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HomeMy WebLinkAboutC_Public_Comment_47.f_180614.email_attch7of7Supporting Attachment No. 17 To Comments made by Richard Lauckhart dated December 11, 2017 Comments Lauckhart made at the October 5, 2017 PSE IRP Advisory Group meeting Comments made by Richard Lauckhart at PSE's October 5 2017 IRP Advisory Committee meeting My name is Richard Lauckhart. I 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. Over the past two years, I 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. Based on my thorough investigation, I must conclude that the Energize Eastside project is not needed. I have placed 15 documents on the record in this PSE IRP docket No. UE-160918 that lead me to this conclusion. I am attaching to these comments a listing of those 16 documents that includes the date when the document was filed with the WUTC and a brief description of what is in each document. in general these documents demonstrate that the load flow studies and other analyses that PSE used to justify the Energize Eastside project are flawed and they need to be redone to fix these flaws. I provided on July 25, 2017 the Lauckhart-Schiffman load flow study that has fixed these flaws. The Lauckhart-Schiffman Soad flow study demonstrates that if these flaws are fixed, then Energize Eastside is not needed now or any time soon. also provided via an email filed on August 14, 2017 a document that lists alternatives to Energize Eastside that would be better if at some point in time there is a need to address a reliability problem on the eastside. These include more DSM, batteries, 230/115 transformer at Lake Tradition, Seattle City Light line option, etc. The September 12, 2017 document I provided for the record includes seven questions under item number 2 that I believe are crucial to understand the need for this project. Yesterday, PSE responded with what they called "high-level responses" that did not answer the seven questions. 1 believe PSE needs to answer these questions. PSE claims that Canadian transfers and generation dispatch have no relevance to the need for Energize Eastside. To prove that they are irrelevant, PSE should rerun the load flow studies without inter -regional flows and with local generation operating. The Lauckhart-Schiffman load flow study found there is no transformer capacity issue or other reliability problem, when these inputs are correct. 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 on the record regarding the need for Energize Eastside is the Lauckhart-Schiffman load flow study. The Lauckhart-Schiffman study is the only one that uses the load forecast PSE gave to the Western Electricity Coordinating Council, correct interregional flows, and appropriate generation dispatch. That study concludes that Energize Eastside is not needed now or any time soon. Documents provided by Richard Lauckhart for the record in PSE 1RlP Docket No. UE-160918 Related to the need for Energize Eastside (EE)l Date document filed Comment Description..... . .............................................. July 25, 2017 Several documents filed as follows: 1-Lauckhart_Schiffman Load Flow study showing EE is not needed (includes my resume) 2- Rebuttal to PSE criticisms of Lauckhart-Schiffman including Q's and challenges to PSE 3-Part 3: 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 FE 6-Backstory on PSE's motive to build EE 7-Setting the record straight on EF Technical Facts July 31, 2017 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 August 2, 2017 Evidence that ColumbiaGrid had no substantive role in determining the need for EE August 14, 2017 Finail describing alternatives that would be better than EE if in the future there is a need for reliability improvements on the Eastside 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 FFRC Open Access Transmission Tariff (GATT) rules available to them in order to enable this option to happen August 21, 2017 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 August 22, 2017 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 BRA 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 Sept 12, 2017 Questions regarding EF for PSE to respond to at their October 5 IRP Advisory Group meeting Sept 14, 2017 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 LE load flow studies to fix the flaws? October 1, 2017 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. October 6, 2017 Comments Lauckhart made at the October 5, 2017 PSE IRP Advisory Group meeting List of documents that I placed on the record in UE-160918 that lead me to conclude that Energize Eastside is not needed now or any time soon.