HomeMy WebLinkAboutC_Public_Comment_42.b_180614.email_attach2of2Comments made by Richard Lauckhart
December 11, 2017
on
Puget Sound Energy application for a Conditional Use Permit File # 17-
120556-LB) ("Application")
These comments include:
1. Introduction
2. A general overview of the comments
3. Comments on specific language in the Application
4. Supporting Attachments 1-17
1. Introduction
My name is Richard Lauckhart. My resume' is included in Supporting Attachment 1 at its Appendix H
have worked in the electric power industry for 40+ years. For 22 of those years I worked for Puget,
most notably 5 years as Vice President of Power Planning. Since leaving Puget, I spent the rest of my
career as a consultant in the electric power industry.
Since May of 2015 1 have spent considerable time and energy investigating PSE's proposed Energize
Eastside project. I have investigated this project on a deeply technical level, for no compensation
whatsoever, because I am compelled by my conscience. I would be very much concerned to see home
owners and ratepayers in the PSE service territory unnecessarily being subjected to environmental
harm, safety risk and increases in their power rates.
As these comments will demonstrate the Energize Eastside line is not needed now or any time soon.
The Supporting Attachments 1-17 to these comments necessarily lead one to this conclusion. PSE has
been aware of these 17 documents through their Integrated Resource Plan activity with the WUTC
[WUTC Docket No. UE-160918] and other forums for a long time. These 17 documents are also an
official part of the record at the WUTC in Docket No. UE-160918. PSE has ignored these 17 documents
in this Application. It is as if these documents do not exist.
By these comments I am including these 17 documents and discussing their relevance to the decisions
that will be made by the City of Bellevue in this permit Application.
2. General Overview of Comments
The PSE Application is voluminous and deals with many aspects of their proposed Energize Eastside
transmission project. The NEED for the project is a key matter that needs to be addressed. I am an
expert in studying the need for these kinds of projects. In Section 3 to these comments I will be
commenting specifically on those portions of the Application that address the question of project NEED.
It is standard industry practice to use a "Load Flow" model to determine the need for a transmission
project like Energize Eastside. In order to assess the reliability of the grid, analysts use specialized
computer software to simulate failure of one or two major components while serving peak load
conditions. Sometimes these models are called "Power Flow" models — PSE tends to use the term
Power Flow model but such a model is the same as a Load Flow model. Just different terminology.
The PSE Application refers to various Load Flow studies that were done which they claim demonstrate
the NEED for Energize Eastside. In part 3 of these comments I will point to specific language in the
Application where PSE identified Load Flow modeling that they claim demonstrate the NEED for the
project. I will also point out the flaws in each of these Load Flow modeling efforts.
In a nutshell, the Load Flow modeling performed by PSE/Quanta is flawed. The primary problem with
their Load Flow modeling is that
(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 Canada during extremely cold
temperatures in the Puget Sound region [See PSE Application — 'Alternative Siting Analysis" —
PDF page 142 — Quanta October 2013 study at page 32, item 4.1.8], and
(b) They erroneously assumed that essentially all of their owned/controlled power plants
located in the Puget Sound region would not be operating during this extremely cold event.
[See PSE Application — "Alternative Siting Analysis" — PDF page 142 — Quanta October 2013
study at page 32, item 4.1.9]
Neither one of these assumptions is legitimate.
First, there is no firm requirement to move large amounts of power to and from Canada. See Supporting
Attachments 3, 4, 8, and 13. Second, it would make no sense for PSE to fail to run its Puget Sound Area
generation in an extremely cold event. PSE could not meet its total System Peak load in such an event if
they did not run their Puget Sound Area generation. See Supporting Attachment 5, at pages 22-26. See
also Supporting Attachment 7.
PSE is not answering questions/challenges related to problems with their Load Flow studies. The
following questions/challenges were asked once on March 28, 2016 [See Supporting Attachment 21 and
again on October 5, 2017 [See Supporting Attachment 14]. PSE has never answered these
questions/challenges. These questions/challenges are:
1. [We] challenge PSE or ColumbiaGrid to cite a specific requirement to transmit 1,500 MW
to Canada in the NERC Reliability Criteria or PEFA.
2. [We] challenge PSE, ColumbiaGrid, or BPA to produce a contract showing a Firm
Commitment to deliver 1,500 MW to Canada.
3. [We] challenge PSE to prove that they did not increase flow to Canada relative to the
WECC Base Case.
4. [We] challenge PSE to explain how they solved issues that arise from their scenario with
the electrical limits of the "West of Cascades -North" transmission lines.
5. [We] challenge PSE to explain their methodology leading to a 2.4% growth rate. We
further challenge PSE to dispute the methodology used by Lauckhart-Schiffman to
estimate future growth. Both methods should be reviewed by qualified experts.
6. [We] challenge PSE to cite standards that require them to turn off 6 local generation plants
at the same time they are serving peak demand with an N-1-1 contingency-
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7. [We] challenge PSE or BPA to provide examples of when 1,500 MW was transferred to
Canada when temperatures in the Puget Sound region were lower than 23° F, as
stipulated in PSE's Energize Eastside Needs Assessment.
During its review of this PSE Application, the City of Bellevue should demand that PSE respond to these
questions/challenges.
But there is even a more critical question that PSE has been asked which it has never answered. That
question is "Why has PSE chosen not to re -run their flawed EE load flow studies to fix the flaws?" See
Supporting Attachment 15. During its review of this PSE Application, the City of Bellevue should demand
that PSE respond to this critical question and demand that PSE re -run its load flow models with these
flaws fixed.
PSE claims that the FERC denial of the CENSE Complaint somehow sends a message that FERC believes
the Energize Eastside line should be built. Nothing could be further from the truth. The FERC Order
denied CENSE's request that FERC use their authorities under FERC Order 1000 to require ColumbiaGrid
to run correct load flow studies on the need for Energize Eastside in an o en and transparent manner
with stakeholder input. See Application copy of FERC Order in Conditional Use Narrative at paragraph 5.
FERC did not say the Energize Eastside project should be built. As I state in more detail in Section 3
number 3 below, FERC denied this CENSE complaint/request because FERC pointed out that "...neither
Puget Sound nor any other eligible party, requested to have the promect selected in the regional
transmission plan..." See Application copy of FERC Order in Conditional Use Narrative at paragraph 62.
That being the case, FERC stated it does not have 'urisdiction to require ColumbiaGrid to do the CENSE
requested load flow studies with stakeholder input. That is why FERC denied the CENSE complaint.
FERC stated that its only jurisdiction in the Energize Eastside matter was its requirement that PSE have
ColumbiaGrid demonstrate that this transmission project, which is being built solely for local reliability
purposes, does not adversely impact neighboring utilities. FERC acknowledged in their Order denying
the CENSE complaint that ColumbiaGrid did make that finding. But as indicated above, the writing in the
PSE/Quanta reports states that the studies were intended to find a solution for the East Side that
enhanced BPA's ability to move power to and from Canada. So, who would expect that the Energize
Eastside project would have an adverse impact on BPA? Since, as FERC has stated, Energize Eastside is
not a part of a Regional Plan, then it is wrong to require the Energize Eastside load flow studies to
enhance BPAs ability to move power to and from Canada. The PSE/Quanta load flow studies should
have been redone to remove this requirement. The Lauckhart-Schiffman load flow studies removed that
inappropriate requirement. See Supporting Attachment 1 at its Appendix D.
PSE recently has claimed that Canadian transfers and generation dispatch have no relevance to the need
for Energize Eastside. See Supporting Attachment 17. To prove that they are irrelevant, PSE should
rerun the load flow studies without inter -regional flows and with local generation operating. Because
PSE refuses to run Load Flow studies without the problematic inputs, I worked with my colleague Roger
Schiffman to run corrected Load Flow studies ourselves. See Supporting Attachment 1. The Lauckhart-
Schiffman Load Flow study found there is no transformer capacity issue or other reliability problem
when these inputs are corrected,
Unless PSE reruns its Load Flow models and makes them available for inspection for people like myself
that have CEII clearance from FERC, the only correct Load Flow model run on the record regarding the
need for Energize Eastside is the Lauckhart-Schiffman Load Flow study. The Lauckhart-Schiffman study
3
is the only one that uses the load forecast PSE gave to the Western Electricity Coordinating Council,
correct inter -regional flows, and appropriate generation dispatch. That study concludes that Energize
Eastside is not needed now or any time soon.
I have also identified alternatives that would be better than EE if in the future there is a need for
reliability improvements on the Eastside. These include more DSM, batteries, 230/115 transformer at
Lake Tradition, Seattle City Light line option, etc. See Supporting Attachments 10 and 11. If a reliability
problem arises in the future on the Eastside, these alternatives would be better solutions than building
Energize Eastside.
Why would PSE want to build a project that is not needed? The answer lies in the Macquarie
investment objectives it had when it decided to buy all of the common stock of Puget nearly 10 years
ago. See Supporting Attachments 5 and 6. Also, note that Macquarie has begun the process of selling its
ownership share of PSE [See https://www.bloomberg.com/news/articles/2017-06-15/macquarie-said-
to-explore-sale-of-stake-in-utility-puget-energy] and Macquarie desperately needs to show potential
purchasers that there will be new large investment coming into PSE's ratebase soon so that the
potential purchaser will believe PSE will be receiving higher revenues from its ratepayers in the near
future.
3. Comments on specific language in the Application
Statement made in Application Responsive Comment
Statement made in Application
Responsive Comment
Conditional Use Narrative Page 1,
Paragraph 1 "The new substation and
This statement if False. See Supporting Attachment 1. Also
upgraded lines are needed to address
note, PSE has never provided a response to the
1
electrical system deficiencies
question/challenge made to them to cite a specific
identified during federally -required
requirement to transmit 1,500 MW
"planning studies"
to Canada in the FERC/NERC Reliability Criteria or PEFA
Conditional Use Narrative Page 2.
"The Energize Eastside project is a key
electrical infrastructure project
2
needed to bring a 230 kV power
This statement is False. See Supporting Attachments 1 and
source to the Eastside region,
17.
including the City of Bellevue, the
region's largest city and job center"
4
3
4
Conditional Use Narrative Page 23.
"Performance requirements for any
integrated transmission system are
heavily regulated at both the federal
and regional levels. PSE's regulators
include FERC, NERC and WECC (the
Federal Energy Regulatory
Commission, North American Electric
Reliability Corporation and Western
Electricity Coordinating Council,
respectively"
Conditional Use Narrative Page 25 et
seq. And Alternative Siting Analysis
page 23. States "five separate studies
performed by four separate parties
have confirmed the need to address
Eastside transmission capacity
(20.20.255.E.4; D.3.b & c): • Electrical
Reliability Study by Exponent, 2012
(City of Bellevue); • Eastside Needs
Assessment Report by Quanta
Services, 2013 (PSE); • Supplemental
Eastside Needs Assessment Report by
Quanta Services, 2015 (PSE); •
Independent Technical Analysis by
Utility Systems Efficiencies, Inc., 2015
(City of Bellevue); and • Review
Memo by Stantec Consulting Services
Inc., 2015 (EIS consultant)"
This statement erroneously ascribes heavy regulation of a
transmission line to be used solely for local needs to FERC,
NERC and WECC. FERC has stated it has no jurisdiction
over this line because it was never intended to be a part of
a Regional Plan. See Application copy of FERC Order in
Conditional Use Narrative at paragraph 62. PSE and
Columbia Grid told FERC that " transmission construction,
siting, and permitting fall within the purview of state and
local jurisdictions..." See Application copy of FERC Order in
Conditional Use Narrative at paragraph 22. And FERC has
stated that it has no jurisdiction over Energize Eastside.
See some FERC Order at paragraph 66. Also at paragraph
67FERC states "Nevertheless, the Energize Eastside Project
is not subject to the Order No. 1000 regional approval
process because it is located completely within Puget
Sound's service territory, it was included in Puget Sound's
local transmission plan to meet Puget Sound's reliability
needs, and neither Puget Sound, nor any other eligible
party, requested to have the project selected in the
regional transmission plan for purposes of cost allocation."
See also Supporting Attachments 1, 9, 14, 16 and 17. A
project to be used solely for local need and not in a
Regional Transmission Plan to help BPA increase its ability
to move power to and from Canada should not have its
Load Flow analysis„requiring these interregional flows.
Also note, the WUTC is reviewing the need for Energize
Eastside in the PSE Integrated Resource Plan Docket No.
UE-160918
None of the five studies have confirmed the need for the
line. (1) The Exponent report simply stated what PSE told
them on the need for the line. Exponent performed no
study of the need for the line. Exponent advised Bellevue
to follow PSE's IRP process at the WUTC. The WUTC is
studying the need for the line in PSE's current IRP. (2) The
Quanta Services 2013 study was flawed as was (3) the
Supplemental Quanta study done in 2015. See Supporting
Attachment 12, 4) The Utility Systems Efficiency analysis
actually found that 4 of the five overloads on the PSE
system go away if you remove the unrequired flows to
Canada. And we have found that the remaining overload is
so small that it can easily be solved by running the PSE
Puget Sound Area generators. See Supporting Attachment
1. (5) The Stantec review memo only parroted what PSE
told them. Stantec performed no independent analysis of
the need for Energize Eastside.
5
5
Conditional Use Narrative Pages 63-
64. These pages contain a July 20
2017 Jens Nedrud letter to City of
Bellevue certifying Reliability Need for
Energize Eastside
This letter includes no analysis, and instead relies on the
flawed analysis performed by others as described in 4
above. There is nothing legitimate that demonstrates that
this certification is correct.
Alternative Siting Analysis Page 21.
"The Energize Eastside Project is
needed to meet local demand growth
This statement is False. See Supporting Attachments 1 and
6
in the eastside of King County,
including Bellevue, Redmond,
17
Kirkland, Renton, Newcastle and
Issaquah"
Alternative Siting Analysis Tetra Tech
document starting at page 44. "Based
on PSE's technical evaluation of
potential solutions, the most effective
7
way to ensure the Eastside's power
By its own admission, Tetra Tech is relying on PSE studies.
system will meet growing demand is
But PSE studies are flawed. See 4 above.
to add a new 230 kV transmission line
to connect PSE's Sammamish
(Redmond) and Talbot Hill substations
(Renton)."
Submitted by Richard Lauckhart
Energy Consultant
44475 Clubhouse Drive
Davis, Ca 95618
lauckir@hotmaii.com
Former VP at Puget
List of Supporting Attachments with Brief Description
These Documents in full have been separately filed with the City of Bellevue
Attachment No. Attachment Brief Description ......................................
Lauckhart-Schiffman Load Flow study showing EE is not needed (includes my resume)
Rebuttal to PSE criticisms of Lauckhart-Schiffman including Q's and challenges to PSE
Email demonstrating that there is no Firm Requirement to deliver Canadian Entitlement
Power to the Canadian Border
4 Copy of "Agreement on Disposals of the Canadian Entitlement within the United States"
covering the years 1998-2024 referred to in the email above
5 Blowing the Whistle Slide show questioning PSE's motive and proof of the need for EE
6 Backstory on PSE's motive to build EE
7 Setting the record straight on EE Technical Facts
8 Comments I made to ColumbiaGrid pointing out the error in their System Assessment
write-up regarding the need to deliver 1,350 MW of Treaty power to the Canadian
border
9 Evidence that ColumbiaGrid had no substantive role in determining the need for EE
10 Email describing alternatives that would be better than EE if in the future there is a need
for reliability improvements on the Eastside
11 Comments demonstrating that the Seattle City Light line is a legitimate and better
alternative to EE if there is a need and PSE chooses to use the FERC Open Access
Transmission Tariff (OATT) rules available to them in order to enable this option to
happen
12 Document describing the "fatal flaws" in the load flow studies PSE ran in an attempt to
justify EE. Documents filed this day also include the documents that PSE has alleged
show the need for EE because these documents are referenced in the "fatal flaws" write-
up
13 Document providing further evidence that the ColumbiaGrid System Assessment write-
up stating there exists a Firm Commitment to deliver 1,350 MW of Treaty Power to the
Canadian Border is not correct. Includes an email from ColumbiaGrid stating that BPA
was the one that told them that such a Firm Commitment exists [even though BPA
responded in a Public Record Act request that no such Firm Commitment exists].
ColumbiaGrid explains that it makes no check on what BPA tells them when they write
their System Assessment document. They just include the BPA un-validated allegation in
their System Assessment write-up. This allegation has subsequently been refuted by
BPA in their response to the Public Records Act request
14 Questions regarding EE for PSE to respond to at their October 5 IRP Advisory Group
meeting
15 One further question for PSE to respond to at their October 5, IRP Advisory Group
meeting, i.e. Why has PSE chosen not to re -run their flawed EE load flow studies to fix the
flaws?
16 Document explaining the difference between (1) a WECC Path Rating and (b) a Firm
Commitment for transmission delivery. Explains that PSE is erroneously treating the
WECC Path Rating for the Northwest to Canada path as if it were a "Firm Commitment"
in its load flow studies allegedly showing the need for EE. This treatment of WECC Path
Ratings is wrong. PSE needs to re -run their load flow studies allegedly showing the need
for EE to eliminate these non -required inter -regional flows.
17 Comments Lauckhart made at the October 5, 2017 PSE IRP Advisory Group meeting
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