Loading...
HomeMy WebLinkAboutC_Public_Comment_42.a_180614.email_attach2of21 Expert Report Richard Lauckhart My Qualifications are included in the Lauckhart-Schiffman report at its Appendix H Problems with Energize Eastside Final EIS re Need and No Action Executive Summary: The Final EIS makes erroneous statements that are not supported by the record. The Final EIS does not properly acknowledge the many comments I made on the draft EIS and makes erroneous conclusions about the need for Energize Eastside and the environmental impacts of the “no action” alternative. This Final EIS, as written, should not be given any weight on the question of whether or not the Conditional Use Permit Application for Energize Eastside should be approved. The Final EIS should acknowledge the fact that there are no adverse environmental effects under the “no action” alternative. I. Background and PSE failure to appropriately look at alternatives: Puget Sound Energy (PSE) claims that the Energize Eastside project is needed in order to maintain reliability on the Eastside of Lake Washington. I have written a report that demonstrates there is no need for Energize Eastside. I provided evidence in my comments on the Draft Energize Eastside EIS that Energize Eastside is not needed and that there will be no adverse environmental impacts if the “no action” alternative is selected. Volumes 3 and 4 of the Final Energize Eastside EIS include the evidence I provided in the EIS process. However, Volume 1 of the Final Energize Eastside EIS does not reflect the truth in the evidence I have provided. And Volume 2 of the Final Energize Eastside EIS (which allegedly responds to comments filed on the Draft EIS) does not respond to the bulk of the comments I provided on the Draft EIS. II. Proper method to analyze the possible need for Energize Eastside: The need for a project like Energize Eastside can only be assessed in a proper load flow study. But what is a load flow study? Transmission grids are a complex spider web of interconnected transmission lines. Attached to these lines are substations that take power out of the grid in order to serve load. Also attached to these lines are generating plants that are capable of injecting power into the grid in order to serve the loads. These load and generation substations are connected to the grid in a very large number of locations. The grid itself distributes the sources of power across the transmission lines in accordance with the laws of physics to the load serving substations. Because there is resistance in the grid lines, there is voltage drop and losses that occur when moving the power over the grid. Vendors have developed very sophisticated computer models that are used to determine how the grid will behave under specific conditions. It is the extreme conditions that need to be studied in order to determine the reliability of 2 the grid. If the grid can operate reliably under these extreme conditions, then the grid will be able to operate reliably under the many other conditions that will exist that are not extreme. NERC/FERC have established reliability criteria to be used in Transmission Planning. Those reliability criteria are described in Reliability Standard TPL-001-4. It can be found at: http://www.nerc.com/_layouts/PrintStandard.aspx?standardnumber=TPL-001- 4&title=Transmission%20System%20Planning%20Performance%20Requirements&jurisdiction=United% 20States As indicated in TPL-001-4, each utility needs to maintain system models within its respective area for performing the studies needed to complete its Planning Assessment. These models need to be provided extensive data in order to perform their calculations. TPL-001-4 also describes the data that needs to be input into these models. The input data include: 1.1.1. Existing Facilities 1.1.2. Known outage(s) of generation or Transmission Facility(ies) with a duration of at least six months. 1.1.3. New planned Facilities and changes to existing Facilities 1.1.4. Real and reactive Load forecasts 1.1.5. Known commitments for Firm Transmission Service and Interchange 1.1.6. Resources (supply or demand side) required for Load When the load flow computer model is run with appropriate data the model provides a large amount of “result” data. Such data includes (a) the loading on each line in the interconnected grid, (b) an indication if any lines are overloaded and (c) and indication if voltages get too low in some areas of the grid as a result of voltage drop caused by current flows through the resistance in the lines. These indications point the utility to areas that need to be fixed on the transmission system. There can be many alternative approaches to fix any identified problems on the grid. The load flow modeling is then used to examine each of these alternatives that might be able to fix the problem. The best alternative solution will balance the cost and environmental impact of any fixes that can solve the indicated reliability problem. FERC requires each utility to build and maintain Base Case data that can be used in the load flow computer models and to make Base Case runs and file those with FERC. Then third parties can request that FERC provide those Base Case studies to them so they can perform their own studies of the reliability of the grid. See http://www.ferc.gov/docs-filing/forms/form-715/overview.asp PSE has filed its Base Cases with FERC and I have asked FERC to provide them to me and FERC has provided them to me. III. Problems with load flow studies PSE provided to show the need for Energize Eastside in the EIS process: 3 As I state in the comments I filed on the Draft Energize Eastside EIS, PSE took the unusual step of hiring an outside consultant, Quanta Technology, to run the load flow models in an attempt to justify the need for Energize Eastside, rather than using the PSE in-house transmission planning experts who normally make these kinds of load flow runs. The Quanta load flow study work has been described in several written reports. But those written reports raise red flags that suggest the load flow studies done by Quanta were flawed. For me there were initially three red flags as follows: (a) They erroneously assumed that the proposed Energize Eastside project must increase the ability of BPA to move large amounts of power to and from the Canadian border during extremely cold temperatures in the Puget Sound region (yet there is no Firm Requirement to move power to and from the Canadian Border…See Lauckhart-Schiffman load flow study report at its Appendix D), and (b) They erroneously assumed that essentially all of the PSE owned/controlled power plants located in the Puget Sound region would not be operating during this extremely cold event (yet PSE could not meet its Total System Peak load obligation if these power plants were not operating during an extremely cold event)1, and (c) With their scenario PSE ignores the Puget Sound Area voltage collapse problem that I first talked about in the Puget 1992 IRP (aka Least Cost Plan). (See page 36 of the transcript from the May 26, 1992 public hearing on that plan Docket No. UE-910151 that can be found on the Washington Utilities and Transportation Commission website.) Clearly the PSE/Quanta load flow analysis must have found this voltage collapse problem. This is likely the reason that PSE refuses to provide me the details of the Quanta load flow studies. As I stated in my comments on the Draft Energize Eastside EIS, I was interested in seeing the actual load flow input and output data from the Quanta load flow studies to see what other data input assumptions might not be correct and to see how Quanta might have been able to avoid the voltage collapse problem or whether they simply ignored the voltage collapse problem. PSE refused to let me see the inputs and outputs of load flow studies performed by Quanta. As I stated in my comments on the Draft EIS, the City of Bellevue should refuse to consider the need for Energize Eastside until PSE provides that information for inspection by interested parties. The Final Energize Eastside EIS does not even respond to that comment. IV. Fixing the problems in the PSE/Quanta load flow studies they provided in the EIS process: 1 According to PSE’s IRP, PSE needs 6,500 MW of supply to meet its System Peak plus reserve requirements in the winter of 2018. According to PSE’s IRP, PSE is “short” by about 2100 MW of having sufficient generation to cover this need. While that is a very large “shortage”, it gets even larger (nearly 3,400 MW) under the Quanta load flow model assumptions…an untenable shortage. 4 As I stated in my comments on the Draft EIS, since PSE refused to provide the data in its load flow studies, the only way to fix the problems in the PSE/Quanta load flow studies is to get the Base Case data that PSE filed with FERC and use that data in a standard load flow model to study the need for Energize Eastside. Roger Schiffman and I did that. I provided the Lauckhart-Schiffman load flow study report in my comments on the Draft EIS. In my comments on the Draft EIS I also provided a large number of documents that support the input assumptions I used in the Lauckhart-Schiffman load flow study. The Final EIS does not respond to those documents that supported the assumptions used in the Lauckhart-Schiffman load flow study. I filed the Lauckhart-Schiffman Load Flow study in my comments on the Draft EIS. It is the only Load Flow study on the record in the EIS proceeding that uses the load forecast PSE gave to the Western Electricity Coordinating Council, correct inter-regional flows, appropriate generation dispatch, and avoids the voltage collapse problem. That study concludes that Energize Eastside is not needed now or any time soon. V. Errors in the Energize Eastside Final EIS Volume 1: Volume I of the Final EIS makes the following statement: “PSE indicates that it has a responsibility for planning its system according to NERC, WECC, and ColumbiaGrid requirements. The Lauckhart/Schiffman Load Flow Study makes a number of assumptions that are not consistent with WECC and ColumbiaGrid model assumptions. Even using their assumptions, the City of Bellevue’s independent analysis found that at least one transformer would exceed capacity. No change in Final EIS. See Key Theme OBJ-3 in Appendix J-1.” This statement is incorrect and inexplicably ignores the many comments I made that dispute what is said in this statement. This statement appears to be based in part on the Booga Gilbertson criticisms of the Lauckhart-Schiffman study that were made on March 23, 2016. But the statement completely ignores the rebuttal I made to the Booga Gilberston criticisms on March 28, 2016. I filed my rebuttal to the Booga Gilbertson criticisms in my comments on the Draft EIS. But the Final EIS does not acknowledge this rebuttal. It is as if my rebuttal comments were never filed in the EIS process. That is wrong. This finding also appears to be based on comments made by PSE and Stantec in the Comment Summary Report in the Phase I Draft EIS. But I also provided a rebuttal to these comments in my April 29, 2016 email to the EnergizeEastsideEIS staff titled “Rebuttal to the criticisms of the Lauckhart-Schiffman report that are included in the Phase 1 Draft EIS Comment Summary Report April 14, 2016”.2 The Final EIS also does not acknowledge this rebuttal. It is as if these April 2016 rebuttal comments were never filed in the EIS process. That is wrong. 2 On April 29, 2016 I provided comments on the Phase I EIS titled Rebuttal to the criticisms of the Lauckhart- Schiffman report that are included in the Phase 1 Draft EIS Comment Summary Report April 14, 2016 . [See Attachment 1] 5 Volume I of the Final EIS also makes the following statement: “Significant adverse impacts to utilities (e.g., rolling blackouts) could occur under the No Action Alternative if capacity increases are not implemented, as described in the Phase 1 Draft EIS.” This statement is incorrect and is also not supported by the record. For example, it ignores the extensive comment I made in the comments I provided on the Draft Energize Eastside EIS that were titled “Setting the Record Straight on Energize Eastside’s Technical Facts.” In that document I specifically point out the flaws in the PSE technical analysis and state “Therefore, the No Action alternative will not result in any blackouts caused by load shedding on the Eastside or elsewhere on the grid and the December 21, 2016 statement by EIS staff is incorrect.” The Final EIS did not respond to the technical facts I provide in this document and the Final EIS ignores this crucial fix they need to make to the Energize Eastside Final EIS. VI. Errors in the Energize Eastside Final EIS Volume 2: Volume 2 is supposed to include responses to all comments made by myself and others. But Volume 2 attempts to simplify comments by dumping many comments into “Key Themes”. In the case of my comments, they all appear to have been dumped into the “Key Theme” that Volume 2 calls “Key Theme OBJ‐3: Lauckhart/Schiffman Load Flow Study suggests project is not needed.” In their “Key Theme OBJ-3”, Volume 2 states as follows: “Commenters pointed to five main findings of the Lauckhart/Schiffman study. Each of these main findings is listed in bold below, followed by a response intended to clarify the issue presented. The responses were developed by the EIS Consultant Team after review of the Lauckhart/Schiffman analysis by Stantec and requests for additional information from PSE regarding its planning assumptions and results.” The Final EIS response/clarifications to the Lauckhart/Schiffman five main findings is woefully inadequate by ignoring most of my comments that refute the Final EIS responses on these five main findings. For example, as mentioned above, on April 29, 2016 I provided an email to the EnergizeEastsideEIS staff which included a document titled “Rebuttal to the criticisms of the Lauckhart- Schiffman report that are included in the Phase 1 Draft EIS Comment Summary Report April 14, 2016”. This document rebuts each of these five main points that the Final EIS attempt to “clarify.” But the Final EIS clarifications do not acknowledge this April 2016 document I provided on these 5 main topics. It is as if these April 2016 rebuttal comments were never filed in the EIS process. That is wrong because the April 2016 rebuttal I provided to the EIS discredits each of these 5 “clarifications” included in the Final EIS. The Chain of events in this EIS went as follows: 6 1. I read the PSE/Quanta Reports on the load flow studies they ran to justify EE 2. I observed the reports provided information on key inputs to the studies, which key input assumptions were flawed 3. I requested that PSE give me the entire data set of input and output assumptions so I could see what other errors PSE/Quanta may have made and to allow me to re-run their load flow studies with fixed input assumptions. 4. PSE refused to show me the load flow data set. 5. I asked FERC to send me the Base Case data set that PSE had provided to FERC. FERC provided me that data set. 6. I observed that the PSE Base Case included better assumptions than what was used by PSE/Quanta in their attempt to justify the need for EE. 7. I recruited a colleague, Roger Schiffman, to license the GE-PSLF load flow model from General Electric and we studied the need for EE with the PSE Base Case data set. We found that EE is not needed now or anytime soon if proper input assumptions are made in the load flow modeling. 8. Roger Schiffman and I wrote the report titled “Load Flow Modeling for Energize Eastside” dated February 18, 2016 and provided it to the Energize Eastside EIS staff. 9. On March 23, 2016 Booga Gilberston of PSE wrote comments criticizing the Lauckhart- Schiffman load flow study report. 10. On March 28, 2016 I wrote a rebuttal to the March 23, 2016 Booga Gilbertson criticisms and sent that to the Energize Eastside staff. In that March 28, 2016 rebuttal I pointed out the main areas of disagreement with the PSE/Quanta load flow studies and the Booga Gilbertson criticisms of it. I posed 7 key questions/challenges for PSE to respond to. PSE never responded. The EIS staff did not require PSE to respond. 11. The Energize Eastside EIS provided a compendium of all comments provided in the Phase I EIS. I observed that PSE and Stantec had commented again on the Lauckhart- Schiffman report. I observed that once again these new PSE and Stantec comments were flawed. So on April 29, 2016 I provided and email to the Energize Eastside staff that included an attachment titled “Rebuttal to the criticisms of the Lauckhart- Schiffman report that are included in the Phase 1 Draft EIS Comment Summary Report April 14, 2016.” 12. In the Final Energize Eastside EIS the EIS staff quoted extensively from the PSE and Stantec criticisms listed above but did not quote from (a) the Lauckhart-Schiffman report or (b) my March 28, 2016 rebuttal or (c) my April 2016 rebuttal. The detailed findings in the Volume 2 “Key Theme OBJ‐3: Lauckhart/Schiffman Load Flow Study suggests project is not needed” are provided below. I first provide in italics the Volume 2 EIS staff “Finding” on the Lauckhart-Schiffman report. Then I provide the EIS staff “clarification” of that finding. Then I provide my response to that “clarification” in which I point out the problems with the EIS staff “clarifications” and the fact that the EIS staff ignored the rebuttal documents I provided as indicated above. I. The First Main Finding: Lauckhart/Schiffman study finding #1 listed in Volume 2 of the FEIS: PSE modified data to increase transmission of electricity to Canada from 500 megawatts (MW) to 1,500 MW, which during winter peak 7 loads creates instability in the regional grid. (The Lauckhart/Schiffman study authors assert this is an unrealistic level of electricity transmitted to Canada.) • EIS staff “clarification” of the finding #1: PSE did modify the Western Electricity Coordinating Council (WECC) model to reflect this amount of peak energy flow to Canada. According to Stantec, modification of the WECC model is a commonly accepted practice, where an individual utility provider uses the model to evaluate its specific system. PSE confirmed that the value for the energy flow to Canada (over the Northern Intertie) that is in the base case was set at 500 MW by WECC, as a starting place for planning studies. Planners are expected to adjust that value to reflect firm transmission commitments, as required by North American Electric Reliability Corporation (NERC) planning standard TPL-001-4 R1. PSE used the value set in its agreements with the regional planning authorities, specifically from the ColumbiaGrid Biennial Plan. Neither the 500 MW nor the 1,500 MW numbers reflect the maximum flows that actually occur over the Northern Intertie during winter conditions. BPA data show that the maximum flow exceeds 2,000 MW at times. The 1,500 MW value is considered reasonable by ColumbiaGrid in its Biennial Plan for planning for heavy winter conditions, which is PSE’s justification for making this modification in the model. According to Stantec, this is the type of adjustment that utility providers are expected to make when using the WECC model for system planning. Furthermore, of the energy flowing over the Northern Intertie, only a small portion flows through the Eastside. The EIS Consultant Team asked PSE to clarify how much of the Northern Intertie flow was flowing through the substations on the Eastside where the capacity deficiency has been identified. PSE clarified that between 1 and 2 percent (15 and 30 MW) of the 1,500 MW flowing north over the Northern Intertie in the heavy winter model currently flows through the substations on the Eastside. The lower value is the amount of flow that would be expected under normal conditions (with all regional grid systems functioning). Stantec confirmed that this was consistent with their expectations, given the presence of higher capacity lines in the region that would have lower resistance than PSE’s existing 115 kV lines, and therefore would be more likely to carry the load flowing north over the Intertie. If the Energize Eastside project were built, PSE indicated that according to the model, this flow would increase to 45 MW under normal conditions. PSE also clarified that the direction and strength of the flow of power can determine which substation would feed the Eastside (Sammamish or Talbot Hill). Under conditions where other portions of the regional grid are not fully functioning, the flow on the proposed lines could rise to as much as 120 MW. Stantec again confirmed that this was a reasonably expected outcome, because the new lines would have lower resistance than the existing lines. While increased flow through the Eastside to the Northern Intertie is an expected result of the upgraded capacity on the Eastside, the increase is not one of PSE’s objectives for the Energize Eastside project, but simply a byproduct of the capacity increase. • This Final EIS “Clarification” of the Lauckhart/Schiffman study finding #1 is woefully inadequate. For example 1. It ignores the extensive comments I made on March 28, 2016 in which I rebut the PSE criticisms of the Lauckhart-Schiffman report and provide 7 key questions and challenges to PSE related to their criticisms of the Lauckhart-Schiffman report. PSE has never responded to these 7 key questions and challenges. This March 28, 2016 rebuttal document was filed as a comment on the Energize Eastside EIS, but the Final EIS does not address these comments. It 8 also ignores my criticism of the PSE and Stantec comments in the Phase I EIS of the Lauckhart-Schiffman report. 2. It also ignores the criticisms I made of Stantec in the Lauckhart-Schiffman load flow study report. 3. Further, by claiming the Lauckhart/Schiffman study uses a WECC Base Case (presuming this is not also the PSE Base Case), this Final EIS Response to Lauckhart/Schiffman study ignores Appendix B “Choice of Basecase” in the Lauckhart/Schiffman study which states clearly that the PSE Base Case is the same as the WECC Base Case. 4. In its Energize Eastside studies, PSE did not just modify the WECC Base Case, the fact is PSE modified its own Base Case… because use of its own Base Case would not be able to demonstrate the need for Energize Eastside. 5. And while this Final EIS response points out that “Neither the 500 MW nor the 1,500 MW numbers reflect the maximum flows that actually occur over the Northern Intertie during winter conditions” this statement fails to recognize that I have pointed out in my March 28, 2016 rebuttal document that the problem arises during heavy winter conditions. 6. One of the Key Questions/Challenges in that rebuttal document was for PSE to provide examples when 1,500 MW was transferred to Canada when temperatures in the Puget Sound region were lower than 23 degrees Fahrenheit as stipulated in PSE’s Energize Eastside Needs Assessment. PSE never responded to this question/challenge and the EIS staff apparently did not require them to do so. II. The Second Main Finding: Lauckhart/Schiffman study finding #2 listed in Volume 2 of the FEIS: PSE assumed that six local generation plants were out of service, adding 1,400 MW of demand for transmission. This assumption also causes problems for the regional grid. (The Lauckhart/Schiffman study authors questioned PSE’s rationale for this assumption.) • EIS staff “clarification” of the finding #2: It is acknowledged that failure of components of PSE's system simultaneously with a high demand period due to high or low temperatures is not a common event. As noted in the Phase 1 Draft EIS, however, having one component of its system down for planned maintenance is relatively common throughout the year. While the exact probability of such an event is not of concern under SEPA, it is acknowledged that it is possible that in any given year, it might not occur. NERC standards require PSE models to “stress the system” to ensure that PSE’s system would operate without damaging other parts of the grid when such stresses occur. PSE ran the model with a group of plants “out of service” for the “low generation scenario” in testing its system. PSE also ran a “low-average generation” scenario with 1,000 MW of generation turned on, to determine if running generation would relieve the overloads seen with the low generation scenario. PSE found that, while the transmission line overloads seen with the low generation scenario were relieved by running generation, the transformer overloads were not relieved for the full 10-year planning period. In the “winter scenarios,” adding 1,000 MW of Puget Sound area generation resulted in 15 MW of change in loading at the Talbot Hill substation, which is not enough to address the increased demand over the 10-year planning period. Having these plants out of service was not the only stress that was modeled. PSE indicated that its studies identified up to 40 different contingencies that violated 9 the NERC standards over the 5- to 10- year study period. In other words, while having the Puget Sound area generation plants out of service was one scenario that contributes to the transmission capacity deficiency PSE has identified, there are others that also could result in violations of the reliability standards, regardless of whether these generators were considered to be “on” or not. Stantec reviewed the results showing there were cases in which, even with these plants set as “on” in the model, there were still overloads in the Eastside, indicating that those overloads are a problem local to the Eastside (Stantec, 2015). • This Final EIS “Clarification” of the Lauckhart/Schiffman study finding #2 is woefully inadequate. For example 1. It ignores the extensive comments I made on March 28, 2016 in which I rebut the PSE criticisms of the Lauckhart-Schiffman report and provide 7 key questions and challenges to PSE related to their criticisms of the Lauckhart-Schiffman report. PSE has never responded to these 7 key questions and challenges. 2. One of those key questions/challenges was for PSE to cite standards that require them to turn off 6 local generation plants at the same time they are serving peak demand under N- 1-1 contingency conditions. PSE never responded to this question/challenge and the EIS staff apparently did not require them to do so. 3. Further, it is both standard practice and prudent utility practice to not schedule maintenance on generation facilities during those times of the year when annual peak load can occur. For example, PSE does not schedule maintenance on its gas fired generation in the Puget Sound area during the winter months when temperatures can get below 23 degrees Fahrenheit during peak hours. 4. This March 28, 2016 rebuttal document was filed as a comment on the Energize Eastside EIS, but the Final EIS does not address these comments. 5. The Final EIS response also ignores my criticism of Stantec in the Lauckhart-Schiffman report and other criticisms I have made of Stantec. See Footnote 2 above. 6. Two of the Key questions in the March 28, 2016 rebuttal document ask PSE to (1) point to specific language in the NERC standards that require PSE to stress the system by requiring 1,500 MW to Flow to Canada and (2) provide a copy of any contract that evidences the existence of a firm commitment to move Treaty power to Canada. PSE has never responded to these questions and for some reason the EIS staff did not ask or require PSE to respond to these questions. The EIS staff appears to simply be taking PSE’s words for it. III. The Third Main Finding: Lauckhart/Schiffman study finding #3 listed in Volume 2 of the FEIS: The study authors assert that even if the regional grid could sustain the level of demand under the condition set up by the first two findings, it is unlikely that regional grid coordinators would continue to deliver 1,500 MW to Canada while emergency conditions were occurring on the Eastside. • EIS staff “clarification” of the finding #3: PSE indicates that it has a responsibility for planning its system according to NERC requirements. Operation of the system as it relates to the flows on the Northern Intertie is up to BPA and not within PSE’s control. PSE used the load levels that 10 were in the WECC model because those are the conditions that utility operators in the region agree that each utility’s system should be capable of accommodating. Furthermore, less than 5 percent of the northward flow over the Intertie flows through the Eastside. Therefore, to use curtailments over the Intertie as a means to address congestion on the Eastside as suggested in the comment, flows over the Intertie would have to be reduced by approximately 20 times the amount of the deficit being experienced on the Eastside transmission system. • This Final EIS “Clarification” of the Lauckhart/Schiffman study finding #3 is woefully inadequate. For example: 1. It ignores the extensive comments I made on March 28, 2016 in which I rebut the PSE criticisms of the Lauckhart-Schiffman report and provide 7 key questions and challenges to PSE related to their criticisms of the Lauckhart-Schiffman report. PSE has never responded to these 7 key questions and challenges. 2. This March 28, 2016 rebuttal document was filed as a comment on the Energize Eastside EIS, but the Final EIS does not address these comments. 3. It also ignores the discussion in the Lauckhart-Schiffman report about the low voltage (aka Voltage Collapse) problem that would occur under the PSE problematic scenario. 4. One of the Key questions in the March 28, 2016 rebuttal document asks PSE to answer how they dealt with this problem. PSE has never responded to this question and for some reason the EIS staff did not ask or require PSE to respond to this question. The EIS staff appears to simply be taking PSE’s words for it. IV. The Fourth Main Finding: Lauckhart/Schiffman study finding #4 listed in Volume 2 of the FEIS: The WECC base case contains a default assumption that PSE may not have corrected. The ratings for critical transformers are based on “summer normal” conditions, but the simulation should use significantly higher “winter emergency” ratings. The study authors suggest the default value could cause PSE to underestimate system capacity and overstate urgency to build the project. • EIS staff “clarification” of the finding #4: PSE used multiple WECC base cases for different study years and seasons, as confirmed by Stantec. PSE has confirmed that they used all the correct ratings in the model, including adjusting for summer, winter, and emergency conditions as required for each scenario evaluated. Stantec confirmed that results are consistent with such adjustments being made, although they did not independently verify all settings in PSE’s model. To do so would require extensive analysis, including verifying the capacity of every piece of equipment that PSE operates, and evaluating past and expected trends in energy usage by PSE customers, which was not considered necessary for purposes of SEPA review. • This Final EIS “Clarification” of the Lauckhart/Schiffman study finding #4 is woefully inadequate. For example 1. it acknowledges that Stantec did not independently verify the settings in PSE’s model. Why not? As I have commented in the EIS process, Stantec needs to verify these setting by looking at the model inputs. 11 2. Stantecs defense that it would require extensive analysis to verify these settings is not sufficient. I have indicated in my comments on the EIS that there should be no finding of “need” unless and until PSE makes its load flow models available for inspection. The EIS staff has ignored these comments. V. The Fifth Main Finding: Lauckhart/Schiffman study finding #5 listed in Volume 2 of the FEIS: The base case shows a demand growth rate of 0.5 percent per year for the Eastside. This is much lower than the 2.4 percent growth rate that PSE cites as motivation for Energize Eastside. • EIS staff “clarification” of the finding #5: WECC base cases are based on each utility’s latest load forecast for the specific years being modeled. The WECC base case in 2012 did not have a specific growth rate from PSE for the Eastside because PSE only performed a system-wide forecast for 2012. The 0.5 percent growth rate cited by the Lauckhart/Schiffman report for the Eastside reflected average growth for PSE’s entire system. The WECC base case did not include a specific rate for the Eastside. PSE subsequently determined that the load for the Eastside area studied in the Phase 1 Draft EIS is expected to grow at a faster rate than the rest of the PSE system. As described in the Phase 1 Draft EIS, PSE’s analysis of growth expected for the Eastside was 2.4 percent. PSE used regional planning employment and population projections provided by the Puget Sound Regional Council and accounted for known growth expectations of its major customers. PSE’s Eastside Needs Assessment Report prepared by PSE, the Supplemental Eastside Needs Assessment Report prepared by Quanta Technology and PSE, and the Independent Technical Analysis prepared by Utility System Efficiencies, Inc. for the City of Bellevue confirms the project need. Stantec reviewed the analyses and found them to be in accord with standard industry practice for electrical system planning. PSE also provided specific comments on the Energize Eastside Phase 1 Draft EIS (March 14, 2016), which are posted on the Partner Cities’ project website at www.EnergizeEastsideEIS.org, as well as in this appendix (following the response to comment narrative). • This Final EIS “Clarification” of the Lauckhart/Schiffman study finding #5 is woefully inadequate. For example 1. It ignores the extensive comments I made on March 28, 2016 in which I rebut the PSE criticisms of the Lauckhart-Schiffman report and provide 7 key questions and challenges to PSE related to their criticisms of the Lauckhart-Schiffman report. PSE has never responded to these 7 key questions and challenges. 2. One of the key questions/challenges made to PSE in this rebuttal documents was a challenged to PSE to explain their methodology leading to a 2.4% growth rate. PSE has never responded to this key question and apparently the EIS staff did not require them to do so. 3. Further, this Final EIS response suggest that the 0.5% was an older forecast that needed to be updated. But it is clear from the most recent Base Case that PSE filed with FERC that the 0.5% is still being used. And that 0.5 % number better reflects what other fast-growing utilities are including in their forecasts of substation increased peak demand. 12 4. Further, this Final EIS “clarification” states that Utility Systems Efficiencies confirms the need for the project. But this statement ignores the following statement that is included in my March 28, 2016 rebuttal to the Booga Gilbertson criticisms: “PSE likes to quote the conclusion of the study performed by Utility System Efficiencies, while ignoring the most stunning finding of the USE report. On page 65 of that report, USE found that 4 of the 5 overloads on PSE’s system disappear if electricity exports to Canada are reduced. The remaining overload is so minor that it could easily be remedied with a relatively inexpensive upgrade to a single transformer or simply by turning on more Puget Sound Area generation.” 5. This March 28, 2016 rebuttal document was filed as a comment on the Energize Eastside EIS, but the Final EIS does not address these comments. 6. The FEIS “clarification” also ignores my criticism of the USE study and the Stantec writings in the Lauckhart-Schiffman report. VII. Conclusion: The Final EIS makes erroneous statements that are not supported by the record. The Final EIS does not properly acknowledge the many comments I made on the draft EIS and makes erroneous conclusions about the need for Energize Eastside and the environmental impacts of the “no action” alternative. This Final EIS, as written, should not be given any weight on the question of whether or not the Conditional Use Permit Application for Energize Eastside should be approved. The Final EIS should acknowledge the fact that there are no adverse environmental effects under the “no action” alternative. 13 Attachment 1 Lauckhart comment to clarify issues for The Energize Eastside Phase 2 Scoping Richard Fri 4/29/2016, 6:57 PM info@EnergizeEastsideEIS.org (info@energizeeastsideeis.org); JStokes@bellevuewa.gov (jstokes@bellevuewa.gov); jchelminiak@bellevuewa.gov; +7 more Sent Items Rebuttal to the criticisms of the L-S with attachment.pdf 2 MB Chronology of Lauckhart CEII requests to PSE.pdf 333 KB Email to: info@EnergizeEastsideEIS.org Re: Clarification of key issues My name is Richard Lauckhart. As you know, I co-authored the Lauckhart-Schiffman “Load Flow Modeling for Energize Eastside” report dated February 18, 2016 which was submitted as part of the EIS record. This report has been repeatedly criticized by the PSE and Stantec. Yet, neither Stantec nor PSE have provided factual and reasonable explanations for such criticism. By way of this letter, I would like to, on record: …….Reiterate key facts regarding my credentials and backgrou nd; and …….Convey to you what I consider to be key points of concern which I recommend that you give particular attention. My credentials and background I am a nationally recognized expert in Pacific Northwest power and transmission planning. I spent more than 20 years in working for Puget Power (PSE’s predecessor) holding numerous positions including transmission and power planning until 1996, including Vice President of power planning. In large part because of my expertise with power and transmission matters in the Pacific Northwest, I was hired by energy consulting firms headquartered in California including Black & Veatch, a global leader in energy consulting, where I worked until 2011. For all of these California based consulting firms I lead their WECC Power Market advisory service which included advice on what was happening in the Pacific Northwest. Since ending my employment with Black & Veatch I have provided independent consulting services to various organizations, including CENSE. As an expert in this field, I am fully up to date on all regional and federal rules and requirements (such as NERC). I am also one of the very few people remaining in the power industry who is intimately familiar with all aspects of the Columbia River treaty 14 and its implications. Moreover, the project which is proposed by PSE (Energize Eastside) utilizes the same concepts and technologies as the dozens of projects I oversaw in my career as Vice President of power planning for Puget Power. Continued lack of reliability of PSE’s load flow study As you are aware, the Lauckhart-Schiffman load flow study raised several serious questions and concerns about how PSE conducted its load flow study. Perhaps realizing the seriousness of issues with its load flow study, PSE and Stantec continue to criticize the Lauckhart-Schiffman load flow study without providing factual support for their arguments. This type of criticism is unsettling given what is at stake for Bellevue and other communities if the ill-conceived Energize Eastside project is built but also, on a personal note, given what appears to be an intentional campaign of misinformation concerning my credentials and expertise. I continue to stand by the integrity and professionalism of the Lauckhart- Schiffman study. To provide further detail and clarification, I have attached document provides an updated response to Stantec and PSE criticisms. I cannot stress this point enough: a reliable load flow study must be the foundation to the entire project. Without verifiable proof that the need for the project truly exists, the City is potentially wasting valuable time, resources and energy. Concerns about PSE’s load flow study could easily be put to rest if PSE were willing to work with me (as the representative of CENSE) in a cooperative manner. To accomplish this, PSE would only have to share data, which, given the magnitude of the EIS process, seems like a simple solution. However, to this date, PSE has continuously refused to produce answers to basic and reasonable questions (please note that I possess all the necessary governmental security clearances). For your records, I have attached a chronology of my attempts at obtaining the data from them that would answer these critical questions. The attached chronology shows that the only hope to start a factual and data driven dialog between PSE and CENSE concerning load flow studies is your involvement. I trust that you will consider this matter and help foster this dialog. Thank you for your time and consideration of this information. I am happy to answer any and all questions you may have for me. Kind regards, Richard Lauckhart Energy Consultant Davis, California 916-769-6704 15 Rebuttal to the criticisms of the Lauckhart-Schiffman report that are included in the Phase 1 Draft EIS Comment Summary Report April 14, 2016. The Phase 1 Draft EIS Comment Summary Report criticizes the Lauckhart-Schiffman study in five areas. These criticisms are unfounded and baseless and it is imperative that the record reflect Lauckhart and Schiffman’s responses. The following indicates in italics the Lauckhart-Schiffman finding number, followed by a summary of the Stantec criticism of that finding and Lauckhart’s response to the Stantec criticism. Lauckhart/Schiffman study finding #1: PSE modified data to increase transmission of electricity to Canada from 500 megawatts (MW) to 1,500 MW, which during winter peak loads creates instability in the regional grid. (The Lauckhart/Shiffman study authors assert this is an unrealistic level of electricity transmitted to Canada.) Stantec criticized finding #1 by first acknowledging that the WECC and PSE Base Cases for winter 2018 do in fact have only 500 MW flowing to Canada. But Stantec then goes on to say that this number should be expected to change in order to reflect firm transmission commitments as required by North American Electric Reliability Corporation (NERC) planning standard TPL-001-4 R1. This criticism fails due to the fact that there is no evidence that there is a firm transmissions commitment to deliver 1,500 MW to Canada. We challenge Stantec or the EIS team to produce a contract that includes a firm commitment to deliver 1,500 MW to Canada. This is the same challenge that was posed to PSE, ColumbiaGrid and BPA in a March 28, 2016 letter from me to Bellevue Mayor Stokes and Council members. So far no such evidence has been provided. Stantec also criticizes finding #1 by stating that “Neither the 500 MW nor the 1,500 MW numbers reflect the maximum flows that actually occur over the Northern Intertie during winter conditions. BPA data shows that the maximum flow exceeds 2,000 MW at times.” This statement by Stantec demonstrates that Stantec is confused about what causes transmission congestion. The power flows generally originate in the Columbia River area. But the power must cross the Cascade Mountains to reach the Puget Sound area, and the eleven transmission lines crossing the Cascade Mountains have limitations. For example, if loads in the Puget Sound area are light (e.g. on a winter day at 2 a.m. when the temperature is 50 degrees Fahrenheit), these lines have low load and can accommodate lots of power flowing to Canada. However, on an extremely cold winter day when loads are high (e.g. at 6 p.m. on a weekday when the temperature is 23 degrees Fahrenheit), these same eleven lines crossing the Cascade Mountains are heavily loaded just to serve load in the Puget Sound area. There is no ability to add another 1,500 MW to these lines to deliver to Canada. We challenge Stantec to provide examples of when the temperature was 23 degrees Fahrenheit at 6 p.m. on a weekday and simultaneously, lots of power is being delivered to Canada. This is the same challenge that was posed to PSE in a March 28, 2016 letter from Mr. Lauckhart to Bellevue Mayor Stokes and Council members. So far no such example has been provided. 16 Lastly on this point, the DEIS Comment Summary report stated that only small amounts of power flow through the Eastside when 1,500 MW flows to Canada. This criticism is based on PSE’s statements (not demonstrated) and Stantec’s subjective view that this theoretically would be the case. But these statements and views are not borne out by the USE load flow models (which showed that 4 of the 5 overloaded facilities are no longer overloaded if the 1,500 MW to Canada is removed) and the Lauckhart-Schiffman study shows that 1,500 MW flow to Canada during extreme cold events cannot even occur without causing blackouts in the Puget Sound area due to limitations on the eleven lines crossing the Cascades. We ask Stantec to show that 1,500 MW can flow to Canada during extreme cold events by showing us a load flow study that demonstrates that to be true. This is the same challenge that was posed to PSE in a March 28, 2016 letter from Mr. Lauckhart to Bellevue Mayor Stokes and Council members. So far no such example has been provided and PSE continues to resist showing us their load flow files. If Stantec has made a load flow study of this case, we ask them to provide that information to us also. Lauckhart/Schiffman study finding #2: PSE assumed that six local generation plants were out of service, adding 1,400 MW of demand for transmission. This assumption also causes problems for the regional grid. (The Lauckhart/Schiffman study authors questioned PSE’s rationale for this assumption.) Criticism of this finding was based on a statement in the DEIS Summary Report that “NERC standards require PSE models to ‘stress the system’ to ensure that PSE’s system would operate without damaging other parts of the grid when such stresses occur.” There is no NERC standard that requires a planning study to assume that six local generators have failed at the same time as two transformers have failed and at the same time the system is experiencing a peak load event. We ask the EIS staff to cite to the NERC reliability criteria that requires a scenario such as six local generators to be offline under these conditions or that any other similar ‘stress’ is required by NERC Reliability Criteria. This is the same request that was asked of PSE in a March 28, 2016 letter from me to Bellevue Mayor Stokes and Council members. So far no such citation has been provided. Lauckhart/Schiffman study finding #3: The study authors assert that even if the regional grid could sustain the level of demand under the condition set up by the first two findings, it is unlikely that regional grid coordinators would continue to deliver 1,500 MW to Canada while emergency conditions were occurring on the Eastside. The criticism of this finding appears to be based on the fact that PSE does not have control over what BPA would do under these conditions. But the fact remains that both BPA and the Northwest Reliability Coordinator have a FERC/NERC based responsibility to assure that operation of the system is done in a reliable fashion. If they do not operate in a prudent manner (which requires assuring reliability above all else) and the result is a blackout (which is what would happen under the PSE load flow assumptions), then both FERC and BPA would be subjected to large penalties for having failed in their obligations. 17 Lauckhart/Schiffman study finding #4: The WECC base case contains a default assumption that PSE may not have corrected. The capability ratings for critical transformers are based on “summer normal” conditions, but any load flow study conducted by PSE should use significantly higher “winter emergency” ratings. Lauckhart-Schiffman suggest the default “summer normal” value could cause PSE to underestimate system capacity and overstate the urgency to build the project. In the draft EIS summary report, Stantec dismissed our finding by stating that they asked PSE if they used the correct rating, and PSE stated they did. However, Stantec did not ask to see the ratings PSE used and simply took PSE’s response at face value. This is a significant point that needs to be independently verified because even if the load growth forecast is indeed 2.4 percent, the year in which the “customer demand” outpaces “electricity” in the “Eastside Customer Demand Forecast” graph which is the image PSE uses as the basis for the whole project would be pushed out past the year 2025. PSE needs to provide its load flow data files so stakeholders can see for themselves what PSE used. The fact that PSE continues to refuse to share the files associated with their Energize Eastside load flow study is indication that PSE may well be aware that there are problems in it. Lauckhart/Schiffman study finding #5: The WECC base case shows a demand growth rate of 0.5 percent per year for the Eastside. This is much lower than the 2.4 percent demand growth rate that PSE cites as motivation for Energize Eastside. The criticism of this Lauckhart-Schiffmann finding appears to be based on the fact that loads (and the accompanying demand growth rates) in the WECC Base Cases were developed in the year 2012 and PSE has since updated their load forecast. However, these same loads and demand growth rates (0.5%) were included in the 2014 and 2015 Base Cases that were filed with FERC. Therefor e, they are the same loads and demand growth rates in the most recent Base Cases that WECC utilities are using to study the adequacy of the grid. The criticism indicates that a new load forecast for the Eastside will show 2.4% demand growth rate. But no independent consultant has verified the accuracy of PSE’s projections and furthermore, no one has studied the load on each substation on the Eastside. One needs to know what the load is on each substation in order to run a load flow study. We ask the EIS staff to explain the methodology leading to a 2.4 percent demand growth rate. This is the same challenge that was posed to PSE in a March 28, 2016 letter from me to Bellevue Mayor Stokes and Council members. So far no such explanation has been provided and PSE has not provided information on what individual substation loading will be under this forecast. For completeness, I am attaching the March 28, 2016 letter from myself to Bellevue Mayor Stokes and Council members that are referenced in the responses above.