the ENMAX No. 65 substation.

138. AltaLink stated that the only section of 727L line that could be delayed under

Grid Power’s proposal is the smaller seven-kilometre portion of the line south of the Magcan

142S substation. There is no dispute between it and Mr. Cline that the 21 kilometres of the 727L

line between Magcan 142S and ENMAX No. 65 substation would have to be rebuilt for the

interconnection of the Saddlebrook power plant to the 138-kV system. The rebuild would also

require a Bow River crossing, which AltaLink is proposing to remove, and would traverse higher

density residential development. According to AltaLink, Grid Power failed to take into account

the impacts of rebuilding the transmission line in residential areas and the environmental impacts

for its 911L at 138-kV proposal.

2.2.3 Views of the Diagonal group

139. The Diagonal group stated that some of the key assumptions underlying the AESO’s

southern Alberta wind generation forecasts were wrong. The factors that have the greatest impact

on relative generation costs are greenhouse gas costs and the natural gas prices. The Diagonal

group submitted that the AESO forecasted greenhouse gas offset prices of between $25 and

$65 per tonne of CO2 between 2010 and 2020, in the 2009 Long-term Transmission Plan, but

that the effective price of CO2 in Alberta today is $1.80 per tonne. The Diagonal group added

that the AESO forecasted a natural gas price of $8 to $10 per gigajoule between 2008 and 2018

in its 2009 Long-term Transmission Plan, but the AESO has acknowledged at the hearing that

the natural gas prices are a lot lower today.

140. The Diagonal group submitted that the southern Alberta wind generation development

has fallen far short of the amount the AESO forecasted. At the time the SATR NID was

developed in 2008, there was only approximately 500 MW of wind generation in southern

Alberta. The system developments approved in the SATR NID were based on 2,700 MW of new

wind generation being developed in southern Alberta between 2007 and 2017. In other words, in

the SATR NID, the AESO was forecasting 3,200 MW of wind generation in southern Alberta by



2017; but that as of today, only approximately 815 MW of wind generation is installed in

southern Alberta. It stated that only 315 MW of southern Alberta wind generation has been

installed half way through the ten-year planning period (2007 to 2017).

141. According to the Diagonal group, current market conditions are not supportive of wind

project development. It pointed out that the AESO’s recently released 2012LTOU has a lower

wind forecast than its 2012LTO. The Diagonal group quoted from the 2012LTOU that the

reduction is a result of both consultation with stakeholders, who indicated current short-term

market conditions are not supportive of wind project development, and a reduction of wind

projects from the AESO connection queue.30 It added that the majority of southern Alberta wind

generation projects on the AESO’s project list today date from October 2007, or earlier. Since

that time, only two new southern Alberta wind generation projects have been proposed and

remain on the AESO’s project list.

142. The Diagonal group argued that the environmental-driven scenario in the AESO’s

2012LTOU is not likely to occur. The environmentally-driven case for wind generation

development in southern Alberta is a worst-case scenario, intended to represent the absolute

maximum amount of wind generation that might be developed. The base case scenario in the

2012LTOU forecasted only 1,560 MW of wind generation in all of Alberta by 2017, and only

approximately 1,240 MW in southern Alberta by 2017.

143. The Diagonal group stated that the 911L line rebuild is not urgent because the forecasted

southern Alberta wind generation development has not materialized. With regard to the AESO

statement that the wind generation in southern Alberta must be limited to approximately

1,150 MW in 2014 to meet the reliability criteria, the Diagonal group argued that there are

basically no new wind projects being proposed and there are only 815 MW of wind generation in

southern Alberta as of June 2013.

144. The Diagonal group submitted that the AESO failed to account for the significant system

development since the SATR NID was developed, i.e. EATL. EATL, a 1,000 MW direct-current

line (expandable to 2,000 MW) that has a southern terminus at Brooks in southeastern Alberta,

and provides another means of egress for wind generation from southeastern Alberta.

145. The Diagonal group concluded that the AESO should take a second look at its plans for

transmission development in southern Alberta due to less wind generation than forecasted and

more transmission capacity than was anticipated at the time of SATR NID approval. It pointed to

Decision 2013-135,31 in which the Commission recently directed the AESO to change an ISO

rule based on a material change between what the AESO forecasted and what has actually

occurred. According to the Diagonal group, this is another example where there has been a

material change between the AESO forecast and what has actually occurred.

146. The Grid Power report prepared for the Diagonal group stated that the AESO’s proposal

in the FATD NID will result in an almost immediate risk of dispatch conflicts between wind

output from the Pincher Creek area, imports over the British Columbia intertie and generation

from southern Alberta’s combined cycle plants. Grid Power recommended a modification of the

30

Exhibit 752.01, AESO 2012 Long-Term Outlook Update, page 10. 31

Decision 2013-135, ATCO Power Ltd. and ENMAX Energy Corporation, Complaints regarding ISO Rule

Section 302.1: Real Time Transmission Constraint Management, April 5, 2013.




two need applications in this proceeding by building a 240-kV connection from the

Langdon 102S substation in the north to the proposed Fidler substation in the south. More

specifically, Grid Power proposed to:

modify the north termination point of the double-circuit 240-kV 1106L/1107L line

between Foothills 237S and ENMAX No. 65 substations proposed in the FATD NID to

Langdon 102S substation instead of ENMAX No. 65 substation

modify the south termination of the double-circuit 240-kV 1037L/1038L line between

Foothills 237S and Windy Flats 138S substations proposed in the SATR NID amendment

to Fidler 312S substation west of the existing Peigan 59S substation; and cancel the

Windy Flats 138S substation

cancel or defer the Goose Lake to Crowsnest (Chapel Rock) transmission development

approved in the SATR NID approval

147. The following map in the Grid Power report illustrates the Fidler to Langdon proposal.



Figure 3 Recommended Configuration

Modifications to the North Foothills

and South Foothills double circuit 240

kV transmission line (SATR Rebuild

911L Calgary South to Peigan)

Figure 5 – Grid Power Fidler to Langdon proposal



148. Specifically in the north end, Grid Power’s conceptual Fidler to Langdon route follows

the preferred north Foothills line route from Foothills 237S substation up to route marker B240

and continues north to parallel the existing 1201L line until it reaches Langdon 102S substation.

The route modification provided by Grid Power is reproduced below and shown in purple.

Figure 6 – Grid Power proposal – Langdon termination

149. In the south end, Grid Power did not propose a defined route. Grid Power recommended

a modification to the preferred south Foothills line route in or near where it leaves the 911L line

route and deviates southeast to run southwest and south until it reaches Fidler 312S substation.

This conceptual Fidler to Langdon route is reproduced below and is shown in purple.



Figure 7 – Grid Power proposal – Fidler termination

150. Grid Power stated that its Fidler to Langdon proposal would offer more system transfer

capability, as opposed to the FATD proposal to build a 240-kV line from ENMAX No. 65

substation to Foothills 237S substation and further south to Windy Flats 138S substation.

Grid Power contended that its Fidler to Langdon proposal would provide sufficient transfer

capability for at least the next ten-year wind generation forecast in the Pincher Creek region,

without risk of any dispatch conflicts between wind output from the Pincher Creek region and

imports from British Columbia and the combined-cycle power plants in southern Alberta.

151. With respect to the north termination at Langdon, the Diagonal group submitted that the

Fidler to Langdon proposal would provide reliability benefits by separating southern Alberta

wind and gas generation south of Calgary (including Saddlebrook generation) to Langdon 102S

substation in one corridor from the substantial output from the Shepard Energy Centre to

ENMAX No. 65 substation in another corridor. With regard to the AESO’s criticism that the

Fidler to Langdon proposal creates an over-reliance on the Langdon substation, where three

different substations are adjacent to each other, the Diagonal group responded that the AESO’s

FATD combines wind generation from southern Alberta, power transmitted on WATL and

power from the Shepard Energy Centre in the Shepard to Janet corridor, arguing the risk



associated with the AESO’s proposal to combine all the different generation sources in a single

transmission corridor is greater than the risk associated with the alleged over-reliance on

Langdon 102S substation in Grid Power’s proposal.

152. Grid Power estimated that compared with the AESO’s proposal, its Fidler to Langdon

proposal will result in cost savings of $389 million, including both direct and indirect savings on

capital costs. The direct savings are contributed from reduced line length, avoidance of

additional costs of monopole structures and reduced number of heavy angle structures. The

indirect savings of $342 million are the avoided costs of the Chapel Rock project. With respect

to potential cost savings from the Fidler to Langdon proposal, the Diagonal group emphasized

that the magnitude of the benefits associated with eliminating the Goose Lake to Chapel Rock

project was huge. Even if the conceptual route to Fidler were to cost more than Mr. Cline’s

estimate because of the challenging terrain, that cost would be more than offset by the avoided

cost of the eliminated Chapel Rock project.

153. With respect to Mr. Cline’s qualification, the Diagonal group argued that siting

transmission lines is inherently not a technical or scientific exercise. It does not depend on

technical or scientific qualification or training. Siting transmission lines is something that is

learned on the job and is ultimately a subjective exercise. It explained that the exercise of siting

transmission lines involves relatively basic skills like looking at maps, counting residences,

identifying existing linear disturbances for the purpose of identifying paralleling opportunities

and looking at public databases for environmental information such as the location and size of

environmentally significant areas. The Diagonal group admitted that Mr. Foley from AltaLink

certainly has more experience than Mr. Cline in siting transmission lines, but does not have

greater expertise.

154. Further, the Diagonal group stated that the Langdon termination would have reduced

residential impacts because the conceptual Fidler to Langdon route is 4.5 kilometres shorter and

has significantly fewer residences than the preferred route. For example, there would only be

three residences within 150 metres on the Langdon route, as opposed to seven residences on the

preferred route. Also, at route marker B240, the conceptual Fidler to Langdon route continues

north, paralleling the existing 1201L line, which would reduce land-use impacts.

155. The Diagonal group argued that the Langdon termination would have a smaller

incremental impact compared to replacing the small wood pole line between route markers

B240 and A260 with a line which uses extremely tall triple-circuit monopoles and would also

result in cost savings of approximately $35 million.

156. The Diagonal group stated that Stantec downplays the environmental effects of locating

the preferred route so close to Mud Lake and crossing the Oldman River. Both routes have

environmental challenges. The preferred route for the south Foothills line passes very close to a

major wetland area (i.e. Mud Lake) and crosses the nationally significant Oldman River. The

Diagonal group’s conceptual Fidler to Langdon route would avoid 18 kilometres of new 240-kV

line through the nationally recognized Environmentally Significant Area 291 and crossing of the

Oldman River valley. It admitted that the conceptual Fidler to Langdon route would cross the

southeastern edge of the Porcupine Hills which was not ideal. The Diagonal group also admitted

that Mr. Cline’s conceptual Fidler to Langdon route would need to be subjected to the greater

scrutiny of a proper route selection process.



2.2.4 Views of Phyllis Robertson

157. Phyllis Robertson specifically opposed the technical solution associated with the 138-kV

transmission system in High River area proposed in the FATD NID. Grid Power stated in its

report that the AESO’s proposed Foothills 237S substation and the associated 138-kV

transmission lines from the Foothills substation to High River and Okotoks are not the best

solution to meet the load supply requirements of the High River regional system.

158. Grid Power argued that the AESO’s proposal would have a negative impact on the

region’s system reliability and would place the region at higher risk of islanding, with possible

damage to loads and generators as a consequence. Grid Power explained that the major

disadvantage of the AESO’s proposal for the High River regional system is that the entire region

is supplied from the proposed Foothills 237S via one new high capacity double-circuit 138-kV

line and leaves the 765L line, the 138-kV line from the Janet 74S to Strathmore 151S

substations, as the only other connection to the grid. If a transmission structure fails or is

knocked over on this new line, the regional system will, under the typical dispatch pattern of the

local generation, separate from the system. Grid Power added that a high intensity lightning

strike could also cause the region to be out-of-step.

159. Grid Power recommended converting a short section of the existing 240-kV 911L line (to

be decommissioned as part of the FATD project) to 138-kV operation and connect it to the

existing 727L line at the MagCan site to create a fourth 138-kV supply line into the region. This

proposal is referred to 911L at 138-kV by Grid Power. The following figure in the Grid Power

report illustrates the proposed configuration for the High River regional system.

Figure 8 – Grid Power 911L at 138-kV



160. Grid Power stated that its 911L at 138-kV proposal would provide 305 MW and 327 MW

of capability for summer and winter loading respectively and concluded that based on the most

recent AESO load forecast, its proposal would provide sufficient load supply capability in the

High River region for the next 20 years.

161. Grid Power also stated that 911L at 138-kV would open up the opportunity to connect the

proposed Saddlebrook power plant to the regional system instead of to the 240-kV system.

System reliability would be improved by connecting this plant to a regional system which would

then be completely independent of the wind production coming north on the 911L line rebuild

and the Shepard Energy Centre on the east side of Calgary. Grid Power admitted that

interconnecting the Saddlebrook power plant to the 138-kV system could result in higher initial

system losses and potentially a higher loss factor cost for the owner of the plant. Mr. Cline also

testified that the Saddlebrook power plant interconnection would require that the 727L line from

Magcan 142S substation to ENMAX No. 65 substation be rebuilt immediately with a large

conductor.32

162. Grid Power stated that its 911L at 138-kV would not have any new impacts while the

AESO’s Foothills 138-kV project involves a new line with its associated land-use impacts.

Grid Power concluded that cancelling the Foothills 138-kV project and utilizing the 911L at

138-kV proposal would address the load supply need in the High River region with no additional

land-use impacts. Compared with the AESO’s proposal, it estimated that the total cost saving

from its 911L at 138-kV proposal would be $98 million.

163. Grid Power agreed with the AESO that both the FATD 138-kV configuration and the

911L at 138-kV configuration would have the same issue of high loading on the transformer at

ENMAX No. 65 substation by 2019, stating that the high loading would be the result of an

incomplete 138-kV system in Calgary. It added that the third circuit out of ENMAX No. 65

substation is not required for its 911L at 138-kV proposal.

164. With respect to siting constraints at ENMAX No. 65 substation, Grid Power argued that

ENMAX No. 65 substation is of comparable size to Janet 74S substation. However,

ENMAX No. 65 substation currently has only four line terminations compared to 14 at Janet 74S

substation.

2.2.5 Views of IPCAA

2.2.5.1 FATD NID

165. IPCAA submitted that it has identified concerns and deficiencies with regards to the

AESO’s FATD need application that, if approved, could have significant negative cost impacts

on ratepayers and would be contrary to the public interest. IPCAA recommended that the

Commission deny this need application on the grounds that it is technically deficient and that it is

in non-compliance with Section 11(3)(f) of the Transmission Regulation and Section 6.1 of AUC

Rule 007 to examine and compare transmission development alternatives for both the 240-kV

and 138-kV components of the application.

32

Transcript, Volume 9, pages 1715-1716.



166. IPCAA submitted that the AESO failed to develop any other 240-kV alternatives to its

240-kV components, and simply relied upon the presumption that to “minimize land impacts and

maximize the efficient use of existing rights-of-way”33 would automatically result in the

preferred alternative. The AESO did not explain why other existing corridors (for example, along

the 1201L line corridor to Langdon) could not have been considered for the 240-kV

development. Further, the AESO did not contemplate any development alternatives that would

require expansion beyond the existing corridors.

167. IPCAA submitted that the AESO’s incremental approach is in fact a piecemeal planning

approach, and that in the absence of a holistic Calgary area plan, it is disconcerting that the

FATD plan may pose limitations on the future flexibility of the large Calgary area development,

ultimately resulting in a sub-optimal plan.

168. IPCAA noted that a 138-kV single-circuit from Okotoks 678S to Carseland 525S

substations is a common element among the three alternatives for the AESO’s 138-kV

components. This circuit would be created by reusing sections of the existing 138-kV lines 727L

or 911L and 850L, as appropriate, to form a new 138-kV connection between the Okotoks 678S

and Carseland 525S substations. IPCAA submitted that the AESO failed to explain the reason or

the economics of salvaging conductors and structures for a significant portion of the existing

727L and 850L lines to form the new 850L line between the Carseland 525S and Okotoks 678S

substations. Further, the AESO did not consider other ways to connect these two substations.

IPCAA concluded that as a result, although the AESO examined three alternatives in its

application, it was nonetheless deficient because all of its designs share a common element that

represents a significant portion of the scope, for which no development alternatives were

considered.


169. IPCAA submitted that the AESO expressed disregard for the cost implications of the

amendment by stating that the primary reason for the amendment was to meet its in-service date.

The AESO did not use the cost information provided by AltaLink to conduct a comparative

analysis and had little or no knowledge of the details that constitute the estimates. IPCAA is

concerned that the AESO has not satisfied its obligation to act in the best interest of ratepayers

by properly considering the cost implications associated with the amendment.

170. IPCAA was concerned about the cost comparison between the Windy Flats configuration

and the original Peigan configuration. It questioned how constructing a brand new Windy Flats

substation would cost only $1.36 million more than upgrading the existing Peigan substation

and, with respect to transmission line cost, how the Peigan option would cost $21.9 million more

than the Windy Flats option. IPCAA was also concerned that the “soft cost” estimated by

AltaLink, which included owner costs, distributed costs and other costs, accounts for close to

$33.7 million of the cost differential between the two configurations. IPCAA submitted that

there is little accessibility to information regarding the soft cost component of transmission

project costs, which makes it difficult for ratepayers to examine soft costs in any general tariff

applications or deferral account proceedings.

33

Exhibit 9.00, AESO Needs Identification Document, pdf page 15, Section 3.2.



171. IPCAA submitted that the Grid Power report made reasonable arguments to support the

Fidler to Langdon proposal and concurred with Grid Power that ratepayers are spending over

$3 billion to install high-voltage direct-current infrastructure into Alberta’s bulk transmission

system which should be put to good use. It argued that the AESO did not appear to be using the

full control capability of these lines to maximize transfer capability.

172. In conclusion, IPCAA recommended that the Commission direct the AESO to conduct a

due diligence of the NID cost estimates provided by AltaLink to gain a clear understanding of

the reasons for the cost reduction in the Windy Flats configuration. Due to the potential cost

savings of $487 million and sufficient time available, IPCAA recommended that the Grid Power

proposal be evaluated by the AESO outside of a regulatory proceeding.

2.2.6 Views of TransCanada Energy Ltd. (TransCanada)

173. TransCanada stated that assuming the AESO will not alter the reliability criteria at an

operational level to address N-2 contingencies, it is generally not opposed to the need

applications. It noted that substantial amount of generation sources need to flow their energy into

the Janet 74S, East Calgary 5S and ENMAX No. 65 substations over a limited number of

transmission lines, most of which are double-circuit. TransCanada examined a N-2 contingency

of the double-circuit 240-kV 985L/1003L line between the Janet and ENMAX No. 25

substations and identified some substantial constraints on the 138-kV transmission system. For

example, the overloads on 138-kV circuits could be as high as 98 per cent. It found that neither

tripping the entire Shepard plant at 850 MW nor shedding load in the southern parts of the

ENMAX system is effective in reducing the 138-kV overloads; it therefore expected the AESO

to address the technical deficiency involving this N-2 event, and to provide a mitigating plan

involving load or generation during the time period between completion of the FATD facilities

until other NID applications are approved and the facilities are completed relative to north

Calgary and the Strathmore/Blackie planning area.

174. TransCanada compared the four mitigation options in the event of a double-circuit outage

between the Janet 74S and ENMAX No. 25 substations proposed by the AESO, and concluded

that among the four options, a circuit swap of the 985L and 1065L lines appears to be the only

option that did not create additional issues with load or generation shedding nor low voltage in

load areas. Mitigation measures such as tripping lines and transformers may not be viable

alternatives because Calgary load continues to grow and southern Alberta generation increases to

meet that demand. Although the Foothills to Sarcee line would eliminate the N-2 contingency by

creating a second path to Calgary and onto points northward, the constructability of the Foothills

to Sarcee line is dependent upon the outcome of the province’s southwest ring-road negotiations,

which are both longstanding and controversial at best. TransCanada reiterated that the circuit

swap represents a similar, effective and viable solution to eliminate the N-2 risk.

175. TransCanada submitted that its Saddlebrook power plant should not be connected to a

lower-voltage transmission system without significant investigation. The studies attached to the

Grid Power report did not offer enough detail for TransCanada to determine whether the

proposed 138-kV system would have sufficient capacity for Saddlebrook output. These studies

were only intended to support Grid Power’s evaluation of options, not a clear recommendation

that the plant be connected to the 138-kV system.



176. TransCanada acknowledged that the primary focus of the FATD was to relieve southern

Alberta transmission constraints, but believed that there was lack of clarity on how the north

Calgary issues would be mitigated until relieved by future transmission development.

TransCanada is supportive of the commitment made by the AESO to include a comprehensive

Calgary area transmission development plan in the long-term plan it has scheduled to be

completed by the end of 2013.

177. TransCanada requested the Commission place the following conditions on the approval

of the FATD NID. The potential for a double-circuit outage between the Janet 74S and

ENMAX No. 25 substations must not result in operational procedures that would require

constraints being imposed on the Saddlebrook power plant. In addition, the potential outage of

these circuits must be resolved by way of a circuit swap or, in the alternative, the AESO must

investigate and implement a solution to the double-circuit outage risk prior to construction of the

FATD facilities.

2.2.7 Views of Ronald and Laurie Conner

178. Ronald and Laurie Conner (the Conners) own lands near the proposed Windy Flats 138S

substation and along the proposed transmission line routes. The Conners submitted that it is not

reasonable nor in the public interest to dispossess them of part of the affected lands and part of

their livelihood by constructing and operating the line and a new Windy Flats 138S substation on

their lands when an upgraded Peigan 59S substation, or the proposed Fidler 312S substation,

would meet the public need in Alberta. They argued that upgrading an existing substation does

not interfere with the private rights of other people to anything like the degree that the

Windy Flats 138S substation would interfere with their private rights.

179. The Conners submitted that the AESO failed to consider technical solutions that follow

existing linear disturbances, as directed by Section 15.1(2) of the Transmission Regulation. They

noted that the AESO is proposing a new, greenfield route for the line including its southern

termination at the Windy Flats 138S substation, which is contrary to the generally-agreed best

practice of following or mirroring the route of existing linear disturbances in the sense of

following the route of the existing 911L line.

180. The Conners submitted that the AESO’s SATR NID amendment is in breach of

Section 15 of the Canadian Charter of Rights and Freedoms because it discriminates between

land and not particular landowners. The indirect effect of the AESO’s recommendation is to

deny benefits and protections to both the Conners and the Piikani First Nation due to their race.

They contend that they would lose the benefits and protection which would result from the

detailed environmental assessment prescribed by the Canadian Environmental Assessment Act

and become subject to a less favourable framework for compensation for lands taken for public

purposes than those which apply under the Indian Act. The Piikani First Nation lose the

opportunity to allow the further use of the reserve lands, already encumbered with electrical

transmission facilities, in return for payments under the Indian Act.

2.2.8 Views of Powerex Corp. (Powerex)

181. Powerex neither supports nor opposes the need application, however it is concerned that

the Alberta-British Columbia intertie capability would be negatively impacted by the proposed

transmission development arising from the SATR NID amendment and the Goose Lake to

Chapel Rock development. It is also concerned that the AESO has proposed transmission plans



without having studied and documented their impact on the Alberta-British Columbia intertie

transfer capability.

182. Powerex submitted that the impact of the SATR NID amendment on the Alberta-British

Columbia intertie was a relevant consideration and should be addressed in the FATD proceeding.

Pursuant to Section 16(1) of the Transmission Regulation, the AESO was directed by the Alberta

government in 2004, to restore the interconnection to its path ratings of 1,200 MW west to east

and 1,000 MW east to west.

183. Powerex stated that any impact the proposed facilities have on the transfer capabilities of

the Alberta-British Columbia interconnection may have direct operational, economic and

efficiency impacts on both the Alberta Interconnected Electric System and the British Columbia

transmission system. Pursuant to Section 38 of the Transmission Regulation, Powerex submitted

that the Commission must have regard for the principle that it is in the public interest to foster a

transmission system that is flexible, reliable and efficient, and preserves options for future

growth, improving transmission system reliability and efficiency.

184. Powertech Labs Inc. (Powertech), on behalf of Powerex, produced nomograms showing

that the British Columbia to Alberta power transfer capability would be increasingly constrained

with the increasing levels of wind generations in the Pincher Creek area. If all of the 349 MW of

wind generation currently installed in the Pincher Creek area operates at maximum output,

Powerex submitted that the British Columbia to Alberta transfers would be restricted to

approximately 925 MW or less as a result of the SATR NID amendment and Chapel Rock

project. Based on the regulatory approvals, Powerex estimated that an additional 466 MW could

be installed by 2015, bringing the total Pincher Creek (Goose Lake) peak wind capacity to

815 MW.34Assuming that all these wind power plants were built by their planned in-service dates

and operated at maximum output, Powerex stated that the British Columbia to Alberta transfers

would be restricted to 600 MW or less.

185. Powertech concluded that British Columbia to Alberta imports are restricted by the 936L

line contingency to 890 MW for the FATD east configuration and 1,015 MW for the FATD east

plus the third-circuit configuration respectively. Powertech added that there may be other more

restrictive contingencies than the 936L line contingency. However, it stated that this spot-check

approach demonstrated at least one contingency that could impact the British Columbia to

Alberta transfers.

186. Powerex agreed with the AESO that the constraints on the transfer capability of the

Alberta-British Columbia intertie can be alleviated by mitigation measures, such as remedial

action schemes and dynamic thermal line ratings. However, Powerex is concerned that if the

implementation measures are not done on a timely basis, there is a risk that the measures will not

be operational in sufficient time to address the identified constraints. In conclusion, Powerex

requested the Commission to place a condition in the approval of the AESO’s SATR NID

amendment, that the AESO implement the necessary mitigation measures no later than the

Chapel Rock project in-service date, to ensure that there is no negative impact to the

British Columbia to Alberta import transfer capability. Alternatively, Powerex requested the

Commission to establish an expedited process to return the application back to the AESO with

the direction that it amend the application to include the implementation of the necessary

34

Exhibit 616.02, Powerex Evidence, page 8, A19.



mitigation measures no later than the Chapel Rock project in-service date, or direct the AESO to

ensure there are no negative impacts to the Alberta-British Columbia intertie capability for all

future NID applications.


187. In Section 2.1.8.1, the Commission found that there is a need to expand or enhance the

transmission system in the southeast Calgary, Okotoks and High River areas. In Section 2.1.8.2,

the Commission confirmed that there continues to be a need to expand or enhance the

transmission system in southern Alberta. In this section, the Commission must evaluate the

AESO’s preferred technical solutions to meet these two identified needs. When evaluating those

applications, Section 38(e) of the Transmission Regulation requires the Commission to decide if

any interested party has demonstrated that the AESO’s assessment of need was technically

deficient or if approval of the FATD NID application and/or the SATR NID amendment would

not be in the public interest.

188. As the Commission understands it, it is IPCAA’s position that the FATD NID application

is technically deficient because it did not include meaningful alternatives to its preferred

technical solutions. Regarding the SATR NID amendment, IPCAA appears to take the position

that its approval is not in the public interest given the cost implications associated with the use of

the Windy Flats configuration versus the Peigan configuration.

189. The Commission understands that it is the position of Phyllis Robertson and the Diagonal

group that it is not in the public interest to approve the FATD NID and the SATR NID

amendment because there are better alternatives available, the Fidler to Langdon and 911L at

138-kV alternatives proposed by Grid Power.

190. Mr. and Mrs. Conner take the position that approval of the SATR NID amendment is not

in the public interest because it is not the best alternative to meet the identified need and because

its approval would breach Section 15 of the Canadian Charter of Rights and Freedoms.

191. Neither TransCanada nor Powerex opposed the approval of the two need applications, but

both asked the Commission to place certain conditions on the approvals it may issue.

192. Given the nature of the issues expressed by interveners with respect to the two need

applications, the Commission’s findings on those applications have been structured as follows.

First, the Commission addresses the issue of whether the FATD NID is technically deficient for

failing to examine and compare alternative technical solutions to meet the need identified.

Second, the Commission assesses the Fidler to Langdon and the 911L at 138-kV alternatives

proposed by Grid Power on behalf of the Diagonal group and Phyllis Robertson. In this

assessment the Commission compares the Grid Power and the AESO alternatives to determine

whether the Grid Power alternatives are superior to those developed by the AESO. Third, the

Commission makes findings specifically with respect to the concerns raised regarding the

Windy Flats substation by Mr. and Mrs. Conner and IPCAA. Finally, the Commission addresses

Powerex and TransCanada’s requests that certain conditions be attached to any NID approvals

issued by the Commission.



Is the FATD NID technically deficient for want of alternatives?

193. Section 11(3) of the Transmission Regulation sets out the information that the AESO is to

include in a needs identification document. Subsection 11(3)(f) states:

(3) In addition to the requirements set out in section 34(1) of the Act, the needs

identification document must describe the timing and nature of the need, constraint or

condition affecting or that will affect the operation, efficiency and reliability of the transmission system, including the following:

(f) the options considered for alleviating the constraint or condition;

194. Section 6.1 of AUC Rule 007 provides further information requirements for NID

applications and includes requirements specific to the comparison of transmission alternatives

considered by the AESO to address an identified need. The introduction to Section 6.1 states that

“the information requirements set out below may not be applicable in all cases; they will vary

with the complexity and size of the project”.

195. IPCAA argued that the FATD NID is technically deficient because it does not comply

with Section 11(3)(f) of the Transmission Regulation and Section 6.1 of AUC Rule 007.

Specifically, IPCAA asserted that the AESO failed to examine and compare transmission

development alternatives for the 240-kV components of that project. It also contended that the

three 138-kV alternatives considered by the AESO shared a single significant common element

and no alternatives to that common element were examined or compared.

196. The AESO explained its approach to developing its preferred alternative for 240-kV

transmission development in the FATD NID application. The AESO stated:

In order to minimize land impacts and maximize the efficient use of existing rights-of-

way that would be required to accommodate such 240-kV developments, reconfiguring,

upgrading and/or rebuilding existing transmission lines was preferred over transmission

development options that required distinctly separate new corridors. Furthermore, voltage

conversion from 138-kV to 240-kV was also considered where possible

197. The AESO stated that, having adopted this approach, it did not identify transmission

alternatives for the study that would similarly maximize the opportunities for the transmission

facility owners to use existing infrastructure and rights-of-way.

198. The Commission notes that when considering the location of new transmission facilities

or enhancements or upgrades to existing facilities Section 15.1 of the Transmission Regulation

requires the AESO to consider:

…

(a) wires solutions that reduce or mitigate the right of way, corridor or other route

required, and

(b) maximizing the efficient use of rights of way, corridors or other routes that already

contain or provide for utility or energy infrastructure.35

35

Transmission Regulation, Section 15.1(2).



199. The Commission finds that the information requirements of Section 11 of the

Transmission Regulation must be read in concert with the directions to the AESO regarding

transmission planning found elsewhere in that regulation, including those in Section 15.1. When

so interpreted, the Commission finds that it is open to the AESO to include only a single

transmission alternative in a NID if it is of the view that there is only one reasonable alternative

that is consistent with the ISO’s transmission planning obligations. Put another way, the

Commission does not believe that Section 11(3) obligates the AESO to develop and compare

transmission alternatives that it does not consider to be reasonable or viable. The Commission

considers that this interpretation is consistent with the flexibility provided in the introduction to

Section 6.1 of AUC Rule 007.

200. In the Commission’s view, the AESO’s decision to not include a discussion of 240-kV

transmission options that required the development of new corridors in the FATD NID was

reasonable, given the presence of existing rights-of-way and transmission infrastructure that was

capable of voltage conversion, and having regard for the population and development density in

the study area. While the Commission considers that it is generally helpful to it and interested

parties to review more than one technical solution to address an identified need, it accepts that in

limited circumstances only a single reasonable alternative will be available.

201. Regarding, the 138-kV upgrades proposed by the AESO, the Commission observes that it

is not uncommon for the AESO to include in a NID several transmission alternatives that share a

common element. If the AESO is of the view that the common element is required regardless of

the various other elements of the technical solutions proposed, then the AESO is obligated, as the

transmission system planner, to include that common element in the technical solutions it

develops and compares. In the Commission’s view, the fact that the three alternatives considered

by the AESO for the 138-kV system, all included a common element does not, on its own, lead

to the conclusion that the FATD NID is technically deficient.

202. Having regard to the foregoing, the Commission is not satisfied that the FATD NID was

technically deficient, as alleged by IPCAA, for non-compliance with Section 11(3) of the

Transmission Regulation.

Is approval of the FATD NID and SATR NID amendments not in the public interest

because the Fidler to Langdon alternative is superior?

Can the Commission consider the Fidler to Langdon alternative?

203. The 240-kV technical solution proposed by Grid Power (i.e. the Fidler to Langdon

alternative) addressed the proposed Windy Flats substation described in the SATR NID

amendment as well as the AESO’s preferred 240-kV technical solution for the FATD NID. The

Fidler to Langdon alternative, which is shown in Figure 5, eliminates the Windy Flats substation

and instead terminates the proposed south Foothills line (i.e. 1037L/1038L line) at Fidler 312S

substation instead of the Windy Flats 138S substation and the proposed north Foothills line (i.e.

1106L/1107L line) at the Langdon 102S substation instead of the ENMAX No. 65 substation.

204. The first issue the Commission must consider when assessing the viability of the Fidler to

Langdon alternative is whether it is consistent with existing NID approvals, including the SATR

NID approval.



205. The Commission finds that the proposed Fidler to Langdon alternative is inconsistent

with the SATR NID approval because it proposes to change or eliminate some of the technical

solutions described in that approval. Although the Diagonal group states that it is not attempting

to re-open the SATR NID approval, many of its arguments and the Grid Power report contend

that the need application approved in relation to SATR should be changed. Significantly,

Grid Power proposed to cancel or delay the Goose Lake to Crowsnest (Chapel Rock)

transmission development that was approved in the SATR NID.

206. In Decision 2012-360, the decision on the process meeting for this proceeding, the

Commission advised interested parties that the continued viability of the SATR NID approval

was not an issue it could or should address in this proceeding. The Commission noted at that

time that it had not received an application to review and vary that approval. No party

subsequently sought a review of the SATR NID and the Commission continues to be of the

position that it would be improper to review any elements of the SATR NID approval that is not

specifically subject to the AESO’s application to amend that approval.

207. The Commission finds that recognizing the Fidler to Langdon technical solution

proposed by Grid Power as viable would be tantamount to granting a de facto review of elements

of the SATR NID approval that are not subject to the AESO’s application to amend that

approval. Accordingly, the Commission is of the view that the Fidler to Langdon alternative is

not a technical solution that it should properly consider in this proceeding. However, even if the

Commission were satisfied that it could properly consider the Fidler to Langdon alternative, it is

of the view that the Fidler to Langdon alternative is not demonstrably superior to the AESO’s

technical solution from a technical and costs perspective and is inferior to the AESO’s solution

from an environmental and land-use perspective. The Commission’s reasons for these

conclusions follow.

Comparison of the AESO’s FATD with the Fidler to Langdon alternative

208. One issue that arose at the hearing was the qualification of Mr. Trevor Cline, the author

of the Grid Power evidence and Grid Power’s witness. Before considering the Fidler to Langdon

alternative prepared by Grid Power, the Commission finds it necessary to address the issue of

Mr. Cline’s qualification as an expert witness.

209. The AESO and AltaLink questioned whether Mr. Cline had the necessary knowledge,

experience and expertise to provide expert evidence on matters related to transmission line

costing and routing, including the associated land-use and environmental impacts. The

Diagonal group challenged this assertion and argued that transmission routing and siting is a

subjective exercise that does not require technical or scientific qualification or training.

210. Mr. Cline has previously testified before the Commission. In Decision 2012-303,36 the

Commission recently ruled on Mr. Cline’s qualifications as a routing expert and the weight to

which his evidence on various subjects would be accorded.

With respect to Mr. Cline, the Commission recognizes that while there may be

deficiencies in Mr. Cline’s qualifications with respect to the siting of transmission lines,

those deficiencies go to the weight to be accorded to his expert opinions.

36

Decision 2012-303, ATCO Electric Ltd., Eastern Alberta Transmission Line Project, Proceeding ID No. 1069,

Application No. 1607153 and 1607736, November 15, 2012.




The Commission notes that much of the evidence given by Mr. Cline, which will be more

fully discussed in the relevant sections below, went to issues that he had no qualifications

upon which to rely in giving opinion evidence. Issues such as the impacts of transmission

lines on agricultural operations, the impact of transmission lines on property values, and,

as discussed above, the environmental impacts of transmission lines and the relevance of

environmentally sensitive areas in the siting process are all areas where Mr. Cline strayed

in giving opinion evidence. The Commission finds, as a general statement, the evidence

provided by Mr. Cline in areas where he was clearly not qualified to opine, will be given

the weight of a lay witness rather than the weight of a properly qualified expert in these

areas. Where that evidence diverges from the evidence of a properly qualified expert

witness, the evidence of the qualified expert witness will be preferred.37

211. The evidence before the Commission in this proceeding was that Mr. Cline has not

acquired any further expertise or qualifications in the above-mentioned areas.

212. Having regard to the foregoing, the Commission accepts that Mr. Cline has expertise in

transmission planning. The Commission notes that Mr. Cline was not qualified as a routing or

siting expert, nor was he qualified to give opinion evidence on the impacts of transmission lines

on residences, agriculture or the environment. Accordingly, in this hearing the Commission has

accorded Mr. Cline’s evidence on topics outside of his area of expertise with the same weight

that it would accord to a lay witness.

213. The Commission’s technical comparison of the Fidler to Langdon alternative to the

AESO’s technical solution focused on total transfer capability, reliability and system diversity to

meet future system needs/growth.

214. Regarding total transfer capability, the Commission finds that neither alternative is

demonstrably superior. The Commission’s conclusion on this issue is driven largely by the fact

that the AESO and Grid Power modelled the dispatches of the WATL and EATL high-voltage

direct-current lines differently for post-contingency conditions. The AESO’s model redispatched

the remaining high-voltage direct-current line only if one of the two high-voltage direct-current

lines is out-of-service; whereas Grid Power’s model appeared to adjust the high-voltage

direct-current line flow for other critical outages as well.

215. While Grid Power concluded that employment of the Fidler to Langdon alternative would

result in greater total transfer capability compared to the AESO’s solution, the Commission is

not convinced of its superiority given that the two parties employed a different dispatch

methodology in their modelling. Further, based on the evidence before it, including the fact that

the AESO has not finalized its operational study on high-voltage direct-current line dispatches,

the Commission is not able to conclude that the methodology employed by the AESO was more

or less reasonable than that employed by Grid Power. Accordingly, the Commission is not

convinced that the Fidler to Langdon proposal will provide more transfer capability than the

AESO’s FATD.

216. Having regard to system diversity and reliability, the Commission finds that the Fidler to

Langdon alternative and the AESO’s alternative are substantially the same. For example, in both

the AESO’s alternative and in the Fidler to Langdon alternative there is a six-kilometre stretch

37

Decision 2012-303, pages 26-27, paragraphs 127 and 128.



between route marker B280 and Janet 74S substation that will have three double-circuit 240-kV

lines on the same path. Electrical power from WATL, the Alberta-British Columbia intertie,

local gas generation and southern wind generation would flow in this transmission corridor for

both the AESO’s FATD and the Fidler to Langdon alternative. Accordingly, the Commission

does not consider that either alternative is superior from the perspective of reliability.

217. Having regard to its technical comparison of the two alternatives, the Commission finds

that neither alternative is clearly superior from a technical perspective.

218. The Diagonal group emphasized that one of the significant benefits associated with the

Fidler to Langdon alternative was its substantial associated cost savings ($389 million) when

compared to the AESO alternative. The Commission notes that approximately 88 per cent, or

$342 million, of these cost savings are directly attributable to the cancellation of the

Chapel Rock (Crowsnest) project approved in the SATR NID. For the reasons provided above,

the Commission is of the view that a decision by it to eliminate the need for the Chapel Rock

project would be a de facto variance of the SATR NID approval. Accordingly, the Commission

does not consider it reasonable or appropriate to take into account the avoided costs of the

Chapel Rock project, when assessing the economic impacts associated with the Fidler to

Langdon alternative.

219. The remaining cost savings associated with the Fidler to Langdon alternative relate to

Grid Power’s estimated project costs. In the Commission’s view, the project costs estimated by

Grid Power are less reliable than those provided by the AESO, for two reasons.

220. First, the AESO’s cost estimate for the FATD was derived from information provided by

AltaLink, the transmission facility owner, which has considerable experience in siting and

costing transmission lines in the project area. By way of contrast, Mr. Cline was not qualified as

a routing expert in the proceeding and the Commission is not convinced, based on his evidence,

that he had the necessary skills, knowledge and experience to offer a credible opinion on the

high-level costs of the Fidler to Langdon alternative. For example, Mr. Cline speculated in his

evidence that it would be cheaper to build through the Porcupine Hills than across the southern

prairies based on a study that AltaLink completed for a project in northern Alberta. AltaLink

responded to Mr. Cline’s claims and pointed out that not only had Mr. Cline significantly

underestimated the cost of the structures, he failed to take into account the fact that conditions

considered in the AltaLink study were considerably different from the conditions in the

Porcupine Hills. Specifically, AltaLink observed that because of increased wind and ice loading

in the southern Foothills area, it would be necessary to use almost twice as many structures than

would be required in the study area in northern Alberta.38

221. The second and related concern for the Commission is that Grid Power did not

reasonably account for the challenges associated with routing a transmission line across the

terrain proposed in its alternative or the additional costs associated with addressing such

challenges. The Commission notes in this respect Grid Power’s application of the per kilometre

average line cost of the south Foothills project to the Fidler termination on the Fidler to Langdon

alternative. As noted by AltaLink, the terrain associated with the south Foothills project is flat

prairie whereas the proposed Fidler to Langdon alternative would traverse the more complex

terrain of the Porcupine Hills.

38

Transcript, Volume 12, pages 2549-2550.



222. The Commission is of the view that, given the shortcomings identified above, it is

difficult, if not impossible, to reasonably quantify the costs associated with Grid Power’s Fidler

to Langdon alternative. The Commission concludes that given these uncertainties, neither

alternative is superior from a cost perspective.

223. The Commission finds that the AESO’s preferred FATD alternative is clearly superior to

the Fidler to Langdon alternative from the perspective of environmental impacts. In this respect,

the Commission considered evidence on environmental impacts from Mr. Cline, and from

Dr. Gahbauer and Dr. Power, two expert witnesses that are employed by Stantec and were hired

by AltaLink to provide expert evidence with respect to environmental impacts.

224. The Commission gives the evidence on environmental impacts from the Stantec expert

witnesses considerably more weight than that provided by Mr. Cline. The Commission found

their evidence with respect to the environmental effects to be credible, well-informed and

premised on their considerable experience in the area. As noted previously, Mr. Cline was not

qualified to give expert evidence relating to environmental impacts.

225. The Commission finds that routing through the eastern Porcupine Hills presents more

environmental challenges than the south Foothills line route on flat prairie and is convinced by

the expert opinion of Dr. Gahbauer and Dr. Power that the combination of the gradient, climate

and concentration of rough fescue grassland along the Fidler to Langdon alternative would lead

to a high level of environmental disturbance.

226. The Commission observes that the Diagonal group did not present any detailed

information on the environmental impacts of the proposed routing for the preferred south

Foothills line in the vicinity of Mud Lake or the crossing of the Oldman River. The Commission

also accepts AltaLink's submissions that the crossing of dozens of tributaries of the Oldman

River has a higher overall potential for impacts than one crossing of a larger river and that

Mud Lake is not recognized as a significant breeding or staging area for water birds.

227. The Commission also observes that, in the past, there has been substantial opposition to

energy development, including the routing of transmission lines in the Porcupine Hills area. In

previous proceedings on new transmission facilities in that area, the Commission heard from area

landowners and the general public regarding their opposition to the construction of transmission

lines in the Porcupine Hills. While previous opposition to energy development in the Porcupine

Hills does not preclude future development, the Commission does accept that there are a number

of Albertans who have previously expressed a strong desire to preserve this area because of its

unique natural characteristics.

228. The Commission observes that, with respect to the Langdon termination, the residential

impacts are similar between the Fidler to Langdon route and the AESO’s alternative, in terms of

the residences that are newly exposed to transmission lines. While the conceptual Fidler to

Langdon route is shorter, the preferred route requires fewer acres of right-of-way.

229. In the above section, the Commission considered whether an interested party had

demonstrated that approval of the FATD NID and the SATR NID amendments were not in the

public interest because the Fidler to Langdon alternative proposed by the Diagonal group and

supported by IPCAA was a better technical solution than that proposed by the AESO. Having

considered the evidence before it, the Commission has concluded that no interested party met



this test. Specifically, the Commission finds that the Fidler to Langdon alternative is

incompatable with the existing SATR NID approval because it incorporates the elimination of

one of the transmission upgrades described in that approval. Further, the Commission is satisfied,

after comparing the two alternatives from the perspectives of technical capability, costs and

environmental and land-use impacts, that the AESO’s FATD alternative is superior to the Fidler

to Langdon alternative.

Comparison of the 138-kV alternatives

230. The AESO’s proposal for the proposed Foothills 237S substation and associated 138-kV

system development in the High River and Okotoks area is based on its long-term transmission

development strategy for both the local system in High River and Okotoks and the bulk system

in southern Alberta. The AESO intends to serve the load in High River and Okotoks area via a

new 240/138-kV source substation instead of from south Calgary, and to interconnect the

Saddlebrook power plant to the grid via this substation. Grid Power’s 911L at 138-kV proposal,

on the other hand, intends to supply the load in the High River and Okotoks areas via three 138-

kV lines from ENMAX No. 65 substation in south Calgary and one 138-kV line from Janet 74S

substation. Grid Power’s alternative eliminates the need for the Foothills substation.

231. In the following sections the Commission compares the two alternatives from the

perspectives of technical capability, costs and land-use impacts.

232. The Commission is of the view that construction of the proposed Foothills substation in

the area would provide greater future operational flexibility between High River and south

Calgary’s regional systems as compared to the Grid Power proposal. The Commission also

agrees with the AESO that construction of the Foothills substation would also open a potential

connection for the future western component of the full FATD from Foothills to Sarcee

substations. The Commission considers this to be an important consideration due to the physical

constraints that prevent the future expansion of the ENMAX No. 65 substation.

233. The load in the High River planning area was 86 MW at the time of the planning area

summer peak in 2011.39 Based on the AESO’s 2012LTO, the load in the High River planning

area is forecasted to be 114 MW in 2021 at the time of the planning area summer peak. The

average annual load growth rate for the High River area is 2.8 per cent.40 The Commission is of

the view that the High River area is not a load centre large enough to accommodate 350 MW of

local generation to its regional 138-kV system without further investigation and is not convinced

that Grid Power’s 911L at 138-kV proposal would provide a better interconnection option for the

Saddlebrook power plant by connecting it to the low voltage system in the High River area.

234. The AESO’s evidence showed that connecting the Saddlebrook power plant to the

138-kV system, as proposed by Grid Power, would result in reliability criteria violations. The

Grid Power report stated that its suggested 138-kV Saddlebrook interconnection is better than the

240-kV interconnection because it leverages the existence of local generation to improve the

reliability for the local load supply; however, Grid Power provided no technical evidence to

support this contention. The Commission finds that connecting the Saddlebrook power plant to

the local 138-kV system in High River as suggested by Grid Power, would likely result in higher

39

Exhibit 10.00, Appendix F AESO 2012 Supplement to Load and Generation Forecast, pdf page 1005,

Table 1: 2012 LTO Summer Load at Planning Area Peak. 40

Exhibit 10.00, Appendix F, AESO 2012 supplement to load and generation forecast, pdf page 1005.



system losses and the need to immediately rebuild approximately 21 kilometres of the existing

727L line.

235. Grid Power stated that its 911L at 138-kV proposal would only cost $2.5 million and

result in a total saving of $98.3 million, including both the savings from the future Big Rock

project and the cancellation of the AESO Foothills 138-kV proposal. As noted previously in this

report, it is the Commission’s view that it would be improper for it to take into account cost

savings that are premised upon foregoing other AESO projects.

236. The AESO estimated that Grid Power’s 911L at 138-kV proposal would cost $60 million

with -40/+80% accuracy, as opposed to $82 million for its Foothills 138-kV proposal based on a

-10%/+20% accuracy. The AESO’s present value analysis indicated that the cost of its proposal

would be in the range of $13 million to $45 million more than Grid Power’s proposal based on

the uncertainty ranges associated with each of the cost estimates.

237. The Commission prefers the AESO’s cost evidence over that provided by Grid Power. As

noted earlier, the Commission is not satisfied that Mr. Cline possesses the necessary skills,

knowledge or experience to provide expert opinion evidence on the costs associated with

transmission upgrades. Regardless of the Commission’s concerns about the Grid Power

estimates, it appears to the Commission that Grid Power’s 911L at 138-kV proposal would have

a lower cost than the AESO’s 138-kV alternative. However, due to the wide range of uncertainty

of these cost estimates (-40/+80%), the magnitude of potential cost benefits associated with

Grid Power’s proposal is not certain.

238. The Commission is of the view that neither alternative is superior to the other from the

perspective of land-use impacts and observes, in this respect, that the AESO’s proposal would

require approximately 14 kilometres of new double-circuit line and seven kilometres of the 727L

line between High River 65S and Magcan 142S substations to be rebuilt while removing

approximately 21 kilometres of the existing 727L line between the Janet 74S and Okotoks 678S

substations. By way of contrast, the Grid Power’s 911L at 138-kV proposal would require

approximately 21 kilometres of the existing 727L line to be rebuilt in order to interconnect the

Saddlebrook power plant. Further, the Grid Power proposal would limit the opportunity to

expand the 138-kV development at the ENMAX No. 65 substation in the future due to its

proximity to the highway and the ring road.

239. The Commission finds that the AESO’s Foothills 138-kV development plan would

provide better operational flexibility and long-term supply security for the High River area than

Grid Power’s 911L at 138-kV proposal, and that building the new Foothills substation would

allow for the bulk system development in southern Alberta and local generation interconnection.

In the Commission’s view, these technical considerations outweigh the cost and land-use

implications in developing the Foothills 138-kV plan.

240. Having regard to the foregoing, the Commission finds that the AESO's Foothills 138-kV

development plan is superior to the Grid Power 911L at 138-kV proposal. Accordingly, the

Commission concludes that no interested party has demonstrated that the AESO’s 138-kV

preferred technical solution was technically deficient or that its approval is not in the public

interest.



The SATR NID amendment and the Windy Flats substation

241. Two interveners argued that approval of the SATR NID amendment was technically

deficient and not in the public interest: Ronald and Laurie Conner, and IPCAA.

242. The Conners take the position that the SATR NID amendment is technically deficient

because the AESO failed to propose a technical solution that follows existing linear disturbances.

As noted earlier, the ISO has numerous statutory obligations associated with its function as the

transmission system planner. While the AESO must consider maximizing the use of efficient

rights-of-way, corridors, or other routes that already contain or provide for utility infrastructure,

this obligation must be read in concert with its other planning obligations as set out in the

Electric Utilities Act and the Transmission Regulation. Specifically, the AESO must plan a

system that satisfies reliability requirements and is sufficiently robust so that 100 per cent of the

time, transmission of all anticipated in-merit electric energy can occur when all transmission

facilities are in-service and, under normal operating conditions, can be dispatched without

constraint.

243. The Commission accepts the AESO’s evidence that the driver for the SATR NID

amendment (i.e. the Windy Flats configuration) is existing constraints on the 911L line and the

prospect of increasing critical constraints on that line starting in 2014, which will increasingly

constrain market participants in southern Alberta if not addressed in the near term. As noted in

Section 2.1.8 above, the Commission is of the view that the AESO has verified and confirmed

the FATD need by performing power system analyses that shows the existing transmission

system will create a “bottleneck” for the transmission of increasing wind generation to Calgary

by 2014. The Commission also finds that the urgency of the need is further supported by the

current constraints on the southern Alberta transmission system: constraints on the existing 911L

line and those experienced by TransAlta at its Ardenville, Blue Trail and Soderglen wind power

plants.

244. The Commission agrees with the AESO that the construction milestone for the 911L line

rebuild in the SATR NID approval has been met. The Commission is also persuaded that without

the FATD, the current and future wind generation will not be able to fully produce power at their

rated MW capacity and it accepts that pursuing the original Peigan configuration would result in

an 18- to 30- month delay and would not meet the in-service date of the 911L line rebuild. The

Commission finds that mitigation measures, such as remedial action schemes, to alleviate the

existing transmission system constraints under normal system operations are not viable

transmission planning solutions, and that it is not in the public interest to delay the 911L line

rebuild and hinder the market participants’ timely access to the transmission system.

245. Given the constraints identified by the AESO and the relative urgency to address these

constraints, the Commission considers that the AESO’s decision to pursue an alternative that

does not follow an existing disturbance or right-of-way for a small portion of the 120-kilometre

long line was reasonable in the circumstances and does not represent a technical deficiency.

246. The Conners also argue that it is not in the public interest because it breaches Section 15

of the Canadian Charter of Rights and Freedoms. A person who alleges a breach of Section 15

must show discrimination "in the sense that it denies human dignity or treats people as less



worthy".41 The Conners submitted no evidence of such discrimination and, in the Commission’s

view, it would not be reasonable to draw such a conclusion from any other evidence filed in this

proceeding.

247. Further, the Commission finds that there is no basis for the argument that the SATR NID

amendment has the effect of discriminating against the Conners or the Piikani First Nation due to

their race. The Commission is satisfied that the reason for the change in the substation location is

due to the potential for delay associated with the Peigan substation upgrades on federal lands

which poses scheduling implications and risks that are unacceptable to the AESO as the

transmission system planner. In the Commission’s view, the fact that the process for acquiring

access to federal lands is different than the process for acquiring access to lands that are subject

to provincial jurisdiction has nothing to do with the race of either the Conners or the Piikani First

Nation. Rather, the Commission considers that the existence of different regulatory approval

regimes for federal and provincial lands simply reflects the division of powers set out in sections

91 and 92 of the Canadian Constitution.42

248. Accordingly, the Commission finds that the Conners have not shown that a breach of

Section 15 of the Canadian Charter of Rights and Freedoms exists or that approval of the SATR

NID amendment is not in the public interest.

249. IPCAA argued that approval of the SATR NID application is not in the public interest

because the AESO failed to take into account the cost implications associated with the upgrade.

250. The Commission finds this argument to be without merit. In the Commission’s view the

AESO took reasonable steps to estimate the costs associated with the proposed SATR NID

amendment. As noted above, the Commission is satisfied that the AESO fulfilled its statutory

planning obligations when it proposed the amendment to address impending constraints on the

southern Alberta system.

251. Neither Powerex nor TransCanada took a position on whether the Commission should

approve the FATD NID and SATR NID amendment. However, both companies asked the

Commission to place conditions on any approval that the Commission might issue.

252. Powerex requested the Commission to condition its approval of the SATR NID

amendment by requiring the AESO to implement mitigation measures to address constraints on

the transfer capability of the Alberta-British Columbia intertie.

253. The Commission asked Powerex to produce a new nomogram in order to determine the

transfer capability of the 815 MW wind generation in the Pincher Creek area assuming the

Chapel Rock project is not yet in-service. The new nomogram submitted by Powerex eliminates

the nomogram interaction between British Columbia to Alberta transfers and Pincher Creek wind

generation output assuming the implementation of mitigations measures. Powerex submitted

that, as a result, the British Columbia to Alberta transfer capability would be limited to the

Western Electricity Ccoordinating Council path rating of 1,200 MW west to east flow for

815 MW of wind generation in the Pincher Creek area. Powerex is not objecting to the two need

applications nor did it argue that the need applications are technically deficient.

41

Gosselin v. Quebec (Attorney General) [2002] 4 S.C.R. 429, paragraph 17,. See also Canadian Foundation for

Children, Youth and the Law v. Canada [2004] 1 SCR 76 at paragraph 53. 42

P. Hogg , Constitutional Law of Canada, paragraphs 55-57.



254. The AESO has confirmed that it will address mitigation measures and the timing for

implementing these measures as part of the intertie restoration program. In the Commission’s

view, the conditions requested by Powerex are of an operational nature and do not arise from the

need application. Consequently, the Commission denies Powerex’s request for conditions to the

approval for the Windy Flats SATR NID amendment.

255. TransCanada requested the Commission to condition its approval of the FATD NID

application by including measures to avoid constraints being imposed upon its Saddlebrook

power plant under certain contingency conditions.

256. The Commission observes that the AESO investigated different mitigation measures to

resolve the N-2 contingency described by TransCanada. Further, the AESO committed to

develop mitigation measures to address all category C5 events that may exist in a timely manner.

Given this commitment, the Commission is of the view that no conditions are required to be

attached to the FATD NID approval.

257. In conclusion, Section 38 of the Transmission Regulation instructs the Commission on

the factors that it must consider when considering a need application filed by the AESO.

258. The Commission is satisfied that the public interest criteria set out in subsection 38(a) of

the Transmission Regulation are met. Reliable electrical transmission facility infrastructure is a

prerequisite to having an efficient and competitive generation market. The AESO has identified

the constraints of the existing transmission system and studied the performance of the proposed

alternative under forecasted load and generation scenarios and different system conditions.

259. The Commission is satisfied that the AESO’s proposed FATD will provide a reliable and

efficient transmission system which also has the flexibility for the future load growth and

transmission expansion. The proposed FATD facilities use land efficiently because the

development aims to maximize the use of existing rights-of-way, upgrading and rebuilding the

existing transmission lines.

260. The Commission is satisfied that the criteria set out in subsection 38(b) the

Transmission Regulation are met. The AESO’s proposed FATD will enhance system reliability,

efficiency and operational flexibility, which will consequently promote a robust competitive

electric market. In this application, concerns about reliability, system efficiency and operational

flexibility are met by means of new 240-kV substations, new transmission lines, new reactive

power compensation devices, the voltage conversion of the existing transmission lines and

discontinuing operation of some existing transmission facilities. The Commission is satisfied that

the proposed FATD will provide system capacity to meet the forecasted load and generation until

2019, and that the proposed transmission enforcement also preserves options for the long-term

plan of the transmission system in the project area beyond 2019.

261. The Commission has reviewed the need applications together with references in the

AESO’s 2012 Long-term Transmission Plan and is satisfied that the need applications and the

long-term plan are consistent. It also finds that this application is reflective of the AESO’s

responsibilities; in particular, its responsibility to plan the capability of the transmission system

to meet the current and future needs of market participants and plan a transmission system that

satisfies reliability standards. The criteria set out in subsections 38(c) and (d) of the

Transmission Regulation are also met.



262. With regard to subsection 38(e) of the Transmission Regulation, none of the interested

parties has satisfied the Commission that the AESO’s assessment of the need to expand the

transmission system in the southeast Calgary, Okotoks, High River, Nanton, Stavely,

Claresholm, Granum and Fort Macleod areas to meet load growth, address congestion, improve

system reliability and allow for the interconnection of future generation in the region is

technically deficient or not in the public interest.

263. Interveners did not take issue with the AESO’s participant involvement program. The

Commission finds that the AESO’s participant involvement program met the requirements of

AUC Rule 007. Further, the AESO applications met the technical requirements set out in

AUC Rule 007.

264. Having regard to all of the foregoing, the need applications and the preferred alternatives

are approved as filed by the AESO. In coming to this decision, the Commission had specific

regard for the evidence and argument of the parties, and the clear direction provided in

subsections 38(a) through (e) of the Transmission Regulation.

265. Finally, the Commission is compelled to comment on the uncivil and accusatory

submissions in Benign Energy's argument and reply. The Commission considers that such

submissions are unacceptable and unwarranted in this, or in any proceeding. Each party is

entitled to make its case before the Commission; no party should be the subject of personal

attack and invective. The Commission took no note of such submissions.

3 Criteria and route siting principles

3.1 AltaLink’s routing methodology

266. AltaLink stated that its objective during the route determination of the facility

applications was to identify one or more routes with lowest overall impact, having regard for

potential agricultural, residential, and environmental impacts, project costs, electrical

considerations, potential visual impacts and special constraints.43 In determining these routes,

AltaLink reviewed environmental and land-use data, considered feedback garnered from a broad

range of stakeholders over the course of its participant involvement program, and relied on its

siting experience and judgement.

267. AltaLink described its routing methodology as a “funnelling process” which

progressively refined the potential routes while more detailed information was gathered and

analyzed. Through this process, less desirable routing alternatives were eliminated until the

routes with the least overall impacts were identified. First, at the conceptual stage, AltaLink

identified potential land related impacts to assist the AESO in determining the best technical

solution for the project. Second, in the preliminary siting stage, AltaLink defined an appropriate

study area, identified major siting constraints within that study area, and then identified workable

preliminary routes. Third, in the detailed siting stage, based on feedback from the first round of

consultation, it further refined the routes, defined them in more detail, and decided upon a

preferred and an alternate route. Fourth, in the final siting stage, detailed routes were presented to

stakeholders on those routes for their input in the second round of AltaLink’s participant

involvement program. Based on the input from stakeholders, these routes were refined further

43

Exhibit 348.00, page 45, paragraph 208.



into the final proposed preferred and alternate route segments, applied for in the applications.

The specifics of AltaLink’s applications in this proceeding are set out below.

3.1.1 Preliminary siting stage

268. The study areas for the project developed to assist the AESO in determining the best

technical solution were further developed in the preliminary siting stage.

269. The study area for the north Foothills project consisted of Township Road 184 to the

south, the quarterline adjacent to Range Road 270 to the east, the quarter section line north of

Highway 22X to the north and Range Road 10 to the west. AltaLink stated that the areas beyond

these boundaries would not provide route options with lower impacts or cost.



Figure 9 – North Foothills project Study Area (with Preliminary Routes)44

44

Exhibit 13.00, page 58. Figure 4-2 Study Area (with Preliminary Routes).



270. AltaLink explained that paralleling existing transmission lines was considered in

developing preliminary routes for the north Foothills project. Within the study area, paralleling

existing transmission lines 1201L, 850L, and 911L was viewed as having potential for lower

overall impacts. Transmission line 1201L runs predominately north-south from the Frank Lake

area to Langdon and is sited through agricultural lands. As the line has been in place since 1985,

agricultural practices have evolved around the transmission line. AltaLink stated that while the

850L line runs diagonal through quarter sections, the line has been in place since 1953 and land

use has developed with the transmission line in place. Where the 850L line switches to a north-

south alignment, it joins up with 911L line, providing another potential site to parallel.

271. For the south Foothills project, the study area was modified to ensure it supported the

AESO NID and a review of the land use and residential densities in the area was conducted. The

study area boundaries for the south Foothills project are Township 7, parallel to 967L/968L line

to the south, the section lines at Range 24 of the Fourth Meridian to the east, the Bow River

valley to the north and the lower slopes of the eastern side of the Porcupine Hills to the west.



Figure 10 – South Foothills project study area (with preliminary routes)45

45

Exhibit 348.00, page 49. Figure 4-2 Study Area (with preliminary routes).



272. The AESO NID identified the proposed 1037L/1038L line as a replacement of the

existing 911L line. The existing 911L line right-of-way could not be repurposed for the new

transmission line because the 911L line cannot be de-energized prior to the new lines being in-

service. As a result, a new right-of-way is required. While the existing right-of-way could not be

used, AltaLink stated a route that parallels the 911L line was identified as an option that would

have a low overall impact. AltaLink stated that after the project is constructed and the 911L line

is removed, there would be a 40-metre shift in the routing, where the line parallels the 911L line.

273. The study area boundaries for the Langdon to Janet project are Township Road 230 to the

south, the section lines at Range 24 west of the Fourth Meridian to the east, Township Road 260

to the north, and the transportation and utility corridor in Calgary to the west.



Figure 11 – Langdon to Janet study area (with preliminary routes)46

46

Exhibit 90.00, page 55. Figure 4-2 Study Area (with Preliminary Routes).



274. AltaLink stated that paralleling of existing transmission lines, use of existing AltaLink-

owned rights-of-way and lands previously used for a railway were considered in developing

preliminary routes.

275. For the 138-kV project, AltaLink identified areas and transmission lines that could be

reused, rebuilt, relocated or salvaged, adding that the re-use of existing lines or rights-of-way is

generally considered to be of lower impact than greenfield routes. Subsequent to the construction

of the proposed transmission lines in the various applications, the 911L line would be available

for reuse or salvage. The AESO functional specification identified the reuse of a segment of the

existing 911L line from the Okotoks 678S substation as an option to complete the 850L circuit to

the Carseland 525S substation. The AESO functional specification also identified a segment of

the 911L line from the Okotoks 678S substation south to the Foothills 237S substation as an

option to reuse at 138-kV between the Foothills 237S substation and Okotoks 678S substation.

AltaLink identified 727L and 727AL lines as transmission lines that could be reused or the

right-of-way re-purposed. The AESO has identified that a segment of the existing 727L line

could be utilized for the connection of the 850L line from Carseland 525S substation to the

Okotoks 678S substation. AltaLink stated that lines 727L and 727AL could be used as double-

circuit lines to reduce impacts.

276. AltaLink also investigated rebuilding the 753L line as a double-circuit line and

converting a portion of the 850L line from 138-kV to 240-kV as options in reducing impacts.

277. The study area for the Foothills 138-kV project was confined due to the use of existing

transmission lines. For areas where greenfield development may occur, AltaLink considered a

study area with the northern boundary following a quarterline south of 338th Avenue, the eastern

boundary located approximately 1.6 kilometres east of the 1201L line, the southern boundary at

562nd Avenue, and the western boundary east of 40th Street and 48th Street in Okotoks.



Figure 12 – 138-kV study area in the High River – Okotoks area47

47

Exhibit 213.00, page 64. Figure 4-3 Study Area for Components A and B.



278. The study area for development between Okotoks and Calgary followed existing

transmission lines 727L, 911L and 850L.

279. To determine potential routes, AltaLink conducted a quarterline analysis. It viewed siting

transmission line on quarterlines of cultivated fields as a low-impact option. Once the

quarterlines in the study area were established, AltaLink reviewed no-go areas. Examples of

no-go areas are urban areas and high-density country residential areas, airport constraint areas,

public road allowances, parks and protected areas, major water bodies and provincial historic

sites. AltaLink’s quarterline analysis then removed quarter sections with residences within

150 metres from the quarterline; gas and oil wells within 50 metres of the quarterline; quarter

sections with residences within 800 metres of the quarterline; and quarterlines that cross lands

identified by the province as environmentally significant areas. After the removal of the no-go

areas in AltaLink’s quarterline analysis, AltaLink explained that there were no continuous

quarterline segments that connected the north study area to the south. As a result, AltaLink began

re-introducing quarterline segments previously removed due to the proximity of oil and gas

wells, residences within 150 metres and 800 metres, and environmentally significant areas.

3.1.1.1 Preliminary routings

280. Based on its quarterline analysis, AltaLink created preliminary routes for consultation.

For the north Foothills project, AltaLink developed preliminary routes north and south of the

Bow River. South of the Bow River, it developed two routes, one which paralleled the 1201L

line and one primarily greenfield route along quarterlines west of line1201L. AltaLink stated a

crossover route was identified, allowing for a combination of these two routes. To the north of

the Bow River, a number of preliminary routes were identified following quarterlines and

paralleling or replacing transmission lines. It also identified three target areas for the Foothills

237S substation.

281. For the south Foothills project, AltaLink explored the paralleling of existing and planned

future linear disturbances such as highways, irrigation canals and rail lines. The potential to

parallel a planned highway bypass east of the town of Claresholm provided AltaLink with an

opportunity to avoid the town.

282. AltaLink created three preliminary routes for consultation with stakeholders. The west

route primarily paralleled the 911L line, included an option to follow the highway bypass to the

east of the town of Claresholm and included an option to utilize a connector to cross over to the

quarterline south of Frank Lake. A central option was developed which originated southwest of

Fort Mcleod crossing the Oldman River and included an option to utilize a connector to cross

over to the 911L line parallel route northwards on quarterlines. An east route was developed

running east of Fort Mcleod crossing the Oldman River and continuing north to the edge of

Vulcan county.

283. For the Langdon to Janet project, AltaLink stated that the typical quarterline greenfield

routing was limited due to the relatively dense development in the area. AltaLink developed two

preliminary routes, one that paralleled the existing 936L/937L line and utilized AltaLink’s

existing right-of-way and a greenfield option that would parallel the Western Alberta

Transmission Line, Highway 560 and a potential irrigation canal.



284. For the new build portion of the Foothill 138-kV project, from the Foothills 237S

substation to the High River 65S substation and Okotoks 678S substation, AltaLink determined

that a double-circuit transmission line out of the Foothills 237S substation would be the best

option, to minimize impacts and land fragmentation. AltaLink developed preliminary routes that

paralleled existing transmission lines, highways as well as routes sited on quarterlines.

Figure 13 – Preliminary routes for the 434L/646L line48

285. For the remainder of the route to the Okotoks 678S substation, AltaLink proposed a

combination of a rebuild of the 727L line, reusing a portion of the 911L line and a short segment

of new transmission line.

48

Exhibit 213.00, page 73. Figure 4-9 Component A – Preliminary Routes for the 434L/646L Line.



Figure 14 – Component B – proposed routing for the 646L Line49

49

Exhibit 213.00, page 74. Figure 4-10 Component B – Proposed routing for the 646L Line.



286. For the components of the Foothills 138-kV project from the Okotoks 678S substation to

the Carseland 525S substation, AltaLink assessed reusing the 727L or 911L lines, but selected

the 911L line because it had fewer residences within 150 metres, had newer and more suitable

structures, and required no additional right-of way. The reuse of 911L line would require that the

voltage be reduced to 138 kV.

287. For the remaining components, AltaLink proposed that a portion of the 850L line be

increased from 138-kV to 240-kV, from ENMAX No. 65 substation to ENMAX No. 25

substation and the salvage of the 727L line between Janet 74S substation and Okotoks 678S

substation. AltaLink stated that there would be minimal visual change to the portion of the 850L

line that is being energized at a higher voltage and no new right-of-way required. Portions of the

salvaged 727L line would still contain FortisAlberta’s single-phase distribution lines underbuilt

on to the poles.

3.1.2 Detailed siting stage

288. During the detailed siting stage, AltaLink utilized feedback from the first round of

consultation and additional data to continue to refine the preliminary routes and identify a

preferred and alternate route. Examples of typical siting-related stakeholder feedback included:

identification of current agricultural practices, including aerial spray programs

identification of relevant area structure plans and development plans

identification of current and future land uses

identification of newly expanded road allowances

constraints around the river crossing locations

preferences for structure locations

identification of other potential route segment alternatives (e.g., along road allowances)

289. In addition to the stakeholder feedback, AltaLink considered the following additional

data:

from preliminary engineering and indicative tower spotting

on historical resources

from field collected environmental data sets (e.g., rare plants, raptor nests)

from updates to existing data sets (e.g., oil and gas wells)

290. For the north Foothills project south of the Bow River, refinements were made around

Frank Lake. AltaLink heard two competing views, one to have the route away from the highway

as south as possible to minimize development impacts, and one to have the route as north as

possible to have a greater distance from Frank Lake. AltaLink developed a mid-quarter route to

balance these views. AltaLink also made refinements on the west preliminary route, removing a

Bow River crossing location from consideration because several towers would be located within

a flood plain and hogback. AltaLink eventually removed the west route from consideration after

consulting with the landowners because additional turns and jogs were required, resulting in

higher agricultural impact and cost. It developed a new route between the west route and the

route paralleling the 1201L line.

291. To the north of the Bow River, the route parallel to the 850L line was refined to match

tower structure placement and to avoid residences. The greenfield preliminary option was shifted



further from Highway 22X to allow for future highway expansion. AltaLink stated that the

preliminary route paralleling the 950L/911L line required an additional eight metres of

permanent right-of-way and 50 metres of temporary right-of-way to accommodate the line.

292. AltaLink stated it considered parcel suitability and impacts of the substation footprint,

interconnection of proposed and future 500 kV and 240 kV transmission lines, 138-kV

connections to High River and Okotoks and 240-kV interconnection of local generation to

determine the site for the Foothills 237S substation. It assessed sites for potential impact on

agriculture, residences, and the environment; electrical reliability; cost; and space for future

expansion of the substation. Preference was given to sites adjacent to the 1201L line, to reduce

cost and impacts to connect the 1201L line to the substation. AltaLink also required a site that

could provide 138-kV interconnections to High River and Okotoks. Lastly, sites close to the

911L line were considered. AltaLink stated that at the commencement of the FATD project, the

911L line would be decommissioned and a portion of the line could potentially be re-purposed to

interconnect local generation, such as TransCanada’s Saddlebrook power plant. It identified

three sites, designated as D8, D12 and C215, as potential substation locations.

Figure 15 – Substation target areas50

50

Exhibit 13.00, page 92. Figure 4-27 Preferred and Alternate Routes with Substation Target Areas.



293. The D8 site was selected because it provided the best opportunity to reuse existing

infrastructure to connect local generation in the future, provided low local impacts and had few

impediments to the connection of future 240 kV and 500 kV lines. The D12 site was eliminated

because it would result in higher impacts for future interconnections for local generation. The

D12 site required a longer 240-kV line to connect the 911L line, which AltaLink envisioned

could be reused for future local generation interconnection. The D12 site was also less centrally

located in the southern study area and would provide less flexibility for future routing options.

294. AltaLink also rejected the C215 site as it would result in the greatest impacts for future

connections. Like the D12 site, the C215 site is less centrally located in the southern study area,

and development to the west near High River, Aldersyde and Okotoks would limit the potential

for future transmission lines. This site would also require a longer length of 240-kV lines to

connect with the 911L line. AltaLink also stated that the 138-kV connections to High River and

Okotoks would have the highest potential for residential impacts and would require a less

favourable river crossing.

295. For the north Foothills project, AltaLink selected the parallel 1201L line option as the

preferred route, with three optional routing segments around Frank Lake, the central diagonal

portion, and Highway 22X. Around Frank Lake, the preferred routing is situated west and north

of the lake. AltaLink also created a preferred variant route that parallels the 1201L line across the

lake. An alternate route was also developed which completely bypasses Frank Lake and its

associated environmentally significant area. The alternate route is sited on quarterlines before

realigning with the preferred route, parallel to the 1201L line.

296. AltaLink created a central alternate route sited on quarterlines as opposed to being

parallel to the 850L line. AltaLink stated the alternate route is long and has a greater number of

residences within 800 metres, but would not be sited diagonally across fields.

297. AltaLink created the Highway 22X alternate route as an option from paralleling the 850L

line in a diagonal configuration. This alternate route would travel north on the quarterline to

Highway 22X and then travel west into the city of Calgary to terminate at the ENMAX No. 65

substation. AltaLink stated this alternate route is longer, has more residences within 800 metres,

has the potential to impact future development, and does not have the opportunity to reuse

existing rights-of-way.

298. AltaLink rejected the remaining preliminary routes when selecting the preferred and

alternate routes.

299. For the south Foothills project, approximately 40 local refinements were made during the

detailed siting stage. For the west route, after considering feedback from landowners and the

town planner, AltaLink added that it refined the routing to follow the highway bypass and the

town of Claresholm to the east, instead of parallel to the 911L line to the west of the town. As

well, the route was adjusted to follow a secondary highway being developed north of High River

at the suggestion of the Town of High River, M.D. of Foothills and other stakeholders. The

adjustment reduced residential and land-use impacts. AltaLink also shifted the routing at the

northern end west of the Highway 2 crossing to reduce residential impacts and one tower on the

911L line was removed from the centre of a field to facilitate the spanning of the field by the

new line.



300. Refinements to the central route were made to take into account a landowner’s cultivation

practices, to reduce residential impacts, and to take into account wetland data. Near the

Windy Flats 138S substation location, the line was shifted five kilometres to the west, resulting

in a 2.5-kilometre reduction in length, a reduction in cost and fewer agricultural impacts. Other

adjustments and jogs were incorporated to reduce impacts on gravel extraction, agriculture and

irrigation, and to avoid surface water.

301. On the east route, adjustments were made to take into account cultivation practices,

preferences to reduce residential impacts, and to take into account wetland data. At the south

end, the line was shifted west of the quarterline to align with a steep side slope. North of

Highway 3, the route was shifted to a diagonal routing at the landowner’s request to reduce

residential impacts, cost and length. Shifts were also created to avoid irrigation, align with

cultivation and agricultural practices, and avoid surface water.

302. AltaLink identified the west route as the preferred route, the central route as the alternate

route and rejected the east route. AltaLink stated that the preferred route presented the lowest

overall impact compared to the other routes. A driving factor for developing the preferred route

was paralleling the 911L line. It added that the 911L line has been in-service since 1964 and

local land use has evolved around the presence of the line. The SATR NID approval also directs

the salvage and removal of the 911L line which would result in a lower incremental impact. The

preferred route would parallel the 911L line for 70 kilometres (59 per cent of its length). While

the preferred route has more residences within 800 metres, it has the fewest residences within

800 metres where it is not in parallel with the existing 911L line. The preferred route also crosses

the fewest kilometres of cultivated lands, has the least potential impact on environmental features

and interactions, parallels the most existing and planned future developments, is the shortest

route and has the lowest cost.

303. AltaLink selected the central route as the alternate route. The alternate route is primarily

a greenfield route situated primarily on quarterlines to reduce potential impacts. When compared

to the east route, the alternate route has a lower potential impact on cultivated land, avoids

potential impacts on parcels bordered on two sides by transmission lines, has a lower number of

raptor nests and observations of species of concern within 800 metres of the right-of-way,

follows more quarterlines that are not in close proximity to existing transmission lines, is shorter,

and is less costly.

304. The east route was rejected because it has greater potential agricultural impacts, higher

numbers of species of concern and raptor nests within 800 metres of the right-of-way, has more

potential for agricultural and residential impacts, crosses the Little Bow River at a crossing

identified as a higher risk with respect to historical resources, and is longer. AltaLink stated that

the new line and existing 138-kV transmission line would be half a mile apart for 39 kilometres,

which has the potential to impact agricultural practices and residences.

305. AltaLink also rejected three route segments in creating the preferred and alternate routes.

A route segment from the High River area to the Aldersyde area was rejected because it had

more potential residential and agricultural impacts, additional river crossings, and was a longer

length. The route segment to the west of Claresholm paralleling the 911L line was also rejected.

It stated that while the option to the east, parallel to the future highway bypass, is more

expensive, it has a lower overall impact, adding that this routing aligns with the town’s

municipal development plan and Alberta Transportation’s future plans. AltaLink also stated that



the move to the east side of town also has a lower potential for residential and agricultural

impacts; there are no residences within 150 metres and 26 first-row residences within 800 metres

of the alignment to the east side of town. To the west of town, there are two residences within

150 metres and 65 residences within 800 metres. AltaLink also removed the route segment into

the Peigan 59S substation because of the proposed SATR NID amendment, removing the Peigan

substation as a potential termination point for the project.

306. AltaLink created four new route segments, connecting the preferred and alternate routes

to create additional route option combinations.

307. For the Langdon to Janet project, the route paralleling the 936L/937L line was

determined to be the preferred route. AltaLink stated that while this route has more residences

within 150 and 800 metres, the overall land-use impacts were lower because it follows existing

linear developments, minimizing fragmentation. The preferred route was further refined from the

preliminary route. The deflection point to cross a double-circuit 240-kV transmission line was

moved to the east to accommodate existing and planned development. The route was further

refined as it approached Langdon 102S substation to utilize the same alignment currently being

utilized by the 936L/937L line. The existing 936L/937L line would then be re-located to the

north side of the new 1064L/1065L line. This refinement moved the existing and new

transmission lines from crossing a parcel diagonally near a residence. AltaLink also created a

variant route option, where the transmission line would continue to run along the old CP Rail

right-of-way to Range Road 274, just north of the Langdon 102S substation. This variant option

has the potential to reduce land-use impacts but would place the transmission line closer to

residences. Another refinement was an offset to the south boundary of the CP Rail parcel after

CP Rail raised concerns regarding potential electrical effects on future rail lines.

308. AltaLink selected the greenfield preliminary route as the alternate route, which primarily

follows quarterlines and has fewer residences within 150 and 800 metres. It applied refinements

to the preliminary route, attempting to align the transmission line with a future stormwater

conveyance system in the area and an existing railway.

309. AltaLink implemented refinements to various components of the Foothills 138-kV

program. The 434L/646L line was relocated from the north side of Highway 23 to the south side

to increase distance from a residence and the route was altered near Highway 2 and

498th Avenue to accommodate an interchange. AltaLink also proposed to terminate both lines

727L and 464L at the High River 65S substation, but determined there was not enough room to

accommodate both lines in that configuration. As a result, it proposed to terminate the 753L line

into a new bay, to free up its existing bay for the new circuit. A number of small refinements

were also implemented to improve clearance and avoid pipelines.

310. AltaLink selected the preliminary route by Highway 543 as the preferred route and the

route parallel to lines 911L, 753L and 727L as the alternate route for transmission line

434L/646L. AltaLink stated that the preferred route is located almost entirely in or adjacent to

municipal road allowances or highway rights-of-way. The alternate route is parallel to existing

transmission infrastructure but traverses more private lands. There are two points in the routing

option that allow for a combination between the preferred and alternate routes.



3.1.3 Final siting stage

311. In the final siting stage, AltaLink presented the preferred and alternate routes to

stakeholders during the second round of consultation to confirm the selection of these routes and

consult with landowners regarding tower placement. Where possible, tower placements were

adjusted to minimize potential residential and land-use impacts. To finalize the preferred and

alternate routes, AltaLink also consulted with Alberta Environment and Sustainable Resource

Development, Alberta Transportation, counties and municipalities. AltaLink also conducted

engineering and design work, additional environmental work, obtained historical resource

information, and updated their environmental, oil and gas, and other data.

312. For the north Foothills project, a triple-circuit structure was proposed for the portion

parallel to the 850L line, after landowners raised issues with agricultural impacts from a new

line. The proposed use of triple-circuit structures resulted in a shift in the proposed centreline to

maintain the line as close to the location of the existing 850L line as possible. This shift resulted

in the centreline moving approximately 20 metres north, placing the new centreline

approximately 14 metres south of the existing 850L line.

313. For the Bow River crossing, landowners requested the use of a pair of single-circuit

transmission lines rather than double-circuit towers after expressing concerns with the height of

the taller, double-circuit structure. AltaLink stated that both options were viable.

314. The use of monopole structures is also proposed within the city of Calgary, to mitigate

concerns with future development. During detailed engineering design work, AltaLink

discovered that the termination of the north Foothills project at the north side of the ENMAX

No. 65 substation would not be feasible and refined the routing to terminate at the south end of

the substation. This places the transmission line within the city of Calgary transportation and

utility corridor. AltaLink stated that it would seek ministerial consent for the portion of the

transmission line within the transportation and utility corridor boundary prior to construction.51

51

Exhibit 13.00, page 150.



Figure 16 – North Foothills project preferred and alternate routes52

315. After continued consultation with stakeholders, AltaLink amended its application to

include the D12 substation site as an alternate site for the substation. AltaLink stated that the

D12 site was a viable option for the Commission to consider.

316. For the south Foothills project, on the preferred route, a new alignment was developed to

align the route along an irrigation canal next to Mud Lake. Adjustments to the preferred route

were also made to avoid a feedlot, accommodate a setback from a sensitive species habitat and

allow for the expansion of an existing irrigation pivot. On the alternate route, adjustments were

made to accommodate agricultural practices, create greater separation from residences and

accommodate a setback from a storage facility. AltaLink also selected the location for a route

segment, designated as the Claresholm Connector, to allow for a combination of the preferred

and alternate routes.

52

Exhibit 13.00, page 105. Figure 4-34 Preferred and Alternate Segments with Designation Points (Final Siting

Stage).



Figure 17 – South Foothills project preferred and alternate routes53

53

Exhibit 348.00, page 16. Figure 3-1 Preferred and Alternate Routes.



317. For the Langdon to Janet project, no further refinements were made at the final siting

stage.

Figure 18 – Langdon to Janet preferred and alternate routes54

54

Exhibit 90.00, page 53. Figure 4-1 Final Routes.



318. Several changes were made during the final siting stage of the 138-kV project. A segment

of the alternate route was adjusted 10 metres to the west to avoid taking an easement and the

double-circuit transmission line was split into two separate single-circuit transmission lines to

cross under line 911L. A corner structure was also moved to avoid crossing over the corner of a

field.

Figure 19 – Foothills 138-kV project preferred and alternate routes55

55

Exhibit 213.00, page 106. Figure 4-37 Final Routing for the Foothills 138-kV Project.



4 Consultation

319. The Commission requires applicants for transmission lines to include a description of

their participant involvement program in their application. Appendix A, Participant Involvement

Program requirements, of AUC Rule 007 specifies that a participant involvement program must

be conducted before an application is filed, and should include the distribution of a

project-specific information package, responses to questions and concerns raised by potentially

affected persons and a discussion of options, alternatives and mitigation measures. The applicant

is expected to ensure that information is conveyed to the public in an understandable manner.

320. The applicant must also make all reasonable attempts to contact potentially directly and

adversely affected persons to discuss the project, and must respond to any questions or concerns

they may have. Additionally, the applicant is required to notify all persons initially consulted to

close the participant involvement loop, if the scope of the project changes or a portion of a

project, such as a preliminary route segment, is no longer being pursued. The applicant must

document the participant involvement program. It must retain communication logs, registered

mail or courier tracking, and personal consultation and notification documents. It must also track

concerns and objections received prior to filing the application and potential mitigations.

321. The applicant must also hold at least one information session or open house meeting in

each community that would be affected by the proposed development.

322. For transmission line developments, the applicant must provide public notification to all

occupants, residents and landowners within 800 metres of the edge of the proposed right-of-way

of the proposed transmission line.

323. The applicant must personally consult with all occupants, residents and landowners on or

adjacent to the right-of-way of the proposed transmission line. Personal consultation must

include a face-to-face visit or telephone conversation. In an urban setting, the applicant must

provide notification to, and personally consult with, all occupants, residents and landowners

within the first row of houses facing the proposed transmission line.

324. Project-specific information packages must be distributed to all occupants, residents and

landowners and should provide detailed information about the proposed development. The

information packages must include applicant contact information, the location of the proposed

project, including a site-specific map, a discussion of any potential restrictions regarding the

development of lands adjacent to the project, a description of the proposed on-site equipment, the

anticipated project schedule and an AUC brochure regarding participation in the Commission

process.

325. The Commission and its predecessor, the Alberta Energy and Utilities Board, have

previously expressed the importance of conducting an effective notification and consultation

program before an application is filed. In Decision 2008-006,56 the Board stated that

“the program should include responding to questions and concerns, discussing options, providing

alternatives and potential mitigation measures, and seeking confirmation that potentially affected

parties do not object.” The Board went on to state that it “expects applicants to be sensitive to

56

EUB Decision 2008-006: Montana Alberta Tie Ltd. 230-kV International Merchant Power Line Lethbridge

Alberta to Great Falls Montana, Applications No. 1475724, No. 1458443 and No. 1492150, January 31, 2008,

page 36.




timing constraints the public may have especially when dealing with landowners engaged in

agricultural endeavours.” The Board also stated that “the consultation process is a two-way street

and it also expects the public to participate in meaningful discussions with a proponent of a

project.”

4.1 Views of AltaLink

326. AltaLink stated that the goal of its consultation process was to inform those who might be

directly and adversely affected by the project, provide an opportunity for stakeholders to ask

questions, express their concerns, discuss alternatives and mitigation measures, and, to obtain

more information about the proposed routes. AltaLink stated it has taken stakeholder input into

consideration in all stages of the project.

327. The participant involvement programs for the Foothills area transmission developments

were quite extensive and were conducted over a period of three and a half years. AltaLink

notified approximately 8,100 stakeholders; conducted consultation with almost 1,400

stakeholders; held a total of 45 open houses and information sessions with more than 860

attendees and conducted consultation with 65 government agencies, 20 municipalities, 98

companies and 35 community groups and other organizations.

328. AltaLink stated that it conducted a two-phase participant involvement program with the

landowners, residents, and occupants in the vicinity of the proposed transmission lines and

substations, as well as local businesses; local, regional, provincial and federal government

representatives and departments; companies with operations in the vicinity of the project,

aboriginal groups, including First Nations and Métis, and special interest groups and

associations.

329. A two-phase consultation process was conducted. The first round of consultation began

with individual landowners in the vicinity of the proposed routes. A project-specific information

package was mailed to each landowner which included:

a project newsletter

the location of proposed facilities, including site-specific maps

a brochure describing AltaLink’s projects in southern Alberta

a brochure discussing electric and magnetic fields

a brochure which provided answers to frequently answered questions on the role and cost

of transmission service

an AUC brochure of the facility application process

a two-page overview of the FATD project supplied by the AESO

330. All individuals identified were provided with strip maps of the area of their land and

residences to allow them to identify their location in proximity to the potential routes.

331. Open houses followed the mail out of project-specific information packages and were

held in communities along the preliminary routes. For example, for Application No. 1608637 -

north Foothills project, the following open houses were conducted during the first phase of

consultation.



Table 1. AltaLink open houses for the north Foothills project

Date

Community

Location

Address

Hours of

operation

April 18, 2011 High River Highwood Memorial

Centre

128 – 5 Avenue West

High River, AB

4 – 8 p.m.

April 19, 2011 Okotoks Foothills Centennial

Centre

4, 204 Community Way

Okotoks, AB T1S 2N3

4 – 8 p.m.

April 20, 2011 Indus Indus Recreation

Centre

225155A Range Road 281A

Indus, AB T1X 0H7

4 – 8 p.m.

April 27, 2011 De Winton Heritage Pointe Golf

Course

1 Heritage Pointe Drive, De

Winton, AB T0L 0X0

4 – 8 p.m.

332. Open houses for all applications were advertised by way of project newsletters,

newspaper advertisements, posters and bold signs in high traffic areas, AltaLink’s website,

information centres, a toll-free telephone line and written correspondence. Information centres

for the public were also set up and staffed by AltaLink representatives.

333. AltaLink engaged third-party community consultation agents to carry out personal

consultation with landowners and residents within 150 metres of preliminary routes, as well as

those known to have unique farming practices or lands with environmental constraints likely to

affect the ultimate choice of routing. Consultation agents also consulted with persons in the

vicinity of a proposed route who requested consultation.

334. Once more detailed preferred and alternate routes were developed, AltaLink conducted a

second round of consultation. The second phase involved the notification of stakeholders still

potentially impacted by routes under consideration and stakeholders along routes that were no

longer under consideration by AltaLink.

335. An information package consisting of a project newsletter, updated maps, information on

structure types and work space requirements, information on the selection of the preferred and

alternate routes, and AESO newsletters for the need for transmission development was also

distributed. As part of the second phase, AltaLink set up an information centre and open houses.

For example, for the south Foothills project, open houses were held on February 28, 2011, in

High River; March 1, 2011, in Nanton; March 2, 2011, in Vulcan; and March 3, 2011, in

Claresholm. The open houses were advertised in the information package, local newspapers,

posters, street signs, and on AltaLink’s website.

336. AltaLink representatives continued to conduct personal consultations and distribute

project-specific information packages as AltaLink further refined and finalized the preferred and

alternate routes.

4.1.1 Group and personal consultation

337. AltaLink stated that personal consultation in phases one and two of its program included

door-to-door visits, telephone calls, one-on-one meetings and direct discussions with landowners

and residents; personal discussions at open houses and information centres; group presentations,

meetings and discussions; and correspondence. The consultation agents conducted face-to-face

visits and telephone conversations with all occupants, residents and landowners on or adjacent to

the proposed right-of-way for proposed routes.



338. AltaLink met with environmental groups and municipal representatives during its

participant involvement program as well as notified all county planning departments and federal,

provincial and municipal departments, and agencies about the proposed transmission lines and

substations. AltaLink also notified companies that own or operate pipelines, well sites or other

infrastructure in the vicinity of the proposed routes. AltaLink sent phase one and phase two

project overview and project information packages, and met with representatives to respond to

questions and discuss issues. AltaLink stated that consultation is ongoing and that no concerns

were identified that could not be resolved through further consultation, implementation of

mitigation measures or additional studies.

4.1.2 Aboriginal consultation

339. AltaLink conducted consultation with First Nation groups based on all components of the

AESO’s FATD NID and SATR NID amendment. It followed the Province of Alberta’s

requirements for First Nations consultation. For these applications, Alberta Sustainable Resource

Development (now known as Alberta Environment and Sustainable Resource Development)

confirmed the need to consult with the following First Nations:

Blood Tribe/Kainai First Nation

Piikani First Nation

Siksika First Nation

Tsuu T’ina First Nation

Stoney Nakoda First Nation (Chiniki, Bearspaw and Wesley First Nation)

340. AltaLink discussed its plans to conduct project-specific traditional land-use assessments

with these First Nations and provided the First Nations with project information packages. It also

provided support for the First Nations to conduct the traditional land-use assessments, and stated

that it continues to maintain communications with First Nations representatives, identify

potential project interactions with traditionally used sites and resources, and to develop

appropriate mitigation strategies. AltaLink also conducted information sessions with numerous

First Nations.

341. AltaLink also engaged Métis groups in consultation, distributed project information to the

Métis Nations of Alberta and held open houses.

4.1.3 AltaLink response to intervener consultation concerns

342. AltaLink stated in its argument that only a very small portion, six of approximately

8,100 stakeholders, took issue with the consultation that was completed on the project. The six

stakeholders were Mr. Nauta, Mr. Maldeghem, Mr. Friesz, Ms. Klatzel-Mudry, Mr. Bretin and

Ms. Carlson.

343. AltaLink submitted that it was clear that these parties were properly consulted and

described its consultation with each of the interveners. AltaLink demonstrated that Mr. Nauta

had been involved in several discussions with AltaLink and in argument, submitted that his

concerns were ultimately with the preferred route for the Foothills 138-kV line, and not with the

consultation program.

344. Mr. Maldeghem stated that he was not properly consulted on the triple-circuit monopole

option. AltaLink put forth that Mr. Maldeghem’s counsel cancelled a meeting due to the fact that



AltaLink does not compensate people for consultation. AltaLink then later provided a sketch of

the monopole option to Mr. Maldeghem’s counsel, but Mr. Maldeghem could not recall if he had

reviewed it.

345. AltaLink questioned Mr. Friesz about a consultation meeting AltaLink had with him.

Mr. Friesz ultimately conceded that he had been consulted on at least six occasions.

346. AltaLink disagreed with Ms. Klatzel-Mudry, who expressed concerns about the tower

design for the Bow River crossing. It contended that the single-circuit option was clearly

explained in the consultation. AltaLink stated that cross-section diagrams of the tower sizes,

which illustrated the differences between the tower options, were taken to all meetings.

347. AltaLink also argued that Mr. Bretin was consulted on a number of occasions and

submitted in undertaking 15 at the hearing that it informed Mr. Bretin of the preferred route on

March 14, 2012, and that the final routing was submitted on July 12, 2012.

348. AltaLink stated that many attempts were made to invite Ms. Carlson to consult.

Ms. Carlson indicated that she did not wish to further consult on the project in May 2011. In

October 2011 she was sent a project-specific information package which showed the revised

alternate route. On March 13, 2012, Ms. Carlson again indicated that she did not wish to consult

when advised by an AltaLink representative that the alternate route would go through her field

and would remain a viable route option. AltaLink maintained that it provided Ms. Carlson with

all the information that she would require to inform herself of the proposed changes to the

alternate route and provided several opportunities to discuss it.

349. AltaLink put forth that, for a project of this magnitude, the limited number of concerns

raised by stakeholders about the consultation conducted speaks to the program’s success, that it

was remarkably effective, and that it exceeded AUC Rule 007.

4.2 Views of the interveners

4.2.1 Langdon to Janet application

350. Members of the Mattson group took issue with AltaLink’s consultation. Mr. Vern Bretin

wrote to the Commission that he now believed that any further involvement by himself in

regards to the activities of SNC/AltaLink could have an impact on the siting upon his land and

that he felt threatened. Ms. Shelia Buckley stated that AltaLink did not respond to a request from

her to have her property bought at a reasonable price.

351. The Mattson group submitted in its argument that it believed that, while the consultation

process may help landowners understand the ‘how’ and ‘why’ of transmission line siting and

give the applicant the possibility to lessen the site-specific burden on landowners, a right-of-way

over a person’s land should be avoided whenever possible.

352. Mr. Daniel Meier stated that he was extremely disappointed by AltaLink’s lack of

communication, adding that his family had not heard anything for over a year and had to

approach AltaLink to receive an update on the project.

353. Ms. Sharon Carlson testified that AltaLink’s consultation was disappointing and grossly

unsatisfactory. She stated that AltaLink failed to disclose or provide reasons why it was



necessary to have a transmission lines across the McLaren/Carlson land and that no notification

of the change between the initial proposed alternate route and the current proposed alternate

route was provided.

354. Mr. and Mrs. McLaren, and Ms. Carlson stated that on May 3, 2011, they attended an

open house in Chestermere and submitted their concerns about the preferred and alternate routes

to Mr. Jay Wildman, an AltaLink land agent, and requested that AltaLink contact them once the

routing of the transmission lines was complete.

355. Except for being contacted by AltaLink on March 2011, and May 13, 2011, when the

original alternate route was discussed, Ms. Carlson stated that they did not receive any further

communication until July 20, 2012, when the alternate route was submitted to the AUC. This

applied-for line was significantly different than what was discussed with them when they were

first approached by AltaLink.

4.2.2 North Foothills and Foothills 138-kV applications

356. Mr. Randle stated at the hearing that he appreciated AltaLink listening to his concerns

and, in fact, that it amended its application to include an alternate substation location. He

mentioned that he got along really well with AltaLink employees. Mr. Randle attended many

open houses, met with AltaLink on his land on many occasions and even met with its

representatives at the AltaLink office.

357. Mr. Maldeghem stated at the hearing that although he did eventually become aware, he

was not initially consulted about the proposal of the monopole option.

358. Mr. Nauta questioned the AltaLink panel on their interpretation of public consultation.

Mr. Nauta stated that he did not receive any real consultation on the project.

359. Although the members of the Diagonal group wrote in their statements of intent to

participate that they had issues with the public consultation program conducted by AltaLink,

their statements did not provide further details about their concerns.

360. The members of the Diagonal group testified that throughout the consultation with

AltaLink, none of the members had been given a cross-section depicting the relative heights of

the new triple-circuit monopole structures versus the existing wood pole structures that were to

scale.

361. Mr. Friesz of the Diagonal group also testified that he thought AltaLink was playing with

his words in the consultation record regarding his preference for a triple-circuit monopole. He

emphasized that AltaLink was trying to convince the members of the Diagonal group that

placing all three of the circuits on a monopole structure was a vast improvement, while he was

saying that the diagonal routing of the line was the major problem. In his view, triple-circuiting

the line was a minor improvement. Mr. Friesz also submitted that he was not shown a picture of

the triple-circuited structure drawn to scale prior to the hearing and he was shocked when he saw

it.

362. Ms. Klatzel-Muldry stated that she was confused by the depiction of a single-circuit and

of a double-circuit version of the Bow River crossing that she received during consultation. She

stated that without a full understanding of the single-tower or two-tower options, it is very



difficult to make a decision on the matter. She submitted that she had no recollection of being

informed that the transmission line would go from one larger tower to two towers, and had never

signed-off or been consulted on the matter.

363. Ms. Klatzel-Muldry added that she had not expected that the consultation forms

completed during the consultation would be used a year and half later at the hearing; and that she

had thrown away her own notes a few months after the consultation because she had not heard

from anyone or thought that they would be useful. Recollecting what she had discussed during

the 2011 consultations was not an easy task.

364. Mr. Brunen of Western Sky-Land Trust stated that they had made contact with AltaLink

to discuss their interest with the Thomson property and their wishes for a single-tower alignment

crossing the Bow River. Western Sky-Land Trust did not receive any follow-up or consultation

from AltaLink other than the telephone call Mr. Brunen initiated.

4.2.3 South Foothills and Windy Flats 138-kV applications

365. Members of the Committee for East Route Conservation (CERC) group wrote in their

statements of intent to participate that they had issues with the public consultation program

conducted by AltaLink, but no further details were provided about their concerns.

366. The Conners stated that during their consultation with AltaLink in 2010, the preferred

route would severely disrupt their ranching and gravel operations. They discussed this concern

with AltaLink on many occasions and AltaLink gave them suggestions on how to navigate

around obstacles. In the end, AltaLink did not pursue any of these suggestions. They stated that

AltaLink would present ideas, only to later inform them that they could not be implemented.

AltaLink presented the amendment location, which was next to the Conners’ residence, after an

agreement on the preferred route was not reached with them.

4.3 Views of ENMAX

367. ENMAX conducted a public consultation process in accordance with the requirements of

AUC Rule 007 for both ENMAX No. 25 substation and ENMAX No. 65 substation. It conducted

public notification of landowners, residents and occupants within 800 metres of the proposed

substations, and personal consultation with all potentially directly and adversely affected

landowners and residents. It also notified local and provincial government officials and other

identified organizations, and held four open houses.

368. ENMAX stated that, throughout the consultation process for the project, no concerns

were raised with respect to the substations’ modifications.

369. ENMAX and AltaLink agreed that AltaLink would perform all consultation on behalf of

ENMAX for the 1064L/1065L line.

4.4 Commission findings

370. The participant involvement program was initiated early in the planning process by

AltaLink and ENMAX, respectively. The Commission considers that AltaLink and ENMAX

made a reasonable effort to ensure that all potentially affected parties were informed of the

application and had an opportunity to consider the potential impacts of the project. The design,

nature and extent of the participant involvement program provided parties with an opportunity to



provide input. AUC Rule 007 does not require compensation for consultation and in previous

decisions, the Commission found that AltaLink acted reasonably in denying payment of fees for

consultation.57 Interveners did not take issue with the AESO’s or ENMAX’s participant

involvement program.

371. Although the Commission acknowledges the importance of the concerns expressed by

interveners regarding AltaLink's consultation, the Commission must assess the participant

involvement program as a whole, in light of the nature and scope of the project at hand.

AltaLink’s participant involvement program notified approximately 8,100 households in the area

of the preliminary routes and personal consultation occurred with approximately

1,400 individuals. Taking into consideration the scale and scope of the program, it is not

surprising that there were some oversights. Although regrettable, the Commission is satisfied that

when these oversights were identified, AltaLink attempted to rectify them.

372. Some landowners expressed concerns that the single-circuit versus double-circuit

configuration or the one versus two tower terminology for the Bow River crossing was confusing

for stakeholders to understand. The Commission agrees that AltaLink could have better

explained the number of towers that were being proposed for each option to cross the Bow River

and the corresponding heights of these towers, but also recognizes that AltaLink made efforts to

take into account the concerns expressed by landowners and residents through its various stages

of routing. For example, in light of the changes to the landowners’ preferences, AltaLink

proposed an alternate tower configuration option for the Bow River crossing portion of the route;

an alternate site location for the Foothills substation was also proposed by AltaLink to reflect its

consultation with Mr. Randle.

373. The Commission will consider a participant involvement program to be effective if it

meets AUC Rule 007 requirements and has allowed stakeholders an opportunity to understand

the project and its potential impacts, express their concerns about the project and to provide

site-specific input to improve the project; however, an effective participant involvement program

may not resolve all stakeholder concerns.

374. The evidence demonstrates that AltaLink undertook a comprehensive participant

involvement program; that it utilized effective communication tools, including direct

consultation, mail notifications, open houses and information sessions. AltaLink also established

information centres and provided a dedicated phone number and an email address. It conducted a

phased approach to consultation to inform persons who might be potentially and adversely affect

by the proposed transmission lines and substations.

375. The Commission finds that potentially affected parties were provided with sufficient

information from AltaLink to understand the project and opportunities to express their concerns

during the participant involvement program. Also, if the persons who were notified and

consulted had unresolved concerns, these persons were informed about the Commission hearing

process, and had an opportunity to participate in the hearing and bring forward their concerns.

57

Decision 2009-049: ATCO Electric Ltd. Construct Updike Substation 886S and 144-kV Transmission Line

7L34, Application No. 1589611, Proceeding ID No. 114, April 28, 2009, paragraph 43; Decision 2011-445:

AltaLink Management Ltd. New 240/138-kV Nilrem 574S Substation, double-circuit 240-kV Transmission

Lines 953L/1047L and double-circuit 138-kV Transmission Lines 679L/680L, Application No. 1606753,

Proceeding ID No. 938, November 10, 2011.



376. Similarly, the evidence shows that ENMAX conducted a comprehensive participant

involvement program consisting of public notification, direct consultation and open houses.

ENMAX did not receive any objections to or concerns about the substations’ modifications

during its participant involvement program.

377. Based on the above, the Commission finds that the participant involvement programs of

AltaLink and ENMAX were conducted in accordance with AUC Rule 007.

5 Environment

5.1 Introduction

378. AltaLink stated that it used a staged approach to integrate environmental considerations

into project development, design and construction and described the following major

components of its environmental approach:

the review of environmental data both from electronic sources and field studies at the

route development stage so that the sensitive environmental features could be identified

and avoided where possible

the avoidance of environmental impacts through the elimination of unsuitable routes

adherence to environmental legislation and guidelines, including Land Use Guidelines for

Protection of Selected Wildlife Species and Habitat within Grassland and Parkland

Natural Regions of Alberta, Guide for Transmission Lines and Conservation and

Reclamation Information Letter Environmental Protection Guidelines for Electric

Transmission Lines (C&R/IL/95-2) and Environmental Protection Guidelines for

Transmission Lines (AE R&R/11-03)

review and consideration of available environmental information and stakeholder

knowledge of the local area during project planning and construction

Identification and evaluation of local environmental features (terrain and soils,

vegetation, wildlife, aquatics resources) and environmentally significant areas with

site-specific field investigations as needed

the implementation of environmental monitoring and reporting during construction

379. AltaLink presented the overview of its staged environmental approach in the following

flow chart.



Figure 20 – AltaLink’s staged environmental approach58

58

Exhibit 13.00, page 149. Figure 10-1 Environmental Approach Overview.



380. AltaLink stated that it retained Stantec to carry out an environmental evaluation of the

FATD project along the proposed preferred and alternate route segments in accordance with the

requirements of AUC Rule 007 and Alberta Environment and Sustainable Resource

Development guidelines for transmission lines. Stantec concluded that with the implementation

of appropriate mitigation measures, both the preferred and alternate route segments are viable

from an environmental perspective.

381. AltaLink stated that it developed the environmental specifications and requirements

(ESR)59 which defined construction-related environmental commitments and expectations for the

FATD project. AltaLink compiled the environmental mitigation measures in the ESR. Prior to

the commencement of the construction, AltaLink committed to require its contractors to prepare

and submit a construction and environmental management plan that meets the ESR for

AltaLink’s approval.

382. AltaLink described mitigation measures to be applied during construction to reduce

potential effects to biophysical resources. Project-wide mitigation measures were to include

scheduling construction, as well as construction and operations mitigations incorporating

provincial transmission line guidelines and industry best practices and standards. AltaLink

further committed to incorporate resource feature mitigations and additional site-specific

mitigations, if required, based upon the results of a pre-disturbance assessment program.

383. AltaLink noted that it had implemented, and would further introduce a number of design

features, to assist in reducing the potential environmental effects of the project. Towers were to

be located in a manner to avoid water bodies, water wells and disturbance to springs. Where

possible, AltaLink proposed towers to be set back from rivers or creeks and no towers were sited

within permanent, open water wetlands. Larger setbacks were applied for towers near outer

erosive river banks and, where possible, AltaLink stated it would avoid building structures

within any stream areas that were inherently unstable. It further committed to locate towers,

access trails and all-weather access roads at least 30 metres from the ordinary high water mark of

water bodies. In addition, Water Act approval will be applied for any water bodies that cannot be

avoided when siting.

384. AltaLink proposed that towers be set back from the edges of steep or unstable slopes and

that existing roads and previously-disturbed areas be used, where feasible, to access the

right-of-way and tower sites. Where possible, access approaches were proposed to be constructed

perpendicular to the watercourse to reduce disturbance to riparian vegetation. AltaLink proposed

to locate towers, access trails and temporary workspaces to avoid or reduce disturbance to rare or

sensitive native vegetation species and communities.

385. AltaLink also committed to develop, prior to construction, a reclamation plan utilizing

current best management practices and to ensure compliance with Alberta Environment and

Sustainable Resource Development’s Environmental Protection Guidelines for Transmission

Lines. Re-vegetation of disturbance was proposed using seed mixes and application rates,

59

Exhibit 23.00, Appendix J AltaLink Environmental Specifications and Requirements for north Foothills

Transmission Project; Exhibit 80.00, Appendix I AltaLink Environmental Specifications and Requirements for

Langdon to Janet Project; Exhibit 204.00, Appendix I AltaLink Environmental Specifications and Requirements

for Foothills 138kV Transmission Project; Exhibit 364.00, Appendix L AltaLink Environmental Specifications

and Requirements for Windy Flats 138kV Project; Exhibit 343.00, Appendix J AltaLink Environmental

Specifications and Requirements for south Foothills Transmission Project.



determined through consultation with landowners. Stantec prepared an environmental evaluation

report for each of the facility applications, which are detailed below.

5.2 Application No. 1608642 – Langdon to Janet

386. AltaLink described the preferred route as running parallel to existing transmission lines

for over 94 per cent of its length and traversing predominately agricultural or previously

disturbed land. The area is described as flat to very gently undulating topography underlain by

glacial deposits. The few relatively steep slopes in the area are associated with man-made

features such as road embankments and irrigation canals.

387. The project area is part of the Western Irrigation District, and characterized by wetlands,

local drainages, irrigation canals and Chestermere Lake, which was identified as the largest lake

in the area, although numerous small ephemeral lakes and wetlands were noted. Several large

wetlands, two large alkali ponds and a poorly drained wetland complex southeast of Langdon

were also noted.

388. Watercourses in the area were classified to be Class D based on the Alberta Environment

and Sustainable Resource Development Code of Practice,60 with a low sensitivity to disturbance.

The Bow River–Chestermere Lake diversion canal supported populations of sport fish but fish

habitat in irrigation canals was considered to be of low sensitivity, not classified under the

Code of Practice and the development would not require authorization under the Fisheries Act.

AltaLink stated that no threatened or endangered fish species occurred within the area.

389. The preferred route would avoid Chestermere Lake, the wetland complex in the eastern

part of the area and most of the larger ephemeral water bodies between the towns of Shepard and

Chestermere.

390. Most of the land is described as agricultural cropland or tame pasture; larger areas of the

remaining native prairie were found north of Chestermere Lake and surrounding Langdon.

Scattered smaller patches of native prairie occur around wetlands and watercourses south of

Chestermere Lake. Native vegetation, consisting of fragments of upland native prairie and

wetlands, were of low abundance on the right-of-way.

391. One plant species at risk and two rare plants were found to potentially occur within the

area, but AltaLink noted that the known occurrences were well outside of the proposed routing.

392. The project area is said to support high biodiversity, including 62 federally- or

provincially-listed wildlife species, some of which cannot be found anywhere else in Alberta.

AltaLink noted that three of those species are listed as endangered species and seven are

considered threatened.

393. Much of the wildlife habitat in the area is said to be highly fragmented with reduced

capacity because of extensive agricultural and urban development. There are few patches of

undisturbed native prairie found in the area, with most of the remaining grassland consisting of

tame pasture with introduced grasses. Remnant wetland, riparian features, areas of tame pasture

and native prairie remain important areas for wildlife.

60

Code of Practice for Watercourse Crossings, adopted under the Water Act and the Water (Ministerial)

Regulation, consolidated to include amendments in force as of June 24, 2013 (AENV 2007).



394. The area was described as situated in prairie pothole habitat with numerous wetlands and

adjacent upland habitat that provided excellent habitat for waterbirds and breeding areas for

amphibians and other species. AltaLink specifically noted that the North American Waterfowl

Management Plan identified prairie pothole habitat as a priority area.

395. A large number of waterfowl were recorded in a large Ducks Unlimited wetland complex

and potholes south of Chestermere Lake. Federally or provincially protected shorebirds were

said to be supported in alkaline wetlands further to the south. Wetlands northeast of Chestermere

Lake also provide important staging habitat within the siting study area; however, it has a highly

developed shoreline with limited wildlife habitat suitability.

396. Both the preferred and alternate routes were routed to avoid Weed Lake and the large

alkaline wetlands south of Chestermere Lake; however they intersect several pothole wetlands

south of Chestermere Lake.

397. AltaLink indicated that a moderate amount of wildlife habitat, including native prairie,

tame pasture, and wetland were found close to the right-of-way and in the landscape area for the

Langdon to Janet segment.

398. AltaLink asserted that the routing process and commitment to site-specific mitigations

had reduced or avoided several potential effects on wildlife. The nature and severity of the

remaining effects on wildlife resource features varies between the routes.

399. AltaLink identified potential effects to wildlife occurring during ground disturbance of

habitat and sensory disturbance during construction. New habitat creation and changes to

predator and prey interactions are also expected to occur during operations. Salvage is expected

to result in short-term sensory disturbance. AltaLink proposed to reduce site-specific effects to

wildlife by applying the proposed mitigation measures.

400. The alternate route parallels fewer existing linear disturbances and was found to contain

more than twice as much native prairie and proportionally more wetland habitat than the

corresponding section of the preferred route which contained proportionally more modified

habitat. As a result, wildlife mortality and habitat loss, sensory disturbance, and altered predator

prey relationships for wetland and grassland wildlife species are more probable along the

alternate route.

401. Risk of avian collision is predicted to be potentially high along portions of both the

preferred and alternate routes, where large numbers of waterfowl were recorded. The risk of

avian collision may be slightly higher for the alternate route because construction of a new

right-of-way would traverse more than twice as many wetlands and more wetland areas of

importance.

5.3 Application No. 1608637 – north Foothills transmission development

402. The environmental evaluation report,61 prepared by Stantec, described the project as

including the transmission line right-of-way, towers, a substation, access trails and temporary

workspaces for construction. Stantec also indicated that there was one crossing of the Bow River

and 16 crossings of tributary streams to Frank Lake.

61

Exhibit 23.00, Appendix J Environment, north Foothills Transmission Project Environmental Evaluation.



403. Stantec assessed soils and terrain, wildlife, vegetation (including wetlands), and aquatic

resources (i.e. water bodies) that were potentially vulnerable to impacts. That evaluation report

was described as being based on available data sets, supplemented by targeted field surveys and

ground truthing on public land, and on private land where landowners allowed access.

404. The primary environmental effect of construction of the proposed Foothills 237S

substation identified was wildlife habitat loss in the area of the substation and access road, and

the change in habitat use, in adjacent areas, due to sensory disturbance.

405. AltaLink’s preferred D8 site for the Foothills substation was described as a cultivated hay

or crop field whereas the alternate substation site D12 was described as reverted tame pasture.

The tame pasture at D12 was said62 to resemble native prairie and was relatively rare in the area;

whereas the land at D8 was described as previously disturbed land and it was said that

comparable forage was available elsewhere.

406. AltaLink asserted that the D8 site was more suitable from a wildlife habitat perspective

despite being on the margin of Environmentally Significant Area 237. AltaLink indicated that

this preference was offset somewhat by the higher incremental risk of avian collisions at the D8

site but emphasized63 Dr. Gahbauer’s testimony that the D8 site was proposed to be more than

900 metres from Frank Lake and expected to pose a risk of avian collision that was comparable

to the D12 site.

407. The application described the preferred route as crossing predominately agricultural and

other previously-disturbed land for about three-quarters of its length. Native vegetation on the

right-of-way was said to be low and consist of upland native prairie fragments, wetlands, and a

number of riparian areas. The preferred route would parallel existing rights-of-way for most of

its length, which would minimize fragmentation, reduce impacts to existing land use, and reduce

incremental visual impacts.64

408. The preferred route was reported to avoid crossing Environmentally Significant

Area 237, Frank Lake, which was described65 as the most important wetland in south western

Alberta for breeding water birds. AltaLink stated that Frank Lake is an important bird area,

which provides staging and moulting habitat during spring and fall for significant numbers of

waterfowl and shorebirds, including several species of concern. It is also the site of major

Ducks Unlimited avian habitat enhancement projects. Because it is a possible breeding water

body for trumpeter swans, in order to reduce avian mortality concerns, AltaLink set the preferred

route back a minimum of 500 metres from the current high water mark. The preferred route

variant is closer to Frank Lake while the Frank Lake alternate route is further away from Frank

Lake.

409. Stantec also identified Blizzard Lake and other smaller key wetlands that form a matrix

of upland pasture and wetland habitat, particularly immediately east of Calgary as well as north

of Gladys and north of Frank Lake.

62

Exhibit 720.04, AML Reply Evidence, Appendix C1 – Environmental Considerations. pdf page 12. 63

Exhibit 854.01, AML Written Argument. page 82-83, paragraph 205. 64

Exhibit 13.00, page 6, paragraph 20. 65

Exhibit 23.00, Appendix J Environment, north Foothills Transmission Project Environmental Evaluation,

page 2-11, Section 2.6, Wildlife.



410. The area where the proposed line would cross the Bow River was characterized as a

riparian area having steep river banks in an area of incised valleys or coulees but concerns about

the terrain were said to be addressed by spanning the valley. Some taller trees would be cleared

or trimmed to allow for safe operation.

411. Four wildlife species of concern were observed in the vicinity of the preferred route near

the Bow River, including two prairie falcon nests within the Alberta Environment and

Sustainable Resource Development-specified 1,000 metres setback distance. Populations of

breeding and staging waterfowl were said to be low.

412. AltaLink identified the 1201L parallel river crossing as the superior location to traverse

the Bow River valley. The alternate west route river crossing was rejected as it was said to

require an additional crossing of the Highwood River and would be closer to residents.

413. AltaLink’s preferred single-circuit design was said to have been selected in consultation

with Fish and Wildlife Management branch of Alberta Environment and Sustainable Resource

Development, and to address stakeholder concern regarding expected impacts to visual

aesthetics.

414. Stantec also stated that the preferred route was better from an environmental perspective

because it spanned valley walls, flood plain and riparian vegetation at the proposed Bow River

crossing. The Bow River crossing would also span McKinnon Flats, a managed site that provides

access to the Bow River. While both options were said to be viable, Stantec expressed a

preference for the double-circuit, indicating that in comparison, the clearing of two rights-of-way

for the single-circuit design would cause greater disturbance and that the additional wires of

single-circuit design would potentially increase the risk of avian collisions during operation.

415. The Frank Lake area alternate route was found66 to be more biophysically suitable and

pose a lower avian mortality risk than the corresponding section of the preferred route. The

Frank Lake alternate route was said to traverse much less native vegetation and less wildlife

habitat, avoid large wetlands, and be further away from Frank Lake. Although said to minimize

environmental impacts and effects to wildlife, compared to the preferred route, the Frank Lake

alternate route was characterized67 as being longer, costing more, fragmenting more agricultural

land and closer to more residences.

416. The preferred route variant, a second alternate route, was described68 as requiring up to

three structures across Frank Lake, adjacent to the existing 1201L line. Also, this route was less

biophysically suitable than the corresponding section of the preferred route because it crossed

open water sections of Frank Lake, which could pose greater erosion concerns crossing more

wetlands and the risk of bird mortality was predicted to be high even with the use of deflectors. 69

417. Stantec reported that the north alternate route and the corresponding section of the

preferred route were biophysically comparable and incrementally add to the risk of waterfowl

66


Section 9.3.1 South Options. 67

Exhibit 13.00, north Foothills Transmission Project Application, page 6, paragraph 20. 68

Exhibit 13.00, north Foothills Transmission Project Application,page 6, paragraph 21. 69

Exhibit 23.00, Appendix J Environment, north Foothills Transmission Project Environmental Evaluation, pdf

pages 69, 104, 105 and 109.



mortality from avian collisions. The majority of each section was described as predominantly

flat, with low risk for wind and water erosion, and traversing primarily modified habitat. The

corresponding section of the preferred route contained more wildlife habitat on the right-of-way

than the north alternate route, which had slightly more wildlife habitat in the landscape area.

418. AltaLink submitted a project-specific north Foothills transmission project ESR70 that

described mitigation measures to be applied during project construction and operations to reduce

or avoid potential adverse effects on biophysical resources. Those measures were said to be

typical of transmission construction projects and effective, irrespective of which route was

approved.

419. Stantec indicated that, after avoidance of adverse environmental effects, the most

important mitigation measure was the timing of construction. Completing construction of the

transmission line and substation in these habitats, outside of spring and early summer and after

seed set was said to reduce the potential for adverse effects. Another key mitigation measure

proposed was the use of bird flight diverters or wire markers to reduce the risk of bird collisions

with the line.

420. As noted above, to further avoid adverse environmental effects, and mitigate effects that

cannot be avoided, AltaLink committed to conducting pre-disturbance assessments of vegetation,

wildlife and habitats, wetlands and water resources.

421. Stantec concluded71 that, with the implementation of appropriate mitigation measures, the

preferred route, Frank Lake alternate route, preferred route variant and north alternate route were

all environmentally viable. The potential environmental effects that were not avoided during

routing could be effectively reduced or avoided, by implementing the measures outlined in

AltaLink’s ESR. The Frank Lake area alternate route was said to be more suitable than the

corresponding section of the preferred route while the preferred route variant was much less

suitable than the other two south options proposed. The north alternate route was said to be

generally comparable to the corresponding section of the preferred route.

422. AltaLink retained Arrow Archaeology Limited (Arrow) to assess historical resources and

submit a Statement of Justification for the Project to Alberta Culture. Alberta Culture outlined

the requirements for historical resources impact assessments for archaeology and paleontology.

423. AltaLink committed to complete an historical resources impact assessment and not

commence construction until clearance under the Historical Resources Act has been granted. It

further committed to implement, in consultation with Alberta Culture staff, mitigation measures

for any historical resources potentially impacted by the project.

5.4 Application No. 1608643 – Foothills 138-kV transmission development

424. AltaLink asserted that potential environmental effects that were not avoided through

routing would generally be reduced or avoided by implementing the mitigation measures

proposed. The preferred route, alternate route, common segment and alternate segment are all

considered to be viable from a biophysical perspective.

70


Environmental Specifications and Requirements, north Foothills Transmission Project, pdf page 1 to 16. 71

Exhibit 13.00, page 9, Section 1.9 Environment, paragraph 47.



425. The preferred and alternate routes are comparable in terms of expected effects to soils,

terrain and vegetation; however, the alternate route is more suitable from a wildlife perspective.

426. The common segment is said to have a moderate number of environmental features, but

AltaLink expects the biophysical effects to be limited because most activities are related to

vegetation removal. The risk of avian mortality from collisions during operations is expected to

decrease because of that removal.

427. The preferred route of the 138-kV line crosses predominantly disturbed land in flat to

gently undulating terrain with very few steep slopes and small areas of soils at high risk for wind

erosion, water erosion or compaction. One crossing of the Highwood River is said to be needed

for the preferred route.

428. AltaLink found relatively low abundance of native vegetation, upland native prairie

fragments, wetlands and riparian areas on the preferred route right-of-way, which is located

within one kilometre from a colony of great blue heron, a protected bird species.

429. The alternate route crosses predominantly disturbed land in flat to gently undulating

terrain, with very few steep slopes and small areas of soils at high risk for wind erosion, water

erosion or compaction. Two river crossings, the Highwood River and Tongue Creek, are required

for the alternate route.

430. A relatively low abundance of native vegetation and a small area of wetland and riparian

habitat were found by AltaLink on the right-of-way of the alternate route. AltaLink stated that

the preferred and alternate routes are comparable in regard to expected effects to soils, terrain

and vegetation; however, the alternate route is said to be more suitable in terms of effects to

wildlife, with only slight differences in wildlife habitat quantity and quality. The alternate route

was found to have slightly more grassland habitat in the landscape area and more wildlife habitat

in the right-of-way. The preferred route contains slightly more wetland habitat, slightly higher

waterfowl counts and is closer to a Highwood River heron colony.

431. The common segment is described as crossing the Bow River and Tongue Creek. A

moderate abundance of native vegetation was noted in the right-of-way of the common segments

but because vegetation removal and rebuild are proposed on an existing right-of-way, AltaLink

predicts few effects to vegetation.

432. A moderate amount of wetland, riparian and grassland wildlife habitat is found in the

landscape area of the common segment. These areas occur mainly along the 727L line which

AltaLink is proposing to remove. As a result, effects on wildlife, particularly from an avian

collision perspective, are expected by AltaLink72 to be limited following removal of the 727L

line and, in the long-term, have a positive effect on wildlife species most susceptible to avian

collision (e.g. waterfowl).

5.5 Application No. 1608861 – south Foothills transmission development

433. AltaLink stated that while both the preferred and alternate routes of the south Foothills

project are viable, the preferred route is more suitable from a biophysical perspective. Based on

available information, potential environmental effects that are not avoided through routing would

72

Exhibit 204.00, Appendix I Foothills 138-kV Environmental Evaluation, exhibit, 204, pdf page 165.



be effectively reduced or avoided with the implementation of the mitigation measures it

proposed.

434. The preferred route parallels a greater length of existing transmission lines and, therefore,

would disturb less native vegetation and contribute to less overall fragmentation of wildlife

habitat than the alternate route. The preferred route is said to traverse less area of moderate or

high quality wetland and riparian habitats; which are expected to result in a lower risk of avian

collisions than the alternate route.

435. The landscape area of both the preferred and alternate routes is characterized as having a

high proportion of cultivated or pasture lands with upland native prairie, wetlands, and riparian

communities composing less than one quarter of the area. Some localized dunes and sandy soil

areas were noted.

436. Both routes crossed the Oldman River, as well as several meandering rivers and creeks. A

wide variety of birds, mammals, amphibians and reptiles were said to occur in the area, including

wildlife species that are protected provincially and federally.

437. After avoidance, construction timing was identified by AltaLink as the second-most

important mitigation measure to minimize adverse environmental effects of the project. It stated

that it would “make efforts to not schedule construction in areas of native vegetation and tame

pasture between approximately April 15 and July 31.”73 Doing so would avoid the migratory bird

breeding period, avoid sensitive periods for other wildlife species, and reduce the potential for

effects on soils and vegetation. AltaLink clarified in its commitments74 that:

Nest surveys will be conducted should construction activity be proposed during the

breeding bird season (April 15 – July 31). Construction will only take place during the

bird breeding season at specific locations using site specific mitigation based on the

results of nest surveys.

438. The Claresholm Connector was described by AltaLink as a viable segment located

predominantly within cultivated land with some areas of wildlife habitat. The Windy Flats

substation variant route was determined to be viable, but less suitable from a biophysical

perspective, than a comparable section of the preferred route because the variant intersects a

much larger amount of native prairie and wetland habitat, and is expected to have higher

potential for avian collisions.

5.6 Application No. 1608862 – Windy Flats 138S substation and line reconfiguration

439. Stantec stated that the majority of the landscape area consists of native prairie with areas

of agricultural (cultivated and pasture) land and small to medium wetlands and drainages. The

project landscape area does not occur in a designated park, protected area or environmental

significant area. Stantec considers that the potential effects of the project on soil quantity and

quality through erosion are low. A very small area of the project right-of-way contains steep

slopes that would be spanned by the project. Stantec concluded that the overall potential effects

of the project on soil compaction would be low.

73

Exhibit 343.00, Appendix J south Foothills Transmission Project, Environmental Evaluation, pdf page 230,

Section 9.2 Preferred and Alternate Routes. 74

Exhibit 807.01, AltaLink undertaking 006.



440. Stantec indicated that there were few drainages and wetlands within the project

right-of-way; that the disturbance to native vegetation from the salvage and rebuild of the lines

was expected to be limited; and that the risk of introducing weed species was expected to be low.

441. Stantec stated that the landscape area has important features for wildlife, including native

prairie, a coulee and a staging wetland. Following effective mitigation measures outlined in

AltaLink’s ESR,75 Stantec concluded that potential effects on wildlife, including mortality and

change in habitat availability and suitability, are expected to be low.

442. Stantec stated that the new monopoles installed during the rebuild would not provide any

additional habitat or perching opportunities for raptors over what already occurred with the

existing line. It concluded that there would be no net change in availability of nesting or perching

opportunities for raptors and that no change in predation pressure on prey species was expected.

5.7 Application No. 1608649 – ENMAX application

443. ENMAX’s application involves modifications to its No. 25 and No. 65 substations. It did

not perform any environmental studies for this application, however, it conducted environmental

assessments in the ENMAX No. 65 substation application (Proceeding No. 1007) and in the East

Calgary transmission system upgrades and Shepard Energy Centre connection application

(Proceeding ID No. 1229), respectively. Both applications were approved by the Commission.

6 Electrical considerations

6.1 Views of the applicant

444. AltaLink stated that stakeholders raised concerns with the electric and magnetic field

(EMF) levels and the effects on human and animal health. AltaLink used a computer model

called Corona and Field Effects to model the expected EMF levels for the proposed 138-kV and

240-kV transmission lines and asserts that the results of the models are well below the

International Commission on Non-Ionizing Radiation Protection (ICNIRP) guidelines. The

profiles generated by the model show that the EMF levels are strongest when close to the lines

and diminish quickly as the distance increases from the lines. Objects such as wood or metal

would cause the electric field to diminish at an even faster rate or to be completely shielded.

AltaLink stated that at 150 metres from centreline, there are no material changes in the calculated

electric or magnetic fields levels when compared to existing levels for all proposed transmission

lines. The electric field 150 metres from centreline is expected to be zero kilovolts per metre

(kV/m) for all lines except for 1064L/1065L, where the reading is 0.1 kV/m. The magnetic field

150 metres from centreline would be between 0.1 to 3.7 milligauss (mG) for the 240-kV lines,

and 0.3 mG for the 138-kV lines. The ICNIRP guideline for electric fields exposure to the public

is 4.2 kV/m and 2,000 mG for magnetic fields.

445. AltaLink stated it treated health concerns seriously and hired Exponent Inc. to prepare a

report on research developments since the 2007 World Health Organization’s review on

extremely low frequency electric and magnetic fields and health. The report concluded that,

based on the research, EMF is not a cause of any long-term adverse effects to humans, plants or

animal health. AltaLink also noted that Health Canada and the World Health Organization,

75

Exhibit 364.00, Appendix L AltaLink Environmental Specifications and Requirements Windy Flats Project.



among other agencies, have reviewed EMF research and that none of these agencies concluded

that exposure to EMF from transmission lines is a cause of any long-term adverse health effects.

446. At the hearing, AltaLink’s EMF expert from Exponent Inc., Dr. L. Erdreich, explained

that the evidence that there are no health effects from EMF has been firmly established for some

time. Dr. Erdreich stated: “This [EMF] is not recognized as a health risk by any of the

international or national health authorities”76 and that the “idea that there’s no adverse health

effects from these kind of exposures that you can get in the ordinary environment has been pretty

solid, since, I would say, maybe 1998 and certainly after the 2007 WHO report.”77

447. AltaLink stated that transmission line magnetic fields are generally too weak to affect

pacemakers and that there are no cases of EMF from transmission lines interfering with

pacemakers recorded in the EMF literature. AltaLink stated that it would continue to assist

stakeholders who express concern with pacemaker interference by providing information on the

expected EMF levels so that the stakeholders could discuss the use of appropriate pacemakers

with their doctors.

448. The corona phenomena occurs when the surface of a transmission line conductor builds

enough electric charge to cause the surrounding air to ionize, potentially resulting in audible

noise and radio and television interference. AltaLink stated that the maximum audible noise from

the transmission lines is 22 decibels A-weighted (dBA) (Leq) for the north Foothills project,

eight dBA (Leq) for the south Foothills project, nine dBA (Leq) for the Langdon to Janet project,

and 10 dBA (Leq) for the Foothills 138-kV project at the edge of the right-of-way. These levels

of audible sound are well below the permissible sound level of 40 dBA (Leq) in rural areas under

fair weather conditions, as required by AUC Rule 012: Noise Control (AUC Rule 012).

449. AltaLink calculated radio interference levels to be below the applicable regulatory

standard for fair weather limits from 138-kV, 240-kV and 500-kV transmission lines and that it

would conduct radio interference measurements following construction to confirm regulatory

compliance.

450. According to AltaLink, it is unlikely that transmission lines would interfere with global

positioning system (GPS) signal reception under normal operation of the transmission line. It

will work with stakeholders to investigate potential GPS related concerns and mitigate any GPS

interference caused by its facilities.

451. AltaLink is confident that the transmission line will not affect cable television, wireless

internet or satellite television reception, but is committed to identifying sources of interference

and mitigate interference caused by its facilities.

452. AltaLink will also work with stakeholders in close proximity to the proposed 138-kV and

240-kV developments to assess potential induction on metallic objects, such as fences, irrigation

pivots and equipment, and install mitigation measures as necessary.

453. A report was prepared on behalf of AltaLink and Astral Media Radio G.P. (Astral) to

assess the impact of the proposed transmission line on CKMX’s AM transmitting facilities. The

76

Transcript, Volume 4, page 660, lines 16-18. 77

Transcript, Volume 4, page 662, lines 5-8.



report concluded that the preferred route will result in lower radiation levels than the existing

line and have no adverse impact on the station. AltaLink developed several mitigation options

with Astral to resolve the reradiation issues posed by the north alternate route. It is aware of the

potential safety risk and has safety work processes during construction and maintenance

activities that mitigate any potential safety concerns to AltaLink personnel.


454. Members of the Diagonal group and Mattson group raised concerns about EMF and its

potential to be a carcinogen, and submitted potential impacts of EMF on animal and plant health,

sleep cycles, stress, and cancer. Mrs. McMurray testified that there is much unknown about EMF

and its potential impact on human and animal health.78 Mr. Nauta also expressed concerns about

EMF. He stated that his family should not have to put up with being exposed to the detrimental

health effects of the transmission line.79

455. However, no expert evidence was filed by the interveners and Dr. Erdreich was not cross-

examined by the interveners on potential health effects of EMF.

456. Astral is opposed to the north alternate route, 800 metres north of the centre of radiation

from its CKMX transmitter site. Astral expressed concerns related to the north alternate route

including potential for reradiation of the CKMX radio signal, and safety risk for the AltaLink

installation and maintenance staff. The north alternate route is 800 metres directly north of the

centre of radiation from the CKMX transmitter site. This route will result in double reradiation of

the existing line and may require expensive treatment or, in a worst case, relocation of the

CKMX transmitter site to avoid compromising the station’s coverage area and Industry Canada-

regulated protection patterns. Astral submitted that the strong radio frequency fields from the

CKMX transmitter site could cause interference to construction equipment, control and telemetry

systems, and introduce potential hazards to workers.


457. The Commission acknowledges the interveners’ concerns about potential impacts of

EMF from transmission lines on human health. However, the evidence submitted by AltaLink

regarding electric and magnetic fields of the proposed lines and their potential impacts is

uncontroverted.

458. Further, the results of AltaLink’s computer modelling of the EMF associated with the

proposed 138-kV and 240-kV transmission lines are credible. The profiles generated by the

model show that the electric fields and magnetic fields are strongest when close to the lines and

diminish quickly as the distance increases from the lines. The electric field levels at the edge of

the right-of-way are expected to be between zero and 3.5 kV/m for the various proposed

transmission lines, which is lower than the ICNIRP guideline of 4.2 kV/m. The magnetic field

levels at the edge of the right-of-way are expected to be between two and 96.1 mG for the

various proposed transmission lines, which is also lower than the ICNIRP guideline of

2,000 mG.

78





459. The Commission took note that on the proposed preferred route for the Langdon to Janet

application, the proposed transmission line would be within 50 metres of Mr. Mattson’s

residence. AltaLink modelled this area under profile A and found that the electric and magnetic

field at 50 metres in this area is 0.1 kV/m and 3.4 mG,80 which is significantly lower than the

ICNIRP guideline of 4.2 kV/m and 2,000 mG.

460. The Commission also considers persuasive the following statement in the Exponent, Inc.

report which reviewed current EMF health research, that:

The numerous national and international scientific agencies that have reviewed this

research have not concluded that exposure to ELF EMF is a cause of any long-term

adverse health effect.81

461. Furthermore, at the hearing, it was reiterated that the health studies have not established a

link between EMF and adverse health effects from electric and magnetic fields.

462. The conclusion of Health Canada that exposure to EMF from transmission lines is not a

demonstrated cause of any long-term adverse effect to human or animal health is considered

important to note. In addition, Health Canada states that:

At present, there are no Canadian government guidelines for exposure to EMFs at ELF.

Health Canada does not consider guidelines for the Canadian public necessary because

the scientific evidence is not strong enough to conclude that exposures cause health

problems for the public (Health Canada, 2010).82

463. Astral has not expressed particular concerns of potential reradiation from its CKMX

transmission site and safety risk in relation to the preferred route of the proposed transmission

line. The Commission accepts the conclusion from the study report that the preferred route will

result in lower radiation levels than the existing line and will have no adverse impact on the

station.

464. Lastly, based on the evidence submitted by AltaLink with respect to noise impacts from

the corona effects, the proposed transmission line and substations meet the requirements of AUC

Rule 012.

465. Accordingly, the Commission finds that there is no evidence in the proceeding that

suggests that there would be adverse impacts from electrical considerations related to the

proposed transmission lines and no evidence that the effects would differ between the preferred

and alternate routes.

80

Exhibit 85.00, EMF Material, page 18, Tables 1-12 and 1-13. 81

Exhibit 85.00, Exponent Inc, Research Developments Since the 2007 WHO Review of Extremely Low

Frequency Electric and Magnetic Fields & Health, page xii. 82

Exhibit 85.00, Exponent Inc, Research Developments Since the 2007 WHO Review of Extremely Low

Frequency Electric and Magnetic Fields & Health, pages 19.



7 AltaLink Application No. 1608642 – Langdon to Janet

7.1 Preferred and alternate route selection

466. The Langdon to Janet project is located in the southeast part of Calgary and the Langdon

area. Seven kilometres of the proposed preferred Langdon to Janet route will be within the

ENMAX service area and will be owned by ENMAX; the remaining portion to the east of the

city limits of Calgary will be owned by AltaLink.

467. AltaLink proposed both a preferred and an alternate route for the Langdon to Janet

transmission line application. The proposed preferred route parallels an existing transmission line

(936L/937L) for almost all of its length, while the proposed alternate route is mainly a greenfield

route. These routes are depicted in Figure 21 below.

Figure 21 – Langdon to Janet project area map83

83

Exhibit 90.00, page 53. Figure 4-1 Final Routes.



468. The preferred route follows the existing 936L/937L line alignment from the Langdon

substation to the Janet substation. The existing 936L/937L line has slight realignment from its

original route as it approaches the Langdon 102S substation. AltaLink is also proposing a route

variant for the final 1.5 kilometres that enters the Langdon substation. The route variant would

continue straight on an abandoned CP railway line and turn south to the Crossings and Langdon

substations. The preferred route in the vicinity of the Langdon 102S substation and the route

variant are depicted in Figure 22 below.

Figure 22 – Preferred route/route variant for entering the Langdon and Crossings substations

84


469. AltaLink stated that the preferred route is the lower impact route because it parallels an

existing transmission line for almost its entire length (94 per cent). Land fragmentation is

minimized on this route due to paralleling the proposed transmission line with the 936L/937

line.85 Also, paralleling would reduce both the required right-of-way and the amount of private

land required for the right-of-way. South of the Janet 74S substation, AltaLink owns

approximately 5.75 kilometres of an existing 90-metre wide right-of-way. This existing

right-of-way would be used for nearly one third of the total length of the proposed line. AltaLink

also stated that paralleling the line would create less potential for impacts on the environment

because the line would run adjacent to existing disturbances. Further, the preferred route for the

84

Exhibit 90.00, page 76. Figure 4-17 Detailed routes near the Langdon 102S substation. 85

Exhibit 90.00, AltaLink application, Langdon to Janet project, paragraph 14.



Langdon to Janet area has less of an impact on agriculture, traversing only four kilometres of

cultivated land, compared to nine kilometres on the alternate route.86

470. AltaLink provided information about the proximity of existing residences to the proposed

and alternate Langdon to Janet routes.87 This information is reproduced in the table below:

Table 2. Proximity to residence comparison between the preferred route and the alternate route

Preferred route Alternate route

Residences within 150 metres of centreline 8 2

Residences within 800 metres from right-of-way edge

49 38

Residences within 150 metres of centreline now closer to transmission line

4 0

Residences within 800 metres of right-of-way edge now closer to transmission line

14 1

471. AltaLink acknowledged that there are more residences along the preferred route,

however, it submitted that the incremental impact of a route paralleling the existing 936L/937L

line was lower than the impact of a new greenfield alignment.88 AltaLink explained that when

planning the transmission line routing, it took into account that residents and landowners who

participated in the consultation were concerned with the viewscape to the west towards the

Rocky Mountains. AltaLink made available simulated photos of tower renderings, cross-

sectional views and visual simulations of the towers in the consultation documents and at the

open houses. It determined in the route determination process that the option to parallel the

existing 240-kV 936L/937L line would reduce the visual impact of the line and added that in

order to mitigate visual impacts, mainly tangent towers were proposed, which reduces the size of

the towers. It also proposed to match the existing tower locations of the 936L/937L transmission

line to reduce the impact of the towers.

472. Witnesses for AltaLink testified that from a visual impact perspective, the preferred route

would have an incremental impact while the alternate route would have a greater impact since it

is primarily a greenfield route.89

473. AltaLink emphasized that by paralleling the existing transmission lines, the preferred

route requires the acquisition of less private land for the right-of-way.

474. AltaLink submitted the following total project costs, within plus 20% or minus 10% of

the costs estimates:

Langdon to Janet transmission line preferred route: $99,184,000 including $22 million in

the ENMAX service area

Langdon to Janet transmission line alternate route: $113,357,000 including $5 million in

the ENMAX service area

86

Exhibit 90.00, AltaLink application, Langdon to Janet project, Table 4-1, page 82. Also see paragraph 274,

pages 82-83. 87

Exhibit 90.00, AltaLink Langdon to Janet Project application, page 82. 88

Exhibit 90.00, AltaLink Langdon to Janet Project application, page 74, paragraph 252. 89




475. AltaLink stated that if the alternate route were approved, there would be a schedule delay

which would result in increased project costs, such as incremental escalation and project carrying

costs. A normalized estimate of the alternate route would be $109 million, with the project costs

presented on a common basis by assuming the work starts at the same time and proceeds on the

same schedule.

476. AltaLink argued that the Mattson group submissions focused on residential impacts,

ignoring other factors that must be collectively considered in assessing overall impacts of

proposed transmission routes. It argued that the preferred route parallels existing linear

disturbances (including an existing transmission line and former railbed), utilizes an existing

92-metre right-of-way, and that all land, with the exception of the Schemenauers, were

purchased by members of the Mattson group after the existing transmission line was present.90

477. AltaLink has stated that Mr. Mattson qualifies for a buyout, which AltaLink has

expressed as its preferred course of action. It has also proposed a monopole option for

Mr. Mattson’s land that it argues would eliminate the need for additional right-of-way on his

land and allow him to continue conducting his existing operations.91

478. Ms. Buckley and Mr. Beck raised concerns over future developments on their property,

including the construction of a residence. AltaLink argued that the only location on their

property where Ms. Buckley and Mr. Beck would not be able to construct a residence would be

within the expanded right-of-way that extends 10 metres onto their property, and that as such,

nearly all of their property would be available for development.92

479. The McLaren/Carlson group raised concerns over the fragmentation of their land by the

alternate route. AltaLink argued that the McLaren/Carlson group would have one tower located

on their parcel along with the associated right-of-way. AltaLink proposed to place the tower near

the low-lying depression that is currently not being cultivated on the property and also addressed

the group’s desire to have the line placed on the southern quarterline. It stated that there were

environmental concerns with moving the proposed transmission line and that the neighbour to

the south indicated that the towers would create obstacles to farm around.

480. AltaLink acknowledged that the right-of-way of the alternate route would have an impact

on the Louson/Gleneagles properties but sited the proposed transmission line to minimize these

impacts as the line would be placed along the CN rail line.


7.3.1 Interveners on the preferred route

481. The Mattson group consists of Vern and Patricia Bretin, Tim Mattson, John Beck and

Shelia Buckley, Patricia and Kenneth Schemenauer, Ravinder Bath and Rejean Leveque. The

group submitted that the construction of the preferred route is not the lowest impact route and

that the application should be denied or alternatively, the alternate route be chosen. The Mattson

group stated that the preferred route has greater residential and agricultural impacts and fails to

provide adequate geographic separation of transmission lines. It also submitted that AltaLink

90

Exhibit 854.01, AltaLink Argument, paragraphs 298-299. 91

Exhibit 854.01, AltaLink Argument, paragraph 302. 92

Exhibit 854.01, AltaLink Argument, paragraph 308.



overstated the alleged impacts along the alternative route and that such impacts could be

mitigated.

482. The Mattson group argued that AltaLink has given paralleling the transmission line with

existing transmission lines more importance than that of avoiding impacts on residences. There

are more residences along the preferred route within 150 metres and 800 metres of the

transmission line. According to the Mattson group, this is a more crucial metric to consider when

siting transmission lines.

483. The Mattson group indicated that on the preferred route, eight houses were within

150 metres of the proposed line and four of those were closer than 70 metres, with two being

within 35 metres of the centreline. The alternate route on the other hand had only two houses

within the 150 metre mark, the closest being 125 metres away. The Mattson group further

submitted that the route with a greater number of residences within 150 metres should be

considered as the higher impact route. The preferred route would also affect 11 more residences

at 800 metres than the alternate route. The Mattson group argued that these residential metrics

support its position that the alternate route is superior.

484. The Mattson group also took issue with AltaLink’s belief that because there is already a

transmission line in the area, the impact of adding another line would be incremental. The

residents do not welcome a new larger transmission line simply because there is an existing one

in the area.

485. The Mattson group disputed AltaLink’s narrow definition of paralleling existing linear

disturbances and stated that any actual physical disruption of land is considered a disturbance

which can include quarterlines and section lines. The alternate route would consequently not

fragment more land. The group contended that it demonstrated that the alternate route parallels

linear developments for 88 per cent of its length. With this assessment of the transmission line,

the alternate route compares favourably to the 94 per cent paralleling of the preferred route; and

that under this definition of paralleling linear disturbances, the alternate route is a superior route

to the preferred.

486. The Mattson group submitted that AltaLink has placed an over-reliance on paralleling

without regard to the impact created by imposing larger rights-of-way on landowners, which in

many cases, result in increased agricultural impacts. Paralleling existing transmission lines

requires increasing the required right-of-way to 92 metres on the preferred route, while the

right-of-way on the alternate route would only require 60 metres. This increase in the width of

the right-of-way on the preferred route would increase the impact for approximately

seven kilometres on cultivated lands along the preferred route. The Mattson group stated that the

placement of the second set of parallel towers would not only increase the additional time

required to maneuver around the extra towers, but also result in additional lost acreage due to

inefficiencies created in field-till patterns. With each additional tower placed on a farmer's lands,

cultivated land is lost to the transmission tower footprint.

487. The Mattson group also added that the presence of a diagonal route had a higher impact

for farming operations. While both routes have diagonal portions, the alternate route travels

approximately half of its length on quarterlines while the preferred route is completely diagonal.



488. The Mattson group stated that the double-parallel diagonal route would intensify the

effects on the agricultural impacts because the lines traverse the middle of the fields, creating

further obstacles for farmers to avoid. It further stated that diagonal routing is superior when it

presents an opportunity to avoid residences or other obstacles that may be close to quarterlines,

which is not the case in the alignment of the preferred route.

489. Furthermore, the group stated that the triple wide parallel circuits running to the north

from route marker B280 where the line turns north to the Janet 74S substation would carry a

significant amount of energy as these circuits are the main suppliers to the city of Calgary. The

ENMAX Energy Centre would also be located between route marker B280 and the Janet 74S

substation. It concluded that there is a reliability concern in this section which could be reduced

if the alternate route were chosen.

490. The Mattson group stated that the Transmission Regulation specifically states that it is in

the public interest to choose a higher cost route if that route provides geographic separation.

491. The Mattson group argued that the increased cost of the alternate route is justified by the

lower residential impact of the alternate route. It emphasized that the Commission has previously

recognized that it need not approve the lowest cost alternative and that the $9 million dollar

higher alternate route was a justified cost to avoid significantly higher residential impacts.

492. Ms. Buckley and Mr. Beck of the Mattson group testified that they purchased a 28-acre

lot and subdivided it into two residential, four-acre lots, with the intention that Mr. Beck would

use the remaining 20-acre lot for his residence. The two four-acre lots were sold with one being

developed and one remaining undeveloped. AltaLink purchased both of the four-acre lots.

Ms. Buckley and Mr. Beck requested that AltaLink also purchase their land, but AltaLink

refused because there was no residence on the property.

493. Ms. Buckley and Mr. Beck further explained that they do not wish to build a residence

within 150 metres of the line and that AltaLink normally buys out a property with a residence

within 150 metres of a transmission line of this size. They asserted that only a very small portion

of the land could be used for a residence.

494. Ms. Buckley stated that she owned land on the alternate route and did not object to the

alternate route because it would be located on the quarterline and would not interfere with her

hayfield or future development of the land.

495. Ms. Buckley also indicated that the trees help cover the view of the existing transmission

line to the north of their property. If the preferred route is chosen, many of these trees would

have to be removed, increasing the impact of the new line.

496. Mr. Bretin of the Mattson group testified that he purchased his property in 1986 and used

the land for a residence and agricultural purposes, including a flower and medicinal plants

business. The Bretins were also developing an equestrian facility on the land, comprised of a

show-jumping ring, a stable, a biogas facility and paddocks for up to 40 horses with all the

permits currently in place for the development.



497. Mr. Bretin stated that they moved the location of their proposed equestrian facility to a

less desirable location on their land when they received the initial information about the

proposed route because the proposed transmission line would interfere with the planned

equestrian facility. As the public consultation progressed, a new proposal showed the lines

passing directly above the planned equestrian facility. Mr. Bretin testified that he was forced to

move the equestrian facility to a third, even less desirable location.

498. Mr. Bretin added that he already has a huge visual impact on his land from the existing

transmission line and the addition of a second line would increase this impact. In his opinion, the

attempted mitigation of moving the line from the centre of his property to the north side would

not relieve the visual impact. The line would also affect his new wheel-move irrigation system as

well as locations of some of the buildings planned to accompany the equestrian facility.

Mr. Bretin also testified that he has found many dead birds under the transmission lines on his

land.

499. Mr. Mattson of the Mattson group testified that he purchased his land because it was near

one of the truckers’ hubs in east Calgary, making this location ideal for his business as a

mechanic. Mr. Mattson constructed a 5,500 square foot shop which can hold two semi-trucks and

their attached trailers at the same time. He stated that if he had known that AltaLink was

proposing such a transmission line, he would never have gone through the effort and expense of

constructing his shop.

500. Mr. Mattson’s main concern was that the proposed transmission line was too close to his

residence and if a tower were to ever fall down there could be a potential loss of life. He was also

concerned about the potential health effects from the transmission lines and the potential

drainage along the right-of-way onto the remainder of his property. Mr. Mattson stated that

Township Road 233 is often flooded during spring melt or with heavy rainfall, and that once the

transmission line is in place, his property would be flooded by excess water and improper

drainage. Mr. Mattson testified that he had incurred significant expense to create a stormwater

management pond so he could develop his shop and was concerned that the construction of the

transmission line would have a negative effect on his pond.

501. Mr. Mattson also indicated that if the preferred route were constructed with lattice

towers, he would lose the parking area, and this would have an adverse effect on his business

because it would cause difficulties for customers having their vehicles towed in and dropped

off.93

502. The proposed transmission line would impact his property value because any interested

buyer in his land would lose interest when they would hear about the proximity of the proposed

transmission line. Certain banks that he spoke to also informed him that the value of his land

would be depreciated.

503. Mr. Mattson pointed out that AltaLink had proposed a monopole option which would

require no additional right-of-way on his land; he was still contemplating this option at the time

of the hearing.

93




504. Mr. Schemenauer of the Mattson group testified that he has resided along the preferred

route since 1979. The Schemenauers rent out their land and have spent considerable sums on

new outbuildings and landscaping of the property. Mr. Schemenauer stated that it was always his

plan to subdivide his 45 acres into 10 four-acre lots and sell those off to fund his retirement, but

is concerned about his plan if the proposed preferred route is approved. He also has health

concerns with living in close proximity to a transmission line and stated that his wife is afraid of

transmission lines.

505. Mr. Levesque of the Mattson group testified that he chose his property on the preferred

route in 2005 because it was the only property from which he had a good view of both downtown

Calgary and of the mountains. Mr. Levesque resides on his property, but also carries his stucco

business, and recently constructed a large shop on his property. He is concerned about the

decrease in value of his property and the impact on his view. He believes that there would need

to be some tree clearing in order to place the transmission line on the preferred route,

approximately 550 feet, from his property. Once the trees were cleared, he would be able to see

the proposed transmission line very well from that distance, and his property value would

decrease accordingly.

506. Camrock Capital Partners GP (40) Ltd. was not present at the hearing, but stated in its

objection to the preferred route that future liquidity and property value of its property located at

36 Industrial Way in southeast Calgary could be affected if the preferred route were approved

and that the line should be relocated one kilometre to the east.

507. Baldev Joneja was not present at the hearing, but stated in a written submission that his

property, located in the northwest and southwest quarters of Section 15, Township 23, Range 28,

west of the Fourth Meridian, would be impacted by the psychological and physical effects of

EMF along the property line and that the Commission should approve the alternate route.

7.3.2 Interveners on the alternate route

508. Louson Investments Ltd. and Gleneagles Investments Ltd. (Louson and Gleneagles)

objected to both the Foothills Area Transmission Development need and to the Langdon to Janet

application. Louson and Gleneagles stated that the FATD NID is not in the public interest and in

the alternative, if the NID is approved, that the preferred route is a superior route.

509. Louson and Gleneagles submitted that their land, located at NE 32-23-28-W4M and

NW 33-23-28-W4M in Rocky View County, has potential for future industrial or business

development as part of the Highway 560/Glenmore Trail joint industrial corridor. The proposed

alternate route would negatively impact the industrial development potential of their land. The

alternate route could influence such development and would provide a visual barrier to the north

portion of the Louson and Gleneagles property.

510. Louson and Gleneagles argued that by contrast to the alternate route, the preferred route

would have a lesser impact because it parallels an existing transmission line and although there

are a greater number of residences in proximity to the proposed preferred route, these residences

are already exposed to an existing transmission line on the preferred route, meaning that there

would be no brand new exposures on the preferred route.94

94

Exhibit 0860.02, Final Argument of Louson Inverstments and Gleneagles Investments, paragraph 9.



511. Also, the alternate route, which is a greenfield route, would have greater negative impacts

on previously undisturbed land. The alternate route only parallels a railway for less than

one kilometre, and a future stormwater conveyance plan, which is depicted to follow natural

drainage features including sensitive wetlands, currently does not exist and may never exist.

Louson and Gleneagles acknowledged that the preferred route also passes through the same key

area for industrial development, but that area already has an existing development constraint.

512. The McLaren/Carlson group stated that the alternate route would sever and fragment its

land, identified as industrial according to the intermunicipal development plan between the City

of Calgary and Rocky View County.95 Ms. Carlson clarified that although they do not yet have

the property rezoned for industrial development, they are looking to have it rezoned and sold as

industrial land at some point in the future.96

513. An expert report was submitted on the group’s behalf by McNally Land Services Ltd.,

which evaluated the routing aspects of both the preferred and alternate routes. This report

concluded that the preferred route has a lesser impact than the alternate route in terms of all

factors, except the number of residences within proximity of the transmission line. The report

added that if the proposed alternate route were changed to the original alternate route proposal,

which followed quarterline boundaries, it would mitigate the severance and fragmentation of

land of the proposed alternate route currently before the Commission.

514. The McLaren/Carlson group proposed that siting 94 per cent of the route adjacent to

existing linear disturbances was a well-accepted practice. The group cited the Western Alberta

Transmission Line Decision 2012-327, in which the Commission determined that paralleling

existing transmission lines results in lower impacts, including less fragmentation of the

environment, fewer new access trails, reduced overall operation costs and less visual impacts

than placing the transmission line on a greenfield route.

515. The McLaren/Carlson group submitted that the only negative factor associated with the

proposed preferred route was that there would be more residences exposed to the transmission

line than on the alternate route. However, the McLaren/Carlson group further submitted that the

impact assessment should not be narrowed to the point where residential impact is the ultimate

deciding factor and that when all impacts are examined among the preferred and alternate

Langdon to Janet routes, the impacts along the alternate route would be greater as it is a

greenfield route.

516. Daniel, Julie, Deborah and Michael Meier (the Meiers) objected to the Langdon to Janet

alternate route. The Meiers stated that they have serious concerns with the potential negative

health effects of transmission lines. They also objected to the construction of the alternate route

on the west side of their property as it would obstruct their view of the city of Calgary, the

Rocky Mountains, and would affect their day-to-day enjoyment of the property.

517. The Meiers also submitted that the northeast quarter of Section 26, Township 23,

Range 28, west of the Fourth Meridian was purchased as an investment property because of its

potential for a subdivision as it is adjacent to the town limits of Chestermere Lake. The Meier

95

Exhibit 600.17, Review of the Preferred and Alternate Routes of the Foothils Area Development East Region

Langdon to Janet Project, March 21, 2013, page 3. 96

Transcript, Volume 12, pages 2527-2528, lines 22-25, 1-6.



land would have five towers; they are concerned that these towers would reduce their ability to

develop the land and reduce the value of the property due to the obstructed view. Also, the

Meiers stated that the transmission towers may affect their ability to check the fences used to

keep in their livestock.

518. The Meiers submitted that the proposed preferred route has an incremental impact

because it would parallel an existing transmission line and is therefore more favourable than the

alternate route. They argued that paralleling linear disturbances have historically been found to

result in less overall impact than greenfield routing and cited the Western Alberta Transmission

Line in support of its argument. The Meiers stated that regard must be given to the fact that

AltaLink is committed to mitigating the visual impacts by matching the tower placements of the

existing transmission line.

519. In reply argument, the Meiers added that the impact of the greenfield alternate route

would be greater because of the number of corners that are required for the alternate route. At

least seven 90 degree turns were required on the proposed alternate route and each of those turns

would require a dead-end structure. The same section of transmission line on the preferred route

would require only one dead-end structure. The structures placed on the greenfield route would

add to the impact because of the varying structure heights. The preferred route would be the less

costly of the two routes.

520. The Forster Family Trust owns land on the alternate route from Langdon to Janet in the

north half of Section 35, Township 23, Range 28, west of the Fourth Meridian. The trust stated

that it was intervening to oppose the alternate route. In its argument, the trust supported the

Meiers, the McLaren/Carlson group, Louson Investments Ltd. and Gleneagles Investments Ltd.,

and their arguments against the alternate route.

7.3.3 Intervener objecting to preferred route variant

521. 1297833 Alberta Ltd., the owner of the southeast, northeast and northwest quarters of

Section 21, Township 23, Range 27, west of the Fourth Meridian, objected to the variant option

to the preferred route. 1297833 Alberta Ltd. stated that the future visual impact of the line would

have a negative effect on future residential development on its land.

522. 1297833 Alberta Ltd. argued that paralleling linear disturbances has historically been

found to result in less overall impact than greenfield routing. It also cited the Western Alberta

Transmission Line decision in which the Commission stated:

In the past, the Commission and its predecessors have stated that, generally,

transmission lines should be placed parallel to existing linear disturbances. Paralleling

is also supported in provincial documents and legislation including the Alberta Land

Use Framework, the Transmission Regulation, and the Environmental Protection

Guidelines for Electric Transmission Lines.97

97

Decision 2012-327, Western Alberta Transmission Line Project, December 2012, paragraph 951.




523. The Commission examined the proposed Langdon to Janet transmission line siting on the

basis of residential impacts, visual impacts, agricultural impacts, electrical considerations,

environmental impacts and of cost.

524. The number of residences within 150 metres and 800 metres of the transmission line

favours the alternate route. However, many of the residences on the preferred route are on the

other side of the existing transmission line and would be no closer to a transmission line if the

preferred route were chosen. Furthermore, because the preferred route parallels the 936L/937L

line, the potential impacts on the residences that are within 150 metres would be incremental, as

opposed to those residences within 150 metres on the alternate route.

525. The Commission finds that paralleling the existing transmission line corridor south from

the Janet substation to the Shepard corner and then paralleling the 936L/937L line east of the

Langdon substation favours the preferred route because the proposed right-of-way only requires

an addition to the existing right-of-way rather than a new right-of-way. As a result, the potential

impacts are reduced from an environmental perspective because the land has been previously

disturbed. The preferred route has less potential for environmental impacts than the alternate

route because the alternate route attempts to follow the future Shepard Regional Drainage Plan,

which is designed to follow low-lying areas and wetlands. The preferred route parallels an

existing transmission line for almost the entirety of the route.

526. The Commission acknowledges that tree clearing around the existing transmission line

would increase the view of the transmission line, as stated by members of the Mattson group, and

also recognizes that the alternate route for the Langdon to Janet transmission line would have a

significant number of dead-end towers with varying heights and widths.

527. There is generally less incremental visual impact of the additional transmission line

paralleling the existing 936L/937L line to the east of route marker B280, and the transmission

line corridor to the north of route marker B280 than that of the mainly greenfield option of the

alternate route.

528. In addition, the preferred route parallels existing transmission lines of comparable size

throughout the transmission line length, which results in an incremental impact. AltaLink is

committed to staggering the towers to match the existing 936L/937L line to mitigate some of the

potential impacts throughout the length of the line.

529. The preferred route has less of an agricultural impact because it crosses less cultivated

land and results in less fragmentation of land as it requires an addition to the width of the

existing right-of-way, instead of new right-of-way.

530. The Commission also finds that the preferred route is superior to the route variant option.

The route variant option would require the removal and relocation of a 1.5-kilometre section of

the 936L/937L line as it enters the Crossings substation. The removal and relocation of the

936L/937L line would place it in close proximity to three residences to the north of the current

routing.

531. The preferred route costs approximately $14 million less than that of the alternate route if

schedule delays are factored in, but will cost $9 million less without the inclusion of any delays.



532. The Mattson group argument, that the proposed paralleling of the preferred route results

in a reliability issue, was not persuasive because no evidence was tendered in this regard and the

AESO has ascertained that the proposed routes meet the Alberta Reliability Standards.

533. Based on the above, the Commission concludes that the preferred route for the proposed

Langdon to Janet transmission line has less of an overall impact than the alternate route and is

therefore in the public interest.

534. The Commission chooses the monopole option past the property of Mr. Mattson. This

option would span monopole structures from route marker B260 to route marker B265 across the

northwest quarter of Section 13, Township 23, Range 28, west of the Fourth Meridian. This

option was put forth to reduce the impacts on Mr. Mattson, his family and his business. The

monopole option will not require a right-of-way on Mr. Mattson’s property and has the potential

to reduce the tower heights. The monopoles range in height from 41 metres to 44 metres while

the lattice structures are between 46 metres and 58 metres.98 Should Mr. Mattson agree to a

buyout of his property before measures are taken to implement the monopole option, the

Commission directs AltaLink to use lattice towers for this section of the transmission line.

8 AltaLink Application No. 1608637 - north Foothills transmission development

8.1 The preferred and stakeholder-proposed Foothills substation site selection

8.1.1 Introduction

535. AltaLink’s preferred site, identified as the D8 site, for the new Foothills 237S substation

is located at NW 35-18-28-W4M, southeast of High River. AltaLink has acquired the entire

quarter section of land on which the substation site would be located to provide room for

expansion. This site was chosen based on the parcel's suitability in relation to the substation

footprint, the interconnection of proposed and future 500-kV and 240-kV transmission lines, the

138-kV connection to High River and Okotoks, and the 240-kV interconnection of local

generation.

536. AltaLink amended its application to include a stakeholder-proposed Foothills 237S

substation site, identified as the D12 site, as an alternate site for the substation, which is located

in the NW 8-19-27-W4M. This site was within one of the substation target areas originally

identified during AltaLink’s preliminary and detailed routing stages, but was dropped from

consideration because the preferred D8 site would provide a better opportunity to reuse existing

infrastructure to connect to local generation with the least amount of new 240-kV line, and

would result in a better environmental route option to connect to the High River 65S and

Okotoks 678S substation. While this evaluation still applies, AltaLink believed that the

stakeholder-proposed D12 site represents a viable alternative and, therefore, added it for the

Commission’s consideration.

98




537. The following interveners expressed views regarding the selection of the Foothills 237S

substation site:

The Randle group was opposed to the preferred D8 site. The group consists of

Fred Randle, the estate of his late wife, Patricia Randle, and two family corporations,

F. R. Farms Ltd. and Randle Farms Ltd. The group’s 17.5 quarter sections of land are

located at the intersection of the north Foothills transmission project, the Foothills

138-kV project and the south Foothills transmission project. The D8 site is on cultivated

land and is adjacent to three quarter sections of the Randle group’s lands.

Randy and Gerry Nauta, who own lands both on the preferred and alternate

Foothills 138-kV transmission line routes, expressed a preference for the D12 site at the

hearing due to their concerns with aerial spraying. Unlike the D8 site, the stakeholder-

suggested 138-kV route, originating from the D12 site, will not cause two sides of their

parcel to be bordered by the proposed transmission line.

Albert Weeks, Craig and Carla Woolridge are opposed to the alternate D12 site and the

stakeholder-suggested 138-kV route originating from the D12 site. The Woolridges are

also opposed to the alternate route in the south portion of the proposed 1106L/1107L line.

Their general concerns include property value, visual impact, electric and magnetic

fields, and increase in traffic and noise. These individuals did not attend the hearing or

make any further written submissions.


538. AltaLink stated that the D8 and D12 sites are fairly comparable and both sites meet the

functional specifications stipulated by the AESO. However, AltaLink is of the view that the D8

site is preferable from an overall impact perspective.

539. AltaLink provided a table99 comparing a number of metrics for the preferred D8 site and

the alternate D12 site in its amendments submitted on December 21, 2012. The $0.9 million cost

difference indicated in this table represented the transmission line costs only and did not include

the costs of the D12 site. AltaLink subsequently indicated in its responses to the information

requests from the Randle group, and confirmed in its reply evidence, that the total cost associated

with the Foothills 138-kV project for the D12 site is approximately $0.5 million100 more than the

D8 site.

99

Exhibit 492.00, AltaLink facility application amendments, page 2, Table 1. 100

Exhibit 720.01, AltaLink reply evidence, page 15, paragraph 62.



Table 3. Siting comparison between the preferred site and alternate site

Potential site: D8 D12

Preferred site Stakeholder-proposed site

1. Impacts at substation footprint

Closest residence 557 m 471 m

Land use Agricultural - Cultivated Agricultural – Grazing

Environmental Preferred Less Suitable

Access Existing (400 m from Highway) Existing (2,200 m from

Highway)

Highway) 2. Interconnection of future transmission

Future to 500 kV Beside Beside

Future 240 kV Open Open

3. Connection to Okotoks and High River

Km of 138-kV line (from B20) 6.0 km 5.5 km

Potential parallel of existing

transmission line

0 0

Potential parallel of existing

road

6.0 km 5.5 km

Residences within 150 m 2 3

Residences within 800 m 6 7

Number of heavy angle structures 6 3

Incremental cost (approx.

$300,000/heavy angle)

N/A ($0.9 M)

4. Interconnection of local generation

Length of 240-kV line to connect

to 911L

3.5 km 9.5 km

540. AltaLink submitted that the D8 site provides the best opportunity to reuse existing

infrastructure, namely a portion of the existing 911L line passing the northeast corner of the town

of High River, to connect future local generation such as TransCanada’s 350-MW Saddlebrook

power plant located near Magcan 142S substation. AltaLink stated that by doing so, the least

amount of new 240-kV transmission line, 3.5 kilometres, would be required. Whereas if the

D12 site were approved, the future Saddlebrook generation interconnection would require

approximately 9.5 kilometres of new 240-kV transmission line.

541. AltaLink submitted that the D8 site is preferable from an environmental perspective

because the D12 site has higher habitat value than the D8 site. AltaLink explained that the

D12 site is part of a contiguous block of habitat and, taking into account wildlife, is considered

significant native prairie. An example of the higher habitat value is the documented presence of

the Sprague’s Pipit, a Species at Risk Act listed bird, that is seldom seen so close to Calgary.

542. AltaLink submitted that at the D8 site, the footprint would be on cultivated land and the

displaced wildlife species would have a variety of other easily accessible and similar foraging

options nearby. The footprint at the D12 site would be on the reverting tame pasture, used as part

of a larger block of permanent or breeding habitat by a number of wildlife species, and in



relatively short supply locally. Despite different environmental considerations, Stantec submitted

that both sites are viable from an environmental perspective.

543. It added that the D8 site is a more suitable site from a wildlife habitats perspective,

despite being on the margin of an environmentally significant area. However, Dr. Gahbauer of

Stantec admitted that this preference is somewhat offset by the higher incremental potential for

collision risk at the D8 site, related to the additional 138-kV transmission lines connecting to the

D8 site from the west. Given that the D8 site is approximately 900 metres away from

Frank Lake, Stantec stated that the incremental risk posed by the 138-kV transmission lines is

expected to be low and can be further mitigated through employment of bird markers. Stantec

agreed that, compared to the D12 site, the D8 site might have a higher risk of potential avian

collision due to the proximity of Frank Lake. However, Stantec reiterated the conclusion from

the recent Avian Power Line Interaction Committee’s report that there is a much reduced risk of

bird mortality once the transmission lines associated with a substation site are beyond 400 or 500

metres.

544. With respect to the proposed 138-kV 434L/646L line routing, AltaLink stated that the

stakeholder-suggested route originating from the D12 site is generally comparable to the

preferred route originating from the D8 site. However, the preferred route is superior from an

environmental perspective. The preferred route is within a previously disturbed road allowance,

while the stakeholder-suggested route abuts a greater area of native prairie and has a somewhat

higher potential for effects on wildlife.

545. With respect to the proposed 240-kV 1106L/1107L line routing in the north Foothills

project and proposed 1037L/1038L line routing in the south Foothills project, AltaLink indicated

that if the D12 site were approved, these two routes would shift slightly in that the 1037L/1038L

line would incorporate the 1106L/1107L line’s preferred route, or the preferred route variant,

between the D8 and D12 sites. Conversely, the 1106L/1107L line would commence at and travel

north from the D12 site.

546. AltaLink submitted that the D8 site offers better cost benefits than the D12 site. When the

cost impacts to the north Foothills transmission project, the Foothills 138-kV project and the

south Foothills transmission projects are considered collectively, the D8 site is estimated to cost

$3.1 million less than the D12 site.

8.1.3 Views of the interveners

The Randle group

547. With respect to the Saddlebrook power plant interconnection, the Randle group argued

that little weight should be given to the fact that the D8 site allows for a future interconnection

by reusing the 911L line because no interconnection application has been filed. Further, the lack

of a detailed siting study for the plant, and the uncertainty of its expected in-service date,

mitigate against the consideration of the interconnection as a factor in favour of the D8 site. The

Randle group referred to the testimony from the representative of the Town of High River that

the portion of the existing 911L line that could potentially be reused traverses the northeast

corner of the town’s newly annexed area, which represents a development constraint within the

area. The Town of High River urged AltaLink to consider the removal of this portion of the 911L

line. It stated that both the AESO and AltaLink acknowledged that the cost of interconnecting the

Saddlebrook power plant will be borne by TransCanada.



548. With respect to the interconnection of future transmission lines, the Randle group

submitted that the proposed Foothills 237S substation will be a major hub with a large number of

future interconnections of 500-kV, 240-kV and 138-kV transmission lines. As stipulated in the

AESO’s functional specification for this substation,101 the ultimate configuration at Foothills

237S substation is designed to have two 500-kV line connections, two 500/240-kV transformers,

ten 240-kV line connections, two 240/138-kV transformers and six 138-kV line connections.

Among these future transmission line interconnections, two 240-kV lines to ENMAX No. 65

substation, two 240-kV lines to Windy Flats 138S substation, two 240/138-kV transformers, one

138-kV line to High River 65S substation, and one 138-kV line to Okotoks 678S substation are

proposed in the FATD proceeding. The two 240-kV lines to Sarcee 42S substation contemplated

by the AESO are not required until 2019 and beyond, based on the AESO’s most recent planning

study. The Randle group argued that the D12 site would keep a large substation away from an

internationally recognized environmental area and that this benefit outweighs the relatively

minimal cost-saving associated with the D8 site.

549. The Randle group submitted that the D12 site is preferable from an environmental

perspective because it is 2,000 metres away from Frank Lake, in comparison to the D8 site,

which is 900 metres away. It added that Figure 23 reproduced from the Stantec’s report102

illustrates the boundaries of the Frank Lake environmentally significant area and important bird

area. The D8 site is within the Frank Lake environmentally significant area complex, which is of

international significance with seasonally important waterfowl use; while the D12 site is outside

of the environmentally significant area. The D8 site is crossed by an important bird area, while

the D12 site is approximately 1,200 metres outside of the important bird area. The D8 site is also

within a mapped aquatic environmentally significant area, while the D12 site is not.

101

Exhibit 18.00, AESO’s Foothills area transmission development east region (FATD East) functional

specification, pdf page 32. 102

Exhibit 720.04, AltaLink reply evidence Appendix C environmental considerations, pdf page 11.



Figure 23 – Frank Lake environmentally significant area and important bird area

550. Mr. Cliff Wallis, the Randle group’s environmental expert, submitted that the D12 site

presents a lower collision risk to waterfowl because it is more than twice the distance from

Frank Lake than the D8 site. Mr. Randle testified that every year, trumpeter swans, tundra swans

and numerous other water birds use the lands in and around the D8 site, particularly in the spring

migration. Both Stantec and Mr. Wallis agreed that Frank Lake is an important staging site for

trumpeter swans during migration. The Randle group submitted that trumpeter swans are

classified as an endangered species under the Wildlife Regulation, Alta Reg. 143/1997. Based on

Stantec’s review of the eBird database, there are peak numbers of trumpeter swans at Frank Lake

in March and April during spring migration and a larger peak (more than 500 individuals



recorded by one observer) in October and November during fall staging. Stantec observed

50 swans feeding at the D8 site in its field investigation conducted on March 27, 2013.

Approximately 20,000 northern pintails, along with many other bird species, were spotted during

Stantec’s field survey. Mr. Wallis indicated that the Ducks Unlimited normal setback guideline is

1.6 kilometres or more. The Randle group concluded that the further distance from Frank Lake

favours the D12 site in terms of avian mortality risk.

551. The Randle group pointed out that migratory waterfowl, including trumpeter swans and

tundra swans, also frequently use a series of sloughs or potholes in the general area to the west

and north of the D8 site. The group was concerned that the numerous future transmission lines in

and out of the substation will pose a significant risk for birds between the cultivated fields on and

near the D8 site, potholes and Frank Lake. Mr. Wallis also confirmed that reverting pasture has

not been widely used by waterfowl. Stantec acknowledged that the birds like to forage on

cultivated land more than on native prairie.

552. The Randle group submitted that the D12 site is preferable because it is farther away

from Frank Lake and will have fewer environmental impacts than the D8 site, particularly with

respect to migratory wild fowl. The group emphasized that the environmental advantage for the

D8 site is especially true given that the Foothills 237S substation is likely to be one of the largest

substations in Alberta with numerous future interconnections contemplated.

553. The Randle group added that the D8 site and the preferred 138-kV route would also have

a disproportionately large agricultural impact on the Randle lands as the routing places a

transmission line on two sides of five Randle quarter sections. Mr. Randle testified that aerial

spraying is particularly difficult when the transmission lines are on more than one side of a field.

The group also contended that its farmland is some of the best farmland in the area, and that the

property tax for the D8 land is assessed at nearly double that of the D12 land. It stated that

AltaLink acknowledged that cultivated land is typically more valuable than pasture land.

Randy and Gerry Nauta

554. Mr. Nauta favoured the D12 site with respect to his concerns about aerial spraying. The

preferred 138-kV line route associated with the D8 site will border his parcel at

NE 10-19-28-W4M on two sides. He testified that having the 138-kV lines on two sides of his

land would impede aerial spraying and consequently cause some crop losses.

555. Mr. Nauta submitted that the D8 site is prime agricultural land. The D12 site is better

suited for a substation site because it is saline pasture land and of poorer soil quality than the D8

site, as is the land running north of the D12 site.

TransCanada

556. TransCanada submitted that the connection between the Saddlebrook power plant and the

transmission system will be at TransCanada’s cost, therefore any change to the location of the

Foothills 237S substation will have a direct impact on the economic viability of the Saddlebrook

power plant. The D12 site will likely require six to seven additional kilometres of transmission

line to connect the Saddlebrook power plant to the transmission system, which will increase the

connections costs.



557. TransCanada concurred with AltaLink that the D8 site appears to be preferable from an

environmental perspective and future construction of transmission lines terminating at the

Foothills substation. For example, the risk of bird strikes did not correlate with the distance from

transmission lines or substations. TransCanada submitted that it will be difficult to find a more

northerly route from the D12 site for a transmission line to serve load on the west side of Calgary

and communities in the west of the province, on account of significant residential development

between Okotoks and High River.


558. With respect to local generation interconnection, the AESO has not yet filed an

interconnection application for the future Saddlebrook power plant. Neither has AltaLink

performed any detailed siting study or undertaken any public consultation. The AESO testified

that the Saddlebrook power plant is currently planned to be connected to the Foothills 237S

substation by using a portion of the 911L line. However, the AESO has not yet finalized its

interconnection plan. Based on the uncertainty of the Saddlebrook power plant’s interconnection

plan, the Commission is of the view that the Saddlebrook power plant interconnection is not a

factor in choosing the substation site.

559. The Commission finds that the D12 site is superior to the D8 site from an environmental

perspective for the following reasons. Unlike the D8 site, the D12 site is situated outside of the

Frank Lake environmentally significant area, which is of international significance, and also

outside a mapped aquatic environmentally significant area. Compared with the D8 site whereby

proposed transmission lines will cross an important bird area, the D12 site is approximately

1,200 metres outside of the important bird area. Such a distance presents a lower collision risk to

waterfowl because there are a great number of migratory waterfowl, including trumpeter swans,

classified as an endangered species, flying around the D8 site more frequently than the D12 site.

The Commission agrees with the Randle group that the proposed Foothills 237S substation is

likely to be one of the largest 240/138-kV substations in the province and a major substation in

southern Alberta. Due to the ultimate size of the substation and potential multi-directional line

connections terminating at the substation, the Commission finds that it is better, from an

environmental perspective, to keep the substation site away from the internationally-significant

environmentally significant area that is Frank Lake.

560. The Ducks Unlimited normal setback guideline is 1.6 kilometres or more. In addition, the

significant number of northern pintails, swans and other bird species recently spotted at the

D8 site rather than at the D12 site convinced the Commission that the distance from Frank Lake

is a factor in relation to wildlife. The distance from Frank Lake to the D12 site is more than twice

the distance to the D8 site. Therefore, the Commission disagrees with Stantec that the distance

between the Foothills substation and Frank Lake is less relevant to bird collisions once the

distance is beyond 400 to 500 metres.

561. The D8 site is cultivated land while the D12 site is reverting tame pasture. The

Commission accepts Mr. Wallis’ view that reverting pasture has not been widely used by

waterfowl. Further, it is acknowledged by both AltaLink and the Randle group that the birds like

to forage on cultivated land more than on native prairie.



562. With respect to the 138-kV 434L/646L line routing, the Commission agrees that the

preferred route originating from the D8 site is comparable with the stakeholder-suggested route

originating from the D12 site. The two routes have different potential environmental impacts in

that the stakeholder-suggested route is adjacent to native prairie, while the preferred route is in

close proximity to Frank Lake.

563. The Commission finds that the location of the Foothills 237S substation will not cause

any material difference between the D8 and D12 sites where the 240-kV 1106L/1107L line and

the 1037L/1038L line routings are concerned. It will simply shift the termination points between

the two routes.

564. Both the D8 and D12 sites are next to the existing 500-kV 1201L line and open to

interconnect to the nearby 240-kV transmission lines. With respect to connecting to Okotoks and

High River, the D8 and D12 sites have very similar impacts in terms of residences, connection

distance and potential to parallel existing transmission lines and roads. Further, compared with

the D8 site, the stakeholder-suggested route originating from the D12 site would require half the

number of heavy angle structures.

565. In the Commission’s view, the D8 site, with its preferred 138-kV line route, poses a

greater agricultural impact on the lands of the Randle group and the Nauta family than the D12

site, with the stakeholder-suggested 138-kV line route. Even if the D12 site were selected, the

Randle group’s land would nonetheless be bisected.

566. With respect to cost consideration, the incremental cost associated with the D12 site is

approximately $3.1 million, which is less than 0.4 per cent of the entire FATD project cost. As

stated in previous decisions, cost is not an overriding consideration for the Commission, and in

this case, the environmental factors outweigh the cost.

567. Consequently, the Commission concludes that the D12 site is a better site because it has

lower overall impacts than the D8 site.

8.2 The preferred and alternate 240-kV transmission routes

8.2.1 Introduction

568. AltaLink proposed four routes for the new 240-kV double-circuit 1106L/1107L line

connecting the Foothills 237S substation to the ENMAX No. 65 substation in southeast Calgary,

in the north Foothills project. There is one preferred route and three alternate route segments: the

north alternate route, the Frank Lake alternate route and the preferred route variant. The north

alternate route is an alternative route to the diagonal portion of the preferred route, north of the

Bow River. The Frank Lake alternate route and the preferred route variant are two alternative

routes near Frank Lake. The Frank Lake alternative route proposes a route further away from

Frank Lake, while the preferred route variant is closer to Frank Lake. These routes are shown on

the map below.



Figure 24 – North Foothills route options



569. The preferred route begins at the proposed Foothills 237S substation using steel lattice

structures to the northwest side of Frank Lake before connecting with the 1201L line. From

there, the line continues north, paralleling the 1201L line until it meets the 850L line. The route

turns northwest, where it will utilize triple-circuit structures paralleling the existing alignment of

the 850L line to the junction of the 850L/911L line. This section of the existing 850L line would

be replaced by the new triple-circuit structures. Where the route turns north, it will utilize

monopole double-circuit structures for the final three kilometres to the ENMAX No. 65

substation. The existing 850L/911L line will be rebuilt along this segment to accommodate the

paralleling of the lines in the right-of-way.

570. The preferred route generally parallels the existing 1201L line to the north, the 138-kV

850L line to the northwest and the 240-kV 911L/138-kV 850L lines to the north again.

Specifically, the preferred route parallels or utilizes existing rights-of-way by:

paralleling approximately 28 kilometres of the 1201L line

paralleling approximately 13 kilometres of the 850L line

utilizing approximately three kilometres of the 911L/850L line right-of-way

571. In the north portion of the project, the preferred route parallels the existing diagonal

138-kV 850L line. Instead, the north alternate route segment predominantly follows quarterlines

on agricultural lands and parallels Highway 22X north of the Bow River.

572. In the south portion of the project, the preferred route predominantly parallels the existing

1201L line. AltaLink has two alternate route segments originating from its preferred D8 site for

the Foothills 237S substation: the Frank Lake alternate route segment and the preferred route

variant. The Frank Lake alternate route segment is farther from Frank Lake, which provides

habitat to waterfowl including several species of management concern. This route segment

proceeds north for approximately nine kilometres from the Foothills 237S substation and then

east for approximately three kilometres, where it connects to the preferred route. The preferred

route variant runs adjacent to the existing 1201L line structures and involves the placement of up

to three structures for the line to cross Frank Lake.

573. Choosing the stakeholder-suggested D12 site for the Foothills 237S substation would

leave only one route option, the preferred route, in the south portion of the project, which would

start from the D12 site, run east to connect to the preferred route and then follow the preferred

route to the north and eventually terminate at the ENMAX No. 65 substation. The following map

illustrates the alternate Foothills 237S substation site (the D12 site) proposed in AltaLink’s

facility application amendments.



T.18

T.19

HIGH RIVER

BLACKIE

2

2

543

783

2A

2A

23

23

799

HIGHWOOD RIVER

FRANK

LAKE

PREFERRED FOOTHILLS237S SUBSTATION SITEIN APPLICATION

1201L

PROPOSED TRANSMISSION LINES FILED IN ORIGINAL

PROPOSED SUBSTATION SITE AND TRANSMISSION

EXISTING TRANSMISSION LINES

911L

R.27W.4M.R.28R.29

FOOTHILLS 237SSUBSTATION SITEIN AMENDMENTS

ALTERNATE

APPLICATIONS

LINE ADDITIONS PROPOSED IN THE AMENDMENTS

Figure 25 – Alternate Foothills substation

574. Choosing the D12 site for the location of the Foothills 237S substation, would mean that

the proposed transmission line from the D12 site southward in the vicinity of the D8 site would

become part of the new 240-kV 1037L/1038L line in the south Foothills project. This portion of

the 1037L/1038L line would either follow the preferred route or the preferred route variant near

Frank Lake and then continue to run to the south, and eventually terminate at the proposed

Windy Flats 138S substation.

8.2.2 Interveners along the north Foothills line routes

575. The Diagonal group, which consists of nine interveners residing within 800 metres of the

diagonal portion of the preferred route between route markers B240 and A260 in the north of the

Bow River, is opposed to the preferred route. Some members of the group own land on both the

preferred and north alternate routes.

576. Reece and Richard Pearson are opposed to the preferred route. The Pearson family owns

the entire section of 17-22-28-W4M along the diagonal portion of the preferred route. The west

boundary of the Pearson section is the Calgary city limits.



577. Bow Vista Farms, which owns over 50 quarter sections of land located southeast of the

city of Calgary and on both the preferred and north alternate routes, is opposed to the north

alternate route.

578. Abdul Hage and Moe Hage are opposed to the preferred route just south of the

Bow River and requested that the Commission deny the application, or in the alternative, select

an alternate route that does not traverse their property. No alternate route was proposed by

AltaLink for this portion of the line.

579. Astral Media Radio GP is opposed to the north alternate route, which would be located

800 metres directly north of the centre of radiation from its CKMX transmitter site.

580. Other individual landowners expressed concerns with the north Foothills project on either

their statements of intent to participate or in brief presentations at the process meeting, but they

did not attend the hearing or make any further submissions. Their stated concerns were with both

the preferred and alternate routes.


581. AltaLink stated that the preferred route minimizes fragmentation of the land, reducing

impacts to existing land uses and avoids crossing Frank Lake. Compared with other routes, the

preferred route has the least impact on areas with potential historical importance.

582. In the north portion of the project, the preferred route parallels the existing 138-kV 850L

line. Instead, the north alternate route segment predominantly follows quarterlines on agricultural

lands and parallels Highway 22X north of the Bow River. The following table compares the

preferred route and north alternate route in detail:



Table 4. Comparison between the preferred route and north alternate route103

103

Exhibit 13.00, AltaLink North Foothills Transmission Project, page 116, Table 4-4.



583. Compared with the preferred route, the north alternate route segment has the following

characteristics:

fewer residences within 150 metres and 800 metres of the line

more of its length along quarterlines

more agricultural land that will be fragmented by the line

greater potential impacts to historical resources

less paralleling or use of existing rights-of-way

a longer line length

a lower estimated cost

584. AltaLink submitted that the preferred route has the lowest impact north of the Bow River.

The preferred route has a greater distance over which it utilizes the rights-of-way of existing

transmission lines. Local land uses along the 1201L and 850L lines have evolved and been

carried on in the presence of the line over the past 28 and 50 years, respectively. The incremental

potential impacts of the new 240-kV line adjacent to these lines will generally be lower than

locating the new 240-kV line along a greenfield route. AltaLink also submitted that the

agricultural impacts along the 850L line are expected to decrease because the triple-circuit

structures will be fewer in number, be easier to farm around than the existing H-frame structures

and will have higher clearances from the ground.

585. AltaLink argued that the diagonal routing with triple-circuit monopole design offers a

shorter and more direct route for the entire farming community. Compared with the north

alternate route, AltaLink submitted that the diagonal routing also offered the following

advantages to individual landowners:

The triple-circuit design reduces the amount of additional right-of-way by utilizing the

existing 850L line right-of-way.

The monopoles have a larger span length, resulting in fewer towers, a smaller footprint

and greater ground clearance compared to the existing 850L line H-frame structures,

which will make it easier to farm around. For example, the preferred route will result in

two fewer towers on the Pearson lands.

The monopoles will follow the same alignment as the existing 850L line which will

minimize agricultural impacts on existing farming patterns.

The visual impact will be from one line instead of two lines.

586. With respect to impacts on aerial spraying, AltaLink acknowledges that there is a setback

for aerial spraying around high-voltage transmission lines. While aerial spraying may be

restricted to some degree by transmission lines, it is still possible. AltaLink submitted that

ground spraying is also available as an alternative. If crop yields around the transmission line

towers are decreased, AltaLink has committed to compensate affected landowners for additional

impacts from the project that cannot otherwise be mitigated.

587. To specifically address Bow Vista Farms’ concern about aerial spraying, AltaLink

submitted that there may be some impact on aerial spraying perpendicular to the line, however,

aerial spraying in a parallel direction would generally be possible with a small safety buffer from

the line at the discretion of the individual aerial spraying operator. AltaLink added that there are



no existing irrigation pivots or other systems on the properties, and that if irrigation pivots were

to be installed, such an irrigation system could be designed to take into account the proposed

transmission line. Specifically addressing the Diagonal group’s concern with aerial spraying,

AltaLink reiterated that farming operations and spraying are possible along the diagonal line.

588. AltaLink submitted that concerns about the impacts of the proposed north alternate route

on Bow Vista Farms’ filming are largely unwarranted. Three filming locations are at least

800 metres or 1,600 metres away from the proposed line. Any filming at these locations taken in

any direction, but due north would not have a view of the line. In addition, if the filming

occurred in the river valley, the transmission lines would be obstructed from the view to the

north. AltaLink added that the two other filming locations are located immediately east of an

existing gravel pit. The viewscapes for any filming in those locations are already constrained by

the large aggregate development situated to the west. The views to the east would be of the

existing agricultural operations on the properties.

589. With respect to Bow Vista Farms’ concern about its aircraft operation along the north

alternate route, AltaLink submitted that there is no impact on the east/west runway or operations

to or from the north. While aircraft operations to and from the south of the north/south airstrip

may be impacted by the north alternate route, the aircraft being used at the airstrip has

performance characteristics that allow it to continue to operate safely from all four runway

directions.

590. With respect to the modified north alternate route suggested by the Diagonal group,

AltaLink stated that it will create new impacts. For example, a pipeline running along the east

quarterline of SW 15-22-28-W4M and NW 15-22-28-W4M would have to be relocated or the

transmission line would have to be placed midfield.

591. AltaLink argued that the Pearson family’s argument of residential impacts on future

development is too speculative for the Commission to consider. The Pearsons did not bring any

evidence on residential development plans and on how the preferred route would affect those

plans should they ever come to fruition.

592. Based on the above, AltaLink favoured the preferred diagonal route to the north alternate

route in the north of the Bow River.

593. The following table compares the preferred route and Frank Lake alternate route in the

south portion of the project in detail.



Table 5. Comparison between the preferred route and Frank Lake alternate route104

104

Exhibit 13.00, AltaLink North Foothills Transmission Project, page 113, Table 4-3.



594. Compared with the preferred route, the Frank Lake alternate route segment has the

following characteristics:

more agricultural land that will be fragmented by the line

greater number of residences within 800 metres

a longer line length

fewer potential environmental impacts, including lower potential effects on wildlife

a higher estimated cost

595. The preferred route variant segment involves the placement of up to three structures for

the proposed transmission line across Frank Lake, adjacent to the existing 1201L line structures.

This route segment arose as a result of concerns expressed by stakeholders between potential

impacts to the environment and existing land uses. AltaLink submitted that most landowners in

proximity preferred the line to cross the lake so that potential impacts to their parcels and land

use could be minimized.

596. AltaLink pointed out the potential environmental impacts arising from placing the

preferred route variant in or near Frank Lake which has been a project water body for

Ducks Unlimited since the 1950s. Ducks Unlimited continues to control the water levels of the

lake with the goal of maintaining water quality and flood control. Frank Lake is regarded by

Ducks Unlimited and other stakeholders as the most important waterfowl staging area in

southwestern Alberta, as it provides habitat to waterfowl, including several species of

management concern. Ducks Unlimited and the Fish and Wildlife branch of Alberta

Environment and Sustainable Resource Development preferred routing further away from the

water body to minimize the potential environmental impacts.

597. AltaLink acknowledged the environmental concerns expressed by Ducks Unlimited and

the Fish and Wildlife branch of Alberta Environment and Sustainable Resource Development. If

the preferred route variant were to be constructed along the 1201L line parallel across

Frank Lake, two shield wires would be placed on top of the towers. AltaLink submitted that

shield wires present a higher risk to birds than conductors, because shield wires are smaller and

less visible. AltaLink also noted that the preferred route variant would place at least two

structures within the water body.

598. In conclusion, AltaLink favoured the preferred route over the Frank Lake alternate route

and preferred route variant, submitting that the preferred route provides a better balance between

the potential environmental impacts of the proposed 240-kV line around Frank Lake and the

other land-use impacts in the area.


Diagonal group

599. The Diagonal group submitted that the preferred diagonal route with triple-circuit

monopole structures will constitute a brand new impact, not an incremental impact. The height of

the proposed triple-circuit monopoles is four to five times higher than the existing wood pole

structures. The Diagonal group argued that the size of the new triple-circuit monopoles

effectively presents a new impact, not mitigated by the existence of the 850L line.



600. The Diagonal group submitted that the preferred route has more residential impacts than

the north alternate route as there are more residences within 150 metres and 800 metres of the

preferred route than the north alternate route. The preferred and north alternate routes have seven

and two residences within 150 metres of the centreline of the route, respectively. The preferred

and north alternate routes have 46 and 41 residences within 800 metres of the centreline of the

route, respectively.

601. The Diagonal group submitted that the preferred route qualitatively has a greater

fragmenting effect than the north alternate route. It explained that routes along quarterlines will

avoid fragmentation caused by going through the middle of the field. The preferred route has less

of its length along quarterlines because it follows a diagonal alignment. By contrast, the north

alternate route has more of its length along quarterlines.

602. The Diagonal group submitted that the preferred route has greater impacts on agricultural

operations than the north alternate route, stating that its members will not be able to do aerial

spraying if the small wood pole structures are replaced by tall steel monopoles. The group added

that if towers of over 50 metres high are going to be built, the impact on aerial spraying would be

less if they follow straight quarterlines, as opposed to running diagonally through the fields.

603. The Diagonal group stated that the preferred route is 36 per cent more expensive than the

north alternate route and that the incremental cost is caused by the high cost of the triple-circuit

monopole structures.

604. The Diagonal group suggested in its argument a modified north alternate route for the

Commission’s consideration. According to the proposed modification, the north alternate route

would continue running straight north from route marker A242 instead of angling off on a

diagonal through Sylvia Busslinger’s property. The route would continue north along the east

boundary of the Busslinger property and another half mile to the northeast corner of

NW 15-22-28-W4M. At that point, it would turn west and run for one mile to where it would

intersect with the existing north alternate route segment. The Diagonal group stated that this

modified route creates no new impacts and eliminates the impacts to Mrs. Busslinger, but did not

file any evidence in this regard.

The Pearson family

605. The Pearson family submitted that the preferred route simply perpetuates the outmoded

diagonal route. Diagonal routing is inefficient in terms of land use and is also midfield, which

will create more agricultural impacts. The Pearson family is concerned that placing the new

monopole line along the diagonal route will result in the creation of two major transportation and

utility corridors (the diagonal route and Highway 22X) within two miles of each other in the

vicinity of the Pearson lands.

606. The Pearson family submitted that the preferred route is many times more visually

imposing than the existing H-frame structure of the 850L line and will require more significant

setbacks for residential development when the city of Calgary inevitably expands into the area.

The Pearson family is concerned that the preferred route will significantly reduce the residential

development value of their lands.



Bow Vista Farms

607. Bow Vista Farms submitted that the greenfield routing of the north alternate route creates

completely new impacts in addition to the existing impacts associated with the 850L line. There

are twelve contiguous quarter sections that form one undisturbed field along the north alternate

route. The preferred route follows an existing linear disturbance for its entire distance, while the

north alternate route does not follow an existing linear disturbance for half its length from the

ENMAX No. 65 substation to route marker B235 once contiguous fields are taken into account.

608. Bow Vista Farms stated that the preferred route has the least impact on residences and

does not have any newly exposed residences. It argued that the north alternate route adds two

residences within 150 metres and 26 residences within 800 metres of the proposed transmission

line. Bow Vista Farms added that if the north alternate route is built, there will be two lines in

close proximity, the existing 850L line H-frames and the new steel lattice towers. As a result,

Sylvia Busslinger’s residence at SW 15-22-28-W4M will have the H-frames on one side and the

steel lattice towers on the other side.

609. Bow Vista Farms further submitted that the preferred route has fewer agricultural impacts

by virtue of being a monopole construction than the north alternate route, which would be built

with lattice towers. It views the monopole design as an improvement over the existing H-frames

on the 850L line because of the smaller base, better clearance, fewer structures and being likely

easier to see in low light. Bow Vista Farms explained that the monopoles require a right-of-way

of 40 metres, whereas the lattice towers require a right-of-way of 60 metres. Because the 850L

line will stay if the north alternate route is built, the north alternate route will require

approximately twice the amount of acres of right-of-way, as compared with the preferred route.

It also stated that the monopole design is more advantageous from a weed control perspective

because it is difficult to get under the lattice towers to control weeds.

610. Bow Vista Farms argued that the north alternate route has significantly greater aerial

spraying impacts than the preferred route because the north alternate route has more than double

the turns, which result in an “L” shape on several fields, creating corners. It contended that

helicopter spraying is not as effective and is simply impractical from a cost perspective.

611. Bow Vista Farms also submitted that the north alternate route would significantly impact

an area important to the film industry in Alberta. The filming areas on Bow Vista Farms are one

of four very suitable areas in the entire province for western period pieces. The presence of the

large lattice towers of the north alternate route would render portions of these lands unusable for

filming. The setting is ideal for period pieces, which cannot have large lattice towers in the

backdrop.

612. Bow Vista Farms further argued that the north alternate route has the potential to impact

an airstrip on its lands because the proposed transmission line may contribute to an incorrect

decision by a pilot upon takeoff or landing. Bow Vista Farms contended that AltaLink’s

assertion that the plane can climb enough to clear the line after takeoff is based on best case

performance data and on temperature and elevation conditions more favourable than those of the

actual airstrip.



Abdul Hage and Moe Hage

613. The Hages stated that since 2007, they have invested significant time and money into

buying, maintaining and making business arrangements with Castillo Homes Ltd., a home

builder and developer, for its property. They stated that they have invested close to $2 million

and Castillo Homes Ltd. had agreed to purchase 11 lots of four acres each at a price of $650,000

per lot and buy the final lot with the existing house for $1.8 million after all 11 lots had been

sold. The Hages submitted that Castillo Homes Ltd. is not prepared to move forward if the

transmission line route across the property is approved and that it would be difficult to find

another developer for this property.

614. The Hages requested that the Commission deny the application or choose a different

route in order to protect the public interests of ensuring fairness to landowners and promoting

suitable development of local communities. The Hages specifically requested that the

Commission clarify, in its decision, that its determination for routing purposes that a

development may be speculative is not intended to apply to the assessment of compensation to

landowners.

Other interveners

615. Other interveners expressed concerns with aerial spraying, EMF, compensation and

property values, but provided little detail in support. These interveners neither participated in the

hearing, nor make any further written submissions.


616. In making its decision on the routing of the proposed 240 kV line, the Commission

considered the portion of preferred route that corresponds with the alternate route segments. The

Commission has divided its findings into two sections.

Routing options north of the Bow River

617. With respect to residential impacts, the Commission favours the preferred route over the

north alternate route. The north alternate route is primarily greenfield and has more newly

exposed residences within both 150 metres and 800 metres of the line than the preferred route.

The Commission considers that the incremental impacts on residences not previously located in

proximity to a transmission line are greater than the incremental impacts on residences already in

proximity to an existing transmission line. It also took note that one residence will be

sandwiched by the new line and the 850L line if the north alternate route is chosen because that

route is premised on the 850L line remaining in place. The Commission does not agree with the

Diagonal group that the impacts of the proposed monopoles are akin to a transmission line on a

greenfield route because the evidence is to the effect that the proposed monopoles will result in

fewer structures than what now exists on the 850L line route.

618. Further, the proposed triple-circuit monopole structures proposed for the preferred route

are much taller than the existing H-frames of the 850L line. However, the height of the monopole

is similar to the height of the lattice structures proposed for the alternate route. The north

alternate route is primarily greenfield, creating brand new visual impacts and the H-frames will

stay if the alternate route is chosen. The preferred route would combine the new line with the

850L line on the same monopoles along the existing right-of-way, which does not add additional

structures for the proposed new line. Considering that the north alternate route results in new



additional visual impacts rather than increasing the existing visual impacts, the Commission

considers the preferred route more favourable than the alternate route.

619. The Commission favours the preferred route over the north alternate route from an

agricultural impact perspective because the triple-circuit monopoles provide longer spans and,

therefore, require fewer structures than the north alternate route. The monopoles also provide

additional ground clearance, have a smaller footprint and result in fewer corners than the lattice

towers on the alternate route. The Commission heard that the lands along the preferred route

have been farmed for over 50 years with the H-frame structures in place, but the greenfield north

alternate route has a large continuous block of cultivated parcels which will be fragmented by the

route. Also, fewer corners on the preferred route means that the concerns with aerial spraying

lands bordered on two sides by a transmission line are addressed.

620. The preferred route requires only one right-of-way, although it will be widened by

27.5 metres, while the alternate route results in a new right-of-way for the alternate route and

leaves the existing right-of-way in place. The north alternate route is longer than the preferred

alternate route and provides no opportunity to parallel any existing transmission lines. As a

result, the Commission favours the preferred route over the north alternate route from a land-use

impact perspective.

621. The preferred route has an estimated cost of $9.5 million105 more than the alternate route

due to the incremental cost of the triple-circuit monopoles. This represents approximately a

four per cent increase of total cost for the north Foothills project. Accordingly, the Commission

finds that cost favours the alternate route.

622. With respect to the concerns expressed by interveners about future potential development

of their land, no evidence in support of specific development plans or subdivision approvals was

filed. Consistent with past decisions, the Commission considers that future developments and

residences that are in the concept stage, or that are at the idea stage, are not certain and may

change depending on the economy, change of circumstances for the potential developer,

amendments to municipal bylaws regarding development or inability to secure municipal

approval. Therefore, there is a great deal of uncertainty on whether such projects would ever

proceed and if so, the timing and the potential impacts. To consider such projects would be

speculative. Although requested by the Hages, the Commission is of the view that there is no

need to add any further clarification with respect to this finding.

623. The Commission observes that the reradiation report states that the preferred route will

result in lower reradiation levels of the CKMX radio signal than the existing line and should

have no adverse impact on the station. However, the alternate route will result in double the

radiation of the existing line and may require mitigation to avoid compromising the station’s

coverage and protections. AltaLink stated that it has safety processes in place during the

construction and maintenance of the transmission line.

624. The Commission heard that the north alternate route may have potential impacts on the

filming activities and risks related to the operation of the existing airstrips. These potential

impacts are not present on the preferred route.

105

Exhibit 501.01, AltaLink response to the AUC information requests, pdf page 46.



625. With respect to the modified north alternate route proposed by the Diagonal group, the

Commission could not consider the proposed route because it was not supported by the evidence

filed and was not tested during the proceeding.

626. Based on the above, the Commission finds that the preferred route has overall lower

impacts than the north alternate route. A portion of the preferred route north of the Bow River, in

the vicinity of the ENMAX No. 65 substation, is within the city of Calgary transportation and

utility corridor. The Commission cannot issue a permit and licence for the construction and

operation of the north Foothills application within the Calgary transportation and utility corridor

without the prior written consent of the Minister of Infrastructure. AltaLink stated that it would

seek ministerial consent for the portion of the transmission line within the transportation and

utility corridor boundary prior to construction.

Routing options near Frank Lake

627. Because the D12 site has been chosen for the location of the Foothills 237S substation,

the Commission considers that the new 240-kV 1106L/1107L line will follow the preferred route

from the D12 site to the north. There is no other route option in the south portion of the north

Foothills project from the D12 site. In addition, the choice of the D12 site results in the proposed

240-kV 1037L/1038L line in the south Foothills project either following the preferred route or

the preferred route variant near Frank Lake. The Frank Lake alternate route is not connected to

the D12 site.

628. The preferred route variant near Frank Lake is less favourable from an environmental

perspective. The Commission took note of the submissions of the Fish and Wildlife branch of

Alberta Environment and Sustainable Resource Development, Ducks Unlimited and other

stakeholders on the potential impacts of a transmission line in close proximity to Frank Lake. As

previously mentioned, Frank Lake is a very important waterfowl staging area in southwestern

Alberta and is both an environmentally significant area and important bird area. In keeping with

the Commission's reasons for choosing the D12 substation site, the Commission favours the

preferred route.

629. The preferred route variant is more favourable than the preferred route from a land-use

perspective because it results in fewer potential impacts on lands suitable for development and

on residences in proximity, and results in less fragmentation of land.

630. The project cost estimate for the preferred route is $232 million within +20/-10%

accuracy, while the cost estimate for the preferred route with the preferred route variant

incorporated is $237 million.106 Therefore, for the portion of the proposed transmission line near

Frank Lake, the preferred route would cost $5 million less than the preferred route variant. Based

on the above, the Commission concluded that the preferred route has the lowest overall impact

especially taking into account the impacts on the environment. It avoids the placement of up to

three tower structures for the proposed new line across Frank Lake and, consequently, results in

fewer environmental concerns.

106

Exhibit 501.01, AltaLink response to the AUC information requests, pdf page 39.



8.3 Tower structure options at the Bow River crossing

8.3.1 Introduction

631. AltaLink proposed the single-circuit option in its application for the tower design at the

Bow River crossing portion of the proposed 1106L/1107L line, which would entail two

single-circuit towers on both the north and south banks of the Bow River. The tower is designed

to match the existing 500-kV 1201L line east of the proposed new 240-kV 1106L/1107L line.

AltaLink derived this two-tower option based on input from Fish and Wildlife branch of Alberta

Environment and Sustainable Resource Development and other stakeholders’ preference at the

time it filed its application.

632. Taking into account that visual impacts are subjective and changes to landowners’

preference, AltaLink proposed a double-circuit, one-tower option in its reply evidence107 for the

Bow River crossing portion of the 1106L/1107L lines. Unlike the two-tower option, the one-

tower option would place only one tower on each of the north and south banks of the Bow River.

While AltaLink believed that both options are viable and comparable from construction and cost

perspectives, its preferred option is still the two-tower option due to landowner preference.

633. Figure 26 illustrates the cross-section drawing of the two different tower design

options.108 The 1201L line tower on the south bank of the Bow River is 39.3 metres high. The

tower height for the double-circuit one-tower option is approximately 65 metres, while the tower

height for the single-circuit two-tower option is approximately 43.6 metres with 67 metres of

separation between the centrelines. AltaLink clarified that there would be some changes in the

range of the tower heights set out in the application because a project of this size goes through

additional engineering and design, though it was confident that if the one-tower option were

approved, it would be able to build the tower approximately 65 metres as illustrated in Figure 26.

Figure 26 – Cross-section drawings of structure options at Bow River crossing

107

Exhibit 720, page 17, paragraph 73. 108

Exhibit 720.01, AltaLink reply evidence, Appendix A, pdf page 117.



8.3.2 Interveners in the Bow River crossing portion

634. The Bow River Crossing group is opposed to the two-tower option at the river crossing.

The group consists of Louise Klatzel-Muldry, the estate of Virginia Klatzel and

Douglas McHugh, Terry Thomson, Frederick Thomson and Western Sky Land Trust. The

Thomsons’ land is located at NW 20-21-27-W4M, and is in the final stages of being donated to

Western Sky Land Trust for a conservation easement. Ms. Klatzel-Muldry and the estate of

Ms. Klatzel and Mr. McHugh own the land at SW-29-21-27-W4M. The Bow River Crossing

group’s lands are within 800 metres of the new 240-kV 1106L/1107L lines as the lines cross the

south bank of the Bow River. The towers to facilitate the crossing would be situated on the

Thomson land and would be approximately 215 metres away from Mr. Thomson’s cabin.

635. Mr. Richard Dugdale and Dugdale Investments Ltd. are opposed to the one-tower option

at the river crossing. The preferred route for the 1106L/1107L line is within 800 metres of their

land, and Mr. Dugdale’s residence is approximately 1,005 metres away from the proposed tower

location. He was also concerned that his access road, which AltaLink is proposing to use, would

possibly be damaged during construction activities.


636. AltaLink stated that the area where the proposed 1106L/1107L line crosses the

Bow River is a riparian area of incised valleys or coulees with steep river banks. AltaLink

submitted that concerns about the terrain are addressed by spanning the valley and some taller

trees would be cleared or trimmed to allow for safe operation. Four wildlife species of concerns

were observed in the vicinity of the Bow River crossing, including two prairie falcon nests.

Population of breeding and staging waterfowl are low. AltaLink proposed the river crossing

route paralleling the existing 1201L line because the alternate route further west would require

an additional crossing of the Highwood River and would be closer to residents.

637. AltaLink indicated that in its discussion with the Fish and Wildlife branch of Alberta

Environment and Sustainable Resource Development regarding the two-tower structure options

at the river crossing, the Fish and Wildlife branch of Alberta Environment and Sustainable

Resource Development expressed its preference for the two-tower option because it would result

in less impact on wildlife and a lower risk of bird mortality; the lines, including the existing

1201L line, would all be on the same horizontal plane and may be easier for birds to navigate.

The Public Lands Division of Alberta Environment and Sustainable Resource Development

preferred one set of taller double-circuit towers, i.e. the one-tower option, because this option

results in fewer towers on Crown land and a narrower right-of-way. Nevertheless, AltaLink

stated that both options are viable.

638. AltaLink stated that Stantec conducted investigations regarding the effects of the

Bow River crossing portion of the new transmission lines and towers on wildlife and particularly

on birds. Stantec expressed the opinion that the one-tower option had slightly lower

environmental impacts than the two-tower option because clearing of two rights-of-way for the

two-tower option would cause greater disturbance than clearing of one right-of-way for the one-

tower option.

639. Stantec pointed out that it is generally accepted that thin shield wires or optical wires

pose the greatest threat to birds because the shield wires are very thin and therefore too difficult



for birds to see. It concluded that the one-tower option is likely to result in fewer avian collisions

due to a fewer number of shield wires.

640. AltaLink, Stantec and Mr. Wallis, the Bow River Crossing group’s environmental expert

witness, agreed that even if the conductors were on the same horizontal plane, the sagging of

each conductor could be different. AltaLink stated that at particularly sensitive locations, it

would be able to mark the lines with bird deflectors, which are intended to reduce the risk of

avian mortality. Nevertheless, Stantec stated that both options are viable from a wildlife

perspective.

641. With respect to landowner preference, AltaLink witnesses testified that the landowners in

the area equally align with one option or the other.

642. There are five residences in the quarter sections in the Bow River crossing area. All of

these residences are in proximity to the existing 500-kV 1201L line. None of them are newly

exposed to a transmission line because they are all within 800 metres of the existing line. Except

for Mr. Dugdale, all four residences will be closer to the proposed 1106L/1107L line than the

existing 1201L line. Except for the Thomson cabin which is 215 metres away from the proposed

tower location, all other residences are more than 600 metres away from the proposed tower

location.

8.3.4 Views of interveners

643. The Bow River Crossing group’s environmental expert, Mr. Wallis, concurred with

Stantec that the one-tower option posed the least risks to the riparian and valley vegetation. He

also testified that spacing between the lines for the two-tower option would potentially create a

less favorable situation in relation to avian mortality than the one-tower option.

644. Western Sky Land Trust testified that the one-tower option would reduce the footprint

and be in line with its conservation and educational goals for the lands. It emphasized that the

lands are of international environmental significance.

645. Mr. Dugdale argued that his views of the Bow River valley towards the mountains in the

west would be impacted by the taller one-tower option and consequently would affect the actual

value on his property. He added that there is no permanent residence in the quarter section where

the proposed 1106L/1107L line crosses the Bow River. Mr. Dugdale testified that he understood

that the height of the two-tower option was going to be two and a half to three times taller than

the existing 1201L line.109 Mr. Dugdale was also concerned that the addition of another

transmission line could contribute to more health risks.

646. The Bow River Crossing group stated that the anticipated height of the tower was the

major factor in the landowners' stated preference. However, it observed that the height of the

tower for each option is not consistent throughout AltaLink’s application and consultation

materials. For example, the cross-section drawings on Appendix H-9110 of the application show

the height of the one-tower option and the two-tower option in comparison with the height of the

existing 500-kV 1201L line. However, the heights are only representative of the angle tower

design, while AltaLink confirmed at the hearing that the dead-end tower will be used at this river

109

Transcript, Volume 7, page 1440. 110

Exhibit 21.00, Appendix H Cross-section drawings, page 10.



crossing location. The group also pointed out that the range of the tower heights also varied

among different parts of the AltaLink documents. It further gave examples on how the height of

the tower was not clearly communicated to the landowners and referred to Mr. Dugdale’s

evidence in support of its views.

647. The Bow River Crossing group submitted that AltaLink’s preference of the two-tower

option relied heavily on what it perceived to be the majority landowner opinion in the area. It

believed that the landowners with facilities on their land, such as members of the Bow River

Crossing group, should have their views more strongly considered because they bear the direct

impact. The group stated that the one-tower option would create less impact on the landowners

most directly and adversely affected by the project. Mrs. Klatzel-Muldry testified of her concern

about a wider span of the lines, which is more significant when on the ground looking up and

through it, as opposed to the one-tower option. Mr. Berrien, the land-use expert for the Bow

River Crossing group also noted the difference between 90 metres of horizontal coverage with

the two-tower option and 35 metres with the one-tower option.


648. From an environmental impact point of view, the one-tower option would require

approximately 21 acres of new right-of-way, while the two-tower option would require 39 acres.

The height of the towers for the one-tower option is approximately 20 metres higher than the

two-tower option. The Commission is of the view that the smaller tower footprint favours the

one-tower option. However, there are also environmental and residential considerations.

649. The Commission accepts the conclusion drawn in the recent Avian Power Line

Interaction Committee’s report that overhead shield wires are a contributing factor for most bird

collisions, which was not disputed by any party at the hearing. Because there will only be one

overhead shield wire for the one-tower option in comparison with two shield wires for the two-

tower option, the Commission agrees with Mr. Wallis, Stantec and AltaLink that even if the

conductors were on the same horizontal plane, the sagging of each conductor can be different.

Mr. Wallis’ submission that the spacing between the lines on the two-tower option would likely

create a situation less favourable to birds than a one-tower option was also noted. Consequently,

the Commission finds that the one-tower option poses a lower risk of bird mortality.

650. Mr. Dugdale’s residence is more than 1,000 metres away from the tower location.

Compared with the existing 1201L line, the proposed new lines will be further away from his

residence and there will be no new facilities on his property. The Commission finds that the

visual impact potentially caused to Mr. Dugdale by the one, higher tower in the far distance is

incremental. With respect to Mr. Dugdale’s access road, AltaLink made a commitment to return

the road to the same state as it was before its use, or better.111 The Commission acknowledges

AltaLink’s commitment in this regard.

651. Lastly, the two options are comparable from a cost consideration.

652. Based on the foregoing, the Commission concludes that the one-tower option is

preferable to the two-tower option.

111

Transcript, Volume 5, pages 918 to 919.



9 AltaLink Application No. 1608643 Foothills 138-kV transmission development

9.1 The preferred and alternate routes

653. AltaLink proposed one preferred route, one alternate route and one alternate route

segment for the new double-circuit 434L/646L lines between Foothills 237S and High River 65S

substations. These routes are shown on the map below.

Figure 27 – Foothills 138-kV route options



654. The preferred route generally traverses within municipal district road allowances and

highway rights-of-way from the Foothills 237S substation to the High River 65S substation.

Approximately 95 per cent of the preferred route is located within, or immediately adjacent to

the road allowances of Highway 23, 144th Street, 498th Avenue, and Highway 543 which are

typically 30 metres or wider.

655. The alternate route generally parallels existing transmission lines, with one segment

traversing within the Highway 2 right-of-way and two segments that follow quarterlines.

Approximately 60 per cent of the alternate route parallels existing 500-kV, 240-kV and 138-kV

transmission lines.

656. AltaLink also proposed an alternate route segment112 between route markers A0 to A5 to

B10 west of the Foothills 237S substation, to provide a local variant route to the preferred route.

This segment could connect the eastern portion of the alternate route to the preferred route.

Figure 28 – Alternate route segment near Foothills substation

657. As discussed in Section 8.1.1, AltaLink amended its application to include a

stakeholder-suggested site shown as D12 for the Foothills 237S substation and associated

138-kV line routing. From site D12, the route travels west along 498th Avenue located one metre

within the road allowance until it intersects with the preferred route at route marker B20. The

stakeholder-suggested 138-kV route associated with the D12 site is shown below.

112

Exhibit 213.00, AltaLink facility application, page 99, Figure 4-30.



T.18

T.19

HIGH RIVER

BLACKIE

2

2

543

783

2A

2A

23

23

799

HIGHWOOD RIVER

FRANK

LAKE

PREFERRED FOOTHILLS237S SUBSTATION SITEIN APPLICATION

1201L

PROPOSED TRANSMISSION LINES FILED IN ORIGINAL

PROPOSED SUBSTATION SITE AND TRANSMISSION

EXISTING TRANSMISSION LINES

911L

R.27W.4M.R.28R.29

FOOTHILLS 237SSUBSTATION SITEIN AMENDMENTS

ALTERNATE

APPLICATIONS

LINE ADDITIONS PROPOSED IN THE AMENDMENTS

Figure 29 – Foothills 237S substation preferred and alternate locations

658. The following interveners were opposed to the proposed routes as follows:

The Town of High River was opposed to the preferred route, particularly the route

section along Highway 543/498 Avenue north of the town’s boundary.

Phyllis Robertson was opposed to the preferred route, particularly the route section

between route markers A43 and A50. She owns lands to the north and south of the

preferred route, as well as to the south of the alternate route.

Randy and Gerry Nauta were opposed to the preferred route. The preferred route near

route marker B20 will border their land at NE 10-19-28-W4M on two sides, although it is

located in the M.D. road allowance.

Syd Mantler was opposed to the alternate route, particularly the portion between route

markers between A29 and A39. He represented both B.F.W. Holdings (2006) Ltd., as the

landowner and Deer-Country Equipment (1996) Ltd., as the business operator.

659. The Randle group’s major concern is the location of the Foothills 237S substation.

Because the Randle group is opposed to the D8 site, it was opposed to all 138-kV transmission

routes originating from the D8 substation site.

660. A few other individual landowners expressed concerns with the Foothills 138-kV project

in either their statements of intent to participate or a brief presentation at the process meeting.

Landowners concerns were associated with the salvaged lines and with the

stakeholder-suggested route. Albert Weeks, Craig Woolridge and Carla Woolridge, who are

stakeholders along the proposed routes, raised concerns with respect to property value,

residential impact, visual impact, health concerns and noise. However, they did not attend the

hearing and no further details or written submissions were filed.




661. AltaLink provided a table comparing a number of metrics between the preferred and

alternate routes.

Table 6. Comparison of the preferred and alternate routes113

662. AltaLink submitted that the preferred route has the following attributes in comparison

with the alternate route:

fewer number of residences within 800 metres

comparable number of residences within 150 metres

lower agricultural impacts

greater length of line located within road allowance

similar environmental impacts

similar number of heavy angle structures

113

Exhibit 213.00, AltaLink Foothills 138-kV application, page 97, Table 4-1.



663. AltaLink added that the alternate route segment provides an opportunity to utilize the

alternate route adjacent to the Foothills 237S substation and connect again to the preferred route.

The alternate route segment has higher overall impacts than the alternate route, but AltaLink

viewed it as a viable route. Compared to the corresponding segment of the preferred route, the

alternate route segment has the following characteristics:

it increases the distance to a residence and a homestead

it parallels the 500-kV 1201L line and is within the 152nd Street road allowance

it has higher potential impacts to agriculture and private lands

it increases the overall route length by approximately 700 metres

664. The stakeholder-suggested 138-kV route originating from the D12 site of the Foothills

237S substation remains on the north side of 498th Avenue and crosses to the south side of the

road to increase the distance of the line from residences and avoid a cluster of large trees.

Compared to the preferred route, AltaLink submitted that the stakeholder-suggested route has

very similar impacts for the 138-kV connection to the High River and Okotoks substations, but is

less suitable from an environmental perspective.

665. AltaLink indicated that approximately 95 per cent of the preferred route is located within

or immediately adjacent to the road allowances and that planning 138-kV transmission line

routes within road allowances generally provides an opportunity to develop lower impact

routing. Road allowances are publicly owned and have been established for the development of

roads, gas, power and communication infrastructure. Planning 138-kV transmission line routing

within road allowances minimizes impacts on private lands and adjacent land uses. AltaLink also

stated that routing within road allowances can also mitigate costs associated with transmission

line planning, easements, access, construction, future maintenance and land acquisition.

666. AltaLink stated that approximately 60 per cent of the alternate route parallels existing

transmission lines and that the paralleling of existing transmission lines provides opportunities

for lower impact routes, but results in some impact to private land.

667. AltaLink noted that the preferred route has more length within road allowance and fewer

residences than the alternate route. It also indicated that the preferred route has lower potential

agricultural impacts, while the alternate route, parallel to the existing 753L line, would have

greater agricultural impacts because farmers cannot utilize the space between the new poles and

the fence line where the 753L line is situated against the fence line.

668. AltaLink concluded that the preferred route has the lowest overall impact because it

minimizes social and economic effects, as well as effects on the environment. It viewed the

alternate route as a viable, next best option.

669. With respect to the Town of High River’s concerns, AltaLink responded that visual

impact is subjective and the Highway 543/498 Avenue corridor is not free of existing electrical

infrastructure. There is already a double-circuit FortisAlberta distribution line, a crossing of the

240-kV 911L line, the 138-kV 727L line, the 138-kV 753L line and the High River 65S

substation. The section of the existing 911L line crossing the northeast corner of the town is

required for future use and therefore cannot be removed.



670. AltaLink submitted that given these existing structures, any impact on the existing views

west of the highway would be incremental.

671. Further, AltaLink argued that there is no preliminary-approved plan associated with

twinning Highway 543. Even if the road does eventually get widened, AltaLink will not be

required to obtain additional right-of-way on private land because it will move the transmission

line along with the road right-of-way. AltaLink submitted that it is not difficult to move the

138-kV transmission line and the costs are not likely to be significant.

672. AltaLink submitted that the preferred route would not directly impact Mrs. Robertson’s

property because it would be situated adjacent to her lands within road allowances. AltaLink

explained that the transmission line would remain in the widened road allowance even if the road

were to be twinned in the future. The structures will remain on public land and not impact private

land. It added that Mrs. Robertson’s plans to undertake residential development of her land

identified as property B are purely conceptual in nature because she has not yet retained a

planning firm to undertake an area structure plan for the development.

673. AltaLink stated that it attempted to minimize the impact to Mr. and Mrs. Nauta by

locating the line on the south side of the road allowance, away from their residence. AltaLink

admitted that there will be a potential impact on aerial spraying around their corner that is

bordered by the proposed transmission line. However, because the line will not be on their

property, AltaLink does not offer compensation for potential loss of farming production.

674. AltaLink discussed, with the AESO, Mr. Nauta’s proposal to put a new double-circuit

line together with the existing 753L line one mile north of the preferred route. The AESO

determined that putting three of the four circuits that supply power to the High River area on to

one structure was not a reliable system solution.

675. AltaLink modified the preliminary alternate route to help mitigate Mr. Mantler’s

concerns on the attractiveness of his property. The final alternate route follows the quarterline on

the eastern edge of his property, behind his building and farther away from the highway.

676. AltaLink submitted that the Randle group’s stakeholder-suggested route is the least

suitable of all routes from a biophysical perspective because it abuts a large area of native prairie

and has a somewhat higher potential for effects on wildlife. The preferred route is the most

suitable because it will be developed almost entirely within previously disturbed road

allowances, abuts predominately cultivated land and has the lowest abundance of wildlife

resource features near the route. However, AltaLink concluded that the stakeholder-suggested

route is generally comparable to the preferred route.


Town of High River

677. The Town of High River’s newly annexed area abuts the south side of Highway 543. The

town has identified Highway 543/498 Avenue as a major traffic road and a scenic corridor

because of the magnificent views towards the west in its newly adopted Town of High River

Growth Management Strategy. The growth management strategy contains a policy that

encourages those views to be protected and enhanced.



678. The Town of High River and the M.D. of Foothills adopted an intermunicipal

development plan relating to the land around the new boundary of the highway. The

intermunicipal development plan recommended the development of a set of guidelines to

preserve the visual character of the Highway 543/498 Avenue gateway.

679. The Town of High River submitted that Highway 543/498 Avenue is considered a major

gateway for the town and will potentially need to be twinned to accommodate future traffic

volumes. The twinning would be accommodated only along the northern portion of

Highway 543/498 Avenue because of the existing FortisAlberta distribution line on the south

portion, as the road was designed to be widened to the north only. The town is concerned that if

the preferred route were approved, the new 138-kV transmission line would have to be removed

in the future, when the needs for widening Highway 543 become a reality and further, because of

the waste of resources if the line had to be moved. The town was also concerned that the

preferred route would impede or hinder the future land use of its two properties immediately

north of Highway 543. In conclusion, the town preferred the alternate route along the existing

753L line.

680. In addition, the Town of High River submitted that the existing 911L line crossing

northeast of the town constrains the future development and reduces the town’s tax revenues.

The town urged AltaLink to remove that portion of the 911L line once it becomes redundant.

Views of Phyllis Robertson

681. Mrs. Robertson submitted that building the preferred route from route markers A39 to

A65 is short-sighted because the lines will likely have to be relocated in the future when

498 Avenue is twinned. Mrs. Robertson was concerned with the extra cost associated with

relocating the 138-kV transmission lines, as well as additional land-use impacts and nuisance.

682. Mrs. Robertson submitted that the current traffic on Highway 543 does not spoil the view

to the west. She explained that there is only one small FortisAlberta distribution line on the south

side of the highway between route markers A43 and A50. Anyone standing at the new

interchange with Highway 2 looking west has a relatively unobstructed view. In contrast, with

the short section between route markers A50 and A65 where power lines are on both sides, the

visual character of this stretch of the highway between route markers A43 and A50 is more

visually pleasing. Mrs. Robertson concluded that routing the transmission line along the

preferred route west of route marker A43 will degrade the visual character of the corridor and

will be inconsistent with the town’s planning documents and the intermunicipal development

plan.

683. Mrs. Robertson testified that she owns both properties A and B as shown in Figure 30.114

Property A is zoned as agricultural land, while property B is identified as residential mixed use

in the future land-use scenario of the intermunicipal development plan.

114

Exhibit 616.03, InterPLAN Strategies Inc. report, page 2, Figure 1.



Figure 30 – Phyllis Robertson’s property location

684. As a landowner who will have either the preferred route or the alternate route on her

lands, Mrs. Robertson stated that she would prefer to give up a small amount of right-of-way on

the north edge of her land identified as property A for the alternate route, as opposed to having a

new transmission line run through the middle and more valuable part of her lands immediately

adjacent to the town of High River. Mrs. Robertson indicated that the majority of the residences

within 800 metres of the alternate route are west of the alternate route, south of route marker

A39, on the other side of the Queen Elizabeth II Highway. To avoid the residential impact

associated with this, she proposed a hybrid route which combines the preferred route from the

Foothills 237S substation to route marker A39 with the alternate route from route marker A39 to

High River 65S substation. Mrs. Robertson submitted that the number of residences within 800

metres of the alternate route would be reduced to 36 from 96 if the hybrid route were approved,

while the number of residences within 800 metres of the preferred route is 45.

685. Mrs. Robertson submitted that the hybrid route will also avoid the visual impacts

associated with the preferred route west of route marker A43. The alternate route west of route

marker A43 is one mile north of the town of High River's boundary and parallels the existing

753L line, which will not affect the scenic corridor along Highway 543/498 Avenue as expressed

in the town’s growth management strategy and intermunicipal development plan with the

M.D. of Foothills.

686. Mrs. Robertson asked the Commission to either approve the alternate route in its entirety

or approve the hybrid route.

687. Mrs. Robertson’s land consultant, Mrs. Acteson of InterPLAN, concurred with the

position of the Town of High River in terms of the future development options in the area which

are discussed above.



Views of Randy and Gerry Nauta

688. Mr. and Mrs. Nauta submitted that the preferred route would be detrimental to the

productivity of their land because the proposed preferred route has a 90 degree turn in the line

adjacent to their farmland, which will make it impossible to aerial spray their crops. Mr. Nauta

explained that even if he were to spray his crops, a number of passes would be required with a

plane, thus increasing the use of insecticides, herbicides and fungicides. He added that AltaLink

will not reimburse them for their crop losses because the lines are not on their land, but simply

next to it.

689. The Nautas were concerned with the health impacts of the preferred route, being metres

away from their home. They were also concerned that the proposed lines will affect their electric

fences. They expressed concerns about the safety hazard posed by the proposed placement of the

transmission line towers in the ditch of busy roads. They believed that the best and fairest

location for a line is on the property line between two adjoining sections of land so that the

adjacent landowners equally share in the compensation for the loss of crops. They added that the

preferred route will ruin their mountain view and devalue their property. Mr. Nauta indicated

they had no concerns with the alternate route. The Nautas also supported the submissions of the

Town of High River.

Views of Syd Mantler

690. Mr. Mantler owns a narrow lot that is situated east of Highway 2 and south of

498th Avenue, which is part of the NW 9-19-28-W4M. The lot has a large building placed

approximately 40 metres from the property line, used by Deer-Country Equipment (1996) Ltd.,

an agricultural and turf dealer in High River. The lot is used to display, assemble and repair

equipment. Typically there are 10 to 15 people working on the premises.

691. Mr. Mantler was concerned that the alternate route would have great visual impact and

reduce property values. He submitted that the proposed transmission line tower will be three

times as high as the building, which will reduce the visibility of the building from Highway 2

and attractiveness of the property which is not encumbered by the 911L line. He noted that

according to the intermunicipal development plan of the Town of High River and the M.D. of

Foothills, his lot is part of lands that are considered to be suitable for future highway commercial

development.

692. Mr. Mantler was also concerned that there may be negative effects on people working

close to a power line, stating that people would prefer not to work next to a large power line.


693. Because the Commission selected the D12 site for the Foothills 237S substation, the

stakeholder-suggested route is the starting point of the 138-kV line. The proposed transmission

line would continue from D12 to route marker B20 and continue west to follow the preferred

route to route marker A39. At route marker A39, the route can follow either the preferred route

or the alternate route and terminate at the High River 65S substation. The Commission must

decide which route, preferred or alternate, has the least overall impact between route marker A39

and the High River 65S substation based on the routing criteria and potential impacts of each of

the routes.



694. The proposed 138-kV hybrid route originates from the D12 site, follows the

stakeholder-suggested route to route marker B20, then follows the preferred route to route

marker A39, and finally follows the alternate route to High River 65S.

695. From a residential impact perspective, it appears that between route marker A39 and the

High River 65S substation there is a similar number of residences within 150 metres of the

two routes. However, Phyllis Robertson submitted that, compared with 45 residences within

800 metres of AltaLink’s entire preferred route, the hybrid route will result in only 36 residences

within 800 metres of the proposed transmission line. The Commission finds that the potential

residential impacts are similar on either route. Although there are fewer residences within

800 metres, the potential residential impacts at that distance are not significant and do not weigh

in favour of the alternate route.

696. The Commission acknowledges that due to the future twinning of Highway

543/498 Avenue, the new 138-kV transmission lines may have to be moved in the future, and

that there are additional cost and land impacts associated with the removal if the road is widened.

Although the timing of twinning the highway is not known, the potential impacts associated with

moving the proposed transmission line favour the alternate route.

697. The alternate route eliminates Mr. Nauta’s concern regarding aerial spraying around the

corner of his parcel surrounded on two sides by the preferred route. Despite the potential

agricultural impacts resulting from the alternate route being on private land between route

marker A39 and the High River 65S substation, Mrs. Robertson prefers having this route on her

property, to AltaLink’s preferred route. There is no evidence of farming of contiguous quarters

along the alternate route. However, the alternate route would parallel the existing 753L line and

would have greater agricultural impacts because farmers would not be able to utilize the land

between the new poles and the fence line (where the 753L line is situated against the fence line).

As a result, the Commission finds that potential agricultural impacts favour the preferred route.

698. Taking into account residential and agricultural impacts, future development and the

potential relocation of the line, the Commission finds that the alternate route is a better route than

the preferred route between route marker A39 and the High River 65S substation. Consequently,

the Commission finds that the hybrid route has the lowest overall impact and approves the hybrid

route.

699. The Commission observes that AltaLink applied to salvage a portion of the 727L line

between the Janet 74S and Okotoks 678S substations and that no issue was raised regarding the

proposed salvage. In addition, no other issues were raised respecting any other new facilities or

alterations to the existing facilities applied for by AltaLink as part of the Foothills 138-kV

project. The Commission accepts the evidence submitted by AltaLink, finds that the facilities

and alterations meet the requirements of AUC Rule 007 and AUC Rule 012, and that the

approval of the requested facilities, alterations and salvage is in the public interest.



10 AltaLink Applications No. 1608861 and No. 1608862 - South Foothills and

Windy Flats 138-kV transmission developments

10.1 Introduction

10.1.1 The preferred and alternate substation sites

700. As stated above, the Commission approved the amendment to the SATR NID approval to

change the southern termination of the1037L/1038L line to a new substation instead of to the

Peigan 59S substation, previously approved in Needs Identification Document Approval

No. U2011-115. The Commission must now consider the AltaLink facility application which is

intended to meet the approved amended needs identification document.

701. The proposed Windy Flats 138S substation would be the southern termination of the

1037L/1038L line and would contain one 240/138-kV transformer, ten 240-kV circuit breakers,

two 138-kV circuit breakers and two 240-kV reactors within a 135-metre by 235-metre fenced

area. AltaLink proposed to site the substation at SW 17-8-26-W4M; however, due to objections

from the landowner, it developed an alternative location at SW 18-8-26-W4M. A third location,

east of the proposed sites, was also developed but was eliminated from consideration when the

final preferred and alternate routing of the transmission line was developed. This third option

was eliminated because it was longer, it had the potential to impact more agricultural lands, it

crossed the Oldman River at a less desirable location, and had a higher cost.

702. AltaLink also proposed the re-termination, at the Windy Flats 138S substation, of the

existing 603L and 608L lines, and to rebuild parts of the 603AL and 725BL lines to allow two

wind generators to be connected at full capacity. The 603AL and 725BL lines would be rebuilt

on the same alignment as the existing 603AL and 725BL lines, utilizing an undeveloped road

allowance, and paralleling the existing 967L/968L line. To re-terminate the 603L and 608L lines

into the Windy Flats 138S substation, two short sections, of approximately 95 metres each,

would be built on the south side of the substation. AltaLink also proposed two airbreak structures

in the 608L and 608AL lines in the SW 15-8-26-W4M and NW 10-8-26-W4M. These airbreak

structures would each require 10-metre easements. AltaLink stated that there are no new

potential impacts from these alterations to stakeholders in the area.

10.1.2 The preferred and alternate transmission line routes

703. For the south Foothills project, a new double-circuit 240-kV transmission line, designated

as 1037L/1038L is proposed. AltaLink proposed a preferred and an alternate route. The preferred

route generally parallels the existing 911L line, while the alternate route is primarily a greenfield

route. AltaLink also proposed a Claresholm Connector, connecting the routing of the preferred

and alternate routes and allowing for the combination of the two routes, which are depicted

below.



Figure 31 – South Foothills project preferred and alternate routes115

115

Exhibit 348.00, page 16. Figure 3-1 Preferred and Alternate Routes.



704. From the Foothills 237S substation, the preferred route proceeds south, parallel to the

1201L line before veering west to create a greater separation from Frank Lake. The line then

proceeds south, parallel to the 911L line to route marker A30, where the alternate route option

begins. AltaLink created a route variant leaving Foothills 237S substation, closely paralleling

1201L line closer to Frank Lake. From route marker A30, the preferred route continues in a

southerly direction, parallel to the 911L line until route marker A45, where the preferred route

cuts to the east side of the town of Claresholm. AltaLink stated the preferred route veers east to

align two major infrastructure projects, the proposed transmission line and the proposed

Highway 2 bypass. Also, this portion of the preferred route is in keeping with the town of

Claresholm’s long-term development plan and the town's request to route around Claresholm.116

The transmission line continues to parallel 911L line, south of Claresholm until route marker

A79, where the transmission line heads in a south east direction towards the Windy Flats 138S

substation. AltaLink proposed two locations for the Windy Flats 138S substation, and created a

route variant to the alternate substation site. The route variant is located to the west of the

preferred route, requiring 1.5 kilometres of additional line and four additional heavy-angle,

dead-end structures.

705. AltaLink’s alternate route is primarily a greenfield route. The alternate route separates

from the preferred route alignment at route marker A30 and proceeds east and south, away from

the towns of Stavely, Claresholm and Granum. The alternate route passes by the southeast side

of Mud Lake before joining the preferred route alignment west of Fort Macleod.

706. The Claresholm Connector, which connects the preferred and alternate routes, allows for

a blended preferred and alternate route. The Claresholm Connector is 8.1 kilometres long and is

located north of the town of Claresholm. According to AltaLink, the connector would be located

at the lowest impact point of connection available near the midpoint of the preferred and

alternate routes; it follows quarterlines and has five residences within 800 metres.

10.1.3 Other project components

707. AltaLink also proposed the series capacitor station SC1 266S at approximately the centre

point of the 1037L/1038L line. The series capacitor station SC1 266S would consist of two

240-kV series capacitors, two 240-kV circuit breakers and the associated protection equipment

within a 101-metre by 139-metre fenced site. AltaLink created two potential locations depending

on whether the preferred or alternate route was selected for the1037L/1038L line. The preferred

location is at SW 15-14-27-W4M on the same site as the Stavely 349S substation. The alternate

location is at NE 15-15-26-W4M and would come within 150 metres of the residence at this site.

A small portion of land would also be required to accommodate the series capacitor site.

AltaLink obtained an option to purchase either of the sites.

708. AltaLink proposed to connect the existing 138-kV 603L and 608L lines to the

Windy Flats 138S substation at either the preferred or alternate site. The removal and rebuild of

parts of the 603AL and 725BL lines are required for the new connections. The existing 603AL

and 725BL lines would be rebuilt using the same alignment, which currently utilizes an

undeveloped public road allowance parallel to the existing 240-kV 967L/968L line.

116

Transcript, Volume 3, page 479, line 8-13.



Figure 32 – Terminate 603L into Windy Flats 138S substation117

709. To connect the 603L line to the Windy Flats 138S substation, AltaLink proposed to

construct 95 metres of new single-circuit 138-kV transmission line from the substation to the

603AL line and redesignate a portion of the 603AL line, from the new line portion to route

marker A10, as the 603L line. The existing jumper at the 603L97 line would be opened in the

direction of Peigan substation. The end result would have the 603L line connect the

Soderglen 248S substation to the Windy Flats 138S substation and the 603AL line connect the

Peigan 59S substation to the 603L97 line.

117

Exhibit 352.00, page 13, Figure 3-3 – Terminate 603L into Windy Flats 138S Substation.



Figure 33 – Terminate 608L into Windy Flats 138S substation118

710. To connect the 608L line to the Windy Flats 138S substation, AltaLink proposed to

construct 95 metres of new single-circuit 138-kV transmission line from the substation to the

603AL line, upgrade the portion of the 603AL line from the substation to route marker A40 as a

single-circuit line, and rebuild a portion of the 725BL line, from route markers A40 to A50, as a

double-circuit line to carry the 608L and 725BL lines. At route marker A50, the rebuilt 608L line

would connect to the existing 608L line via a T-tap and the existing 608L line from this point to

Blue Trail 528S substation would be redesignated as 608AL. The 725BL line would continue

east on its existing routing. AltaLink also proposed to install two airbreaks on either side of the

T-tap junction for isolation and reliability purposes. Lastly, AltaLink would open the existing

jumper on line 608L71 in the direction of the Peigan 59S substation, and the portion of the 608L

line from this jumper location to the Peigan 59S substation would be re-designated as 608BL.

The end result would be the 608L line connecting the Windy Flats 138S substation to the

Ardenville 1418S substation, the 608AL line running from line 608L102 to Blue Trail 528S

substation, and the 608BL line running from the 608L71 line to the Peigan 59S substation. The

725BL line would continue on its existing routing but would be on an upgraded, double-circuit

tower between route markers A40 and A50.

118

Exhibit 352.00, page 15, Figure 3-4 – Terminate 608L into Windy Flats 138S Substation.



10.2 Preferred versus alternate route


Table 7. Project assessment metrics for the preferred and alternate routes119

Major aspects and considerations Preferred route Alternate route

Total right-of-way length (km) 118 125

Agriculture

Cultivated Land Crossed (km) 76 84

Cultivated land crosses where there is no existing parallel transmission line (km) 26 70

Forage Land (Tame Pasture) Crossed (km) 11 2

Irrigated Parcels Crossed (km) 7 2

Residential

Residences within 150 m of centreline (#) 2 1

Residences within 800 m from right-of-way edge (#) 99 76

Environmental

Surface Water in of within 800 m of right-of-way (ha) 269 461

GVI - Total Native Prairie Crossed (km) 22 21

Protected or Provincially Designated Areas and Environmentally Sensitive Areas in or within 800 m of right-of-way (#) 2 2

Species of Management Concern and Species at Risk Act Listed Species Observations in or within 800 m of right-of-way (#) 124 81

Special considerations

LSDs with Listed Historical Values in or within 800 m of right-of-way (#) 455 364

Class 1 0 0

Class 2 0 0

Class 3 0 0

Class 4 20 40

Class 5 435 324

Airfields in or within 800 m of right-of-way edge (#) 1 1

Aggregate Areas in or within 800 m of right-of-way edge (#) 1 1

Opportunity to parallel transmission line to be salvaged (#) 70 17

Technical considerations

Number of Heavy Angles or Dead-end structures (#) 56 60

711. While AltaLink stated that both the preferred and alternate routes of the south Foothills

project are in the public interest, it stated the preferred route is the superior route because it is

shorter, has fewer potential agricultural impacts, has fewer potential environmental impacts, has

fewer heavy angle or dead-end structures, and costs less.

119

Exhibit 793.01, AML Undertaking 008.



712. In terms of potential agricultural impacts, AltaLink submitted that the preferred route

would cross 76 kilometres of cultivated lands while the alternate route crosses 84 kilometres.

However, out of the 76 kilometres of cultivated lands on the preferred route, only 26 kilometres

would not parallel an existing transmission line. While the preferred route would cross more

irrigated parcels than the alternate route, the preferred route impacts fewer irrigation pivots.120

The preferred route would cross more forage lands than the alternate route.

713. AltaLink’s metrics indicated that the preferred route would cross fewer hectares (ha) of

surface water and that the number of native prairie, protected or provincially-designated areas

and environmentally sensitive areas crossed, are similar. The preferred route contains more

species of management concern, Species at Risk Act listed species observations within

800 metres of the edge of the right-of-way, and more sections of land with listed historical

resource values in or within 800 metres of the edge of the right-of-way.

714. While both routes run parallel to the existing 911L line, the preferred route runs parallel

for 53 kilometres more than the alternate route, which potentially reduces impacts. As the 911L

line will be salvaged at the end of the project, the potential impact along the paralleled portions

result in a substitution impact rather than a new or incremental impact. AltaLink stated that one

benefit of paralleling the 911L line would be that local land use has been carried out with the

presence of the 911L line for 49 years. Because of the familiarity of the transmission line, many

impacts are incremental rather than new. For example, agricultural practices, irrigation systems

and access roads have each accommodated transmission lines so there would be fewer potential

impacts of replacing the 911L line with the new 240-kV transmission line than impacts

associated with locating the line in a greenfield setting.121 Another example of an incremental

impact is the number of irrigation pivots potentially impacted by the transmission line. While

both the preferred and alternate routes will impact two irrigation pivots, on the preferred route,

one pivot is currently impacted by the 911L line. If the preferred route were selected, only one

additional pivot would be impacted, while the alternate route would impact two new irrigation

pivots.

Table 8. Incremental residential impacts122

Major aspects

and

considerations

911L Preferred route

Portion of preferred

transmission route on parallel

Preferred route

incremental

Alternate route

Portion of alternate route on parallel

Alternate route

incremental

Number of residences within 150 metres of centreline

4 2 2 0 1 0 1

Number of residences within 800 metres from the edge of the right-of-way

211 88 41 47 75 14 61

120



Exhibit 348.00, page 100, Table 4-4 Incremental Residential Impacts.



715. AltaLink stated that while the raw numbers for residential impact favour the alternate

route, when comparing the impacts in relation to the existing 911L line, the preferred route has

lower impacts than the alternate route. The existing 911L line impacts four residences within

150 metres of the centreline and 211 residences within 800 metres from the edge of the

right-of-way. While the preferred route has two residences within 150 metres of the centreline,

both residences are located where the transmission line will parallel the 911L line. The residence

on the alternate route within 150 metres is located where there is currently no transmission line.

Similarly, for the 800 metre metric, 41 residences are located on the preferred route where it is

parallel to the 911L line compared to 14 residences on the alternate route. This results in an

incremental impact to 47 residences within 800 metres of the edge of the right-of-way for the

preferred route versus 61 for the alternate route.

716. AltaLink elaborated that for residences within 150 metres of the preferred route, one is an

abandoned residence that is to be razed (and not included in the table above), and the other is a

recently added trailer that can be moved. On the proposed alternate route, AltaLink stated that it

will purchase the residence that is within 150 metres to facilitate the series capacitor station site.

As such, AltaLink submitted that there is no appreciable difference between the two routes when

using the metric of residences within 150 metres.123

717. AltaLink added that while the new towers are larger, which could increase visual impact,

the incremental impacts would be lower than if the transmission line were not adjacent to another

transmission line.

718. AltaLink submitted that because the preferred route parallels the 911L line for 53 more

kilometres than the alternate route, the environmental evaluation concluded that the preferred

route has fewer potential environmental impacts.124

719. AltaLink stated that opposition to the south Foothills project was primarily by

landowners located either in or near the town of Claresholm, or at the south end of the south

Foothills project near the portion of the route that is common to both the preferred and alternate

routes, on lands associated with the Windy Flats substation site. Opposing landowners in or near

the town of Claresholm combined to form the Committee for East Route Conservation (CERC)

and wanted a route to the west of the town to be considered (the CERC route).125

720. In response, AltaLink argued that it originally considered this route, but abandoned it in

favour of the preferred route. It added that while the preferred route is longer and more

expensive than the CERC route, the incremental cost of the preferred route is justified given the

lower site-specific impacts associated with the preferred route to the east of Claresholm.126

721. AltaLink stated that the main considerations in routing the preferred route to the east of

the town of Claresholm were the alignment of the proposed transmission line with the

Highway 2 bypass, pipelines, major infrastructure projects, and the request of the Town of

Claresholm and its long-term development plan.127 AltaLink rejected the preliminary route to the

123








west of the town of Claresholm because it believed the east route has a lower overall impact than

the route to the west of Claresholm, favoured by CERC.

722. More specifically, AltaLink argued that the preferred route would have fewer residential

impacts than the CERC route. There are 26 first-row residents within 800 metres and none within

150 metres on the preferred route, and 65 first-row and two residences within 150 metres of the

CERC route; 128 however, more residences would be newly exposed to a transmission line on the

preferred route because the CERC route is in an area that parallels the 911L line. It added that

the preferred route is better from a visual impact perspective and provided aerial photos of the

CERC members’ properties, which showed many of the residences would have obstructed views

of the transmission line to the east.129 AltaLink stated that visual impacts could be further

mitigated through tower siting and that the Highway 2 bypass would be sited between these

residences and the transmission line.130 In contrast, AltaLink stated that most of the homes on the

west side of Claresholm are oriented to the west with unobstructed views towards the west.131 It

added that the preferred route contains fewer towers on cultivated fields.132

723. AltaLink emphasized that it considered the preferred route’s alignment with the

Highway 2 realignment a benefit, and that it took into account the town’s long-term plans.

AltaLink stated that the municipal development plan is an official land use planning document

used to guide future development of the town of Claresholm, and consideration of the municipal

development plan was critical to the process of identifying the best route because transmission

lines are of long duration.133

724. AltaLink stated that from an impact perspective, the creation of a common footprint

corridor for major infrastructure would result in low impacts.134 It argued that the Highway 2

bypass plans are not speculative and that, while it has not been designated as a highway, it has

gone through consultations, studies and plans.135 In addition, AltaLink has been given assurances

by Alberta Transportation that the Highway 2 bypass would proceed.136

725. AltaLink stated that the Town of Claresholm made it clear that it opposed the

transmission line being routed to the west of town and preferred the realignment option east of

town137 and explained that municipalities with populations exceeding 3,500 are required to adopt

a municipal development plan, which includes the land uses proposed for the municipality and

the manner of future developments in the municipality.138

726. Summarizing the position of the town, AltaLink indicated that the Town of Claresholm

opposed an alignment of the new transmission line along the 911L line because this alignment

would be inconsistent with the following two objectives: encouraging residential development

128



Exhibit 854.01, pages 47-48, paragraph 109. 131


Exhibit 588.01, CERC.AML-008. 133




Transcript, Volume 4, pages 556-557, lines 11-25, 1-2. 137

Transcript, Volume 3, pages 484-485, lines 12-25, 1. 138

Exhibit 720.01, page 8, paragraphs 17-18.



and expansion to the west, and maximizing views of the Porcupine Hills to the west.139 The town

favoured the alignment to the east of town along the Highway 2 bypass and other linear facilities

because it was more consistent with its land use planning objectives to the east of the town.140

The Town of Claresholm sent a letter to AltaLink on April 29, 2013, confirming its support of

the preferred route.141

727. AltaLink argued that the Berrien report142 was deficient due to the absence of consultation

with residents on the west side of Claresholm, town officials and town planners who would be

affected by the CERC route. Stakeholder input allows AltaLink to identify specific concerns,

gain local knowledge and discuss site-specific mitigation measures,143 and there is an inherent

bias when only one group of stakeholders is consulted.144 AltaLink consulted on preliminary

routes both on the east and west sides of Claresholm, as well as with town and government

officials, to conclude that the route to the east of Claresholm is the lower impact route.145

728. With regard to the siting of Windy Flats 138S substation, AltaLink’s preferred location

for the substation would have lower overall impacts than the alternate site or locations suggested

by Ronald and Laurie Conner (the Conners), and potential impacts identified by the Conners can

be mitigated. The impacts to the Conners’ gravel extraction can be mitigated by setbacks,

side-slopes around towers and compensation for any sterilized gravel reserves.146 AltaLink also

attempted to minimize impacts to the gravel operation through tower placement, siting as few

towers as possible on the gravel deposits.147

729. AltaLink stated that it considered various options with the Conners, including routing the

transmission line along the east side of the Peigan reserve and locating the substation off of the

Conners property.148 AltaLink concluded the preferred location was the lowest impact, but

developed an alternate site, west of the Conners’ property.

10.2.2 Views of interveners

730. The Commission received submissions from 648825 Alberta Ltd., Ron and

Bonnie Atkinson, Neil and Ginger Besplug, Debra Bronson, Donald and Carol Brunner, Wayne

and Jeanne Burnham, Ronald and Laurie Conner, Doug Umscheid Farms Ltd., Art and Pat

Fisher, Kathleen Fisher, Gary and Diane Hutton, R. Garry and Mayanne Johnson, Judith and

Michael Lelek, Betty and Lee Mainprize, Collin Markle, Gregory and Marjory Martin,

M.E. Meyerhoffer, Elizabeth Jean Mulholland, Gary Murray, Nanesco Sales Ltd., Karen

Needham, Dennis Nelson, Mildred Nelson-Pugh, James and Bev Senos, and Lynda and Bill

Thiessen. All participants along the preferred route, with the exception of Mr. Markle and the

Conners, combined to form CERC. The Conners are located on a common portion of the

preferred and alternate route near the southern terminus and their evidence is discussed below in

the alternate route section.

139

Exhibit 590.03, page 8. 140


Exhibit 720.02, pdf page 1. 142

Exhibit 587 and 588, Expert report from Bob Berrien. 143

Exhibit 720.01, pages 6-7, paragraphs 9 to 13. 144








731. The members of CERC primarily own land on or near Fifth Street East on the east edge

of the town of Claresholm. The members’ primary concerns were visual impacts and decreased

property value. The CERC members argued a route paralleling the 911L line to the west of

Claresholm is a superior route.

732. The CERC group retained Mr. Berrien, Mr. Wallis and Mr. Donaldson to prepare reports

comparing the preferred route to the CERC route. Mr. Berrien stated that the CERC route has

minimal incremental impacts, fully parallels an existing route, is a route that existed earlier in the

process and is a superior route with the lowest overall impact.149 CERC argued that the preferred

route does not follow an existing linear disturbance150 because the proposed highway alignment

has not been approved and may not be built.151

733. Mr. Berrien testified that he was mandated to evaluate the preferred route near

Claresholm and that he did not study the alternate route to the extent that he could form a decent

opinion on it.152

734. In Mr. Wallis’ report, prepared on behalf of CERC, he evaluated both the preferred and

alternate routes from an environmental perspective and concluded that there is no clear choice;

both routes could be considered equal in their impacts, depending on how the different attributes

were weighted.153 The Wallis report concluded that the preferred route contains fewer wetlands

and parallels the existing 240-kV transmission line for a greater distance and that the alternate

route contains a lower proportion of environmentally significant areas, native uplands and known

rare plant locations.

735. CERC submitted that the preferred route is a longer and more expensive route. The

Berrien report estimated the increased cost to be no less than $10 million.154 In addition to the

preferred route being 5.3 kilometres longer, CERC argued that seven temporary poles are

required at a cost of $1 million, which would not be required in the CERC route.155 CERC added

that although the preferred route parallels the 911L line for over half the route, it deviates to a

greenfield route near the town of Claresholm.156

736. CERC stated that the CERC route is the lower impact route from an agricultural

perspective; it would be parallel to the 911L line, where farming practices have developed over

time in the presence of towers, while the preferred route would be a greenfield scenario where

farming around transmission towers would be a new impact.157 The CERC route would also

require fewer structures to farm around.

149

Exhibit 587.02, Section 3.2.1.5 Final Opinion and Recommendations. 150


Exhibit 587.02, page 33. 152



Exhibit 587.02, page 43. 155

Transcript, Volume 3, pages 426-427, lines 23-25, 1-10 and page 456, lines 12-23. 156





737. CERC submitted that while the CERC route has more residences within 800 metres, the

impact is lower because it would be incremental due to the presence of an existing line. AltaLink

agreed with CERC on this.158 In contrast, CERC stated that the preferred route would impact

newly exposed residences. CERC pointed out that AltaLink indicated that a benefit of paralleling

the 911L line is that the line has been in place for 49 years and that local land use had evolved

and been carried out through the years in the presence of the line.159 In addition, Mr. Berrien

argued that given the current population growth rate, little additional residential land would be

required in the future.160

738. CERC argued that the preferred route would result in a new visual impact to the

residences on the east side of Claresholm while residences along the CERC route have had a

power line in their view and would be newly exposed. CERC contended that AltaLink’s

evidence on the home orientation was either incorrect161 or that the house orientation did not

indicate the direction of views from other parts of the house, such as kitchen windows and

outdoor patios.162

739. CERC stated that its route is better from an environmental perspective. In addition to

being a shorter route, the Wallis report stated that the preferred route is in proximity of wetlands

and native upland habitats while the CERC route contains a tiny area of degraded grassland.163 A

CERC member testified that the concentration of multiple lines in multiple directions, like the

preferred route, poses a greater risk for avian collisions than a single north-south alignment such

as paralleling the existing 911L line.164

740. CERC contended that the preferred route did not accord with the Town of Claresholm’s

municipal development plan because paragraph 11.4.4 of the municipal development plan states

that the town is opposed to any utility development that could negatively impact future growth. It

submitted that the preferred route would negatively impact industrial development in

NW 24-12-27-W4M due to the setbacks from the transmission line and the existing pipelines,

therefore, the preferred route was in contradiction with the plan.165

741. CERC stated that its route would not negatively impact the town’s future growth.

Mr. Berrien testified that the existing approved Prairie Shores area structure plan provides

enough residential development for the town, and the CERC route would not constrain

residential development to the west towards the 911L line.166 Mr. Donaldson added that

residential development is an acceptable land use in proximity to power lines.167 Mr. Donaldson

submitted that the Claresholm land-use bylaws do not regulate views or the protection of views

and do not implement the policies of the municipal development plan regarding the desire of the

town to relocate the transmission line to the east side of town.168

158


Exhibit 348, page 5, paragraph 18. 160

Exhibit 587.02, page 32. 161



Exhibit 591.02, page 18. 164


Transcript, Volume 3, pages 497-499, lines 24-25, 1-25, 1-3. 166



Exhibit 590.02, page 12.



742. Mr. Berrien stated that, although the primary driver for the preferred route is the

paralleling of a future highway alignment, the highway alignment is not approved and has no

start date. Except for transmission utility corridors, transmission lines paralleling highways is not

seen as viable routing.169 Mr. Berrien testified by putting the transmission line in first, there is a

risk that it would have to be moved if it interfered with the highway.170 He also recommended the

use of monopole structures due west of the populated area of Claresholm.171

743. CERC argued that the absence of consultation should not be viewed as a shortcoming in

Mr. Berrien's approach. According to Mr. Berrien, individual preferences should not trump good

siting principles.172

744. Mr. Wallis stated that the CERC route was shorter in length and intersected significantly

less native habitat than the preferred route.173

745. CERC requested that the Commission send AltaLink back to investigate the CERC route

and require it to file an amendment to the application.

746. Mr. Markle submitted concerns that the transmission line would cross the west end of his

primary aircraft runway, rendering it unusable. Mr. Markle wished to relocate the runway, but

deemed AltaLink’s compensation to be inadequate to secure the land required to develop a new

runway.

747. The Conners filed submissions on the location of the Windy Flats 138S substation along

the common portion of the preferred and alternate route. The Conners, who operate a cattle

operation, and whose lands are used for grazing and growing hay, objected to the proposed

Windy Flats 138S substation location because the transmission line would dissect their land. The

transmission line would also traverse their gravel desposit which is excavated by McNally

Contractors (2011) Ltd. The Conners argued they would suffer a material reduction in their

income due to the loss of grazing land and, more significantly, from the impact to their mining

operation. The Conners stated that 50 per cent of their income comes from gravel royalties, and

they were unsure how these royalties would be affected by a loss in the mineable area of the

gravel deposits.

748. The Conners also expressed concerns with noise, stating their lands already contain wind

turbines and transmission lines, and the noise would increase with the new line.

749. The Conners submitted that should the transmission facilities be approved, they would

suffer encumbrances on the affected sections of land where there are none currently; they would

lose the ability to develop these sections of land, and would suffer visual impacts.174 They also

stated that their residence is within close proximity of the proposed substation location and

would be subjected to visual and noise impacts.

169

Exhibit 587.02, page 45. 170


Exhibit 587.02, page 47. 172

Exhibit 587.02. page 46. 173





750. The Conners contended that the southern termination point of the transmission line and

the Windy Flats substation discriminates between land, and not with particular landowners, and

that the indirect effect of the applications, if approved, is to deny benefits and protections to both

the Conners and the Piikani First Nation due to their race, in breach of Section 15 of the

Charter of Canadian Rights and Freedom. They argued that they would lose the benefit and

protection which would result from the detailed environmental assessment prescribed by the

Canadian Environmental Assessment Act, and become subject to a less favourable framework for

compensation for lands taken for public purposes than those which apply under the Indian Act. In

terms of the Piikani First Nation, the Conners alleged that the Piikani lose the opportunity to

allow the further use of Reserve lands, already encumbered with electrical transmission facilities.

751. McNally Contractors (2011) Ltd. submitted concerns with the routing of the south

Foothills line stating that the line may impact the gravel extraction operation, potentially

sterilizing the land.175 It requested that the Commission consider compensation for lost

extraction, relaxation of setback from the line, potential crossing and encroachment conflicts,

gradelines of the line’s right-of-way, and potential grant of easements to access the gravel when

evaluating the south Foothills project.

752. Sabrina and Jason Paradis submitted their concerns regarding health effects, property

value and visual impacts. They stated that there was no guarantee that transmission lines do not

impact health, and that their property value would decrease because the transmission line would

be directly in front of their property. The Paradis, who did not attend the hearing, added that they

did not want the transmission line on the alternate route and that it should be placed by the

existing 911L line.176

10.3 Hybrid A versus Hybrid B


753. AltaLink developed two hybrid routes utilizing the Claresholm Connector. Hybrid A

consists of the south portion of the preferred route, the Claresholm Connector, and the north

portion of the alternate route. Hybrid B consists of the south portion of the alternate route, the

Claresholm Connector, and the north portion of the preferred route.

175

Exhibit 437.02, McNally Rule 001 Section 24 response to notice. 176

Exhibit 707.01, Paradis Rule 001 Section 24 response to notice.



Table 9. Project assessment metrics for the hybrid routes177

Major aspects and considerations Hybrid A Hybrid B


Agriculture

Cultivated Land Crossed (km) 77 94


Forage land (tame pasture) crossed (km) 11 2

Irrigated parcels crossed (km) 7 2

Residential



Environmental

Surface water in or within 800 m of right-of-way (ha) 486 249

GVI - total native prairie crossed (km) 28 19

Protected or provincially designated areas and environmentally sensitive areas in or within 800 m of right-of-way (#) 2 2

Species of management concern and Species at Risk Act listed species observations in or within 800 m of right-of-way (#) 162 44


LSDs with listed historical values in or within 800 m of right-of-way (#) 520 299

Class 1 0 0

Class 2 0 0

Class 3 0 0

Class 4 40 20

Class 5 480 279


Aggregate areas in or within 800 m of right-of-way edge (#) 1 0



Number of heavy angles or dead-end structures (#) 70 47

754. AltaLink stated that, when comparing the two routes which utilized the

Claresholm Connector, Hybrid B appears to be superior based on the metrics set out above.

Hybrid B is the shorter route, has fewer residential and environmental impacts and fewer special

considerations.

755. When comparing agricultural impacts, Hybrid A would cross fewer cultivated lands, both

in total and where there is no existing parallel transmission line. However, Hybrid A would cross

more forage land and more irrigated parcels than Hybrid B.

177

Exhibit 793.01, AML undertaking 008.



756. Both residential impacts and environmental impacts favour the Hybrid B route. Hybrid B

had fewer residences within 150 metres and 800 metres, and outperformed Hybrid A from an

environmental perspective. In addition, Hybrid B contains fewer sections of land with listed

historical resource values, airfields and aggregated areas within 800 metres of the edge of the

right-of-way, parallels existing transmission lines for a greater length and utilizes fewer heavy

angle or dead-end structures.

757. Hybrid A would impact all interveners who objected to the projects, while Hybrid B

would bypass both the CERC group and the Paradis lands. Because the Conners are located on a

common portion of the preferred and alternate routes, they would be impacted by both hybrid

options. Mr. Mark Lamb, whose residence is located along the Claresholm Connector, would

also be impacted by both hybrid routes.


758. Mr. Lamb submitted his concerns, in writing, that the transmission line would interfere

with his haystacks and calf operation. He was also concerned about decreased cellphone

reception and decreased property value. The transmission line right-of-way would run in

between two of his sections of land. He did not file any evidence and did not attend the hearing.

No other comments or evidence on the hybrid routes was submitted by any of the interveners.

10.4 Preferred versus Hybrid B


759. The Hybrid B route consisted of the north portion of the preferred route, the

Claresholm Connector, and the south portion of the alternate route. To compare the two routes,

the south portion of the preferred route could be compared with the south portion of the alternate

route in combination with the Claresholm Connector. AltaLink provided a route assessment

metric of the half routes in its undertaking 008; however, this table did not factor in the

Claresholm Connector.



Table 10. Project assessment metrics for the south portion of the preferred and alternate routes178

Major aspects and considerations Preferred route -

south Alternate route -

south

A100-A60 A100-B64-B50


Agriculture

Cultivated land Crossed (km) 25 38


Forage land (tame pasture) crossed (km) 11 2

Irrigated parcels crossed (km) 7 2

Residential



Environmental

Surface water in or within 800 m of right-of-way (ha) 228 205

GVI – Total native prairie crossed (km) 18 13

Protected or provincially designated areas and environmentally sensitive areas in or within 800 m of right-of-way(#) 1 1

Species of management concern and Species at Risk Act listed species observations in or within 800 m of right-of-way (#) 114 34


LSDs with listed historical values in or within 800 m of right-of-way (#) 367 211

Class 1 0 0

Class 2 0 0

Class 3 0 0

Class 4 17 17

Class 5 350 194


Aggregate areas in or within 800 m of right-of-way edge (#) 1 1



Number of heavy angles or dead-end structures (#) 28 19

760. When comparing the preferred route to the Hybrid B route, AltaLink stated that the

preferred route is the route with the lowest overall impact179 because there are fewer agricultural,

residential, and environmental impacts on the preferred route and that costs would be similar.

761. AltaLink argued that while the Hybrid B route has 16 fewer residences within

800 metres, all residences along the Claresholm Connector and south alternate route (five and

32 residences, respectively) would be newly exposed to transmission lines because the

178

Exhibit 793.01, AML undertaking 008. 179




residences are not near existing lines.180 The Hybrid B route has one less residence within

150 metres of the centreline.

762. AltaLink stated the preferred route provides greater opportunities to minimize potential

agricultural impacts than the Hybrid B route as the preferred route crosses less cultivated land.181

763. AltaLink also argued that the preferred route has less environmental impacts. While

Hybrid B has fewer species of management concern and Species at Risk Act listed species

observations within 800 metres, the majority of these are hawks nesting on the existing 911L line

structures, which will be salvaged regardless of which route is selected. It pointed out that an

advantage of the preferred route is that new structures will be constructed near the 911L line,

allowing the hawks an opportunity to relocate nests on the new structures in the area. With the

Hybrid B route, the existing 911L line structures would be removed but the new structures would

not be erected in the area, removing the potential for hawks to relocate in the existing area.182

764. AltaLink added that Hybrid B has fewer sections of land with listed historic resource

value in or within 800 metres but noted that the majority of these historic resources have a value

of Class 5, which are limited in terms of significance.183

765. According to AltaLink, the cost of the two options would be similar. While Hybrid B is a

longer route, it requires fewer dead-end structures.184

766. AltaLink indicated that 80 per cent of landowners along the preferred route have agreed

to the siting of the preferred route and that land procurement has not occurred for the

Claresholm Connector or the alternate south route. It also stated that Mr. Lamb, located on the

Claresholm Connector, would have the right-of-way across all three of his quarter sections and

four structures located on his lands.

767. Overall, AltaLink views the preferred route as a better route because a large portion of

the line is parallel to the 911L line. For Hybrid B, a portion of the line would be a new impact,

siting a line where none previously existed.185


10.5.1 Preferred versus alternate route

768. In making its decision, the Commission took into account that for a majority of the route,

the preferred route parallels the existing 911L line which is scheduled to be salvaged at the end

of the SATR development. As a result, the majority of the route would continue to have similar

impacts, with the new 1037L/1038L line replacing the 911L line.

769. The Commission also finds the preferred route is a better route as it is shorter in length,

has fewer agricultural impacts, and because it will cross less cultivated lands and a majority of

these cultivated lands are lands where the existing 911L line is paralleled. Farming activity in

180

Exhibit 854.01, page 26, paragraph 54 (b). 181

Exhibit 854.01, page 26, paragraph 54 (a). 182

Exhibit 854.01, page 26, paragraph 54 (c). 183

Exhibit 854.01, page 26, paragraph 54 (d). 184

Exhibit 854.01, page 26, paragraph 54 (e). 185




these areas has adapted in the presence of the existing lines and the impact to agriculture is

viewed as an incremental impact. The Commission views impacts on agriculture where no line

currently exists as having a greater potential impact. The alternate route crosses nearly three

times more agricultural lands with no existing transmission lines than the preferred route. While

more irrigated parcels are crossed by the preferred route, the incremental impact on irrigation

pivots is higher on the alternate route than the preferred route.

770. The preferred route also crosses significantly fewer lands with nearby surface water.

While the preferred route has a high number of observed species of concern or listed species, this

is a lower impact given the amount of the transmission line that is parallel to the 911L line. In

contrast, the alternate route would be sited on a greenfield route and potentially has a greater

impact to these species. In making this finding, the Commission considered the following

evidence by Mr. Wallis:

Of the proposed routes, the preferred route is considered more suitable from a biophysical

perspective primarily because it:

• Parallels a greater length of transmission lines and, therefore, contributes to less

overall fragmentation of habitat;186

771. While the preferred route contains more sections of lands with listed historical resource

values within 800 metres of the right-of-way, the majority of these resources are designated as

Historical Resource Value (HRV) 5. In addition, the impacts to these historic resource values can

be mitigated.

772. It was noted that none of the interveners advocated for the alternate route. During

testimony, the experts of the CERC group commented that they either did not evaluate the

alternate route,187 or that both routes were equal.188

10.5.2 Hybrid A route versus Hybrid B route

773. According to the assessment criteria provided by AltaLink, the Hybrid B option is better

in nearly every aspect. Hybrid B is shorter, has fewer residential and environmental impacts,

fewer impacts on historical resources, and parallels more existing transmission than Hybrid A.

Hybrid B is also less costly189 because it is shorter and contains significantly fewer heavy angle

and dead-end structures.

10.5.3 Preferred route versus Hybrid B route

774. The Hybrid B route consists of the same north portion as the preferred route, but

incorporates the Claresholm Connector and the south portion of the alternate route.

775. The Commission finds that the preferred route and the Hybrid B route appear to be

similar in terms of route length, agricultural impacts, residential impacts, environmental impacts,

and cost. When considering the benefits of paralleling existing linear disturbances, the preferred

route appears to have fewer overall impacts. Hybrid B consists of the south alternate route,

which does not parallel the existing 911L line.

186

Exhibit 591.02, Cliff Wallis Expert Report, page 19. 187


Transcript, Volume 5, pages 743-744, lines 19-25, 1. 189

Exhibit 794.01, AML undertaking 009.



776. The Commission considers that while the raw number of residences within 150 metres

and 800 metres appear to favour the Hybrid B route, Hybrid B would newly impact more

residences. The potential environmental impacts appear to be similar between the preferred route

and the Hybrid B route with the exception of the observed listed species metric. As a significant

proportion of the preferred route is parallel to the 911L line, many potential impacts on wetlands

and native prairie along the preferred route are incremental. Along the Hybrid B route potential

impacts on wetlands and native prairie would be new. More listed species were observed along

the preferred route than the Hybrid B route, but approximately half of the preferred route is

parallel to the 911L line. Where the observed listed species are viewed along the section of the

preferred route which parallels the 911L line, observed species on the equivalent segment of the

Hybrid B route would be along a greenfield route. However, the evidence submitted was that

hawks, which were the observed species, are able to relocate their nests in a similar area on the

preferred route, which offers an additional reduction of environmental impacts.

777. The Commission finds that the preferred route has lower agricultural impacts because it

crosses less cultivated land, both overall and where there is no existing parallel transmission line.

The Hybrid B route crosses much more cultivated land where no existing transmission line is

present. For lands with historical resource value, the equivalent south portions of the Hybrid B

route and the preferred route contain the same number of sections of land with a historical

resource value of 1, 2, 3 and 4 while the preferred route has more HRV 5 lands, which tend to be

less significant. AltaLink estimates that both the preferred and Hybrid B routes will be similar in

cost; therefore cost is not a significant factor in choosing the better route.

778. The Commission finds that overall, the preferred route will be of lower impact than the

Hybrid B route. In the longer term the preferred route would result in incremental impacts, where

the line would be sited next to the existing 911L line, followed by a substitution impact, once the

911L line is salvaged; whereas for portions of the Hybrid B route, there would be a new impact

on a greenfield route. In addition, the approval of the Hybrid B route would result in a delay in

construction and the AESO has stated that the need for the 911L line rebuild is urgent.190

10.5.4 Preferred route versus CERC route

779. The proposed CERC route appears to be a shorter option compared to the preferred route,

and would parallel the 911L line. However, the preferred route has lower agricultural impacts

because there are fewer towers in cultivated fields.

780. The preferred route does not have any residences within 150 metres, while the CERC

route has two residences within 150 metres. Similarly, the preferred route has considerably fewer

residences within 800 metres. While the new towers are larger than the existing 911L line

towers, the CERC route would generally result in similar visual impacts to what is currently

experienced. On the preferred route, the transmission line would result in a new visual impact.

AltaLink’s evidence was that there are more unobstructed views of the transmission line along

the CERC route than there would be on the preferred route. There are more residences on the

west side of Claresholm and many of the residences on the east side have trees and buildings

obstructing the view of the line on the proposed route to the east. The future Highway 2 bypass

will be situated between the residences along the east side of town and the transmission line.

Based on the above, the Commission finds that the overall residential impact is lower on the

190




preferred route and that the visual impact is similar along both routes, given the subjective nature

of visual impacts. Despite the fact that more residences are situated along the CERC route than

the preferred route, the Commission finds that the CERC route would generally result in

incremental residential and visual impacts due to the existence of the 911L line. Further, the

preferred route is a greenfield route, which would result in new residential and visual impacts.

781. The Commission finds that the environmental impact is slightly greater on the preferred

route because it crosses more wetlands and is longer. The preferred route is also a greenfield

route, despite the fact that a future highway will be situated nearby.

782. The Commission encourages the paralleling of existing linear disturbances because it

reduces impacts. The CERC route parallels the 911L line for the entire length. While the

preferred route moves away from the 911L line near the town of Claresholm, it will be parallel to

the future Highway 2 bypass. The Commission agrees with AltaLink and the Town of

Claresholm that transmission lines are compatible with commercial and industrial land uses. The

Commission does not agree with CERC that the transmission line will interfere with commercial

and industrial development because it views them as compatible developments.

783. CERC argued that there is uncertainty that the Highway 2 bypass will be built and that

the transmission line could impede the highway because it would be built first. The Commission

has not heard evidence regarding the status of the highway project, but notes that Alberta

Transportation supports the preferred route. Further, AltaLink’s evidence is that it has worked,

and will continue to work, with Alberta Transportation on the alignment of the transmission line

with the highway.

784. The Commission finds that AltaLink’s preferred route may be the lower impact route of

the two, given its lesser residential impact. In the longer term, the preferred route will be

paralleling a major linear structure; whereas, the CERC route will not. The preferred route also

more adequately aligns with the Town of Claresholm’s development plans and is supported by

the M.D. of Willow Creek. The preferred route is however a greenfield route, in a location where

an existing transmission line is not present, while the CERC route would be situated next to an

existing transmission line where land use has evolved with the presence of the line. The

Commission does find the argument for the CERC route to be compelling, because the route

parallels the 911L line as it passes the town of Claresholm, resulting in a shorter and less

expensive route. Further, the Commission took into account the submissions of AltaLink

regarding the paralleling of the 911L line and the reduction in impacts in relation to a greenfield

route. The Commission considers that paralleling an existing transmission line or using an

existing right-of-way results in fewer impacts as discussed above and finds merit in the CERC

submissions. However, as AltaLink did not apply for the CERC route, additional information on

this route such as stakeholder consultation is not on the record. Consequently, while the

Commission approves the preferred route over the alternate route in this area, the Commission

also directs AltaLink to examine the CERC route in accordance with the requirements of AUC

Rule 007.

785. AltaLink is directed to file a report with the Commission describing the progress of this

investigation by December 31, 2013. If the CERC route can be achieved with a reduction in

overall impact, the Commission will determine whether AltaLink will be required to file an

amendment to the permit and licence.



10.5.5 Windy Flats 138S substation

786. With regard to the siting of the Windy Flats 138S substation, the alternate substation site

would require the transmission line to pass close to the Conners’ residence, while at the preferred

substation site the transmission line would be further from the residence, but closer to the gravel

pit. The Commission has taken into account that any gravel that is sterilized by the transmission

line may be compensated and finds that the potential impacts on the Conners’ residence would

be greater than on the gravel pit.

787. The Commission views grazing and hay farming activities as not incompatible with the

presence of a transmission line. Considering that there is an operating gravel pit in the vicinity of

the proposed substation, as well as existing wind turbines, and that the gravel pit is closer to the

residence than the proposed substation, the Commission did not accept the Conners' submissions

on potential visual impacts and noise impacts of the proposed substation and transmission line on

their land. In addition, the substation and proposed transmission line satisfy the noise

requirements of AUC Rule 012.

788. As a result, the Commission finds that the preferred location is the lowest impact location

for the proposed Windy Flats 138S substation.

789. Regarding the alleged breach of Section 15 of the Charter of Canadian Rights and

Freedoms, a person who alleges the breach must show discrimination "in the sense that it denies

human dignity or treats people as less worthy".191 There is no evidence in this proceeding of any

such discrimination. The Conners did not submit any evidence of any such discrimination nor

can any such conclusion be drawn from any other evidence before the Commission in this

proceeding. Further, the Commission is of the view that there is no basis for the argument that

the effect of the SATR NID approval amendment is to discriminate against the Conners or the

Piikani First Nation due to their race. The Commission is satisfied that the reason for the change

in the substation location is due to the potential for delay associated with the Peigan substation

upgrades on federal lands, which poses scheduling implications and risks that are unacceptable to

the AESO as the transmission system planner.

790. The fact that the process for acquiring access to federal lands is different than the process

for acquiring access to lands that are subject to provincial jurisdiction results in the delay has

nothing to do with the race of either the Conners or the Piikani First Nation. The fact that

different legal regimes apply to the Piikani First Nation and other Crown lands, and to the

Conners, is reflective of the division of powers set out in sections 91 and 92 of the

Canadian Constitution.

791. Accordingly, the Commission finds that the Conners have not shown that a breach of

Section 15 of the Charter exists.

191

Gosselin v. Quebec (Attorney General) [2002] 4 S.C.R. 429, paragraph. 17. See also Canadian Foundation for

Children, Youth and the Law v. Canada [2004] 1 SCR 76 at paragraph 53.



11 ENMAX Application No. 1608649

11.1 Discussion

792. The Alberta Electric System Operator identified a need to reinforce the transmission

system in the south Calgary and High River planning areas. This reinforcement would alleviate

the existing and anticipated constraints arising from the expected load growth and integration of

the proposed generation capacity within the applications area, as well as facilitate the

transmission of generation from southern Alberta.

793. The ENMAX portion of the proposed system upgrade has three main components.

Modifications to both the ENMAX No. 65 and ENMAX No. 25 substations as well as the

construction and operation of a 240-kV transmission line designated as 1064L/1065L, which will

be within the ENMAX service territory from the Langdon and Janet substations.

794. The ENMAX No. 65 substation is located at 9100 Marquis of Lorne Trail S.E., Calgary,

Alberta. The AESO has requested that ENMAX modify the ENMAX No. 65 substation by

disconnecting the existing AltaLink 240-kV 911L line, and terminating three new AltaLink

240-kV transmission lines 1106L, 1107L and 1109L.

795. The ENMAX No. 25 substation is located at 9500-100 Street S.E. Calgary, Alberta. This

substation will require the interconnection of two new AltaLink 240-kV transmission lines

1109L and 985L.

796. ENMAX will also be the owner and operator of the portion of 240-kV 1064L/1065L line

in the ENMAX service territory. ENMAX and AltaLink have agreed that AltaLink would

perform all consultation and construction on behalf of ENMAX. ENMAX will be the owner and

have joint operating procedures with AltaLink to ensure safe reliable operation of the lines.

797. ENMAX stated that the cost for the project modifications of the ENMAX No. 25 and

ENMAX No. 65 substations is $4.3 million based on a +20%/-10% contingency.

798. ENMAX indicated that the construction for the ENMAX No. 65 substation would be

contained entirely within the substation fence. Construction for the ENMAX No. 25 substation

would take place within the substation, and would consist of the installation of additional

protection and control equipment within the substation control building to accommodate the

240-kV line additions. No outdoor construction would be required for the ENMAX No. 25

substation. ENMAX added that the potential environmental impacts and noise impact assessment

for both the ENMAX No. 25 and ENMAX No. 65 substations had not changed since these

substations were approved in AUC Decisions 2012-283 and 2011-435, respectively.


799. The Commission accepts ENMAX's submissions that there would be no new

environmental impacts caused by the modifications of the ENMAX No. 25 and ENMAX No. 65

substations, because the modifications would be entirely within the substation fence for the

ENMAX No. 65 substation and within the control building for the ENMAX No. 25 substation.

800. The Commission is satisfied that the technical information submitted by ENMAX fulfills

the requirements of AUC Rule 007 and that the participant involvement program was conducted

in accordance with AUC Rule 007.



801. No persons objected to the ENMAX application.

802. The Commission further finds that the modification to the substation is consistent with

the need identified in the FATD NID.

803. Based on the forgoing, the Commission approves the applications to modify both the

ENMAX No. 25 and No. 65 substations and finds that the modifications are in the public interest

pursuant to Section 17 of the Alberta Utilities Act.

12 Decision

804. After careful consideration of the record of the proceeding and for the reasons set out

above, the Commission finds that the approval of the project, as follows, is in the public interest

having regard to the technical, social and economic effect of the project, and its effects on the

environment.

805. Pursuant to Section 34 of the Electric Utilities Act and Section 38 of the

Transmission Regulation, the Commission approves the following applications and grants the

AESO the needs identification document approvals which will be distributed separately:

Application No. 1608620, application of the Alberta Electric System Operator for

approval of the needs identification document for 240-kV and 138-kV transmission

system expansion in the vicinities of southeast Calgary, Okotoks and High River –

Foothills Area Transmission Development Plan

Application No. 1608846, Windy Flats Amendment to the Alberta Utilities Commission

Southern Alberta Transmission System Reinforcement (SATR) Approval No. U2011-115

(SATR NID Approval)

806. Pursuant to sections 14, 15, 18, 19 and 21 of the Hydro and Electric Energy Act, the

Commission approves the following applications and grants permits and licences with specific

conditions as detailed below to AltaLink, and ENMAX, respectively. The approvals will be

distributed separately.

Application No. 1608642 Langdon to Janet project

Application No. 1608637 north Foothills transmission project

Application No. 1608643 Foothills 138-kV project

Application No. 1608861 south Foothills transmission project

Application No. 1608862 Windy Flats 138S substation and line reconfiguration

Application No. 1608649 ENMAX alterations to ENMAX No. 25 and No. 65 substations

807. With respect to Application No. 1608642, the Langdon to Janet project, the preferred

route is approved for the proposed 1064L/1065L line. However, the approval is subject to the

following condition:

The use of monopole structures immediately adjacent to Mr. Mattson’s property from

route marker B260 to route marker B265 across the northwest quarter of Section 13,

Township 23, Range 28, west of the Fourth Meridian if Mr. Mattson declines the buyout

option offered by AltaLink.



808. With respect to Application No. 1608637 north Foothills transmission project, the

following is approved:

the D12 site for the Foothills 237S substation site

the preferred route for the proposed 1106L/1107L line

the one-tower option at the Bow River crossing

809. However, the approval is subject to the following conditions:

AltaLink will file with the Commission the written consent of the Minister of

Infrastructure, to construct the portion of the 1106L/1107L line within the transmission

utility corridor on the east side of Calgary .

810. With respect to Application No. 1608643, the Foothills 138-kV project, the hybrid route

as described below is approved for the double-circuit portion of the proposed 434/646L line.

To start from the D12 site of the Foothills 237S substation, follow the

stakeholder-suggested route to route marker B20, then follow the preferred route to route

marker A39, and finally follow the alternate route to the High River 65S substation.

811. Lastly, with respect to Application No. 1608861, the south Foothills transmission project,

the preferred site is approved for the proposed Windy Flats 138S substation and the preferred

route is approved for the proposed 1037L/1038L line. However, the approval is subject to the

following:

AltaLink will examine the CERC route in accordance with the requirements of AUC

Rule 007 and is directed to file a report with the Commission describing the progress of

this investigation by December 31, 2013. If this route can be achieved with a reduction in

overall impact, the Commission will determine whether AltaLink will be required to file

an amendment to the permit and licence.

Dated on October 7, 2013.


(original signed by)

Anne Michaud

Panel Chair


Neil Jamieson

Commission Member


Patrick Brennan

Acting Commission Member



Appendix A: Proceeding participants who have registered a statement of intent to

participate

Name of Person or group Counsel or Representative

Alberta Electric System Operator D. Davies and J. Cusano

AltaLink Management Ltd. P. Feldberg

ENMAX Power Corporation D. Wood

590140 Alberta Limited C. Simonelli

1297833 Alberta Inc. S. FitzGerald

Alberta Tourism Parks and Recreation

M. Arca

Astral Media Radio B. Stovold

Benign Energy Canada II Inc. A. Kettles

B.F.W. Holdings (2006) Ltd. Syd Mantler

Bow River Crossing group S. Stenbeck

Bow Vista Farms Ltd. S. Stenbeck

J. Camacho

Camrock Capital Partners GP (40) Ltd

A. Chehabeddine




M. Chehabeddine

Committee for East Route Conservation (CERC)

R. and L. Conner C. McGarvey

D. Coonfer

T. Dawson

Diagonal Group G. Fitch

ENMAX Green Power Inc. R. McKee

ENMAX Shepard Inc. J. Schlauch

Foster Family Trust N. Patterson

F.L. and E. Fowler

Abdul and Mohamed Hage J. Tannahill

Industrial Power Consumers Association of Alberta M. Forster and V. Bellissimo

H. Jackson

B. Joneja

F. Kaaki

J. Kyle




G. Lamb

K. Lamb

M. Lamb

Louson Investment Ltd. and Glen Eagles Investments Ltd. G. Fitch

F. Lozeman

J. and D. MacLellan

C. Markle

Mattson Group M. Niven and N. Ramessar

The McLaren and Carlson group J. Price and J. Bolton

D. Meier, D. Meier and M. Meier S. FitzGerald

R. Miller

L. Moor

W. Moore

D. Nauta

R. and G. Nauta

J. and S. Paradis




H. Park

R. and R. Pearson J. Laycraft

D. Pope

Powerex Corp. C. Ferguson

Randle group J. Laycraft

P. Robertson G. Fitch and M. Barbero

Scandinadian Development Consultants C. Hansen

B. Schnarr

J. Shutiak

V. Steele

Y. Shin

J. Taplin

TD&T Properties D. Leeds

Town of High River K. Mohammed

TransAlta Corporation

TransCanada Energy Limited S. Kley




M. Vandervalk

Volker Stevin/McNally Contractors (2011) Ltd.

T. Wallace

A. Weeks

C. and C. Woolridge

D. Zuck



Appendix B: Oral hearing

Name of Person or Group Counsel or Representative

Witnesses

Alberta Electric System Operator D. Davies A. Culos

J. Doering G. Lam L. Papworth A. Rehman

AltaLink Management Ltd. P. Feldberg J. Liteplo B. Hunter J. Yearsley

L. Erdreich H. Foley M. Gahbauer C. Harvey D. Hoover J. Howland W. Mundy J. Power A. Reimer S. Sutherland

ENMAX Power Corporation D. Wood

S. Kumar M. Wong

1297833 Alberta Inc. S. FitzGerald

B.F.W. Holdings (2006) Ltd. S. Mantler

Benign Energy Canada II Inc. A. Kettles

Bow River Crossing group S. Stenbeck

R. Berrien J. Brunen L. Klatzel-Muldry D. Pate C. Wallis

Bow Vista Farms Ltd. S. Stenbeck

L. Azevedo R. Berrien M. Janzen C. Malgedhem C. Wallis

Committee for East Route Conservation (CERC) R. Secord

R. Berrien C. Brunner D. Brunner J. Burnham W. Burnham G. Donaldson A. Fisher K. Fisher P. Fisher E. Mulholland D. Nelson J. Senos C. Wallis



R. and L. Conner C. McGarvey

L. Conner R. Conner

Diagonal Group G. Fitch

S. Acteson T. Cline L. Dugdale R. Dugdale K. Friesz G. Harmeson S. McMurray

Foster Family Trust N. Patterson

Industrial Power Consumers Association of Alberta N. Patterson

V. Bellissimo J. Cheng P. Kos

Louson Investment Ltd. and Glen Eagles Investments Ltd. G. Fitch

Mattson Group M. Niven and N. Ramessar

J. Beck V. Bretin S. Buckley R. Levesque T. Mattson K. Schemenauer

The McLaren and Carlson group J. Price and J. Bolton

S. Carlson D. McLaren P. McLaren R. Telford

D. Meier S. FitzGerald

R. and G. Nauta


R. Pearson

Powerex Corp. C. Ferguson L. Manning

G. Dobson-Mack K. Kabiri

Randle group J. Laycraft

R. Berrien F. Randle C. Wallis

P. Robertson G. Fitch and M. Barbero

S. Acteson T. Cline P. Robertson

TD&T Properties D. Leeds

Town of High River K. Mohammed



TransCanada Energy Ltd. S. Kley

Alberta Utilities Commission Commission Panel A. Michaud, Panel chair N. Jamieson, Commission member P. Brennan, Acting Commission member Commission Staff

G Bentivegna (Commission Counsel) T. Chan S. Jiang V. Choy K. Taylor E. Neuhart L. Charest J. Law



Appendix C: Abbreviations

2012LTO AESO’s 2012 Long-Term Outlook Load and

Generation Forecast

2012LTOU AESO 2012 Long-Term Outlook Update

AESO Alberta Electric System Operator

AltaLink AltaLink Management Ltd.

Arrow Arrow Archaeology Limited

Astral Astral Media Radio GP

AUC Alberta Utilities Commission

AUC Rule 007 AUC Rule 007: Applications for Power Plants,

Substations, Transmission Lines, and Industrial System

Designations

AUC Rule 012 AUC Rule 012: Noise Control

Benign Energy Benign Energy Canada II Inc.

CERC Committee for East Route Conservation

CERC route Route option preferred by the CERC group

CO2 Carbon dioxide

Commission Alberta Utilities Commission

dBA decibels A-weighted

EATL Eastern Alberta Transmission Line

EMF electric and magnetic fields

ENMAX ENMAX Power Corporation

EGPI ENMAX Green Power Inc.

ESA environmentally significant area

ESI ENMAX Shepard Inc.

ESR Environmental Specifications and Requirements



EUB Alberta Energy and Utilities Board

FATD Foothills Area Transmission Development

FC2009 AESO’s 2009 Corporate Load Forecast

GHG greenhouse gas

Gleneagles Gleneagles Investments Ltd.

GPS global positioning system

Grid Power Grid Power Development and Design Inc.

ha hectares

HRV Historical Resource Value

HVDC High-voltage direct-current

ICNIRP International Commission on Non-Ionizing Radiation

Protection

ISO Independent System Operator

IPCAA Industrial Power Consumer Association Alberta

km kilometres

kV kilovolt

kV/m Kilovolts per metre

Leq equivalent sound level

Louson Louson Investments Ltd.

m metres

M.D. Municipal district

Meiers Daniel, Julie, Deborah and Michael Meier

mG milli gauss

MVA megavolt ampere

MW megawatt



NID Needs Identification Document

OPP Operating Policies and Procedures

Powerex Powerex Corp.

Powertech Powertech Labs Inc.

SATR Southern Alberta Transmission Reinforcement

Stantec Stantec Consulting Ltd.

TransAlta TransAlta Corporation

TransCanada TransCanada Energy Ltd.

TTC total transfer capability

WATL Western Alberta Transmission Line



Appendix D: Process meeting Decision 2012-360

Decision 2012-360.pdf

(consists of 27 pages)

Decision 2012-360

Alberta Electric System Operator, AltaLink Management Ltd. and ENMAX Power Corporation Foothills Area Transmission Development Process Meeting Decision December 24, 2012


Decision 2012-360: Alberta Electric System Operator, AltaLink Management Ltd.

and ENMAX Power Corporation

Foothills Area Transmission Development - Process Meeting

Applications No. 1608620, No. 1608637, No. 1608642, No. 1608643,

No. 1608649, No. 1608846, No. 1608861 and No. 1608862

Proceeding ID No. 2001

December 24, 2012

Published by

Alberta Utilities Commission

Fifth Avenue Place, Fourth Floor, 425 First Street S.W.

Calgary, Alberta

T2P 3L8

Telephone: 403-592-8845

Fax: 403-592-4406

Website: www.auc.ab.ca

http://www.auc.ab.ca/

AUC Decision 2012-360 (December 24, 2012) • i

Contents

1 Introduction and background .............................................................................................. 1 1.1 Details of the applications .............................................................................................. 1 1.2 Applications filed by the AESO ..................................................................................... 1 1.3 Applications filed by AltaLink....................................................................................... 1 1.4 Application filed by ENMAX ........................................................................................ 2

1.5 Commission’s process .................................................................................................... 3

2 Legislative framework .......................................................................................................... 4 2.1 Assessment of need ........................................................................................................ 4 2.2 Assessment of the facility applications .......................................................................... 5

3 Issues ...................................................................................................................................... 7 3.1 Issues related to the AESO’s applications ..................................................................... 7

3.2 Issues for the facility applications .................................................................................. 8

4 Standing ................................................................................................................................. 9 4.1 Standing for the AESO applications .............................................................................. 9

4.2 Standing for the AltaLink and ENMAX facility applications ..................................... 11 4.2.1 Landowners or residents within 800 metres of a proposed right-of-way ....... 11

4.2.2 Landowners or residents outside of 800 metres .............................................. 11 4.2.3 Landowners with insufficient information...................................................... 12 4.2.4 Landowner groups .......................................................................................... 12

4.2.5 Other parties .................................................................................................... 13

4.2.6 Further written process for standing ............................................................... 13

5 Hearing process, schedule and location ............................................................................ 13 5.1 Hearing process and schedule ...................................................................................... 14

5.2 Written submissions ..................................................................................................... 14 5.3 Hearing location ........................................................................................................... 14

5.4 Staged proceeding ........................................................................................................ 14

Schedule A – Process meeting participants .............................................................................. 17

Schedule B – Persons with standing .......................................................................................... 19

Schedule C – Persons outside of 800 metres ............................................................................. 21

Schedule D – Persons with insufficient information ................................................................ 22

Schedule E – Groups with members that have standing ......................................................... 23

AUC Decision 2012-360 (December 24, 2012) • 1


Calgary, Alberta

Alberta Electric System Operator

AltaLink Management Ltd. and

ENMAX Power Corporation Decision 2012-360

Foothills Area Transmission Development Proceeding ID No. 2001

1 Introduction and background

1.1 Details of the applications

1. In this proceeding the Alberta Utilities Commission (AUC or the Commission) is

considering eight applications. These include: two applications filed by the Alberta Electric

System Operator (AESO), five facility applications filed by AltaLink Management Ltd.

(AltaLink) and one facility application filed by ENMAX Power Corporation (ENMAX).

1.2 Applications filed by the AESO

2. The AESO filed need Application No. 1608620 with the AUC on July 5, 2012,

requesting approval of the needs identification document for the proposed 240-kilovolt (kV)

and 138-kV transmission system expansion in the vicinities of southeast Calgary, Okotoks and

High River.

3. The AESO also filed Application No. 1608846 with the AUC on September 21, 2012,

seeking approval to amend the existing need approval for the Southern Alberta Transmission

Reinforcement (SATR). In the application, the AESO proposed to replace upgrades at the Peigan

substation with construction of the new Windy Flats substation and associated transmission lines

in southern Alberta.

1.3 Applications filed by AltaLink

4. AltaLink filed three facility applications on July 12, 2012, proposing new facilities to

meet the needs identified in the AESO’s need Application No. 1608620. Each project is

described in detail in its respective application.

5. Application No. 1608642 is for the Langdon to Janet project. The major components of

this project are:

a) The construction of approximately 18 kilometres of double-circuit 240-kV transmission

line from Langdon 102S substation to Janet 74S substation.

b) Modifications to some existing transmission lines and/or substations.

c) Modifications to transmissions lines approved in AUC Proceeding ID No. 1229.

d) Modifications to a proposed substation currently being considered in AUC

Proceeding ID No.1045.


2 • AUC Decision 2012-360 (December 24, 2012)

6. Application No. 1608637 is for the North Foothills Transmission Project. The major

components of this project are:

a) The construction of a new 240-kV Foothills 237S substation, located west of Frank Lake.

b) The construction of approximately 51 kilometres of double-circuit 240-kV transmission

line from Foothills 237S substation to ENMAX No. 65 substation.

c) The relocation of some existing transmission lines.

7. Application No. 1608643 is for the Foothills 138-kV Transmission Project. The major


a) The addition of two new 240/138-kV transformers at the Foothills 237S substation.

b) Construction of two new 138-kV transmission lines from Foothills 237S substation to

High River 65S substation and to Okotoks 678S substation including 14 kilometres of

new double-circuit lines.

c) Alterations to some existing transmission line and substations.

8. On September 25, 2012, AltaLink filed two additional facility applications. These

applications are intended to implement the transmission system upgrades proposed in the

AESO’s Application No. 1608846. Each project is described in detail in its respective

application.

9. Application No. 1608861 is for the South Foothill Transmission Project. The major


a) The construction of a new 240-kV Windy Flats 138S substation located southwest of

Fort McLeod in the southwest quarter of Section 17, Township 8, Range 26, west of the

Fourth Meridian.

b) The construction of approximately 120 kilometres of double-circuit 240-kV transmission

line from Windy Flats 138S substation to Foothills 237S substation.

c) Construction of a new series capacitor station SC1 266S.

d) Modifications to some existing transmission lines to facilitate the interconnection of the

Windy Flats substation to the grid.

10. Application No. 1608862 is for the Windy Flats 138-kV Project. The major components

of this project are:

a) The construction of new 138-kV substation equipment at Windy Flats 138S substation.

b) The re-termination of existing 138-kV transmission lines 603L and 608L to Windy

Flats 138S substation from the existing Peigan 59S substation.

1.4 Application filed by ENMAX

11. ENMAX filed facility Application No. 1608649 with the AUC on July 13, 2012,

requesting approval to modify ENMAX No. 25 substation and ENMAX No. 65 substation. The

proposed system reinforcement includes the following major components:

a) Addition of two 240-kV circuit breakers at ENMAX No. 65 substation.



b) Termination of transmission lines 1106L, 1107L and 1109L at ENMAX No. 65

substation.

c) Termination of transmission lines 1109L and 985L at ENMAX No. 25 substation.

d) Disconnection of transmission line 911L at ENMAX No. 65 substation.

1.5 Commission’s process

12. The proposed development, including all of the applications noted above, will be referred

to as the Foothills Area Transmission Development (FATD) project.

13. The Commission issued its notice of applications for the FATD project on

August 28, 2012, after receiving the first five applications in July 2012. The notice was mailed

directly to landowners, residents and other interested parties within the Commission’s

notification zone for the project. In addition, the notice was delivered to all residences and

addresses in the project area by way of a general postal code drop. The notice of applications was

also published in five newspapers in the area of application.

14. Upon receipt of the second application filed by the AESO, as well as the additional two

facility applications filed by AltaLink described above in paragraphs 3, 9 and 10, respectively, in

September 2012 the Commission determined that it would combine these eight applications

under the same proceeding due to the related nature of the Foothills 237S substation in both

filings. The Commission issued its revised notice of applications for the FATD project on

October 19, 2012. The revised notice outlined the date and location for the process meeting.

15. The revised notice was again mailed directly to landowners, residents and other interested

parties within the Commission’s notification zone for the project. In addition, the revised notice

was delivered to all residences and addresses in the project area by way of a general postal code

drop and was also published in 11 area newspapers.

16. The Commission held three information sessions prior to the process meeting for the

FATD project; the first was held at Highwood Memorial Centre in High River, Alberta on

September 24, 2012, the second at the Indus Recreational Centre in Indus, Alberta on

September 25, 2012, and the third at the Claresholm Community Centre in Claresholm, Alberta

on November 13, 2012.

17. The process meeting was held on November 26, 2012, at the Heritage Inn Hotel &

Convention Centre before Commission Member Anne Michaud. Those interested parties who

appeared at the process meeting are set out in Schedule A to this decision.

18. At the process meeting, interested parties were invited to make a brief appearance before

the Commission to identify their interest in the application, their intended scope of participation,

the issues relevant to the application, and to comment on the preliminary process schedule.

19. In reaching the determinations set out in this decision, the Commission has considered

the record of the process meeting, and the submissions and statements of intention to participate

provided by each party. References in this decision to specific parts of the record are intended to

assist the reader in understanding the Commission’s reasoning relating to a particular matter and



should not be taken as an indication that the Commission did not consider all relevant portions of

the record as it relates to that matter.

2 Legislative framework

20. New transmission facilities that do not meet the definition of critical transmission

infrastructure require two separate approvals from the AUC: an approval of the need for

expansion or enhancement to the Alberta Interconnected Electric System pursuant to Section 34

of the Electric Utilities Act, and a permit to construct and licence to operate a transmission

facility pursuant to sections 14 and 15 of the Hydro and Electric Energy Act.

2.1 Assessment of need

21. The AESO, in its capacity as the independent system operator established under the

Electric Utilities Act, is responsible for preparing a needs identification document (NID) and

filing an application for approval of the NID with the AUC pursuant to Section 34 of the Electric

Utilities Act, which states:

34(1) When the Independent System Operator determines that an expansion or

enhancement of the capability of the transmission system is or may be required to meet

the needs of Alberta and is in the public interest, the Independent System Operator must

prepare and submit to the Commission for approval a needs identification document that

(a) describes the constraint or condition affecting the operation or performance of

the transmission system and indicates the means by which or the manner in

which the constraint or condition could be alleviated …

22. Section 38 of the Transmission Regulation sets out the matters to which the Commission

must have regard when considering a needs identification document:

38 When considering whether to approve a needs identification document under

section 34(3) of the Act, the Commission must

(a) have regard for the principle that it is in the public interest to foster

(i) an efficient and competitive generation market,

(ii) a transmission system that is flexible, reliable and efficient and

preserves options for future growth, and

(iii) geographic separation for the purposes of ensuring reliability of the

transmission system and efficient use of land, including the use of

rights of way, corridors or other routes that already contain or provide

for utility or energy infrastructure or the use of new rights of way,

corridors or other routes, notwithstanding that geographic separation

for the purposes of ensuring reliability of the transmission system or

efficient use of land may result in additional costs,

(b) have regard for the following matters when it considers an application for a

transmission facility upgrade or expansion, or operations preparatory to the

construction of a transmission facility, namely, the contribution of the

proposed transmission facility:

(i) to improving transmission system reliability;



(ii) to a robust competitive market;

(iii) to improvements in transmission system efficiency;

(iv) to improvements in operational flexibility;

(v) to maintaining options for long term development of the transmission

system;

(vi) to a project to which section 27 applies to provide system access service,

(c) take into account the transmission system plan filed with the Commission,

(d) take into account the ISO’s responsibilities under any enactment

(e) consider the ISO’s assessment of the need to be correct unless an interested

person satisfies the Commission that

(i) the ISO’s assessment of the need is technically deficient, or

(ii) to approve the needs identification document would not be in the

public interest.

23. Need applications filed by the AESO have generally been organized into two parts. The

first part describes the need for the proposed transmission upgrade. The discussion is based on

load forecasts, generation forecasts and system studies. The second part of a need application

describes the AESO’s preferred technical solution to address the identified need. This includes a

comparative analysis of the various options, based on three general criteria: technical attributes

and functional capability, costs and a high level assessment of land use impacts.

24. In Decision 2004-087,1 the AUC’s predecessor, the Alberta Energy and Utilities Board

(EUB or the Board), described the NID process as follows:

It is the Board’s view that section 34 contemplates a two-stage consideration of an NID.

In the first stage, the Board must determine whether an expansion or enhancement of the

capability of the transmission system is necessary to alleviate constraint, improve

efficiency, or respond to a request for system access…

If it is determined that expansion or enhancement of the system is required to address

constraint, inefficiency, system access requests, or any combination thereof, the Board

must then assess, in the second stage, whether enhancement or expansion measures

proposed by AESO are reasonable and in the public interest.2

25. The Commission has followed this two stage assessment process for all subsequent need

applications.

2.2 Assessment of the facility applications

26. The facility applications for the FATD were filed under sections 14, 15, 18 and 21 of the

Hydro and Electric Energy Act which include, in part:

1 EUB Decision 2004-084: ECNG Limited Partnership – Temporary Exemption from Requirement to Obtain

Board Approval for Compliance Plan in Accordance with Section 30(1) of the Gas Code of Conduct Regulation,

Application No. 1359872, September 29, 2004. 2 EUB Decision 2004-087, pages 13-14.




14(1) No person shall construct a transmission line or any part of a transmission line

unless the person is the holder of a permit issued by the Commission.

…

15 No person shall operate a transmission line unless the person is the holder of a

subsisting licence to operate the transmission line, issued by the Commission.

18(1) The owner or operator of a power plant, transmission line or electric distribution

system shall not connect that power plant, transmission line or electric distribution

system, or cause or permit it to be connected,

(a) to any other power plant, transmission line or electric distribution

system, unless the connection is in accordance with an order under this

section, or

(b) to any industrial system or other service where the connection may

seriously affect the operation of an interconnected electric system or a

communications system as prescribed in the regulations.

…

21(1) No holder of an approval, permit or licence under this Part, and no person who

operated a hydro development, power plant or transmission line on June 1, 1971, shall

discontinue the operation of, or dismantle or remove any works or installations forming

part of, the holder’s or person’s hydro development, power plant or transmission line

unless the holder or person has obtained the authority in writing of the Commission to do

so.

27. Facility applications are prepared by a transmission facility owner assigned by the AESO.

In this case, both AltaLink and ENMAX prepared their respective facility applications based on

their designated service territories. The transmission facility owner files the facility application

with the AUC for consideration. The AUC may approve or deny the application, or approve it

subject to any terms or conditions it prescribes.

28. When deciding upon a transmission facility application, the Commission is directed, by

Section 17 of the Alberta Utilities Commission Act, to consider whether construction and

operation of the proposed transmission facilities is in the public interest, having regard for their

social, economic and environmental effects. The Commission described its public interest

mandate as follows, in Decision 2009-028:3

When considering an application for a transmission line the Commission is obliged by

section 17 of the Alberta Utilities Commission Act to consider whether the proposed

project is in the public interest having regard to its social and economic effects and its

effect on the environment. The Commission recognizes that there is no universal

definition of what comprises the “public interest” and that its meaning cannot be derived

from strictly objective measures. The Commission acknowledges that the ultimate

determination of whether a particular project is in the “public interest” will largely be

dictated by the circumstances of each transmission facility application.

3 Decision 2009-028: AltaLink Management Ltd. - Transmission Line from Pincher Creek to Lethbridge,

Application No. 1521942, Proceeding ID No. 19, March 10, 2009.




In the Commission’s view, assessment of the public interest requires it to balance the

benefits associated with upgrades to the transmission system with the associated impacts,

having regard to the legislative framework for transmission development in Alberta. This

exercise necessarily requires the Commission to weigh impacts that will be experienced

on a provincial basis, such as improved system performance, reliability, and access, with

specific routing impacts upon those individuals or families that reside or own land along

a proposed transmission route as well as other users of the land that may be affected. This

approach is consistent with the EUB’s historical position that the public interest standard

will generally be met by an activity that benefits the segment of the public to which the

legislation is aimed, while at the same time minimizing, or mitigating to an acceptable

degree, the potential adverse impacts on more discrete parts of the community.

3 Issues

29. Interveners identified the issues they intend to pursue in the hearing in their statements of

intention to participate and also in their oral submissions at the process meeting.

3.1 Issues related to the AESO’s applications

30. As noted above, the AESO filed two applications in this proceeding. Application

No. 1608620, is a new application that describes the need for transmission upgrades between

south Calgary and High River (FATD need application). For this application, the issues the

Commission must consider are whether the AESO’s assessment of the need for this project is

technically sufficient, and whether approval of the needs identification document is in the public

interest.

31. The Commission considers the relevant issues for Application No. 1608846, which is an

application by the AESO to amend its existing SATR need approval, to be slightly different. The

amendment proposed by the AESO in this application is not to its assessment of the need to

expand or enhance the transmissions system in southern Alberta. Rather, the AESO is seeking to

amend the technical solution it proposed to address that need. Accordingly, the Commission

finds that neither the AESO’s assessment of the need for transmission reinforcement in southern

Alberta, nor the Commission’s previous approval of that need in Decision 2009-1264 are issues

associated with this application. The issue that this application does raise, however, is whether

the specific amendments proposed by the AESO to its need approval for the Southern Alberta

Transmission Reinforcement are in the public interest. In other words, the Commission will not

be considering whether the the construction of a new 240-kV Windy Flats 138S substation and

its associated transmission lines are required to meet the need, but whether the technical solution

(Windy Flats solution) proposed is the most appropriate technical solution to meet that need.

32. Mr. Gavin Fitch, counsel for the Diagonal Group, Louson Investments Ltd. and Glen

Eagles Investment Ltd., and P. Robertson, submitted that another issue that the Commission

should consider in this proceeding is whether the SATR need approval should be reviewed in its

entirety. He argued that the SATR need approval was based on earlier forecasts of wind power

generation submitted by the AESO, which may no longer be accurate due to recently approved

4 Decision 2009-126: Alberta Electric System Operator – Needs Identification Document Application –

Southern Alberta Transmission System Reinforcement, Application No. 1600862, Proceeding ID No. 171,

September 8, 2009.




transmission development plans. Mr. Fitch proposed that this issue should be considered by the

Commission as a preliminary matter. Many interveners, including the Industrial Power

Consumers Association of Alberta (IPCAA), expressed support for a review of the SATR need

approval as a preliminary matter.

33. A number of interveners also expressed concern regarding the increased cost of SATR.

For these reasons, some interveners recommended that a preliminary hearing is required to assess

the SATR need approval prior to the commencement of the hearing to consider the facility

applications for the Foothills Area Transmission Development project.

34. AltaLink and the AESO both objected to a complete review of the SATR need approval

within the FATD proceeding. AltaLink noted that none of the interveners has brought forward an

application to review the SATR need approval. AltaLink questioned the foundation for such an

application and noted that the SATR need approval was issued following a public hearing with a

substantial record.

35. AltaLink stated that the AESO’s application to amend the SATR need approval to take

into account the new Windy Flats substation does not result in a complete re-opening of the

SATR need approval and emphasized that the amendment proposed by the AESO relates to a

specific technical solution to meet the need for area upgrades approved in the SATR need

approval, not to the need itself.

36. As stated above, the AESO’s application to amend the SATR need approval does not, in

itself, give rise to a complete review of that need approval. Rather, it requires the Commission to

consider only one aspect of that approval, i.e. whether the Windy Flats substation option is the

best option to address the identified need. Further, and as AltaLink and the AESO have pointed

out, the Commission has not received an application to review and vary the SATR need

approval. Accordingly, the Commission finds that continued viability of the SATR need

approval is not an issue that it can or should address in this proceeding at this time.

3.2 Issues for the facility applications

37. Interveners at the process meeting stated that they intend to raise the following issues

with respect to the FATD project:

route selection

human and animal health and safety

property value

impacts on the environment

social and economic impacts of the proposed line

land use and visual impacts

public consultation

impacts on agricultural operations

impacts on existing business operations



38. The Commission finds the issues above to be relevant for consideration at the public

hearing in accordance with the public interest consideration identified under Section 17 of the

Alberta Utilities Commission Act. The Commission does not consider this list to be exhaustive

and does not preclude the consideration of other relevant issues at the hearing.

4 Standing

39. Persons, including individuals and corporations, who may be directly and adversely

affected by the Commission’s decision on the applications are entitled to participate in a public

hearing. These persons are said to have standing to participate in the process.

40. Participants with standing are eligible to apply for cost recovery and will be able to fully

participate in the public hearing, which includes submitting evidence, cross-examining

witnesses, including those of the applicant, and submitting final argument.

41. Standing before the Commission is determined by subsection 9(2) of the Alberta Utilities

Commission Act which states:

(2) If it appears to the Commission that its decision or order on an application may

directly and adversely affect the rights of a person, the Commission shall

(a) give notice of the application in accordance with the Commission rules,

(b) give the person a reasonable opportunity of learning the facts bearing on the

application as presented to the Commission by the applicant and other parties to

the application, and

(c) hold a hearing.

42. In Cheyne v. Alberta (Utilities Commission), the Alberta Court of Appeal characterized

subsection 9(2) as the equivalent of subsection 26(2) of the Energy Resources Conservation

Act and confirmed that the two-part test for standing under subsection 26(2) applies to

subsection 9(2). The Alberta Court of Appeal described that test as follows:5

…s. 26(2) has two branches. First is a legal test, and second is a factual one. The legal

test asks whether the claim right or interest being asserted by the person is one known to

the law. The second branch asks whether the Board has information which shows that the

application before the Board may directly and adversely affect those interest or rights.

The second test is factual.

4.1 Standing for the AESO applications

43. The AESO filed two applications in this proceeding: Application No. 1608620, the

FATD need application and Application No. 1608846, the application to amend the SATR need

approval.

44. It is the Commission’s view that the approval of a need application has the potential to

effect all Alberta electricity ratepayers as they bear the costs of new transmission facilities

approved in conjunction with a NID approval. Need applications also have the potential to affect

those persons that own or occupy lands within those areas (sometimes referred to as swathes) of

land identified by the AESO for the transmission options described in the need application.

5 Cheyne v. Alberta (Utilities Commission), 2009 ABCA 94 (CanLII), at paragraph 13.



When, as in this case, a need application is being considered concurrently with an associated

facility application, it is clear that those that may be potentially affected by the Commission’s

decision on a facility application may also be potentially affected by the associated need

decision.

45. Several interested persons expressed concern with respect to the FATD need application.

Most of the concerns expressed were general in nature and provided little information regarding

the technical sufficiency of the application or whether its approval is in the public interest.

However, given the fact that this need application is so closely related to its companion facility

applications, the Commission finds that those persons who have standing in relation to the

companion facility applications, as outlined below in Section 4.2.1, should also be granted

standing for this need application. Accordingly, persons granted standing with respect to facility

Application No. 1608642: Langdon to Janet project, Application No. 1608637: North Foothills

Transmission project and Application No. 1608643: Foothills138-kV Transmission project, will

be granted standing for the FATD need application.

46. A number of interested parties also expressed concern with the application to amend the

SATR need approval. The Commission is prepared to grant standing with respect to this

application to those parties that have standing in the companion facility applications. Therefore,

persons granted standing, as outlined below in Section 4.2.1, with respect to facility

Application No. 1608861: South Foothill Transmission project and Application No. 1608862:

Windy Flats 138 kV project, will be granted standing for the application to amend the SATR

need approval. However, the Commission considers it important to emphasize that intervener

submissions on this application should address the proposed amendment to the SATR need

approval, i.e. the substitution of the Windy Flats solution for the previously approved Peigan

solution, and should not address the underlying need that the solution is designed to address.

47. The Diagonal group, Louson Investment Ltd., Glen Eagles Investment Ltd.,

Phyllis Robertson, the Mattson group, the Randle group and Reece and Richard Pearson

expressed general concerns about the FATD need application and the application to amend the

SATR need approval. The Commission is prepared to grant these groups standing with respect to

both AESO applications.

48. Benign Energy II Inc., Powerex Corp. and TransCanada Energy Ltd. expressed concerns

that their interests may be potentially impacted by the AESO applications to the extent that the

assessment of the proposed transmission system expansion may affect their generation

opportunities in the region. The Commission is of the view that its decision with respect to either

of the AESO applications has the potential to impact the interests of these parties. Accordingly,

the Commission grants standing to Benign Energy II Inc., Powerex Corp. and TransCanada

Energy Ltd., with respect to both applications filed by the AESO.

49. In its statement of intention to participate, IPCAA did not specify which of the AESO’s

applications it was objecting to. Further, IPCAA’s objection appears to be predicated upon its

concerns about the continued viability of the existing SATR need approval. As stated earlier, the

Commission is of the view that the viability of the SATR need approval is not an issue raised in

this proceeding at this time. Accordingly, the Commission cannot grant standing to IPCAA

based on the information it has filed to date. Should IPCAA wish to further pursue standing with

respect to some or all of the applications being considered in this proceeding, it must file

additional information with the Commission specifying which applications it is objecting to and



describing the grounds for those objections. Such information must be filed by no later than

January 21, 2013.

50. A number of persons without standing in any of the five facility applications, as outlined

below in Section 4.2.2, also expressed concerns or objected to one or both of the AESO’s

applications. These persons did not indicate what aspect of the AESO’s applications it was

objecting to. Therefore, the Commission cannot grant standing to persons for either of these two

applications where these persons were not given standing with respect to any of the five facility

applications. However, as stated above in paragraph 44, the Commission notes that the approval

of the FATD need application as well as the application to amend the SATR need approval may

affect all Alberta electricity rate-payers because they bear the costs of new transmission

facilities. Therefore, should these persons wish to pursue standing with respect to the FATD need

application or the application to amend the SATR need approval, they must file additional

information with the Commission specifying which application they are objecting to and

describing the grounds for those objections. This information must be filed by no later than

January 21, 2013.

4.2 Standing for the AltaLink and ENMAX facility applications

51. In this proceeding the Commission has decided to grant standing to persons that own or

reside on property that is within 800 metres of a transmission facility (transmission line or

substation)6 proposed in the facility applications filed by AltaLink and ENMAX, subject to there

not being any objections to that standing from another party. The Commission also finds that

persons that own or reside on property located within 800 metres of the transmission facility are

local interveners, who qualify for intervener funding under the Alberta Utilities Commission Act,

subject to any objections from another party.

52. If there is an objection to a person’s standing to participate or status as a local intervener,

the Commission will make a decision on whether the person has standing or qualifies for local

intervener costs based on the facts and evidence presented by both parties. Any persons that own

property or reside on property located outside the 800-metre zone may apply to the Commission

for standing or for local intervener status. The Commission will make a determination on

standing or local intervener status on a case-by-case basis by determining whether that person

may be directly and adversely affected by any one of the applications.

4.2.1 Landowners or residents within 800 metres of a proposed right-of-way

53. As stated above, the Commission finds that persons that own or reside on property

within 800 metres of the transmission facilities proposed in the AltaLink and ENMAX

applications have standing to participate in this proceeding pursuant to Section 9 of the

Alberta Utilities Commission Act. Persons falling into this category are set out in Schedule B to

this decision.

4.2.2 Landowners or residents outside of 800 metres

54. At this time, persons do not have standing if they own or reside on property that is more

than 800 metres from either the preferred or alternate right-of-way edge. Based on the record, it

is not clear to the Commission how these individuals may be directly and adversely affected by

6 For transmission lines the 800 metres has been measured from the edge of the right-of-way. For substations the

800 metres is measured from the substation boundary.



the Commission’s decision on the applications. Accordingly, the Commission cannot grant

standing to these participants at this time, however, participants can apply to the Commission for

standing by demonstrating how they may be directly and adversely affected as outlined in

Section 4.2.6 below. Persons that fall into this category are set out in Schedule C to this decision.

55. These persons may also participate in this proceeding without a further ruling on

standing, by joining one of the groups identified in Section 4.2.4, subject to the limitations

described in paragraph 62 of that section.

4.2.3 Landowners with insufficient information

56. Some persons who filed statements of intent to participate in the proceeding did not

indicate whether they own or reside on land that is within 800 metres of the right-of-way edge.

The Commission has insufficient information to determine whether these parties may be directly

or adversely affected by the Commission’s decision on the FATD applications. Accordingly, the

Commission cannot grant standing to these participants at this time. These persons are set out in

Schedule D to this decision.

57. Any person whose name appears in Schedule D who wishes to assert standing should

provide their legal land description and state whether they reside upon or own land within

800 metres of the edge of a preferred or alternate right-of-way when they file supplemental

information with the Commission even though they may have indicated, in their statement of

intent to participate, where their land is located (i.e. legal land location).

58. These persons may also participate in this proceeding without a further ruling on

standing, by joining one of the groups identified in Section 4.2.4, subject to the limitations

described in paragraph 62 of that section.

59. With respect to Benign Energy II Inc., Powerex Corp. and TransCanada Energy Ltd., the

Commission has insufficient information to determine whether these parties may be directly or

adversely affected by the Commission’s decision on any of the facility applications in this

proceeding. Accordingly, the Commission cannot grant standing to these participants at this

time. Should these parties wish to pursue standing with respect to any of the facility applications,

they must file additional information with the Commission describing how their rights may be

directly and adversely affected by the Commission’s decision on any of the facility applications.

4.2.4 Landowner groups

60. Groups of individuals that are comprised of one or more persons with standing and

persons who do not have standing may, at the discretion of the Commission, participate in this

proceeding. The basis for these groups’ participation is that one or more of its members have

standing. Groups that fall into this category are set out in Schedule E to this decision.

61. It is the practice of the Commission to allow such groups to participate in Commission

proceedings. However, please note that individuals who do not have standing on an individual

basis, but belong to a group that does have standing, are not eligible to apply for the recovery of

costs of their individual participation. For example, group members without standing (i.e. who

reside more than 800 metres from the edge of a proposed right-of-way) will not be eligible to

receive honoraria and reimbursement for out-of-pocket expenses incurred, nor will they be able

to appear before the Commission to put their individual interests forward to any extent greater



than that of an individual without standing who may participate by filing a written submission or

making a brief oral statement.

62. The Commission requests that individuals wishing to participate in this proceeding, over

and above their participation as members of a group, identify the scope of their individual

participation.

4.2.5 Other parties

63. The Commission continues to receive statements of intention to participate from

interested parties. The Commission will continue to process these statements as they are

received.

4.2.6 Further written process for standing

64. Persons listed on schedules C and D must provide further information to the Commission

if they wish to request standing in this proceeding. Parties must explain to the Commission what

rights they are claiming and how those rights may be directly and adversely affected by the

Commission’s decision on the application and, for those persons shown in Schedule D,

information regarding their land location. Until the Commission receives this further

information, parties listed in schedules C and D do not have standing in this proceeding but will

still be eligible to submit a written statement or make a brief oral statement at the formal hearing.

65. The Commission has established the following process schedule to receive requests for

standing that contain the information mentioned above:

1) Written submissions requesting standing must be submitted to the Commission on or

before January 21, 2013, to obtain standing in this proceeding.

2) The applicants may respond in writing to the submissions received on or before

January 28, 2013.

5 Hearing process, schedule and location

66. The Commission included a draft process schedule in its revised notice and asked

interested parties to comment on that schedule at the process meeting.

67. The majority of interveners stated that May 13, 2012, was a reasonable start date for the

formal hearing. No particular concerns were raised on the tentative process steps.

68. Many interveners were in favor of the phased hearing process and hearing locations close

to the project area. Several locations were proposed by interveners for the phased hearing,

including High River, Calgary, Okotoks, Claresholm, Fort MacLeod and Pincher Creek.



5.1 Hearing process and schedule

69. In setting the schedule for the hearing, the Commission is mindful that the process and

schedule must allow all participants sufficient time to prepare and review evidence or reply

evidence, draft and respond to information requests, and prepare witnesses for the formal

hearing. The Commission is of the view that the following schedule establishes a process that is

fair to all participants and includes all of the contemplated process steps

Date Process step

February 8, 2013 Deadline for intervener information requests to applicants

March 1, 2013 Information responses due from the applicants

March 22, 2013 Intervener evidence due

April 5, 2013 Deadline for information requests to interveners

April 19 , 2013 Information responses due from interveners

May 3, 2013 Reply evidence due from the applicants

May 14, 2013 Public hearing to commence

5.2 Written submissions

70. Parties who want to have an opportunity to express their views on the FATD project but

who do not wish to participate in the formal hearing may file a written submission with the

Commission or give a brief oral submission to the Commission at the public hearing. Written

submissions may be filed at any time up until the close of the evidentiary portion of the hearing.

As the Commission cannot predict when that might occur, it encourages parties to file their

written submissions prior to March 22, 2013.

5.3 Hearing location

71. In selecting the locations for the hearing, the Commission concurs with the interveners

that a phased hearing process is appropriate and convenient to consider the projects which

involve a large geographic area and diverse groups of interveners. It is the intention of the

Commission to first consider the applicants’ evidence in a location that is central to all the

participants and then consider interveners’ evidence at locations close to the interveners’

properties or residences.

72. The Commission has reviewed the venues in all the locations suggested by the

interveners and noticed that there is no suitable venue available in either Claresholm,

Fort McLeod, or in the south Calgary/Okotoks area between May and June 2013. At this time,

the Commission has determined that the hearing will commence on May 14, 2013, at the High

River Heritage Inn & Convention Centre, located at 1104 11 Street S.E., High River, Alberta.

The dates and venues for the remainder of the hearing will be determined at a later date. Further

details of the hearing dates and locations will be advised in the notice of hearing.

5.4 Staged proceeding

73. Given the scope of this proceeding, some interveners expressed concern that this

proceeding may be complicated in nature and thought that it would not be easy for them to fully

participate.



74. The Commission is of the view that because the Foothills 237S substation is under

consideration in both the North Foothills Transmission Project and the South Foothills

Transmission Project, it would not be plausible to consider the additional facility applications in

a separate proceeding without causing prejudice to potentially affected stakeholders related to

applications in the other proceeding. The Commission observed that the proposed phased hearing

process was supported by interveners.

Dated on December 24, 2012.



Anne Michaud

Commission Member



Schedule A – Process meeting participants

Name of Organization (Abbreviation) Counsel or Representative

Alberta Electric System Operator J. Cusano

AltaLink Management Ltd. P. Feldberg

ENMAX Power Corporation

D. Wood

Diagonal Group

G. Fitch

Louson Investment Ltd. and Glen Eagles Investments Ltd.

G. Fitch

P. Robertson

G. Fitch

Bow Vista Farms Ltd.

S. Stenbeck

Mudry family and McHugh family

S. Stenbeck

T. and F. Thomson and Western Sky Land Trust

S. Stenbeck

Mattson Group

N. Ramessar on behalf of M. Niven

Randle Group J. Laycraft


Committee for East Route Conservation (CERC)

R. Secord

D. and L. Conner D. Van Moorsel

C. Hansen

The McLaren and Carlson group

J. Price and J. Walton



Name of Organization (Abbreviation) Counsel or Representative

Town of High River

K. Mohammed

ENMAX Green Power

R. McKee

TransCanada Energy Limited

R. Stevens

Benign Energy Canada II Inc.

A. Kettleson

Astral Media Radio

B. Stovold

R. and G. Nauta

H. Jackson

M. Chehabeddine

R. Miller

V. and P. Bretin

TD&T Properties

D. Leeds

Alberta Utilities Commission Commission Panel A. Michaud, Commissioner Commission Staff

JP Mousseau (Commission Counsel) M. Ali (Commission Counsel) T. Chan S. Jiang K. Taylor L. Charest



Schedule B – Persons with standing

Application No. 1608642: Langdon to Janet Transmission Project

197833 Alberta Ltd. Glen Eagles Investments Limited

590140 Alberta Limited / Simonelli, Carlo Joneja, Baldev

Beck, John Kyle, Janet

Bretin, Patricia Louson Investments Inc.

Bretin, Vern Mattson Group

Buckley, Sheila McLaren and Carlson Group

Camrock Capital Partners GP (40) Ltd. Steele, Vanessa

Application No. 1608637: North Foothills Transmission Project

Astral Media Radio MacLellan, Debra

Bow Vista Farms Ltd. Maldeghem, Charles

Chehabeddine, Afif Miller, Richard

Chehabeddine, Mustapha Moore, Wayne

Coonfer, Douglas Pearson, Reece

Diagonal Group Pearson, Richard

Hage, Abdul Randle Group

Hage, Mohamed Taplin, James L.

Jackson, Harvey E. Thomson, Frederick

Kaaki, Faten Thomson, Terry

Klatzel-Mudry, Louise / McHugh Family Western Sky Land Trust



Application No. 1608643: Foothills 138-kV Transmission Project

B.F.W. Holdings (2006) Ltd. Nauta, Gerry

Chehabeddine, Afif Nuata, Randy

Chehabeddine, Mustapha Pope, David

ENMAX Green Power Inc. Randle Group

ENMAX Shepard Inc. Robertson, Phyllis

Kaaki, Faten Town of High River

Nauta, Dan

Application No. 1608861: South Foothills Transmission Project

Committee for East Route Conservation Paradis, Jason

Conner, Laurie Paradis, Sabrina

Conner, Ron Randle Group

Markle, Collin R. Volker Stevin / McNally Contractors (2011) Ltd.

Application No. 1608862: Windy Flats 138-kV Transmission Project

Conner, Laurie Conner, Ron

Application No. 1608649: ENMAX application for modifications to substations

ENMAX Green Power Inc. ENMAX Shepard Inc.



Schedule C – Persons outside of 800 metres

Arca, Mavito

Fowler, F.L. & E.

Shutiak, James

TDT Properties Ltd.7

7 TDT Properties Ltd. is within 800 metres of another existing line. It does not appear to the Commission that it is

within 800 metres of any of the proposed FATD transmission line projects.



Schedule D – Persons with insufficient information

Benign Energy II Inc.

Brunner, Linda

Dawson, Tom

Jackson, Harvey E.8

Jeske, Jan

Lozeman, Fred

Powerex Corp.

Scandinadian Developments Consultants (Charles Hansen)9

Schnarr, Bill

TransCanada Energy Ltd.

Vandervalk, Marvin

Wallace, Todd

8 Mr. Havey E. Jackson referred to Application No.1608861 in the process meeting. However, based on the LSD

provided, it appears that his interests may be affected by Application No.1608637. 9 Mr. Hansen appeared at the process meeting and stated that he had discussed the matter with persons within

800 metres. However, it is not clear to the Commission that he owns or resides upon lands within 800 metres or

if he is representing persons who meet that criteria.



Schedule E – Groups with members that have standing

GROUP

Diagonal Group

Committee for East Route Conservation

Mattson Group

McLaren and Carlson Group

Randle Group

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