DEPARTMENT OF PLANNING AND ZONING
308 Byers Ave · P.O. Box 239 · Hot Sulphur Springs · Colorado · 80451
970-725-3347 Ext 129 or Fax 970-725-3303

September 14, 2007

Mr. Rodney D. Jones
NEPA Document Manager
Western Area Power Administration,
Rocky Mountain Region
5555 E. Crossroads Blvd.
Loveland, CO 80539-3003

Re: Western Area Power Administration (Western), Granby Pumping Plant to Windy Gap Transmission Line Rebuild Project

Dear Mr. Jones,

Grand County appreciates the opportunity to provide comment on the above referenced project. Considering this proposed project is located entirely within Grand County, the County would appreciate consideration as a cooperating agency on this project. We have expertise regarding the project and believe that it is connected to the direction in with Senate Document 80, in which we are named specifically.

It is our understanding that the project will remove about 12 miles of existing 69-kV transmission line followed by the construction and operation of approximately 12 miles of new 138/138-kV double circuit transmission line which would be operated at 69/138-kV and the addition of a second power transformer. The existing system is an 'H-frame' structure approximately 60 feet high; they will be replaced with a single tower structure of a height up to 120 feet high. Modifications will be needed at both the Granby Pumping Plant Switchyard and the Windy Gap Substation to accommodate the second line. The latter facility will be a joint project with Western, Tri-State General, Mountain Parks Electric, and the Northern Water Conservancy District.

Grand County has concerns regarding the direct consequences of the proposed installation with overall impact and impairment to visual resources and wildlife in the area within and adjacent to the Arapaho National Recreation Area. The Arapaho National Recreation Area (ANRA) is comprised of 36,000 acres located within the upper reaches of the Colorado River Valley. Established by Congress in 1978, the enabling legislation, Pub. L. 95-450 states that the area was established not only due to the high quality recreation, but to protect and conserve the scenic and historic values.

We support that objective to improve system reliability and understand the benefits to the citizens of Grand County, however, we do believe that there are elements of the project that are inconsistent with criteria in the Three Lakes Design Review Area (Section 14.5) of the Grand County Zoning Regulations. We hope that these comments will articulate our concerns, and that we can work with Western to examine other options in order to determine how these concerns can be mitigated.

MAINTAINING OPEN SPACE AND WILDLIFE HABITAT
We have concerns that this proposal may have an adverse impact on the wildlife habitat, particularly with critical winter range habitat and migration routes. It is our understanding that you have acquired the services of two environmental contractors, EDAW, Inc. of Fort Collins and RMC, Inc. of Lakewood to evaluate the natural human and cultural resources that could potentially be affected by the proposed project. Upon completion of this analysis, Grand County recommends that Western shall incorporate mitigation that will minimize side effects such as wildlife habitat disruption in their final proposal.

PROTECTING THE COUNTY'S RURAL CHARACTER WHILE MAINTAINING THE ECONOMY
Reliable, cost-effective electrical services are a basic need for the citizen's of Grand County, and Mountain Parks Electric is responsible for this service. Mountain Parks Electric will receive a direct benefit from Western's proposed upgrade. We appreciate their ability to provide cost effective, dependable electrical service to the varied topography, remote areas and diverse ecosystems within Grand County. We also commend their proactive outlook to identify current and future service needs of the community, and to identify appropriate capital improvements to meet those needs.

IMPROVING THE QUALITY OF NEW DEVELOPMENT AND MINIMIZING ITS IMPACT
We acknowledge that system reliability will be improved with the looped transmission. The delivery of reliable, cost-effective electrical service will support the needs of existing and future customers in an area extending from Rocky Mountain National Park, South to the YMCA Snow Mountain Ranch, between Byers Canyon and the Continental Divide.

During previous review of this request, Grand County staff received several comments from concerned citizens regarding the question of underground installation and why it was not evaluated. Staff recommended that Western consider underground installation, and is please to see these options on the recent materials provided during the August 30, 2007 public scoping meeting.

With regards to the proposal using above ground facilities, we encourage Western to limit site disturbance and vegetation clearing that is visible from residential developments and public roads by means of minimizing clear-cut widths and other established landscape techniques, such as a revegetation plan. The proposed option of a single pole tower does not minimize this impact.

GRAND COUNTY ZONING REGULATIONS ­ SECTION 14.5 THREE LAKES DESIGN REVIEW
The Three Lakes Design Criteria was developed to support the enabling legislation of the Arapaho National Recreation Area. It is the intent of these standards to foster sensitive and creative solutions for facilities located in this area. It is utilized in review for all projects located within the area. We encourage Western to fully analyze the impact of the proposed tower structures on the landscape within the Three Lakes Area. The key element of design criteria in this area is a harmonious and appropriate design. The proposed tower structures at 120 feet, are intrusive to the overall panoramic mountain and scenic view shed and do not easily blend into the natural, surrounding landscape.

The Grand County Zoning Regulations require electric utilities to minimize the visual degradation of the landscape caused by power lines and towers. Again, staff requests that Western evaluate the use of the existing water pipeline between Windy Gap and Lake Granby to carry the proposed electrical transmission lines. Joint use of the pipeline for both conveyance of water and installation of the electrical lines is a sustainable alternative that would eliminate a portion of the 12 mile project to currently be only evaluated in an aboveground option. As stated above, we believe this process should include an evaluation of the use of underwater electrical cabling to carry the proposed electrical service from Windy Gap to Lake Granby.

ENSURING THAT NEW DEVELOPMENT IS SERVED BY ADEQUATE INFRASTRUCTURE
The main objective of this project is to enhance system reliability by providing a looped transmission system. Currently there is concern with the potential loss of the 69-kV cable in the Alva B. Adams Tunnel. This cable supplies a secondary source of electrical power for a major share of the citizens of Grand County. It allows looped transmission service between Estes Park and the Windy Gap Substations. As you have indicated, this cable is antiquated and in need of replacement. It has always been the belief of Grand County that replacement of the Adams Tunnel line should be one of the alternatives studied. Cost is not a reason to eliminate an alternative if it is the least environmentally damaging. By not including replacement of the Adams Tunnel line, this eliminates the possibility of Grand County to obtain cheaper power (the hydro component of the Colorado Big Thompson Project has paid for itself many times over) and does not meet the national perspective stating that "Green Power" is necessary for environmental health of the nation.

If you have further questions on these issues, please contact Kristen Manguso, Grand County Department of Planning and Zoning, 725-3347. Thank you.

Sincerely,

Kristen Manguso
Planning Director

cc: County Commissioners
County Manager
Deputy County Attorney
Joe Pandy, Mountain Parks Electric
Les Shankland, Mountain Parks Electric
Patricia Hesch, U.S. Forest Service
Barbara Green
David Taussig