HomeMy WebLinkAboutPSE Renton CUP response narrative- Final
Conditional Use Permit
Comment Response
September 18, 2018 1
As requested by the city of Renton (“City”), Puget Sound Energy, Inc. (“PSE”) provides the following
information in response to public comments submitted to the City on PSE’s Energize Eastside
Conditional Use Permit application.
The comments are addressed by general topic as the majority were addressed as part of the related
Environmental Impact Statement public comment process. Unique comments that have not been
answered previously are also addressed below or in the accompanying letter to the City.
Background
Electricity is currently delivered to the Eastside area1 through two 230 kV/115 kV bulk electric
substations – Sammamish substation in Redmond and Talbot Hill substation in Renton. The electricity is
then distributed to neighborhood distribution substations using the many 115 kV transmission lines
located throughout the area. Although PSE has made many 115 kV system improvements in the
Eastside area over the years, the primary 115 kV lines that connect the Sammamish (Redmond) and
Talbot Hill (Renton) substations to the Lakeside switching station (Bellevue) have not been upgraded
since the 1960s. Since then, the Eastside’s population has grown from approximately 50,000 to nearly
400,000 people. Growth is expected to continue.
As part of the mandatory North American Electric Reliability Corporation (“NERC”) Compliance
Enforcement Program2, PSE performs an annual comprehensive reliability assessment3 to determine if
any potential adverse impacts to the reliability of delivery of electricity exist on the PSE transmission
system. Studies performed in 2013 and 2015 demonstrated PSE could not meet federal reliability
requirements by the winter of 2017/18 and the summer of 2018 without the addition of 230 kV/115 kV
transformer capacity in the Eastside area.
To respond to the deficiencies identified in the transmission planning studies, PSE launched the Energize
Eastside project in December 2013. After an analysis of alternatives, PSE ultimately proceeded with a
project that entails installing approximately 16 miles of new 230 kV transmission line between the
existing Sammamish and Talbot Hill substations using the same utility corridor where 115 kV lines now
exist, the construction of a new 230 kV/115 kV electric substation site (Richards Creek substation) and
continued aggressive conservation. The Richards Creek substation will be located adjacent to the
Lakeside switching station, from which most of the Eastside’s 115 kV power is routed to customers.
System Reliability Planning
The performance requirements of any integrated transmission system are heavily regulated at both the
federal and regional levels. PSE’s regulators include the Federal Energy Regulatory Commission
(“FERC”), the North American Electric Reliability Corporation (“NERC”) and the Western Electricity
Coordinating Council (“WECC”). As certified by FERC, NERC is the regulatory authority that develops and
enforces reliability standards. NERC has delegated the task of monitoring and enforcing the federal
reliability standards to WECC, a regional entity that has authority over the Western region, including
PSE. Like all system operators, it is PSE’s responsibility to plan and operate the electric system to ensure
reliable power delivery to customers.
1 For the purpose of this project, the Eastside is defined as the area between Renton and Redmond, bounded by Lake
Washington to the west and Lake Sammamish to the east.
2 NERC Reliability Standards for the Bulk Electric Systems of North America
3 PSE Planning Studies and Assessment TPL-001 to TPL-004 and TPL-001-4 Compliance Reports
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The NERC standards mandate that certain forecasts and studies be completed to determine if the
system has sufficient capability to meet expected loads now and in the future. When completing
transmission planning studies, contingencies are simulated to determine if the electric system meets the
NERC mandatory performance requirements 4 for a given set of forecasted demand levels, generation
configurations and levels, and multiple system component outages. This conservative planning
methodology, which has been developed over decades, is implemented to prevent large-scale,
cascading, transmission system blackouts, like those that have occurred in the recent past (e.g., the
2003 Northeast blackout that affected 55 million people in the Northeast and Midwest regions of the
United States and into Canada).
Eastside Planning Studies Results
PSE transmission planning studies demonstrated that, under certain contingencies and scenarios
required by NERC, the delivery system on the Eastside cannot continue to meet the mandatory reliability
requirements without significant infrastructure upgrades or by dropping load (i.e., turning customers’
power off). The Needs Assessment reports, published in 2013 and updated in 2015, which PSE
performed pursuant to the mandatory transmission planning standards, identified four major areas of
concern:
1. Overload of PSE facilities in the Eastside area. Specifically, studies identified potential overloading of
transformers at Sammamish and Talbot Hill substations. Transformers are a key piece of electrical
equipment that allows the electricity to get from its generation source (e.g., wind farm,
hydroelectric, etc.) to customers’ homes and businesses. Additionally, several 115 kV transmission
lines routing power around the Eastside area are also at risk of overloading under certain conditions.
2. Small margin of error to manage risks from inherent load forecast uncertainties. PSE’s planning
studies rely in large part on load forecast data. Imbedded in PSE’s load forecasts are several factors
that include elements of risk, including conservation, weather, and block loads.
• Conservation: To date, PSE customers have achieved 100 percent of the company’s
conservation goals, which are very aggressive according to industry experts. If 100 percent
of conservation goals are not achieved, then the transmission system capacity would be
surpassed sooner than expected.
• Weather: PSE’s load forecast assumes “every other year” cold weather, which is not as
conservative as most other utilities that study system performance during the coldest and
hottest weather in five or ten years. If the region experiences weather extremes outside of
those used in the planning studies, electricity demand would surpass the transmission
system capacity sooner than expected.
• Block loads: These include large development projects that add significant load to the
system. If block load growth increases more than anticipated, demand for electricity would
surpass the transmission capacity sooner than expected.
3. Increased use and expansion of Corrective Action Plans (CAPs) to keep the system compliant.
CAPs are a series of steps used to prevent system overloads or loss of customers’ power. They are a
short-term fix to alleviate potential violations that could put the local area or the entire Western
4 The transmission planning standards that were in effect in 2012-2013 were: TPL-001-3, TPL-002-0b 2nd Rev (TPL-002-
2b),TPL-003-0b 2nd Rev (TPL-003-2b), and TPL-004-2. TPL-001-3, TPL-002-2b, TPL-003-2b, and TPL-004-2 are being retired
as they are replaced in their entirety by TPL-001-4. Enforcement started 1/1/15. http://www.nerc.com/pa/Stand/Reliability
Standards/TPL-001-4.pdf
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grid at risk. They protect against large-scale, cascading power outages; however, they can put large
numbers of customers at increased risk of power outages. For example, to prevent winter overloads
on the Talbot Hill transformer banks, PSE currently is using CAPs, which increases outage risk to
customers. As growth continues, additional CAPs will be required.
4. Impacts to regional grid identified by ColumbiaGrid. Because the electric system is interconnected
for the benefit of all, it is a federal requirement to study all electric transmission projects to ensure
there are no adverse impacts to the reliability or operating characteristics of PSE’s or any
surrounding utilities’ electric systems. ColumbiaGrid, the regional planning entity, produces a
Biennial Transmission Expansion Plan that addresses system needs in the Pacific Northwest,
including the PSE system. PSE has to be mindful of those plans and understand the identified risks.
PSE’s 2015 Supplemental Needs Assessment Report reconfirmed the earlier 2013 Needs Assessment
Report by stating the following:
By winter of 2017‐18, there is a transmission capacity deficiency on the Eastside that impacts PSE
customers and communities in and around Kirkland, Redmond, Bellevue, Issaquah, Newcastle, and
Renton along with Clyde Hill, Medina, and Mercer Island. By winter of 2019‐20, at an Eastside load
level of approximately 706 MW, additional CAPs are required that will put approximately 63,200
Eastside customers at risk of outages.
The 2015 Needs Assessment also confirmed that by summer of 2018, there will be a transmission
capacity deficiency on the Eastside that impacts PSE customers and communities in and around
Kirkland, Redmond, Renton, Bellevue, Issaquah, and Newcastle along with Clyde Hill, Medina, and
Mercer Island. By summer of 2018, CAPs will be required to manage overloads under certain
Category C contingencies and the use of these CAPs will place approximately 68,800 customers at
risk and could require 74 MW of load shedding, effecting approximately 10,900 customers.
If certain scenarios were to have occurred, PSE may have implemented additional CAPs that could have
resulted in PSE intentionally turning the power off to tens of thousands of customers in order to help
prevent widespread outages to additional tens of thousands of customers in the Eastside area and
beyond.
Solution to Meet the Need
A third party assessment5 commissioned by the City of Bellevue confirmed PSE’s identification of this
transmission capacity deficiency in the Eastside area. Any solution to solve this deficiency must meet all
NERC performance criteria, address all relevant PSE equipment overloads, and continue to meet the
performance criteria for at least 10 years after construction. The studies for the needs assessment
shows that the solution needs to be in-service by winter 2017-18, to meet the NERC TPL-001-4
performance requirements.
After extensive study and evaluating dozens of alternatives 6, PSE determined that the most effective
solution that meets all criteria and complies with the federal performance requirements is the addition
of a 230 kV/115 kV transformer in the center of the Eastside load area connected by 230 kV
5 Utilities Systems Efficiencies, Independent Technical Analysis of Energize Eastside for the City of Bellevue, April 28, 2015.
6 PSE Eastside Transmission Solutions Report, King County Area, October 2013; Updated 2014 & Supplemental Eastside
Solutions Study Report, Transmission System, King County, May 2015.
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transmission lines from both the Sammamish and Talbot Hill substations, as well as continued aggressive
conservation.
Project Need
PSE disagrees with unsubstantiated commenter statements related to project need. Energize Eastside is
needed to address area growth and to meet federal reliability requirements during peak demand for
electricity. This has been confirmed by independent experts retained by Bellevue and as part of the EIS
process. The last major upgrade to the backbone of the Eastside’s electric grid was more than 50 years
ago. Since then, our population has grown eight-fold, and the demands residents and businesses place
on the system have increased. Four years ago, PSE’s studies– again, confirmed by independent experts–
revealed our transmission grid is strained today under peak conditions, just at the time when our
customers need reliable power the most.
As stated above, the city of Bellevue retained - at the request of members of the public - an
independent expert, Utility System Efficiencies, Inc. (USE) to perform an independent study of project
need. Members of the public helped the city determine the scope of the study. USE modeled scenarios
in power flow cases and verified that PSE followed industry practice in forecasting demand load.
Based on key questions posed by the public, the April 28, 2015, USE study concluded:
• Is there a need for this project to address growth in Bellevue? YES.
• Is the EE project needed to address the reliability of the electric grid on the Eastside? YES.
• If the load growth rate was reduced, would the project still be needed? YES.
• If generation was increased in the Puget Sound area, would the project still be needed? YES.
• Is there a need for the project to address regional flows, with imports/exports to Canada
(ColumbiaGrid)? Modeling zero flow to Canada, the project is still necessary to address local
need.
In addition to the review by Bellevue’s consultant, the Partner Cities (including Renton), retained their
own independent EIS subcontractor, Stantec, to review and opine on the PSE needs assessment. Stantec
stated:
“Based on my expertise, I found that the PSE needs assessment was overall very thorough and applied
methods considered to be the industry standard for planning of this nature. Based on the information
that the needs assessment contains, I concur with the conclusion that there is a transmission capacity
deficiency in PSE’s system on the Eastside that requires attention in the near future.” ‐ Review Memo by
Stantec Consulting Services Inc., July 31, 2015.
Project opponents have wildly inflated the cost for the Energize Eastside. While PSE does not know the
precise total cost of the project, it is estimated to be between $150 million and $300 million.
PSE is a heavily regulated investor-owned utility whose actions are carefully monitored and reviewed by
the Washington Utilities and Transportation Commission (UTC). PSE invests in capital infrastructure
based on need and consequence – i.e., what happens if the infrastructure is not built. Our rate of return
is regulated by the state, not PSE. The company’s rate of return on any infrastructure investment is
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never guaranteed, contrary to what has been stated by many commenters, and may change with every
rate case.
Reliable power is critical to the community’s health, safety and vitality. The alternative of doing nothing
or delaying the project could put the Eastside at an economic disadvantage and could have local
economic impacts, as indicated by an independent study by Nexant.7
It is PSE’s responsibility to provide safe, reliable power to all of its customers. Energize Eastside is the
most reliable and cost-effective solution for doing so and the need has been confirmed.
Pipeline Safety
When evaluating the replacement of the existing 115 kV transmission lines with 230 kV lines in the
utility corridor, one of the key factors studied was the impact (if any) of the colocation of the
transmission lines with the petroleum pipelines operated by Olympic Pipeline Company (Olympic).
Customer safety is PSE’s first priority, and we have a long history of working closely with Olympic to
ensure continued protection and safe operations of existing pipelines and high voltage transmission
lines that have shared the corridor for decades.
PSE proactively engaged a technical consultant, DNV GL, to study and provide recommendations on
collocating Energize Eastside with Olympic’s pipelines. This study was one of the first conducted by a
transmission line operator to assess the potential AC interaction between the transmission lines and the
pipelines 8. Based on DNV GL’s recommendations, in order to minimize AC interaction with the
pipeline(s), PSE has designed the project to have at least a 13-foot separation distance between the
pipeline and the pole grounding system. This exceeds both federal regulations and Olympic’s
requirements for separation. Additionally, using the existing corridor and mitigating impacts by
operating both of the replacement lines at 230 kV, is expected to reduce the level of potential
interaction to less than the modeled conditions of the existing 115 kV system.
PSE continues to work with Olympic to refine the design of the transmission line in accordance with
industry and engineering best practices for the safe construction and operation of both facilities. This
effort includes using advanced technologies like ground-penetrating radar to survey pipeline locations.
During construction, PSE and Olympic follow prescribed notification and inspection procedures when
working in the corridor. Prior to excavation work in the corridor, PSE and Olympic meet onsite to
inspect the area and confirm the location of the pipeline(s). Additionally, specialized equipment is
typically used for the excavations required for pole installation. Vacuum trucks are commonly used to
excavate the holes to depths greater than the pipelines.
The Partner Cities’ EIS team also analyzed pipeline safety, which is documented in the Final EIS in
Chapter 4.9 Environmental Health – Pipeline Safety and in Section 6.18 Summary of Response to
Comments on Public Services. The Final EIS concluded that:
7 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/pse_energize_eastside_outage_cost_study_-
_final__10.30.2015_.pdf
8This study was recently presented by DNV-GL at the 2018 National Association of Corrosion Engineers (NACE) national
conference.
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September 18, 2018 6
“Even with worst-case assumptions related to the increased risk during operation and
construction, the likelihood of a pipeline release and fire would remain low, and no
substantial increase in risk compared to the existing conditions was identified. It is expected
that with the implementation of additional mitigation measures, any increase in risks within
the corridor can be fully mitigated. As a result, no significant unavoidable adverse impacts
have been identified.” (page 1-31)
As stated previously, PSE’s existing transmission lines and Olympic’s pipelines have shared a utility
corridor for more than 40 years. During that time, PSE has safely replaced poles within the shared utility
corridor. In 2007 and 2008, PSE worked with Olympic to replace more than 130 poles and reframe more
than 200 poles in this corridor and others. As recently as 2016, we safely replaced two poles adjacent to
the pipelines in Newcastle. PSE understands the community’s concerns, and we will continue to work
with Olympic Pipeline to implement safe construction practices and operations.
Using the existing transmission corridor limits impacts
By using the existing corridor, Energize Eastside affects the fewest number of trees and avoids the
construction of new utility corridors. The existing corridor was first developed during the late 1920s and
early 1930s. Neighborhoods have since built up around it and PSE has managed and maintained (i.e.,
topped and/or trimmed) the trees underneath the existing transmission lines to prevent them from
causing safety and reliability issues.
The Partner Cities’ Final EIS confirms that “PSE’s policy is to restore vegetation other than trees within
transmission corridors to as like or better condition. Outside of the Managed Right-of-Way, tree
replacement is agreed upon with the property owner (in some cases the owner may prefer tree removal
without replacement). Tree replacement would also comply with local code requirements, as described
above in Section 3.4.1 of the Phase 2 Draft EIS.” (Section 4.4.4.1, page 4.4-4).
Furthermore, the EIS process considered a worst-case scenario for tree removal, and the maximum
number of trees that could potentially be removed for the entire project (from Redmond to Renton) is
about 3,600 trees. However, this overestimates the number of trees that will be removed, because PSE
is working with property owners to better assess and reduce the number of trees affected. We know
our customers value trees. PSE will meet the tree replacement mitigation requirements and work with
property owners to replace trees. Our goal is that, when the project is complete, there will be more
trees, not fewer. We’re working with city staff, and with property owners, to ensure that we accomplish
this.
Other alternatives were studied; Energize Eastside is the right solution
The Partner Cities’ EIS Team and PSE, as well as other experts, have studied other alternatives, including
conservation/energy efficiency, new generation, and batteries. These alternatives were eventually
eliminated because they did not solve the problem, did not meet federal planning standards, would be
difficult to permit, or rely on voluntary participation.
We understand customers want us to consider innovative solutions like batteries. PSE and energy
storage industry experts determined batteries are not a cost-effective or practicable solution for the
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Eastside’s transmission capacity deficiency. This technology has not been used for the type and scale of
problem facing the Eastside.
Energize Eastside solves the Eastside’s transmission capacity deficiency. The project’s combination of
continued aggressive electric conservation, a new substation, and upgraded transmission lines is the
most reliable and cost-effective solution. To review the various studies on alternatives, visit the Partner
Cities’ EIS Library www.EnergizeEastsideEIS.org/library.html.