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Direct Testimony: Sheldon Mains for Seward Neighborhood Group, Inc.
STATE OF MINNESOTA
OFFICE OF ADMINISTRATIVE HEARINGS FOR THE PUBLIC
UTILITIES COMMISSION
In the Matter of the Application OAH Dockett15-2500-20599-2

for a HVTL Route Permit for the PUC Docket E-002/TL-09-38
Hiawatha Transmission Project
TESTIMONY OF
SHELDON MAINS
On Behalf of the Intervener
the
SEWARD NEIGHBORHOOD GROUP, Inc.
April 26, 2010

1
1 INTRODUCTION AND BACKGROUND
2 Q: Please state your name.
3 A: Sheldon Mains.
4 Q: What organization are you representing and what is your position with that
5 organization?
6 A: I am testifying as the president of the Seward Neighborhood Group, Inc. Our
7 business address is 2323 East Franklin Avenue, Minneapolis, Minnesota, 55406.
8 President of the board is a volunteer position that I have held for over two years.
9 I also held that position in the mid 1970s.
10 Q: What is the Seward Neighborhood Group, Inc.?
11 A: The Seward Neighborhood Group (SNG) is a Minnesota nonprofit corporation
12 that has IRS 501.c.3 tax status. Seward Neighborhood Group is one of the oldest
13 neighborhood organizations in Minneapolis, now celebrating its 50th
14 anniversary. SNG is the designated citizen participation organization by the City
15 of Minneapolis for the Seward Neighborhood. SNG works to improve the
16 neighborhood—it’s housing, institutions, employment and businesses.
17 Q: What are the boundaries of the Seward Neighborhood?
18 A: The Seward Neighborhood is bounded by Interstate 94 on the north, the
19 Mississippi River on the northeast and east, the Midtown Greenway and the
20 railroad right-‐of-‐way to the south and the Hiawatha LRT on the west. Several of
21 the proposed Hiawatha substation locations are within the Seward
22 Neighborhood.
23 Q: What is your background?

Seward Neighborhood -‐1-‐ PUC Docket ET2/TL-‐09-‐38
Group, Inc. April 26, 2010 OAH Docket 15-‐2500-‐20599-‐2

1 A: I have an eclectic background that includes diverse pertinent training and
2 experience:
3 • As a licensed electrical engineer, I served as senior engineer and manager for
4 the Minnesota Environmental Quality Board when the power plant siting and
5 transmission line routing program was housed in the MEQB. One of my first
6 job duties was to translate between electric utility engineers and the public. I
7 was hired right after the first state routing project—the DC power line from
8 North Dakota-‐-‐literally blew-‐up in protest. I then managed the transmission
9 line routing program in the early 1980s.
10 • I am currently self-‐employed as a consultant to nonprofit organizations
11 helping them use technology to better serve their communities.
12 • Besides a bachelors degree in electrical engineering from the University of
13 Minnesota, I also have a master of arts degree from the Humphrey Institute
14 of Public Affairs, specializing in urban planning and energy policy.
15 • I was the first president of the Milwaukee Avenue Development Corporation.
16 The corporation was responsible for coordinating the public improvements
17 to the Milwaukee Avenue Historic District in Seward, for rehabilitating a
18 number of houses in the district, for the process of finding private owners
19 who rehabilitated a number of other houses in the district and for
20 coordinating and approving the new in-‐fill construction.
21 • I have recently served as a member of:
22 o the Minneapolis Library Board,
23 o the Minneapolis Board of Estimate and Taxation, and


1 o the Minneapolis Planning Commission.
2 Q: Could you briefly summarize the review of this project within the Seward
3 Neighborhood Group?
4 A: This project has been extensively discussed at a number of Seward
5 Neighborhood Community Development Committee meetings and SNG
6 Environment Committee meetings. This project was also discussed at full board
7 meetings of the Seward Neighborhood Group. Numerous resolutions were
8 adopted by the two committees and approved by the full board. This testimony
9 is based on those resolutions and those discussions. The final version of this
10 testimony was reviewed by the chair of the SNG Development Committee and
11 approved by the SNG Executive Committee.
12
13 Need and reasonableness of the project:
14 Q: Does the Seward Neighborhood Group have any concerns regarding the need for
15 and reasonableness of this project?
16 A: Seward Neighborhood Group knows the importance of reliable electrical power
17 for our residents and our businesses. However, SNG is concerned that there has
18 been no independent, public analysis of whether there is a need for this project.
19 Further, SNG is concerned that even if there is a need, there has been no
20 independent, public analysis of whether the project proposed by Xcel Energy is
21 the most effective way to meet that need.
22 Q: Could you be mores specific about lack of an analysis of need for this project?


1 A: This proposed transmission line routing project is the first project under the
2 Minnesota routing process in a dense urban area. Even though it is less than 10
3 miles long and therefore is exempt under the law from a Certificate-‐of-‐Need, it
4 will affect many more people than a 100-‐mile long rural transmission line. It
5 deserves a public Certificate-‐of-‐Need process. Without that public process, a
6 large segment of the public in the area will continue to believe that the project
7 was never needed.
8 Q: If there is a need for additional electric power, what options for meeting that
9 need should be considered?
10 A: If there is a need for additional electric power to serve customers in the project
11 area or throughout South Minneapolis, options that should be reviewed in detail
12 to determine if this is the most effective solution include:
13 • All the options considered in the Xcel application, especially options A-‐3 (one
14 substation) and A-‐4 (using 34.5 kV Sub-‐transmission and substations).
15 • Adding capacity to existing substations including Elliot Park, Southtown,
16 Aldrich, and St. Louis Park; alone or in combination with parts of options A-‐3
17 and A-‐4.
18 • It is not likely that any one alternative source (including conservation) could
19 meet the full need Xcel has claimed. However, a combination of alternative
20 sources, conservation, peak load management and parts of this project may
21 be a solution. Only a process as thorough as a Certificate-‐of-‐Need process
22 can analyze these more complex options.


1 In the application, Xcel has implied that there is not space at the existing
2 substations serving this area for additional distribution transformers. Xcel has
3 argued that in the built-‐up areas these substations are located in, there is no
4 space available for expansion. While it may be difficult to expand the existing
5 sites, it may not be as difficult as adding a new substation and transmission line
6 in the middle of an extremely dense neighborhood. In fact, there is space to
7 expand the Southtown substation to the immediate east of the substation by
8 using the driveway that was used by trucks for the now vacant Purina facility on
9 the north end of the block. There may be similar opportunities at other
10 substations.
11 Xcel also noted that adding a fourth distribution transformer to these
12 substations would result in substations that differ from the “standard” Xcel
13 substation. However, two of the alternatives considered in the application (A-‐3
14 and A-‐4) would be “non-‐standard” substations but were considered. In this
15 dense urban environment, Xcel needs to consider ‘non-‐standard” options if a
16 growing need for electric energy is found.
17 SNG is also concerned that the cost of these options has only been compared
18 to an overhead transmission line project serving a new mid-‐town substation.
19 Since it may be determined that the only feasible and prudent option for the
20 proposed transmission line will be an underground transmission line (see
21 testimony below), the cost of other methods of meeting any need should be
22 compared to an underground transmission line option.
23


1 Route Alternatives:
2 Q: Does SNG have a preferred route if need is established?
3 A: If it is determined that there is a need and that two standard substations with
4 two new transmission circuits connecting the substations is the best option; SNG
5 prefers Route D, an underground transmission line under 28th Street. In fact, SNG
6 believes that this is the only feasible and prudent option for this transmission
7 line.
8 Q: Why does SNG consider this the only feasible and prudent alternative?
9 A: We believe this would have the least impact on the Midtown Greenway and on
10 property values in neighborhoods bordering Seward. SNG knows that for
11 Seward Neighborhood to thrive, our neighboring communities also have to
12 thrive. The negative effects that an overhead transmission line would have on
13 any of the overhead routes through the neighborhoods would be a significant
14 handicap to improving these neighborhoods:
15 • Residential properties within the fall zone of any tower will not be able to
16 receive Department of Housing and Urban Development backed financing.
17 This will make affordable housing development extremely difficult.
18 • The negative effect on property values of office or residential buildings of
19 having high voltage conductors at the same elevation of upper story windows
20 and only about 10 to 30 feet from the window.
21 • The effect on property values of having the front of the property directly abut
22 a high voltage transmission line.


1 • Developers and individuals will be less likely to rehabilitate old buildings or
2 invest in new developments because of the perception that Xcel will do a
3 poor job of maintaining these new facilities. This perception is likely based
4 on the graffiti on the current Hiawatha HVTL towers; the rust and weeds and
5 graffiti at the Southtown substation; and the current condition of the vacated
6 Oakland substation.
7 • The historic fabric of the neighborhoods, and especially the Midtown
8 Greenway, will be significantly harmed by seventy-‐five foot tall structures
9 and the 115 KV conductors whether the towers are metal or wood.
10 • It is likely that on some routes towers will have to be placed next to
11 important individual historic properties including the Midtown Exchange
12 and the Swedish Institute.
13 Q: Does SNG have additional concerns regarding an overhead transmission line
14 along the Midtown Greenway?
15 A: Yes, we are concerned that overhead high voltage transmission lines will negate
16 the positive effect the Midtown Greenway is having on improving the greater
17 Phillips Neighborhood. In Seward Neighborhood, we have seen how new
18 amenities can improve the neighborhood. Both creating Matthews Park in the
19 1960s and the creation of the Milwaukee Avenue Historic District a few decades
20 latter had significant positive effects on property blocks away. We are already
21 starting to see improvements near Phase III of the Greenway.
22 Q: Do SNG have specific concerns about underground transmission lines on either
23 of the proposed underground routes along the Midtown Greenway?


1 A: Yes. Under cross examination by the applicant, Paul Ogren from the City of
2 Minneapolis agreed with Xcel’s attorney that it is best to place underground
3 facilities in locations where they will not have to be moved. If the alignment is
4 along 29th Street, it is very possible that the transmission line would have to be
5 moved each time one of the bridges is replaced since replacing the abutments
6 requires excavation significantly past the present abutments. If the alignment is
7 on the north edge of the Greenway trench, it is likely that the transmission line
8 will have to be moved if any type of transit is installed, especially in the
9 narrower portions the Greenway. These problems do not exist for an alignment
10 down the center portion of 28th Street.
11 Q: How should the extra cost of an underground transmission line be paid for?
12 A: The extra cost of putting the line underground should go into the overall Xcel
13 rate base.
14 • First, as stated previously, SNG believes that an underground line is the
15 only feasible and prudent option for this proposed transmission line.
16 • Second, Xcel has placed other 115kK lines underground in less sensitive
17 areas:
18 o The transmission lines feeding the Elliot Park substation that,
19 when built, were surrounded by industrial buildings.
20 o The south end of the underground portion of the Southtown to
21 Elliot Park substation that goes through an area of two and three
22 story residential construction.


1 o The 115 kV line from Aldrich to West River Road is underground
2 for its entire length, mostly through an industrial area.
3 • Third, the Minnesota transmission line routing rules note that routing
4 along rights-‐of-‐way and survey lines is preferred to diagonally crossing
5 agricultural land. When this is done, it adds cost to the project. This
6 added cost is not born by the farmer or local ratepayers. It is included in
7 Xcel’s overall rate base. This is a similar situation.
8
9 Substation Locations:
10 Q: Does Seward Neighborhood Group have any preferences regarding the Hiawatha
11 substation location?
12 A: SNG is opposed to both the Hiawatha East and the Zimmer Davis sites because of
13 the impact on the businesses and on neighborhood employment. SNG has
14 worked for years with neighborhood partners and the city to bring businesses to
15 Seward. It is not always easy to get businesses to locate in the inner city and SNG
16 is thrilled that these businesses have chosen to invest in our neighborhood and
17 provide jobs in our community. Also, a substation at either of these sites would
18 have significant negative effects on the new multi-‐story housing immediately
19 south of those sites—both aesthetically and acoustically.
20 SNG is also opposed to the proposed Hiawatha West site. This is one of a
21 very few large open spaces on the Midtown Greenway. Also, the broader
22 community has invested time, effort (mainly volunteer time and effort) and
23 money in planting over 200 trees and shrubs on the site in over the last two


1 years. Finally, since this is the intersection of the Midtown Greenway and the
2 Bike/Pedestrian path along the Hiawatha LRT line that connects the Greenway
3 to downtown, it is a significant hub in the bicycle/pedestrian trail network in
4 Minneapolis.
5 SNG urges Xcel to reconsider the possibility of the G-‐4 site (Between the
6 railroad right of way, Hiawatha, Lake and the southern edge of the unused Xcel
7 substation building at approximately 31st Street). This would be an ideal site for
8 a substation. In planning jargon; a substation on this location may be the highest
9 and best use of this site.
10 Q: How would the G-‐4 site work? Hasn’t Xcel ruled that site out as too small?
11 A: Xcel only considered the MnDOT land when reviewing the G-‐4 site. According to
12 the testimony of Xcel’s witness McNelly, she tried to fit a substation in the 153
13 foot width of the MnDOT land and could only get the design down to 180 feet
14 wide. Immediately east of that land is Canadian Pacific right-‐of-‐way that appears
15 under-‐utilized. There are five tracks in that right of way. One of the tracks is used
16 to serve one or two rail customers to the south. The other four tracks are sidings
17 that were used when Hiawatha Avenue was a major grain shipping center. These
18 sidings appear to be only used for occasional storage of a few rail cars.
19 Q: Do you know if that railroad land could be used for this purpose?
20 A: No. But I do know that the proposed Xcel low-‐profile layout for the Hiawatha
21 West site would use Canadian Pacific land that is part of this same rail line. I also
22 know that Hennepin County purchased a portion of the right-‐of-‐way on the east-‐
23 west portion of this rail-‐line for Phase III of the Midtown Greenway. I also called


1 David Drauch in the Canadian Pacific real estate department. He said he had
2 talked with Xcel about the land at the Hiawatha West site. When I asked him if
3 Canadian Pacific would be willing to sell part of their right-‐of-‐way south of Lake
4 Street and east of the MnDOT park-‐and-‐ride lot, he said that this was the first
5 time he heard about that option and he would have to research it.
6 Q: If the G-‐4 site will not work, does SNG have a preference between the three other
7 sites under consideration?
8 A: No, not officially. But I discussed what a minimally acceptable option would be if
9 G-‐4 was ruled out with the executive committee, the chair of the development
10 committee, staff at Seward Redesign and a number of other community
11 members. Based on those discussions.
12 I believe there are conditions that could make Hiawatha West a minimally
13 acceptable location if G-‐4 is not possible:
14 • A high-‐profile substation with a footprint of approximately 260 feet by 270
15 feet.
16 • The substation located as far south and east as possible, using a portion of
17 the Canadian Pacific right-‐of-‐way (but avoiding moving the track or the
18 control room). This would be similar to the location in Exhibit 169 B. It is
19 interesting that when Xcel considers a low profile substation on this site, Xcel
20 is willing to use railroad right-‐of-‐way (Appendix B.7 of the Application) but
21 for a high profile substation Xcel has stated that it wants to avoid the railroad
22 right-‐of-‐way.


1 • The substation located to allow a pedestrian/bike path from the Greenway to
2 Lake Street. (One person suggested that Xcel should build that path.)
3 • Night-‐sky friendly lighting for the substation.
4 • Walls at least 28 feet high. Walls could be lowered by the amount the
5 substation is excavated into the ground.
6 • Landscaped with mature trees and bushes.
7 • Replacement of any open space, trees and other vegetation taken for the
8 substation with an open space of equal size and quality along the Midtown
9 Greenway in the project area.
10 • The new 115 kV transmission lines enter the substation underground.
11 One interesting comment was that Xcel could improve it’s image in the area if it
12 invested in significantly improving the appearance of the Southtown substation
13 as well.
14 Q: Does the Seward Neighborhood Group have a position regarding the location of
15 the midtown substation?
16 A: SNG has no position on the location of the midtown substation.
17 Q: Does this conclude your testimony?
18 A: Yes


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Direct Testimony: Sheldon Mains for Seward Neighborhood Group, Inc.

In the Matter of the Application OAH Dockett15-2500-20599-2

On Behalf of the Intervener

SEWARD NEIGHBORHOOD GROUP, Inc.

April 26, 2010

2 Q: Please state your name.

9 I also held that position in the mid 1970s.

10 Q: What is the Seward Neighborhood Group, Inc.?

11 A: The Seward Neighborhood Group (SNG) is a Minnesota nonprofit corporation

13 neighborhood organizations in Minneapolis, now celebrating its 50th

16 neighborhood—it’s housing, institutions, employment and businesses.

17 Q: What are the boundaries of the Seward Neighborhood?

21 the proposed Hiawatha substation locations are within the Seward

23 Q: What is your background?

8 North Dakota-­‐-­‐literally blew-­‐up in protest. I then managed the transmission

9 line routing program in the early 1980s.

10 • I am currently self-­‐employed as a consultant to nonprofit organizations

11 helping them use technology to better serve their communities.

14 of Public Affairs, specializing in urban planning and energy policy.

16 The corporation was responsible for coordinating the public improvements

17 to the Milwaukee Avenue Historic District in Seward, for rehabilitating a

20 coordinating and approving the new in-­‐fill construction.

21 • I have recently served as a member of:

22 o the Minneapolis Library Board,

23 o the Minneapolis Board of Estimate and Taxation, and

5 Neighborhood Community Development Committee meetings and SNG

7 meetings of the Seward Neighborhood Group. Numerous resolutions were

11 approved by the SNG Executive Committee.

13 Need and reasonableness of the project:

15 and reasonableness of this project?

21 the most effective way to meet that need.

5 deserves a public Certificate-­‐of-­‐Need process. Without that public process, a

7 was never needed.

9 need should be considered?

12 to determine if this is the most effective solution include:

14 substation) and A-­‐4 (using 34.5 kV Sub-­‐transmission and substations).

15 • Adding capacity to existing substations including Elliot Park, Southtown,

21 be a solution. Only a process as thorough as a Certificate-­‐of-­‐Need process

22 can analyze these more complex options.

16 growing need for electric energy is found.

18 to an overhead transmission line project serving a new mid-­‐town substation.

22 compared to an underground transmission line option.

2 Q: Does SNG have a preferred route if need is established?

14 handicap to improving these neighborhoods:

16 receive Department of Housing and Urban Development backed financing.

17 This will make affordable housing development extremely difficult.

22 a high voltage transmission line.

11 important individual historic properties including the Midtown Exchange

12 and the Swedish Institute.

14 along the Midtown Greenway?

23 of the proposed underground routes along the Midtown Greenway?

10 down the center portion of 28th Street.

18 o The transmission lines feeding the Elliot Park substation that,

19 when built, were surrounded by industrial buildings.

22 story residential construction.

2 for its entire length, mostly through an industrial area.

7 Xcel’s overall rate base. This is a similar situation.

19 south of those sites—both aesthetically and acoustically.

9 and best use of this site.

7 sites under consideration?

11 members. Based on those discussions.

13 acceptable location if G-­‐4 is not possible:

8 North Dakota-‐-‐literally blew-‐up in protest. I then managed the transmission

10 • I am currently self-‐employed as a consultant to nonprofit organizations

20 coordinating and approving the new in-‐fill construction.

5 deserves a public Certificate-‐of-‐Need process. Without that public process, a

14 substation) and A-‐4 (using 34.5 kV Sub-‐transmission and substations).

21 be a solution. Only a process as thorough as a Certificate-‐of-‐Need process

18 to an overhead transmission line project serving a new mid-‐town substation.

13 acceptable location if G-‐4 is not possible:

3 • Night-‐sky friendly lighting for the substation.