COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION KENTUCKY UTILITIES COMPANY D/B/A OLD DOMINION POWER COMPANY For approval and certification of electric transmission facilities under Va. Code § 56-46.1 and the Utility Facilities Act, Va. Code § 56- 265.1 et seq. ) ) ) ) ) ) CASE NO. PUR-2020-00XXX DIRECT TESTIMONY OF KYLE W. BURNS DIRECTOR TRANSMISSION ENGINEERING AND CONSTRUCTION KENTUCKY UTILITIES COMPANY D/B/A OLD DOMINION POWER COMPANY Filed: June 2, 2020
Transcript
COMMONWEALTH OF VIRGINIA
STATE CORPORATION COMMISSION
KENTUCKY UTILITIES COMPANY
D/B/A OLD DOMINION POWER COMPANY
For approval and certification of electric
transmission facilities under Va. Code § 56-46.1
and the Utility Facilities Act, Va. Code § 56-
265.1 et seq.
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CASE NO. PUR-2020-00XXX
DIRECT TESTIMONY OF
KYLE W. BURNS
DIRECTOR TRANSMISSION ENGINEERING AND CONSTRUCTION
KENTUCKY UTILITIES COMPANY
D/B/A OLD DOMINION POWER COMPANY
Filed: June 2, 2020
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INTRODUCTION 1
Q. Please state your name, position, and business address. 2
A. My name is Kyle W. Burns. I am Director Transmission Engineering and Construction for 3
LG&E and KU Services Company, which provides service to Louisville Gas & Electric 4
Company and Kentucky Utilities Company (“the Companies”). KU does business as Old 5
Dominion Power Company (“KU-ODP”) in the Commonwealth of Virginia. My business 6
address is 220 West Main Street, Louisville, Kentucky 40202. A statement of my 7
education and work experience is attached to this testimony as Appendix A. 8
Q. What are your job responsibilities for KU-ODP? 9
A. I oversee and direct strategic engineering and construction projects for LG&E and KU’s 10
entire electric transmission system, which is operated as a single interconnected system 11
covering more than 5,400 circuit miles in Kentucky and approximately 200 circuit miles 12
in Virginia. 13
Q. What is the purpose of your testimony? 14
A. The purpose of my testimony is to describe, support, and provide operational context to 15
KU-ODP’s application for approval of the transmission structure replacement project set 16
forth in this application. 17
Q. Are you sponsoring any exhibits? 18
A. Yes. I am sponsoring KU-ODP’s responses to the State Corporation Commission’s 19
Guidelines for Transmission Line Applications Filed Under Title 56 of the Code of 20
Virginia, published August 10, 2017 (“Guidelines”), and the attachments thereto, all of 21
which are set forth in the Appendix to the application herein. I am also sponsoring the 22
following exhibits attached to my testimony: 23
Exhibit KWB-1 Map of KU-ODP Transmission Lines in Virginia 24
2
Exhibit KWB-2 Map of Lines for Structure Replacements. 1
BACKGROUND 2
Q. Describe KU-ODP’s operations in Virginia. 3
A. KU-ODP provides electric service to approximately 28,000 customers in five Virginia 4
counties: Wise, Lee, Russell, Scott, and Dickenson. KU-ODP owns and maintains 5
hundreds of line miles of transmission and distribution infrastructure in these five counties. 6
A map showing KU-ODP’s transmission lines in Virginia is attached to my testimony as 7
Exhibit KWB-1. KU-ODP does not own or operate any electric generating facilities in 8
Virginia. 9
KU-ODP’s territory in Virginia covers approximately 450 noncontiguous square 10
miles, almost all of which is located in rural, mountainous terrain. KU-ODP operates a 11
service center and business office in Norton and a business office in Pennington Gap, 12
Virginia. While KU-ODP serves customers in five counties in Virginia, most of its 13
customers are located in Wise County. 14
Q. How does KU-ODP plan for maintenance of infrastructure in Virginia? 15
A. The Companies’ transmission and distribution assets, including KU-ODP’s assets in 16
Virginia, are jointly planned and operated. In total, these assets serve nearly a million 17
electricity customers. Virginia customers being served by KU-ODP’s operations therefore 18
benefit from economies of scale created by joint system planning across LG&E and KU’s 19
entire service territory. This planning ensures that investments are made where they are 20
most needed, regardless of territory or system ownership. 21
Q. How does KU-ODP identify transmission assets in need of replacement? 22
A. Inspection and replacement of transmission infrastructure has been a point of emphasis for 23
the Companies over the past five-plus years as they have faced challenges with aging 24
3
assets, often past their useful life, and increasing customer expectations for reliability of 1
service. In 2017, KU-ODP filed with the Commission LG&E and KU’s Transmission 2
System Improvement Plan (“TSIP”) – a comprehensive plan to minimize outage 3
occurrence and duration and improve overall reliability of service to customers.1 A major 4
component of this plan is inspection and, where required, replacement of defective line 5
equipment, including replacement of deteriorated wood poles and structures with steel. 6
The TSIP has been implemented throughout LG&E and KU’s entire service territory, 7
resulting in $349 million in capital investment for transmission asset replacements over the 8
past three years. The structure replacements proposed in this application have resulted 9
from the Companies’ system-wide efforts to identify and replace aging transmission 10
infrastructure to ensure system integrity and the reliability of its transmission system now 11
and long into the future. 12
TRANSMISSION LINE STRUCTURE REPLACEMENT PROJECT 13
Q. Describe the project for which the Company seeks approval with its application. 14
A. KU-ODP seeks a certificate of public convenience and necessity to replace certain wood 15
poles with galvanized steel structures on three separate 161kV transmission circuits in its 16
existing service territory in Lee and Wise Counties in western Virginia. This is not a 17
project to completely demolish and rebuild transmission lines. Approximately half of the 18
structures on the affected circuits in Virginia are proposed to be replaced. No substations 19
or other transmission infrastructure are proposed to be replaced as part of the project and 20
no conductor replacements are contemplated. Specifically, KU-ODP proposes to complete 21
the following on its existing transmission lines: 22
1 Application of Kentucky Utilities Company d/b/a Old Dominion Power for an Adjustment of Electric Base Rates,
Case No. PUR-2017-00106, Direct Testimony of Lonnie E. Bellar, Exhibit LEB-2 (Sept. 29, 2017).
4
• Dorchester to Arnold Line, 14.4 miles, remove and replace 27 wood structures with 1
Q. Does the Company propose any new rights-of way with this project? 7
A. No. The proposed structure replacements will be completed entirely within the Company’s 8
existing rights-of-way for these transmission lines. 9
Q. Will structure replacements on the affected lines be occurring only in Virginia? 10
A. Only the Dorchester to Pocket North line is located completely within Virginia. Significant 11
portions of the Harlan Wye to Pocket North and Dorchester to Arnold lines are located in 12
Kentucky. LG&E and KU will also be replacing structures on these two lines in Kentucky. 13
A map showing the affected lines is attached as Exhibit KWB-2 to my testimony. 14
Q. Will there be a parallel proceeding in Kentucky for the structure replacements being 15
performed there for the two affected lines? 16
A. No. Kentucky and Virginia have different regulatory requirements. Because replacement 17
or upgrading of any existing electric transmission system is considered to be an ordinary 18
extension in the usual course of business a CPCN is not required for this project in 19
Kentucky. KU also filed the TSIP with the Kentucky Commission in connection with its 20
base rate cases.2 21
2 Application of Kentucky Utilities Company for an Adjustment of its Electric Rates and for Certificates of Public Convenience and Necessity, Case No. 2016-00370, Direct Testimony of Paul W. Thompson, at 25-28 and Exhibit
PWT-2 (Ky. PSC Nov. 23, 2016).
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Q. Why are the structure replacements required? 1
A. As the transmission plan discussed above contemplates, replacement of transmission 2
equipment, including support structures, is generally required when equipment reaches the 3
end of its useful life. Portions of these transmission lines have been in place in the same 4
right-of-way beginning in the early 1960s, with the Dorchester-Arnold transmission right-5
of-way being the newest at roughly 45 years old. 6
Line replacements are essential to ensure the reliability of its electric service to 7
customers. As part of system-wide inspections throughout the KU and LG&E services 8
territory, the Companies performed detailed inspections on these lines during 2018. Pole 9
inspections are performed by trained technicians and include detailed visual observation, 10
sounding, and, when possible, climbing of the poles to observe their condition. The 11
Company evaluates each defect and assesses its impact to determine whether a wood 12
structure has deteriorated to the point where it must be replaced, or whether it can be 13
repaired. Criteria widely used and accepted as standard for wood pole inspections in the 14
electric utility industry are applied KU-ODP when making these decisions. 15
Much of the deterioration of these structures is due to general weathering, insect 16
activity, woodpecker activity, rotting near the base, splitting, bowing, o r other normal 17
environmental conditions commonly experienced with wood structures. The Company 18
proposes in this project to replace only those structures that qualify for replacement and 19
cannot be repaired under the inspection criteria. Structures that exhibited some signs of 20
deterioration upon inspection but which are structurally sound and can be maintained that 21
way through treatment will be repaired instead of replaced. 22
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Q. Can the Company simply decommission the transmission lines instead of replacing 1
structures? 2
A. No. In May 2019, the Company completed a line asset study on the Dorchester-Arnold, 3
Dorchester-Pocket North, and Harlan Wye to Pocket North lines to determine whether each 4
line was critical to meeting transmission planning performance requirements specified by 5
North American Reliability Electric Reliability Corporation (“NERC”) reliability 6
standards and LG&E/KU planning guidelines. That study is attached to Section I (A) of 7
the Appendix. The Company’s analysis concluded that for each of these three lines, flow 8
violations could occur if the line was not in service during peak periods, and thus each was 9
critical to meeting NERC’s TPL-001-4 reliability standard and internal guidelines. 10
Q. Why is the Company proposing to use galvanized steel for the replacement 11
structures? 12
A. Steel structures have a much longer expected life than wood and are much more resistant 13
to elements that often require replacement of wood structures. Furthermore, steel 14
structures are more resilient to hazards and severe weather events and do not deteriorate 15
like wood poles. Using steel will minimize the need to replace these structures compared 16
to wood or other alternatives. 17
Q. How did the Company select the structure type and configuration for the replacement 18
structures? 19
A. Attachment II (B)(3) in the Appendix details the structure type and configuration for all 20
proposed replacements. In general, the structure type and configuration were selected to 21
match the existing configuration so that the same conductor configurations could be used. 22
This approach eliminates the need for a complete demolition and rebuild of the lines and 23
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minimizes cost. No conductor replacements are proposed as part of this project. All 1
replacement structures have been designed to stay fully within the existing rights-of-way. 2
Q. How do the heights of the proposed structures compare to the height of the existing 3
structures? 4
A. In planning for these replacements, structure heights were kept to the minimum necessary 5
to meet the engineering needs of the project and comply with National Electric Safety Code 6
(NESC) standards for conductor to ground clearance. Most of the replacement structures 7
are comparable in height to the structures they are replacing, and in some cases they are 8
lower. Where proposed replacement structures are taller than the existing structures, the 9
expected increase in height is modest – generally ten percent or less over existing structure 10
height. None of the proposed replacement structures are expected to exceed existing 11
structure height by twenty percent or more. 12
Q. Has the Company considered the impact of the project on scenic, environmental, and 13
historic features? 14
A. Yes. These transmission lines are not new by any measure. The lines have been in place 15
for decades. In fact, these transmission lines have been in place in the same rights-of-way 16
from 45 to nearly 60 years. Nevertheless, consistent with Section III of the Commission’s 17
Guidelines, the Company has worked with its consultant, Arcadis, to provide a 18
comprehensive analysis of the project’s impact on scenic, environmental and historic 19
features and areas near the project and the right-of-way. That analysis is set forth in detail 20
in Section III of the Appendix and the DEQ Supplement attached thereto. The analysis 21
concludes that the impact of the proposed structure replacements on nearby scenic, 22
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environmental, and historic resources will be temporary in nature or, to the extent changes 1
are permanent, will have minimal impact on these resources. 2
Q. What are the estimated capital costs of the project? 3
A. The estimated conceptual costs of this project as proposed are as follows: 4
Dorchester-Arnold Line - $3.2 million (27 replacements) 5
Dorchester-Pocket North Line - $10.7 million (89 replacements) 6
Harlan Wye-Pocket North Line - $0.9 million (5 replacements). 7
Q. What is the expected in-service date for the project? 8
A. If the Company’s application is approved, the expected in -service date of the structure 9
replacements on the Dorchester-Arnold line is July 30, 2021. The expected in-service date 10
of the Dorchester-Pocket North line is October 28, 2022. The expected in-service date for 11
the replacements on the Harlan Wye-Pocket North line is September 2021. 12
Q. Do you have a recommendation? 13
A. Yes, I recommend that the Company’s application for a certificate of public convenience 14
and necessity for the proposed transmission structure replacements be approved and that a 15
certificate be granted. This project is needed to continue KU-ODP’s reliable electric 16
service in Virginia and for the long-term overall health of the transmission system. The 17
project has been carefully planned to manage cost and to minimize the impact of structure 18
replacements on neighboring properties and environmental and historic resources. 19
Q. Does this conclude your testimony? 20
A. Yes.21
APPENDIX A
Kyle W. Burns
Director, Transmission Engineering and Construction LG&E and KU Services Company
220 West Main Street Louisville, KY 40202
History of Positions:
Manager, Transmission Substation Construction and Maintenance (2018-2019) Manager, Generation Engineering (2011-2018) Supervisor, Instrument/Electrical and Mechanical Maintenance (2007-2011)
Supervisor, Production (2005-2007) Business Continuity Coordinator (2004-2005) Project Engineer (2002-2004) Sourcing Analyst (2001-2002)
Compensation Analyst (2000-2001)
Professional Membership, Boards, Civic Activities & Achievements:
Past Engineering Council Chair, LG&E/KU
Past Vice President Administration – National Black MBA Association YMCA Safe Place – Ignite Louisville Partnership
Elizabethtown Independent Schools Project Lead the Way Partnership Council
Education:
Bachelor of Science in Electrical Engineering – University of Louisville (1998) Master of Business Administration – University of Louisville (2000)
Lee County
Wise County
Scott County
Russell County
NortonCity
ARNOLD| 161 kV |
HARLAN WYE| 161 kV |
DORCHESTER| 161 kV |
POCKET NORTH| 161 kV |
VSCC Pole and Structure Replacement CPCN Application
¯
0 20 4010 Miles
Lee Scott
WiseRussell
"/ StationCounty Boudary
Service TerritoryODPPowell Valley
Transmission Line69 kV138 kV161 kV
345 kV500 kVNo Voltage
KU-ODP TRANSMISSION SYSTEM OVERVIEWExhibit KWB-1
ARNOLD161 kV
DORCHESTER161 kV
HARLANWYE161 kV
POCKETNORTH161 kV
UV38
UV1926
UV699
UV160
UV65
UV68
UV221
UV510
UV624
UV606
UV610
UV522
UV640
UV987
UV619
UV880
UV463
UV624£¤119
£¤119
£¤58
£¤421
£¤421£¤421
£¤58
£¤58
£¤421
£¤23
£¤23
£¤421
£¤119
VSCC Pole and Structure Replacement CPCN Application "/ StationKY-VA Border
