HomeMy WebLinkAboutExhibit_23_Cense_ReportsBEFORE the HEARING EXAMINER for the CITY OF RENTON, WASHINGTON
In Re
Puget Sound Energy, Inc
“Energize Eastside” Talbot Hill Substation (2400 S Puget Dr.) continuing
north along the existing PSE transmission line corridor
to the northern City limits
Project File Number - PR18-000049
Land Use File Number - LUA18-000055, CU-H, SME
Coalition of Eastside Neighborboods for Sensible Energy
1
Table of Contents
Section 1 Summary of CENSE Position on Energize Eastside in Renton
1.0 Energize Eastside in Renton Don Marsh, President, CENSE
Section 2 Application Legal Analysis
2.0 Application Legal Analysis
Rick Aramburu, Attorney
Section 3 Description of Applicant: Puget Sound Energy
3.0 Description of Applicant / Puget Sound Energy
Jeanne DeMund, CENSE
Section 4 Cost of Project
4.0 Introduction
4.1 Lifetime Cost Analysis for Energize Eastside
Jeffrey King, Economist
4.2 Cost of Talbot Hill/Lakeside Transmission Line Project
Jeanne DeMund, CENSE
Section 5 Rebuttal to PSE’s Assertions
5.0 Introduction
5.1 Needs and Costs of Energize Eastside
Robert McCullough, Expert Witness
5.2 Analysis Needed for Project Alteration
Rick Austria, Principal, Pterra Consulting
5.3 How PSE is Selling Energize Eastside
Jan Medley, Russell Borgman - CENSE
5.4 Community Advisory Group (CAG) Dissenting Report
Coalition of Eastside Neighborhoods for Sensible Energy
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Section 6 Alternatives
6.0 Introduction
6.1 Supreme Court Decision on “Demand Response” Written by Justice Kagan
Jan Medley, CENSE
6.2 Bonneville Power Administration Decison to Cancel I-5 Corridor Project
Karen Esayian, CENSE
6.3 ColumbiaGrid and Seattle City Light Connection
Karen Esayian, CENSE
Section 7 Environmental Impacts
7.0 Impacts to Tree Canopy
Karen Esayian, CENSE
Section 8 Visual and Aesthetic Impacts
8.0 Impact on Scenic & Aesthetic Views -
Karen Esayian, Deron Ferguson, CENSE
Section 9 Zoning and Land Use Impacts
9.0 Introduction
9.1 Regulations Related to Transmission Lines
Karen Esayian, Deron Ferguson, CENSE
9.2 Project Impacts on Residential Parcels
Karen Esayian, Deron Ferguson, CENSE
9.3 Project Impacts on Public Right of Ways
Karen Esayian, Deron Ferguson, CENSE
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Coalition of Eastside Neighborhoods for Sensible Energy
Energize Eastside in Renton
January 7 , 2020
Executive summary
The Coalition of Eastside Neighborhoods for Sensible Energy (CENSE) is a non-profit organization with
over a thousand members throughout the Eastside, including dozens who currently reside in Renton.
CENSE was created as a non-profit organization (501-c4) in 2014 to advocate for energy solutions that
provide the Eastside with improved electrical reliability while respecting community values, reducing
risks to public safety, preserving the environmental and aesthetic features of residential neighborhoods,
and keeping rate increases reasonable.
Energize Eastside isn’t the only energy project that CENSE has challenged during its five-year history, but
this project inspired the formation of CENSE and continues to be a primary focus of the organization.
This document addresses three topics:
1. Energize Eastside’s impacts on Renton
2. Assumptions used to justify Energize Eastside
3. Winners and losers created by the project
It’s important to note that the project Renton is asked to permit is different from the original project
that PSE proposed in late 2013. The original project would have upgraded 16 miles of transmission lines,
connecting two large substations in Renton and Redmond. That project was intended to serve both a
local and regional purpose. It was the project that was studied by PSE, considered by a Community
Advisory Group, and evaluated in the Environmental Impact Study (EIS).
The current project is only the South Segment of the original project, about 8.8 miles long. Although it is
shorter and probably cheaper, the South Segment poses the same threats to the safety, aesthetics,
property values, and environment of Renton residents. It would provide little, if any, improvement in
electrical reliability for the City of Renton. The EIS has significant flaws due to forecasts that have been
disproved with the passage of time. EIS evaluations of feasible alternatives are biased or omitted.
Furthermore, the hazards of building the project near 50-year-old Olympic pipelines are minimized.
However, PSE pursues the project to garner a generous 9.8% return on investment allowed by the
Washington Utilities and Transportation Commission (WUTC). Because no third-party bidding is
required for transmission projects, PSE can collect more revenue compared to less expensive
alternatives that would be safer and less harmful to neighborhoods and thousands of urban trees.
2
Contents
Executive summary ...................................................................................................................................... 1
1. Energize Eastside’s impacts on Renton .................................................................................................... 3
1.1 Two projects compared ..................................................................................................................... 3
1.2 Aesthetic impacts .............................................................................................................................. 7
1.3 Homeowner impacts ......................................................................................................................... 8
1.4 Economic costs .................................................................................................................................. 8
1.5 Environmental impacts .................................................................................................................... 10
1.6 Fire safety ........................................................................................................................................ 11
1.7 Pole safety ....................................................................................................................................... 14
2. Assumptions used to justify Energize Eastside ...................................................................................... 16
2.1 Incorrect winter demand trends ...................................................................................................... 16
2.2 Incomplete summer analysis ........................................................................................................... 19
2.3 Omitted analysis of alternatives ...................................................................................................... 20
3. Winners and losers created by the project ............................................................................................ 23
Questions and Answers ............................................................................................................................. 26
Conclusion ................................................................................................................................................. 27
Addendum A: PSE refuses to provide Eastside peak demand data .......................................................... 28
Addendum B: PSE refuses to provide solar peak data .............................................................................. 29
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1. Energize Eastside’s impacts on Renton
The Energize Eastside project would replace 115 kV transmission lines mounted on wooden poles with
230 kV lines mounted on taller steel monopoles. The existing poles range in height from 50 to 70 feet.
In Renton Highlands, the proposed poles have an average height of 86 feet. The tallest proposed pole in
Renton would be 115 feet high.
1.1 Two projects compared
Similar transmission projects have been proposed by utilities in other states. For good reason, most 230
kV transmission lines are not situated in densely populated urban areas. For example, contrast Energize
Eastside with the “Independence Energy Connection West” project, a 29-mile 230 kV transmission line,
connecting the towns of Rice, Pennsylvania and Ringgold, Maryland.1 The following table shows
Energize Eastside would be significantly more disruptive and harmful than the more rural Pennsylvania-
Maryland project.2
Energize Eastside Independence Energy
Connection West
Purpose Avoids rare outage
scenario
Saves $800 million/year
in congestion fees
Length 16 miles 28.8 miles
Cost $150-$300 million $240 million
Closer than 600 feet:
• Homes 3,970 30
• Schools 7 0
• Religious institutions 7 0
• Trails 7 0
Trees to be removed 3,600 0
Length of co-located pipeline 13 miles 0 miles
Pole height 50-115 ft. (ave. 86 ft.) 135 ft.
Two similar 230 kV transmission projects are compared
The last two rows of this table highlight safety concerns with Energize Eastside. PSE’s project would
share a narrow utility corridor with two 50-year-old petroleum pipelines that transport 13 million
gallons of jet fuel and gasoline through the Eastside each day. In 1999 and 2004, these pipelines caused
fires that killed three children in Bellingham and sent Renton emergency responders to a hospital.
Although utility corridors sometimes contain more than one type of infrastructure, no comparable
project locates two 230 kV transmission lines and two hazardous liquid pipelines within a 70- to 100-foot
corridor with houses on both sides.
1 https://www.heraldmailmedia.com/news/tri_state/pennsylvania/transource-power-line-foes-
continue-opposition/article_96402eb0-49df-595b-889a-7202474b0d51.html
2
https://energizeeastside2.blob.core.windows.net/media/Default/CAG/Meeting4a/7_CAG_UpdatedDataTable_201
4_0625.pdf (see data for “Willow” route)
4
The Phase 1 Energize Eastside Environmental Impact Study (EIS) notes the challenges of safely locating
230 kV transmission lines within the existing corridor:3
Clear zones. To ensure safe and reliable operation of overhead or underground transmission
lines, the NESC [National Electric Safety Code] specifies minimum horizontal and vertical
clearance requirements for overhead lines, where trees and overhanging branches must be
removed, and structures are generally prohibited (the clear zone). … The clear zone for an
overhead 230 kV line could be approximately 120 to 150 feet wide. The transmission line could
be located along existing 115 kV easements, which are typically 70 to 100 feet wide. Therefore,
this analysis assumes that use of a 115 kV corridor could require the corridor to be widened by
up to 50 feet.
Here is a summary of the NESC guidelines that the EIS refers to:4
National Electric Safety Code requires corridor width of 120-150 feet
NESC says “specific easement agreements might require more clearance.” The co-location of two 50-
year-old petroleum pipelines would normally impose additional clearance requirements. The EIS says:
“… if standard corridor widths were added to the 50-foot separation that BPA generally advised for
locating transmission lines from any co-located pipeline, the corridor width would be greater than
described in the Phase 1 Draft EIS, and numerous homes would need to be removed.”5 However, PSE
has not announced any adjustments to the width of the corridor. If PSE were to condemn even a few
3 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/02_chapter_2_project_alternatives.pdf, p. 2-23
4 https://www.aepohio.com/global/utilities/lib/docs/info/facts/aepohio-encroachment-ontransrow.pdf
5 https://fortress.wa.gov/ecy/separ/Main/SEPA/Document/DocumentOpenHandler.ashx?DocumentId=32163, p.
J1-66
5
homes, it would increase the appeal
of alternatives with less impact to
the community and less cost. In any
case, safety assumptions in the EIS
differ from what PSE plans to build.6
The difference in pole heights
between Energize Eastside and the
Pennsylvania-Maryland project
projects is another concern. PSE has
reduced pole heights in many
neighborhoods to minimize aesthetic
impacts. At the location where PSE’s
transmission lines pass under the
Seattle City Light lines, PSE proposes
using poles 50 feet high. This departs
from industry recommendations of
95 to 145 feet for a 230 kV line.7 The
average proposed pole height in
Renton is 86 feet, while the
Pennsylvania-Maryland project
proposes 135-foot poles to ensure
safe operation of its power line.
In Pennsylvania, the transmission lines are always at least 150 feet from homes, measured horizontally.
In Renton, the transmission lines would be less than 10 horizontal feet from the home at 3224 NE Sunset
Blvd.
Energize Eastside passes through dozens of densely populated Eastside neighborhoods. In Renton, PSE’s
lines are very close to:
• 4 neighborhoods (Shadow Hawk, Liberty Ridge, Sunset, Honey Creek Ridge)
• 67 homes
• 2 apartment buildings
• 2 schools (Renton Technical College, Highland Preschool)
• 2 churches (Renton Seventh-day Adventist Church, Church Evangelical Chinese SKC)
• 3 parks (Sierra Heights Park, May Creek Park, Cedar River Park)
• 9 businesses (Plum Delicious, Sunset Pet Hospital, La Fuente, Reyna Hair Salon, Little Peking,
O’Reilly Auto Parts, Chevron, McDonald’s, Renton Collision Center)
The following map shows some of these land uses in relation to PSE’s and Seattle’s transmission lines.
6
https://transourceenergyprojects.com/IndependenceEnergyConnection/docs/open_house/August/IECP_Proposed
_Structure_Poster_August_FINAL.pdf
7 http://capx2020.com/Images/Transmission_Line_Factsheet_7-2008.pdf
6
Renton map showing Energize Eastside, Seattle City Light power lines,
neighborhoods, and community features nearby
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1.2 Aesthetic impacts
Even though PSE has proposed unusually short poles to carry its 230 kV power lines, the new poles
would be almost 50% taller than existing poles. The proposed poles would be more prominent in the
landscape and visible from greater distances.
Renton already has one 230 kV line passing through the city, owned by Seattle City Light. A second 230
kV line running only blocks from Seattle’s line (less than 600 yards in many parts of the city) will
reinforce an impression of a city crisscrossed with industrial infrastructure. This is at odds with Renton’s
desire to be known as a 21st-century city.
The following photo from Google Maps was taken near the Renton location where PSE’s transmission
lines pass under Seattle City Light’s lines (the ones supported by metal lattice towers). The number of
wires won’t change if Energize Eastside is built, but the crossing of four 230 kV lines (12 wires total)
close to two petroleum pipelines is a concentration of critical infrastructure that should be treated with
caution. An accident in this location would have major impacts on energy delivery throughout the Puget
Sound.
A Renton neighborhood is burdened with excessive industrial infrastructure
PSE lines
Seattle lines
local lines
Olympic pipeline
access station
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1.3 Homeowner impacts
The economic impacts for some Renton
homeowners could be substantial. For example,
the home at 1078 Lynnwood Ave. NE will lose
eight trees categorized as “significant” (marked
with red crosses, not all are visible in this photo).
The trees provide privacy and filter noise from
the busy street behind the house. The proposed
pole will be 86 feet tall, approximately 30 feet
higher than the existing poles, but nearly 50 feet
shorter than 135-foot poles in the Pennsylvania-
Maryland project. Shorter poles put dangerous
voltages and electromagnetic fields closer to
people. PSE’s compromise harms both
aesthetics and public safety.
There are many homes in Renton that would be impacted by proximity to higher voltages, taller power
poles, and shorter trees. Such homes may face long-term declines in property value, and the City of
Renton would collect less property tax revenue.
1.4 Economic costs
While individual homeowners who live near the power line would bear most of the aesthetic impacts,
safety risks, and lower property values imposed by Energize Eastside, every customer who pays PSE a
monthly electric bill will pay for the project through higher electricity bills. Every residential and
business using electricity in Renton would be affected.
PSE estimates the initial cost of the project will be $150 million to $300 million. Divided among PSE’s 1.1
million customers that’s $136 to $272 per customer over the life of the project through higher electricity
bills (just an extra buck or two per month, as PSE has said).
But there is another cost that is not well known. The State of Washington allows PSE to raise electric
rates to collect a 9.8% annual rate of interest on PSE’s major infrastructure investments. For Energize
Eastside, PSE will collect an additional $15 million to $30 million each year for the anticipated 50-year
life of the physical assets. Each customer would pay an extra $13 to $26 every year. Over time, each
customer would pay approximately $1000 to cover the initial cost of the project plus yearly interest, for
a total cost of over $1 billion. That is a significant tax on the local economy.
At the Bellevue hearing for Energize Eastside, PSE dismissed these concerns. A company representative
said the funds come from PSE’s capital improvement budget, so if Energize Eastside isn’t built, the
money would just be spent on something else. But this deflects the main issue. Ratepayers don’t mind
paying for projects that provide cleaner, safer, more reliable electricity. Instead of providing benefits to
the community, Energize Eastside destroys things the community does value, like trees, neighborhood
character, and a sense of safety in our homes.
PSE uses economic threats to scare business owners and increase support for Energize Eastside. In its
September 2019 Fact Sheet, PSE states “PSE may have to utilize additional corrective action plans that
9
plan for intentional load shedding to meet federal requirements. This could affect more than 130,000
customers as early as the summer of 2018, at a cost of tens of millions of dollars to the local economy.”8
PSE’s statement is misleading in many ways. First, federal requirements published as NERC TPL-001-4
explicitly allow dropping of non-consequential loads in the unlikely circumstances PSE assumes (peak
demand, two major grid components out of service, half a dozen generation plants offline, and huge
amounts of electricity being transferred to Canada or California).9 In this case, curtailment of huge
“non-firm” transfers to California and Canada would relieve stress on PSE’s equipment and eliminate the
need for rolling blackouts.
Second, PSE’s claim that 130,000 customers could be affected is misleading. If rolling blackouts were
needed, PSE would turn off power to approximately 10,000 customers at a time, for half an hour or less,
and only during hours of peak power consumption (approximately three hours in the morning or three
hours in the early evening). Again, this scenario is extremely unlikely to occur after transfers to
California or Canada are curtailed, but it illustrates PSE’s tendency to use exaggerated consequences to
build support through scare tactics.
Energize Eastside would impose real
costs on the Eastside economy
through many months of invasive
construction. The Energize Eastside
EIS describes a construction process
that involves vegetation clearing,
construction of temporary access
roads, pole foundation excavation,
concrete curing, pole erection, and
wire stringing over a period of nine
months (for the southern segment).10
There will be noise, heavy
equipment, work crews, road
closures, and even evacuations of
homes and schools for safety purposes.
These have economic costs that would drain millions of dollars from the local economy due to delays,
detours, and disruption. Renton will be especially impacted, because the 4-mile length of the Renton
segment is longer than any segment in other cities.
Surprisingly, the economic costs of construction were not tallied in the EIS.
8
https://energizeeastside2.blob.core.windows.net/media/Default/AbouttheProject/2019_0903_PSE_EE_Factsheet_
v1_WEB.pdf
9 https://www.nerc.com/files/TPL-001-4.pdf, p.9, scenario “P6”
10 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_2_project_alternatives.pdf, p. 2-37
Pole construction from PSE’s fact sheet
10
1.5 Environmental impacts
Washington’s ground-breaking Clean Energy Transformation Act (CETA), enacted by the state in 2019,
bears upon Energize Eastside because it requires PSE to invest in cleaner sources of electricity and smart
technology to reduce demand peaks. Specifically, CETA allows PSE to raise electricity rates by 2 percent
per year to divest itself of coal-generated electricity by 2025, achieve carbon neutrality by 2030, and use
only 100% renewable electricity by 2045.11 This will be a monumental effort for PSE, which currently
relies on fossil fuels to generate 56% of its electricity.12
To comply with the CETA mandate, PSE must significantly increase the percentage of our electricity
produced by renewable resources like solar and wind. To maintain reliability on calm, cloudy days, PSE
will need energy storage technologies like pumped hydro (using electricity to pump water back up to a
reservoir when electricity demand is low) and grid-sized batteries. Batteries are particularly effective
when placed close to customers with large electrical loads. This would reduce the amount of electricity
that needs to be transmitted through long transmission lines during peak hours – exactly the need that
Energize Eastside is designed to serve.
In addition to requiring more renewable energy, CETA will strongly incentivize PSE to reduce peak
consumption. To serve peak demand, PSE currently fires up natural gas “peaker plants.” These facilities
only run for short periods but are expensive to operate and emit high levels of carbon dioxide, methane,
and other pollutants per megawatt generated. Peak demand can be reduced in many ways, such as
“demand response” programs that provide customers incentives to shift energy use away from peak
hours. To achieve CETA goals, PSE will need to invest in batteries, demand response, energy efficiency,
and other advanced technologies, further diminishing the perceived need for Energize Eastside.
Energize Eastside also harms the environment by cutting down valuable urban trees. In Renton, PSE
would remove over half of the 641 trees within the project area (339 trees would be cut, and 238 are
classified “significant.”) These trees provide storm water control, shade, carbon storage, noise
mitigation, human health benefits, and wildlife habitat – benefits to society the EIS values at over
$700,000. PSE promises to replace the trees with shorter varieties that won’t grow dangerously close to
the power lines, but these will take many years to mature. The replacement trees would have smaller
root balls, and fewer leaves or needles. They would never provide the full benefits of the trees that
would be removed.
11 https://www.vox.com/energy-and-environment/2019/4/18/18363292/washington-clean-energy-bill
12 https://www.pse.com/pages/energy-supply/electric-supply
11
1.6 Fire safety
The EIS acknowledges an increased risk of pipeline fires due to the proximity of the proposed poles and
excavation of large holes next to the existing Olympic pipelines. Renton already survived a close call in
an accident involving these same pipelines.
On the morning of May 23, 2004, an explosion occurred at a Renton facility owned by Olympic
Pipeline.13 Approximately 50 firefighters arrived on the scene, where 20-foot flames erupted from a
pinhole leak in the pipeline. Thousands of gallons of gasoline were released, and it took three hours to
extinguish the fire.
Renton facility damaged by a pipeline explosion in 2004
Compared to the fatalities and 1.5-mile path of destruction that occurred in the Bellingham pipeline fire
five years earlier, Renton was fortunate to escape with relatively minor injuries that sent three
emergency responders to the hospital.
In Renton, the Sierra Heights Elementary School is located 225 yards from the Olympic pipelines, less
than half the distance California safety codes require between schools and hazardous liquid pipelines.14
PSE proposes to install a new pole approximately 7 feet from one of the pipelines at this location. This is
less than the minimum separation of 13 feet recommended by PSE’s pipeline safety consultant, DNV-GL.
13 https://response.epa.gov/site/site_profile.aspx?site_id=864
14 https://www.cde.ca.gov/ls/fa/sf/title5regs.asp, Article 2, Section 14010(h)
12
The consultant says the risk might be mitigated by installing arc shielding protection.15 However,
another consultant, Stantec, does not agree that this recommendation would ensure protection from
arcing and accelerated corrosion of the pipeline that could lead to a breach:16
In Stantec’s opinion, although the [DNV-GL] study and modeling performed is sufficient as a
sensitivity analysis, it cannot be used to determine the mitigation requirements for the pipelines
related to the final design of the powerlines. …
As such, we recommend the following be performed in the detailed design stage of the project: …
• Reassess the safe separation distance to minimize arcing risk based on NACE SP0177 and
considering the findings in CEA 239T817.
• Ensure that the separation distance between the pipelines and the powerline structures
exceeds the safe distance required to avoid electrical arcing.
• Design monitoring systems to monitor the AC corrosion risks along the pipelines.
• Install and commission the AC mitigation and monitoring systems prior to energization of the
230 kV powerline.
Neither PSE nor the Olympic Pipeline Company have responded to these recommendations with
detailed proposals to reassure the community that Energize Eastside will operate safely near these
pipelines for decades.
If an accident were to happen in this location, leaking fluid would likely flow downhill and potentially
ignite nearby trees. An unbroken path of dense vegetation leads from the pipeline location to
approximately 40 yards from the school.
The EIS analyzed a theoretical accident of more than 300,000 gallons of fuel spreading and burning on
flat ground, as shown in the following diagram:17
15
https://energizeeastside2.blob.core.windows.net/media/Default/Safety/PSE_AC_Analysis_Bellevue_WA_FINAL_P
P16591_12132016.pdf, p. 30
16
http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/stantec_peer_review_of_corrosion_report_05_0
2_2017.pdf, p.2
17 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_4.9_pipeline_safety.pdf, p. 4.9-16
13
The EIS warns that the diagram is a “simplistic representation and does not show site-specific
conditions.”
This insufficient analysis of pipeline fire risk in the EIS was noted by the City of Newcastle in its council
agenda for June 20, 2017:18
While the DEIS characterizes the hypothetical pool fire as a “worst case” scenario, it also
acknowledges that if “hilly conditions, waterbodies, or catch basins were present, the pipe
contents could flow away from the site of the release … The City’s elevation and topography are
strikingly different from the “pool fire” scenario discussed in the DEIS (pages 3.9-28 – 3.9-29).
The DEIS should evaluate the impacts of a potential release or rupture under scenarios where
actual hilly conditions, waterbodies or catch basins are present to better understand the
potential impacts in all of the partner cities.
A hill near the Sierra Heights Elementary School and abundant vegetation invalidate simplistic
assumptions made in the EIS risk analysis.
18 https://newcastle.civicweb.net/filepro/document/14614/AB%2017-39_Energize%20Eastside.pdf
14
1.7 Pole safety
PSE suggests that steel poles will be safer for nearby homes than aging wooden poles. According to an
industry website, “Whether made of wood, light-duty steel, concrete, fiberglass or composite materials
like resins and glass, all utility poles and towers can bend, break and bob when Mother Nature kicks up
her heels.” 19
During the past decade, steel poles have failed due to accident, corrosion, weld failures, ice loading, and
extreme winds.
Seventeen steel poles fell in Teton Village, Wyoming, 2/8/1720
19 https://www.power-grid.com/1999/01/01/wood-steel-concrete-mother-nature-can-bring-em-all-down/
20 https://www.wyomingnews.com/news/teton-village-without-power-after-storm-downs-power-
lines/article_0aee7dce-ee57-11e6-8017-eb7fa13cd38b.html
Weld failure Corrosion
15
Contrary to PSE’s implication that steel poles would be safer than aging wooden poles, H-frame wooden
structures of the type that currently support the power lines are resilient and have remained standing in
challenging circumstances.
At least ten Renton homes and other community buildings are located within the fall radius of PSE’s
proposed poles:
• 1074/1078 Lynnwood Ave. NE
• 859/863/867/1005 Monroe Ave. NE
• 154/160/166/174 Glenwood Pl. NE
• Renton Seventh-day Adventist Church
• Highlands Preschool
• Renton Technical College (Building A)
This photo shows the strike zone of a proposed 113-foot pole in Renton that could fall on any of four
nearby homes:
Four homes are within the fall radius of a proposed 113-foot pole
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2. Assumptions used to justify Energize Eastside
To justify building Energize Eastside, PSE commissioned Quanta to perform two studies in 2013 and
2015. The primary purpose of the project was to serve growth in downtown Bellevue and the
developing Spring District in Bellevue. In Renton, growth has been less vigorous.
Quanta’s assumptions have not stood the test of time:
1. Quanta assumed winter peak demand would increase rapidly. It has fallen.
2. When analyzing a peak demand scenario in summer, Quanta ignored critical details of where
electricity is produced and consumed.
3. Quanta did not consider technology that can address summer demand.
2.1 Incorrect winter demand trends
The peak winter demand scenario studied by Quanta is not well understood by the public or the
businesses that PSE scares with warnings of impending blackouts.
Here are all the conditions that must occur simultaneously to cause a blackout:
• An arctic weather system settles on the Puget Sound area, plunging temperatures below 23° F
for more than a day.
• During peak hours on a weekday (6-9 AM or 5-9 PM), electricity consumption spikes.
• Two of the four 230 kV transformers that supply electricity to the Eastside fail.
• Half a dozen gas peaker plants whose main function is to serve peak demand in PSE’s service
territory are inexplicably offline.
• The Northwest is sending 1,500 MW to Canada, some of which flows through the Eastside and
increases load on PSE’s remaining transformers.
• Peak demand on the Eastside has increased at an annual rate of 2.4%, year over year, eventually
straining the limits of the system to handle all these stresses.
Even under this extremely unlikely set of circumstances, there would be no blackouts. PSE claims it
would have to change operational parameters for the Eastside grid, and the grid would become
vulnerable to a blackout if an additional failure or emergency occurred.
PSE has admitted that this confluence of events is unlikely to occur, but the company claims federal
NERC standards require Energize Eastside to be built anyway. CENSE agrees that federal standards
require PSE to anticipate the first three events (cold, peak demand, and failure of two critical
components). However, the subsequent items go well beyond what PSE is required to handle.
In a letter to PSE dated June 19, 2018, the Utilities and Transportation Commission (WUTC), expressed
similar concerns about the offline peaker plants, impact of regional flows, and aggressive demand
forecasts.21 PSE did not respond for over 16 months. On November 4 ,2019, five members of PSE’s
21
https://www.utc.wa.gov/_layouts/15/CasesPublicWebsite/GetDocument.ashx?docID=1760&year=2016&docketN
umber=160918, p. 10
17
Technical Advisory Group sent PSE a letter, asking if the company would ever answer WUTC’s four
questions.22 PSE responded on November 27, 2019.23 In short, the answer was “No.”
Although each of these questions deserves a thorough answer, this document will focus on Quanta’s
2015 winter demand forecast, which was simplified and published on PSE’s website in June 2015:24
PSE’s 2015 forecast of Eastside omits historical data and increases 2.4% per year
The graph shows demand rising quickly (2.4% per year) and exceeding the “system capacity range” by
the winter of 2018. CENSE added the orange arrow to call attention to the lack of historical data that
might help the public understand how these trends have developed over time. Members of the public
also wondered why the forecast rate of growth was more than double the rate of population growth.
Where would all that electricity go?
PSE reports peak demand annually to the Federal Energy Regulatory Commission (FERC). During the
past 15 years, peak demand has been declining throughout PSE’s service territory:
22
https://oohpseirp.blob.core.windows.net/media/Default/Action_Items/2019_1104_CENSE_Vashon_CAG_Bridle_T
rails_Energize_Eastside.pdf
23
https://oohpseirp.blob.core.windows.net/media/Default/Comment_Reports/2019_November_IRP_CommentSum
mary_WEB.pdf, p. 10
24 https://web.archive.org/web/20150623080514/http://www.energizeeastside.com:80/need
No historical
data 2004-2014!
18
PSE’s annual peak demand and extrapolated trends
The orange line shows peak demand as reported to FERC. The dashed blue lines show a range of trends
that can be extrapolated from the peak demand data. Standard statistical analysis finds with 95%
certainty that peak demand levels are falling in PSE’s service area at a rate between 0.1% and 1.0% per
year. The red dashed line shows the system-wide “Overload Level” of 5205 MW that Quanta identified
in the Eastside Needs Assessment.25 Exceeding this level might require a project like Energize Eastside.
(Note that the previous graph showed Eastside “system capacity” at 700 MW, only part of the system-
wide peak of 5205 MW shown here.)
For many people, declining demand comes as a surprise, especially because PSE’s customer base grew at
an annual rate of 0.8% during this same time period. There are several factors driving declines for
utilities in the Puget Sound region and across the country. Technology like LED lighting, smart
thermostats, and efficient heat pumps became widely available during the past decade. Growing
concern for the climate has focused efforts to reduce energy consumption in homes and businesses. At
the same time, winters are becoming warmer in the Pacific Northwest, requiring less use of electricity
for heating.
Demand trends are falling progressively farther away from the “Overload Level.” It is not apparent that
Energize Eastside will ever be needed to serve winter peak demand on the Eastside.
25
https://energizeeastside2.blob.core.windows.net/media/Default/Library/Reports/Eastside_Needs_Assessment_Fi
nal_Draft_10-31-2013v2REDACTEDR1.pdf, p. 9
19
2.2 Incomplete summer analysis
Quanta analyzed both winter and summer peak demand scenarios. The summer scenario is much like
the winter scenario (two transformers failed, peaker plants offline), with a few key differences:
• The highest levels of summer demand occur when weather is hot and air conditioners are
running continuously.
• The highest recorded summer peak (3508 MW in July 2009) was 29% lower than the highest
winter peak (4911 MW in December 2009).
• Transformers and wires are less efficient in hot weather.
• Regional transfers reverse direction in summer, and 2,850 MW is sent to California (instead of
Canada).
Unlike the winter scenario, peak demand data reported to FERC shows summer peak demand is
gradually increasing:
Growth of summer demand appears to match customer growth
The solid orange line shows peak demand as reported to FERC. The orange dashed line shows a best-fit
trend line increasing at 0.84% per year. The shaded area of the graph represents the number of
customers reported by PSE. The gray dashed line shows the growth trend for customers, which also
increases at 0.84% per year.
20
The rising trend for summer peaks exceeds PSE’s “Level of Concern” in 2009, 2017, and 2018. This may
appear to justify PSE’s case in favor of building Energize Eastside. However, it is important to
understand three mitigating factors before drawing conclusions:
1. The “Level of Concern” line is misleading.
2. The large regional flow of electricity to California is not apparent in this graph.
3. Sources of electricity are not identified.
At 3350 megawatts, the system-wide “Level of Concern” documented in the 2013 Eastside Needs
Assessment is 36% lower than the winter “Overload Level” of 5205 megawatts. Although wires and
transformers are somewhat less efficient in the summer heat, the difference is usually 20% at most.
Why is the summer level so much lower?
The difference may be due to the amount of regional electricity flowing through Eastside power lines at
the same time peak demand is being served. These regional transfers do not show up in the orange
peak demand line, because the electricity is not consumed by PSE customers. Instead, the regional flow
pushes the “Level of Concern” lower, raising the urgency of a summer solution.
The effect of the California flow is documented in a 2015 study by Bellevue’s independent analyst, Utility
System Efficiencies.26 The analyst predicted that regional flow of this magnitude would cause six
different grid elements to overload in the summer of 2020. However, if the regional flow is reduced, all
six overloads disappear, leaving the system in good working order for Eastside customers.
Regional grid operators can curtail large transfers to California within 15 minutes if equipment outages
threaten service on the Eastside. To defend its project, PSE insists that large regional transfers must be
maintained under all circumstances. In other words, PSE would require its customers to pay hundreds
of millions of dollars to maintain these large transfers to California. No federal standard requires PSE’s
customers to overbuild local infrastructure to guarantee California receives electricity during an
unprecedented emergency on the Eastside. If Californians want guaranteed delivery of electricity from
the Northwest, they should pay for the larger transmission lines needed to deliver it. Those lines do not
need to run through Eastside neighborhoods.
2.3 Omitted analysis of alternatives
PSE did not ask Quanta to evaluate alternatives to PSE’s desired transmission line upgrade. The EIS
should have considered realistic alternatives for both winter and summer scenarios, but it shortchanged
the summer analysis. Now that the summer peak has become PSE’s main justification for Energize
Eastside, no one knows if alternatives would be more effective than the transmission line.
For example, electricity produced by rooftop solar panels is increasing rapidly, as shown in the following
graph from the public utility serving Snohomish county (PSE refused to provide equivalent data for its
service territory, see Addendum B).
26 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/cob_independent_technical_analysis_1-3.pdf,
p. 67
21
Local solar production is climbing rapidly
As rooftop solar energy becomes more prevalent, stress on electrical infrastructure could decline even if
peak demand increases. Locally produced electricity does not run through the transformers and
transmission lines that PSE has identified as a bottleneck in peak demand scenarios.
Although the above graph shows data from Snohomish, the overall trend is likely to be similar in PSE’s
service territory. The future promises broader use of solar panels because their cost is rapidly declining
while PSE’s electric rates are increasing. Also, greater use of solar energy is needed to meet the clean
energy goals adopted by our state (CETA).
Skeptics may argue that midday peak solar production does not align with peak consumption occurring
at 5-6 PM. However, recent solar panel installations are being paired with batteries, and batteries can
store solar energy to help meet peak demand later in the day. Like solar panels, electricity provided by
batteries adds no stress to transformers or transmission lines. Battery costs are declining as well:27
Solar and battery prices continue to decline
27 https://www.nrel.gov/docs/fy19osti/72399.pdf, p. viii, and https://about.bnef.com/blog/behind-scenes-take-
lithium-ion-battery-prices/
0
2
4
6
8
10
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018MegawattsSnohomish Local Solar Peak Production
$0.00
$2.00
$4.00
$6.00
$8.00
2010 2011 2012 2013 2014 2015 2016 2017 2018
Cost (2018 adjusted US dollars)Cost of solar and batteries
Solar (2018$/W)Battery (2018$/Wh)
22
The inadequate analysis of solar energy to meet summer need is demonstrated in this quote from the
EIS: “Solar could help reduce summer peak loads but because additional capacity would continue to be
needed for winter, the use of solar generation to address the transmission capacity deficiency would
need to be matched by winter generation capacity and therefore would be redundant.”28 Feasibility of
batteries in the summer was also not considered in the EIS: “Summer requirements were not evaluated
because the limitations identified during the winter study indicated that energy storage would not be a
feasible stand-alone alternative.”29 Now that the summer scenario has become the main justification
for the project, solar and batteries should be carefully studied to see if they provide a less expensive,
less damaging, and less risky solution to Eastside energy needs.
One other significant change has occurred since alternatives were last considered: the scope of the
project has been significantly reduced.
In 2016, the Phase 1 Draft EIS stated the whole 16-mile project was necessary to meet the
perceived need: “The area identified by PSE as having a transmission capacity deficiency is
situated between the Sammamish substation on the north end (Redmond/Kirkland area) and
the Talbot Hill substation on the south end (Renton area). Transmission improvements would
need to be tied to these two substations in order to address the need for the project.”30
In 2019, the Bellevue City Staff Report states: “The full buildout of the Energize Eastside project
will include a similar connection from the Sammamish substation in the north to provide
redundancy, but the south portion of the Project … can function independently.”31
The only way these seemingly contradictory assessments can both be true is if new assumptions have
been made in the intervening three years. However, PSE has not disclosed any changes in assumptions
or parameters. If assumptions have changed, it is possible that alternatives would be feasible that were
previously on the cusp of feasibility.
If a single segment is now sufficient to meet the need, the northern segment should also be studied.
The northern segment would run through Bellevue and less than a mile in Redmond. Building the
northern segment would leave existing lines in Renton and Newcastle undisturbed. Only through
transparent studies can the public weigh the merits of each alternative.
2.4 Unforeseen alternatives
In addition to solar panels and batteries, new options have become available to serve the Eastside’s
energy future.
A September 2019 report found that a “Waste-To-Energy” processing plant would be more economical
to process waste from King County than exporting the waste to remote landfill locations by railroad. It
would also become a local source of electricity that would not be dependent on wind or sunshine. The
28 Ibid., p. 2-39
29 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/02_chapter_2_project_alternatives.pdf, p. 2-
40
30
http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/00_cover_letter_fact_sheet_table_of_contents_
glossary.pdf, p. FS-i
31 https://bellevuewa.gov/sites/default/files/media/pdf_document/Staff%20Report%20FINAL%201242019.pdf, p.
111
23
report concludes, “[A Waste-To-Energy plant] will provide a gross savings of approximately $4.3 to $7.2
billion … when compared to [shipping waste by rail] over the 50-year planning period and [Waste-To-
Energy] has a significant advantage on improving recycling rates and energy recovery.”32
With these positive findings, the county appears poised to evaluate a plant sited at the Cedar Hills
Regional Landfill located about six miles east of Renton. This is the same location PSE considered for a
natural gas-powered plant to generate electricity as an alternative to Energize Eastside, but the
company determined the plant could not resolve the original deficiencies. However, with altered
assumptions and some help from solar panels and batteries, a Waste-To-Energy plant might solve both
waste issues and electricity issues with one facility, saving customers even more money over several
decades. CENSE believes this significant opportunity warrants a closer look requiring updated
disclosures from PSE.
3. Winners and losers created by the project
Energize Eastside has been a divisive project because PSE has promoted the idea that businesses and
developers in downtown Bellevue would benefit, while simultaneously minimizing the economic, safety,
and aesthetic burdens that would be borne by families and neighborhoods located near the taller poles
and higher voltages. The name itself, “Energize Eastside,” is a marketing term intended to unify support
for the project in the impacted cities. “Energize Downtown Bellevue” might be a more accurate name.
In 2015, the City of Bellevue engaged Stantec, an energy consulting firm, to evaluate the need for
Energize Eastside to support conclusions in the EIS. Stantec states, “For the Eastside the highest load
densities are north of I-90 and west of Lake Sammamish.”33 The identified area is mostly in Bellevue.
Here is a list of the winners and losers created by Energize Eastside.
Winner: Bellevue developers. PSE’s marketing machine has created an impression that the city is
headed for frequent blackouts if Energize Eastside is not built. This is a marketing strategy and a scare
tactic, not a fact. PSE’s technical studies show that “the peaks occur for just a few hours per year,”34 and
rolling blackouts would only be necessary if an extraordinarily unlikely set of circumstances occurs
during those few hours (half of the 230 kV transformers serving the Eastside fail, half a dozen generation
plants are offline, and large amounts of electricity are being transmitted to California or Canada).
But Bellevue likes to be known as a city “open for business.” By demonstrating its willingness to ignore
the concerns of its residents in order to keep downtown businesses awash in electricity (even if no
realistic threat exists), Bellevue confirms its commitment to commercial developers.
32 https://mkcclegisearch.kingcounty.gov/View.ashx?M=F&ID=7759006&GUID=168AF89C-8137-4EE8-B95C-
D4135F9FA486, p. 6-1
33
http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/stantec_review_memo_eastside_needs_assessm
ent_report.pdf, p.8
34
https://energizeeastside2.blob.core.windows.net/media/Default/Library/Reports/SupplementalNeedsAssessment
Report_Redacted_April2015.pdf, p. 38
24
Loser: Renton. Not only will Renton have more miles of the new transmission line than any other city (4
miles vs. 3.3 miles in Bellevue), Renton will receive the least benefit. A map in the 2013 Eastside Needs
Assessment shows shaded areas where PSE would enact rolling blackouts if the company’s highly
unlikely scenario were to occur.35
PSE’s map shows 66,000 customers “at risk” of rolling blackouts. (Without explanation, PSE later
inflated the number to 130,000 “at risk” customers.) PSE does not clarify that a blackout would not
affect all these customers simultaneously. Perhaps less than 10,000 customers would lose power for
half an hour before the rotation advances to the next group. In fact, only a small portion of North
Renton bordering Lake Washington would be affected. However, these customers are much less likely
to experience such a blackout as opposed to other outages that affect PSE’s distribution system (such as
tree limbs falling on neighborhood distribution lines, non-peak equipment failure in local substations,
and animal incursions).
35
https://energizeeastside2.blob.core.windows.net/media/Default/Library/Reports/Eastside_Needs_Assessment_Fi
nal_Draft_10-31-2013v2REDACTEDR1.pdf, p.35
A sliver of Renton customers is included in PSE’s rolling blackout map
25
Loser: Newcastle. The combination of pipelines and transmission lines passes closer to Newcastle’s
downtown core than any other city. The utility corridor passes less than 75 feet from Newcastle’s City
Hall. An economic analysis in the EIS considers what could happen if the project reduces assessed
property values fall by $10 million: “… the City would need to reduce its budget (for items covered by
property tax) by approximately $20,000.”36 This would be a challenge for a city currently struggling with
budget issues.
Winner: PSE’s investors. PSE is owned by Canadian and Dutch private equity funds, most of which
participated in the acquisition of PSE in 2009. The investors are keen to reverse a dramatic decline in
PSE’s operating revenues during the past decade:
While electricity consumption has been flat for the last 15 years, PSE’s gas business has suffered from
low gas prices and decreasing gas consumption. Energize Eastside provides some relief for PSE’s bottom
line. A transmission line is particularly profitable, because PSE doesn’t have to engage in competitive
bidding to build the project. The cost is whatever the company says it is (within reason). The higher the
cost, the higher future revenues will be due to the generous interest rate PSE collects over decades.
Loser: PSE’s customers. All 1.1 million of PSE’s customers will pay the initial cost of Energize Eastside,
plus a 9.8% rate of interest for 50 years or more. The total could exceed $1 billion. Less expensive
alternatives were improperly dismissed by the company and the EIS, which failed to evaluate solar
panels and batteries for the summer scenario that PSE says has become the main reason to build the
project.
Winner: businesses in downtown Bellevue. By overbuilding transmission capacity, Bellevue businesses
have an energy solution that requires little effort from them. No poles or wires will be installed in their
section of the city, stricter building codes may be delayed, and increased energy efficiency becomes an
optional element in Bellevue’s energy future.
36 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/section_3.10_economics.pdf, p. 3.10-9
26
Loser: residential neighborhoods and the environment. Both neighborhoods and the environment
would incur uncompensated costs. Residential neighborhoods would experience higher voltage,
industrial infrastructure, negative aesthetic impacts, reduced property values, increased risk of fires and
pipeline accidents, and loss of valuable trees. The environment would lose carbon storage, wildlife
habitat, and financial resources to pursue smart energy programs.
Loser: transparency and local accountability. If PSE is permitted to build this project without providing
evidence that electric demand is increasing on the Eastside, an unfortunate precedent will be set. PSE
has refused to answer reasonable questions about Energize Eastside from ratepayers, the Utilities and
Transportation Commission, and the company’s self-selected Technical Advisory Group. It is alarming
that a profit-oriented corporation can thwart inquiries from regulators, advisors, and the public.
Questions and Answers
Q: What about electric cars? Won’t they increase consumption of electricity?
A: Yes, increasing electrification of our economy is likely to increase total consumption. But for Energize
Eastside, the main question is when the electricity is consumed, not how much. Like most utilities, PSE
serves varying demand throughout the day. Demand is low from 10 pm to 6 am. If customers are
educated and financially incentivized to charge their cars during these hours, peak demand will not
increase. There are many benefits to customers, PSE, and the environment if we use smart technologies
and policies to keep peak demand from growing.
Seattle is anticipating lots of electric cars and buses, but Seattle City Light is forecasting falling peak
demand for at least two decades:37
Seattle City Light’s 2018 forecast of average load and peak demand
37 https://www.seattle.gov/light/IRP/docs/2018_Integrated_Resource_Plan_Progress_Report.pdf, p. 10
27
Q: You are worried about the large fall zone of tall poles, but high-voltage wires on short poles raise
different safety concerns. Which do you prefer?
A: The problem is the voltage. Residents have lived with 115 kV lines for decades, and we understand
the risks. Doubling the voltage should be the last solution considered from a safety standpoint.
Q: The current poles are so old. Wouldn’t new poles be safer?
A: We support robust maintenance and replacement of any old poles that are becoming unsafe. PSE
hasn’t proven that it’s necessary or desirable to double the voltage in the corridor. We support
investments that make our service more reliable, safer, and better for the environment.
Q: Maybe there isn’t a need for Energize Eastside now, but isn’t it a good idea to build it, just in case?
A: It’s true that transmission lines take a long time to build. However, there are many new technologies,
like batteries, that can be installed within a few months if the need arises. Elon Musk bet he could
install a utility-scale battery in Australia in less than 100 days, and he did it.38 There are lots of smart
things we can do if a problem develops, but it is very unlikely that we will face this kind of peak demand
reliability issue any time in the next decade.
Conclusion
Here are nine facts we would like you to remember:
1. Energize Eastside would impact safety, aesthetics, property values, and environment in Renton.
2. The winter scenario that PSE initially warned about has not materialized.
3. PSE has shifted focus to a summer scenario, but the EIS did not evaluate rooftop solar panels
and batteries to serve summer demand.
4. New alternatives like a King County Waste-To-Energy plant can save customers money.
5. If a transmission line is proven to still be the best solution, a northern segment affecting only
Bellevue and less than a mile in Redmond would leave lines undisturbed in Renton and
Newcastle. This option has not been studied.
6. The EIS assumes the utility corridor would be widened to maintain safety as 230 kV transmission
lines and two petroleum pipelines pass by homes, schools, churches, businesses, and parks. PSE
is not planning to widen the corridor.
7. The EIS did not properly evaluate the site-specific risk of a pipeline fire on a hill surrounded by
vegetation (a concern for Sierra Heights Elementary School).
8. Energize Eastside would soon become redundant with efforts PSE must take to comply with
Washington’s new Clean Energy Transformation Act (CETA), but ratepayers will continue to pay
9.8% interest on the cost of the project for decades.
9. PSE has significant financial incentives to pursue a no-bid transmission project at the expense of
its customers and the environment.
38 https://www.engadget.com/2017/11/23/tesla-australia-powerpack-100-day-bet/
28
Addendum A: PSE refuses to provide Eastside peak demand data
(Donald Marsh is a member of PSE’s Technical Advisory Group and has security clearance from FERC)
Via Electronic Mail
May 13, 2016
Mr. Donald Marsh
4411 137th Avenue SE
Bellevue, WA 98006
Re: CEII Information Request
Dear Mr. Marsh:
By way of a recap, you submitted a CEII request to Puget Sound Energy, Inc. (PSE) that we received on March 14,
2016. Your request asked for, among other things, historical loading, peak load information and load flow
information related to the Energize Eastside Project.
We responded to your request on April 15, 2016 and provided some of the information you requested.
Additionally, we asked you to provide additional information to support your request so that we could evaluate
your eligibility to receive CEII, a legitimate need for CEII and ability to protect the confidentiality of CEII.
You responded to our request for additional information in your letter dated April 27, 2016. This letter was very
informative in helping us better understand what information you were looking for and we appreciate your clarity.
By our count, you asked for four things in your letter: (1) historical loading on each of the 230/115 kV substations
you consider to be on the Eastside as well as each of the 115/12 kV substations you consider to be on the Eastside;
(2) the amount of electricity being transmitted to Canada; (3) the ratings of the transformers that are overloading
in the simulation; and (4) whether the simulation was run in DC mode.
Historical loading on individual substations is confidential in order to protect customer sensitive information so this
request is denied. The remaining requests are not considered CEII and our responses are as follows. Power flows
between the Northwest and Canada can be found to be 1500 MW in the south to north direction for winter
scenarios and 2850 MW in the north to south direction for summer scenarios. Ratings on transformers that are
overloading in the winter simulation are 484 MV A for both Talbot Hill transformer banks and ratings on
transformers that are overloading in the summer simulation are 429 MVA for Sammamish Transformer #1 and 410
MV A for Sammamish Transformer #2. Finally, the simulation was not run in DC mode.
Your letter also mentions the CEII clearance you received from FERC, as well as that received by Mr. Lauckhart.
Please note that FERC approval does not constitute PSE approval. FERC jurisdictional entities such as PSE have their
own CEII processes and procedures that are meant to function and be applied for separately and independently
from those of FERC.
Lastly, you state in your letter that you are not planning to run a simulation. Based on that acknowledgment, the
technical data you asked for in your original request that we received on March 14, 2016 does not fulfill a
legitimate need and that request is therefore denied.
Sincerely,
Puget Sound Energy, Inc.
By George Marshall
Its: Manager Transmission Policy and Contracts
29
Addendum B: PSE refuses to provide solar peak data
(Donald Marsh requested solar peak data as a member of PSE’s Technical Advisory Group)
From: Netik, Irena <irena.netik@pse.com>
Sent: Monday, December 23, 2019 10:27 AM
To: Don Marsh <don.m.marsh@hotmail.com>
Cc: Kvam, Michele <michele.kvam@pse.com>
Subject: RE: Solar output for PSE customers
Don
Unfortunately, I have not been able to track down the information you requested. The solar capacity
installed on our system is about 60 MW currently.
Thank you,
Irena Netik
D: 425.462.3671 M: 206.434.2336
From: Don Marsh <don.m.marsh@hotmail.com>
Sent: Saturday, December 14, 2019 4:14 PM
To: Netik, Irena <irena.netik@pse.com>
Cc: Kvam, Michele <michele.kvam@pse.com>
Subject: Solar output for PSE customers
CAUTION: This email originated from outside of the organization. Exercise extra caution when
responding, opening attachments, and clicking links.
Hi, Irena.
As a member of PSE’s Technical Advisory Group, I am trying to understand how photo-voltaic solar
panels are contributing to our energy supply in the Puget Sound. If possible, I would like to know the
peak energy generated in megawatts for each year 2009-2018 in PSE’s service area. It would also be
helpful to know how many solar panel systems were operating for each of those years.
Can PSE provide this information, or put me in touch with someone who can?
Sincerely,
Don Marsh
1
Coalition of Eastside Neighborhoods for Sensible Energy
Energize Eastside in Renton
January 7 , 2020
Executive summary
The Coalition of Eastside Neighborhoods for Sensible Energy (CENSE) is a non-profit organization with
over a thousand members throughout the Eastside, including dozens who currently reside in Renton.
CENSE was created as a non-profit organization (501-c4) in 2014 to advocate for energy solutions that
provide the Eastside with improved electrical reliability while respecting community values, reducing
risks to public safety, preserving the environmental and aesthetic features of residential neighborhoods,
and keeping rate increases reasonable.
Energize Eastside isn’t the only energy project that CENSE has challenged during its five-year history, but
this project inspired the formation of CENSE and continues to be a primary focus of the organization.
This document addresses three topics:
1. Energize Eastside’s impacts on Renton
2. Assumptions used to justify Energize Eastside
3. Winners and losers created by the project
It’s important to note that the project Renton is asked to permit is different from the original project
that PSE proposed in late 2013. The original project would have upgraded 16 miles of transmission lines,
connecting two large substations in Renton and Redmond. That project was intended to serve both a
local and regional purpose. It was the project that was studied by PSE, considered by a Community
Advisory Group, and evaluated in the Environmental Impact Study (EIS).
The current project is only the South Segment of the original project, about 8.8 miles long. Although it is
shorter and probably cheaper, the South Segment poses the same threats to the safety, aesthetics,
property values, and environment of Renton residents. It would provide little, if any, improvement in
electrical reliability for the City of Renton. The EIS has significant flaws due to forecasts that have been
disproved with the passage of time. EIS evaluations of feasible alternatives are biased or omitted.
Furthermore, the hazards of building the project near 50-year-old Olympic pipelines are minimized.
However, PSE pursues the project to garner a generous 9.8% return on investment allowed by the
Washington Utilities and Transportation Commission (WUTC). Because no third-party bidding is
required for transmission projects, PSE can collect more revenue compared to less expensive
alternatives that would be safer and less harmful to neighborhoods and thousands of urban trees.
2
Contents
Executive summary ...................................................................................................................................... 1
1. Energize Eastside’s impacts on Renton .................................................................................................... 3
1.1 Two projects compared ..................................................................................................................... 3
1.2 Aesthetic impacts .............................................................................................................................. 7
1.3 Homeowner impacts ......................................................................................................................... 8
1.4 Economic costs .................................................................................................................................. 8
1.5 Environmental impacts .................................................................................................................... 10
1.6 Fire safety ........................................................................................................................................ 11
1.7 Pole safety ....................................................................................................................................... 14
2. Assumptions used to justify Energize Eastside ...................................................................................... 16
2.1 Incorrect winter demand trends ...................................................................................................... 16
2.2 Incomplete summer analysis ........................................................................................................... 19
2.3 Omitted analysis of alternatives ...................................................................................................... 20
3. Winners and losers created by the project ............................................................................................ 23
Questions and Answers ............................................................................................................................. 26
Conclusion ................................................................................................................................................. 27
Addendum A: PSE refuses to provide Eastside peak demand data .......................................................... 28
Addendum B: PSE refuses to provide solar peak data .............................................................................. 29
3
1. Energize Eastside’s impacts on Renton
The Energize Eastside project would replace 115 kV transmission lines mounted on wooden poles with
230 kV lines mounted on taller steel monopoles. The existing poles range in height from 50 to 70 feet.
In Renton Highlands, the proposed poles have an average height of 86 feet. The tallest proposed pole in
Renton would be 115 feet high.
1.1 Two projects compared
Similar transmission projects have been proposed by utilities in other states. For good reason, most 230
kV transmission lines are not situated in densely populated urban areas. For example, contrast Energize
Eastside with the “Independence Energy Connection West” project, a 29-mile 230 kV transmission line,
connecting the towns of Rice, Pennsylvania and Ringgold, Maryland.1 The following table shows
Energize Eastside would be significantly more disruptive and harmful than the more rural Pennsylvania-
Maryland project.2
Energize Eastside Independence Energy
Connection West
Purpose Avoids rare outage
scenario
Saves $800 million/year
in congestion fees
Length 16 miles 28.8 miles
Cost $150-$300 million $240 million
Closer than 600 feet:
• Homes 3,970 30
• Schools 7 0
• Religious institutions 7 0
• Trails 7 0
Trees to be removed 3,600 0
Length of co-located pipeline 13 miles 0 miles
Pole height 50-115 ft. (ave. 86 ft.) 135 ft.
Two similar 230 kV transmission projects are compared
The last two rows of this table highlight safety concerns with Energize Eastside. PSE’s project would
share a narrow utility corridor with two 50-year-old petroleum pipelines that transport 13 million
gallons of jet fuel and gasoline through the Eastside each day. In 1999 and 2004, these pipelines caused
fires that killed three children in Bellingham and sent Renton emergency responders to a hospital.
Although utility corridors sometimes contain more than one type of infrastructure, no comparable
project locates two 230 kV transmission lines and two hazardous liquid pipelines within a 70- to 100-foot
corridor with houses on both sides.
1 https://www.heraldmailmedia.com/news/tri_state/pennsylvania/transource-power-line-foes-
continue-opposition/article_96402eb0-49df-595b-889a-7202474b0d51.html
2
https://energizeeastside2.blob.core.windows.net/media/Default/CAG/Meeting4a/7_CAG_UpdatedDataTable_201
4_0625.pdf (see data for “Willow” route)
4
The Phase 1 Energize Eastside Environmental Impact Study (EIS) notes the challenges of safely locating
230 kV transmission lines within the existing corridor:3
Clear zones. To ensure safe and reliable operation of overhead or underground transmission
lines, the NESC [National Electric Safety Code] specifies minimum horizontal and vertical
clearance requirements for overhead lines, where trees and overhanging branches must be
removed, and structures are generally prohibited (the clear zone). … The clear zone for an
overhead 230 kV line could be approximately 120 to 150 feet wide. The transmission line could
be located along existing 115 kV easements, which are typically 70 to 100 feet wide. Therefore,
this analysis assumes that use of a 115 kV corridor could require the corridor to be widened by
up to 50 feet.
Here is a summary of the NESC guidelines that the EIS refers to:4
National Electric Safety Code requires corridor width of 120-150 feet
NESC says “specific easement agreements might require more clearance.” The co-location of two 50-
year-old petroleum pipelines would normally impose additional clearance requirements. The EIS says:
“… if standard corridor widths were added to the 50-foot separation that BPA generally advised for
locating transmission lines from any co-located pipeline, the corridor width would be greater than
described in the Phase 1 Draft EIS, and numerous homes would need to be removed.”5 However, PSE
has not announced any adjustments to the width of the corridor. If PSE were to condemn even a few
3 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/02_chapter_2_project_alternatives.pdf, p. 2-23
4 https://www.aepohio.com/global/utilities/lib/docs/info/facts/aepohio-encroachment-ontransrow.pdf
5 https://fortress.wa.gov/ecy/separ/Main/SEPA/Document/DocumentOpenHandler.ashx?DocumentId=32163, p.
J1-66
5
homes, it would increase the appeal
of alternatives with less impact to
the community and less cost. In any
case, safety assumptions in the EIS
differ from what PSE plans to build.6
The difference in pole heights
between Energize Eastside and the
Pennsylvania-Maryland project
projects is another concern. PSE has
reduced pole heights in many
neighborhoods to minimize aesthetic
impacts. At the location where PSE’s
transmission lines pass under the
Seattle City Light lines, PSE proposes
using poles 50 feet high. This departs
from industry recommendations of
95 to 145 feet for a 230 kV line.7 The
average proposed pole height in
Renton is 86 feet, while the
Pennsylvania-Maryland project
proposes 135-foot poles to ensure
safe operation of its power line.
In Pennsylvania, the transmission lines are always at least 150 feet from homes, measured horizontally.
In Renton, the transmission lines would be less than 10 horizontal feet from the home at 3224 NE Sunset
Blvd.
Energize Eastside passes through dozens of densely populated Eastside neighborhoods. In Renton, PSE’s
lines are very close to:
• 4 neighborhoods (Shadow Hawk, Liberty Ridge, Sunset, Honey Creek Ridge)
• 67 homes
• 2 apartment buildings
• 2 schools (Renton Technical College, Highland Preschool)
• 2 churches (Renton Seventh-day Adventist Church, Church Evangelical Chinese SKC)
• 3 parks (Sierra Heights Park, May Creek Park, Cedar River Park)
• 9 businesses (Plum Delicious, Sunset Pet Hospital, La Fuente, Reyna Hair Salon, Little Peking,
O’Reilly Auto Parts, Chevron, McDonald’s, Renton Collision Center)
The following map shows some of these land uses in relation to PSE’s and Seattle’s transmission lines.
6
https://transourceenergyprojects.com/IndependenceEnergyConnection/docs/open_house/August/IECP_Proposed
_Structure_Poster_August_FINAL.pdf
7 http://capx2020.com/Images/Transmission_Line_Factsheet_7-2008.pdf
6
Renton map showing Energize Eastside, Seattle City Light power lines,
neighborhoods, and community features nearby
7
1.2 Aesthetic impacts
Even though PSE has proposed unusually short poles to carry its 230 kV power lines, the new poles
would be almost 50% taller than existing poles. The proposed poles would be more prominent in the
landscape and visible from greater distances.
Renton already has one 230 kV line passing through the city, owned by Seattle City Light. A second 230
kV line running only blocks from Seattle’s line (less than 600 yards in many parts of the city) will
reinforce an impression of a city crisscrossed with industrial infrastructure. This is at odds with Renton’s
desire to be known as a 21st-century city.
The following photo from Google Maps was taken near the Renton location where PSE’s transmission
lines pass under Seattle City Light’s lines (the ones supported by metal lattice towers). The number of
wires won’t change if Energize Eastside is built, but the crossing of four 230 kV lines (12 wires total)
close to two petroleum pipelines is a concentration of critical infrastructure that should be treated with
caution. An accident in this location would have major impacts on energy delivery throughout the Puget
Sound.
A Renton neighborhood is burdened with excessive industrial infrastructure
PSE lines
Seattle lines
local lines
Olympic pipeline
access station
8
1.3 Homeowner impacts
The economic impacts for some Renton
homeowners could be substantial. For example,
the home at 1078 Lynnwood Ave. NE will lose
eight trees categorized as “significant” (marked
with red crosses, not all are visible in this photo).
The trees provide privacy and filter noise from
the busy street behind the house. The proposed
pole will be 86 feet tall, approximately 30 feet
higher than the existing poles, but nearly 50 feet
shorter than 135-foot poles in the Pennsylvania-
Maryland project. Shorter poles put dangerous
voltages and electromagnetic fields closer to
people. PSE’s compromise harms both
aesthetics and public safety.
There are many homes in Renton that would be impacted by proximity to higher voltages, taller power
poles, and shorter trees. Such homes may face long-term declines in property value, and the City of
Renton would collect less property tax revenue.
1.4 Economic costs
While individual homeowners who live near the power line would bear most of the aesthetic impacts,
safety risks, and lower property values imposed by Energize Eastside, every customer who pays PSE a
monthly electric bill will pay for the project through higher electricity bills. Every residential and
business using electricity in Renton would be affected.
PSE estimates the initial cost of the project will be $150 million to $300 million. Divided among PSE’s 1.1
million customers that’s $136 to $272 per customer over the life of the project through higher electricity
bills (just an extra buck or two per month, as PSE has said).
But there is another cost that is not well known. The State of Washington allows PSE to raise electric
rates to collect a 9.8% annual rate of interest on PSE’s major infrastructure investments. For Energize
Eastside, PSE will collect an additional $15 million to $30 million each year for the anticipated 50-year
life of the physical assets. Each customer would pay an extra $13 to $26 every year. Over time, each
customer would pay approximately $1000 to cover the initial cost of the project plus yearly interest, for
a total cost of over $1 billion. That is a significant tax on the local economy.
At the Bellevue hearing for Energize Eastside, PSE dismissed these concerns. A company representative
said the funds come from PSE’s capital improvement budget, so if Energize Eastside isn’t built, the
money would just be spent on something else. But this deflects the main issue. Ratepayers don’t mind
paying for projects that provide cleaner, safer, more reliable electricity. Instead of providing benefits to
the community, Energize Eastside destroys things the community does value, like trees, neighborhood
character, and a sense of safety in our homes.
PSE uses economic threats to scare business owners and increase support for Energize Eastside. In its
September 2019 Fact Sheet, PSE states “PSE may have to utilize additional corrective action plans that
9
plan for intentional load shedding to meet federal requirements. This could affect more than 130,000
customers as early as the summer of 2018, at a cost of tens of millions of dollars to the local economy.”8
PSE’s statement is misleading in many ways. First, federal requirements published as NERC TPL-001-4
explicitly allow dropping of non-consequential loads in the unlikely circumstances PSE assumes (peak
demand, two major grid components out of service, half a dozen generation plants offline, and huge
amounts of electricity being transferred to Canada or California).9 In this case, curtailment of huge
“non-firm” transfers to California and Canada would relieve stress on PSE’s equipment and eliminate the
need for rolling blackouts.
Second, PSE’s claim that 130,000 customers could be affected is misleading. If rolling blackouts were
needed, PSE would turn off power to approximately 10,000 customers at a time, for half an hour or less,
and only during hours of peak power consumption (approximately three hours in the morning or three
hours in the early evening). Again, this scenario is extremely unlikely to occur after transfers to
California or Canada are curtailed, but it illustrates PSE’s tendency to use exaggerated consequences to
build support through scare tactics.
Energize Eastside would impose real
costs on the Eastside economy
through many months of invasive
construction. The Energize Eastside
EIS describes a construction process
that involves vegetation clearing,
construction of temporary access
roads, pole foundation excavation,
concrete curing, pole erection, and
wire stringing over a period of nine
months (for the southern segment).10
There will be noise, heavy
equipment, work crews, road
closures, and even evacuations of
homes and schools for safety purposes.
These have economic costs that would drain millions of dollars from the local economy due to delays,
detours, and disruption. Renton will be especially impacted, because the 4-mile length of the Renton
segment is longer than any segment in other cities.
Surprisingly, the economic costs of construction were not tallied in the EIS.
8
https://energizeeastside2.blob.core.windows.net/media/Default/AbouttheProject/2019_0903_PSE_EE_Factsheet_
v1_WEB.pdf
9 https://www.nerc.com/files/TPL-001-4.pdf, p.9, scenario “P6”
10 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_2_project_alternatives.pdf, p. 2-37
Pole construction from PSE’s fact sheet
10
1.5 Environmental impacts
Washington’s ground-breaking Clean Energy Transformation Act (CETA), enacted by the state in 2019,
bears upon Energize Eastside because it requires PSE to invest in cleaner sources of electricity and smart
technology to reduce demand peaks. Specifically, CETA allows PSE to raise electricity rates by 2 percent
per year to divest itself of coal-generated electricity by 2025, achieve carbon neutrality by 2030, and use
only 100% renewable electricity by 2045.11 This will be a monumental effort for PSE, which currently
relies on fossil fuels to generate 56% of its electricity.12
To comply with the CETA mandate, PSE must significantly increase the percentage of our electricity
produced by renewable resources like solar and wind. To maintain reliability on calm, cloudy days, PSE
will need energy storage technologies like pumped hydro (using electricity to pump water back up to a
reservoir when electricity demand is low) and grid-sized batteries. Batteries are particularly effective
when placed close to customers with large electrical loads. This would reduce the amount of electricity
that needs to be transmitted through long transmission lines during peak hours – exactly the need that
Energize Eastside is designed to serve.
In addition to requiring more renewable energy, CETA will strongly incentivize PSE to reduce peak
consumption. To serve peak demand, PSE currently fires up natural gas “peaker plants.” These facilities
only run for short periods but are expensive to operate and emit high levels of carbon dioxide, methane,
and other pollutants per megawatt generated. Peak demand can be reduced in many ways, such as
“demand response” programs that provide customers incentives to shift energy use away from peak
hours. To achieve CETA goals, PSE will need to invest in batteries, demand response, energy efficiency,
and other advanced technologies, further diminishing the perceived need for Energize Eastside.
Energize Eastside also harms the environment by cutting down valuable urban trees. In Renton, PSE
would remove over half of the 641 trees within the project area (339 trees would be cut, and 238 are
classified “significant.”) These trees provide storm water control, shade, carbon storage, noise
mitigation, human health benefits, and wildlife habitat – benefits to society the EIS values at over
$700,000. PSE promises to replace the trees with shorter varieties that won’t grow dangerously close to
the power lines, but these will take many years to mature. The replacement trees would have smaller
root balls, and fewer leaves or needles. They would never provide the full benefits of the trees that
would be removed.
11 https://www.vox.com/energy-and-environment/2019/4/18/18363292/washington-clean-energy-bill
12 https://www.pse.com/pages/energy-supply/electric-supply
11
1.6 Fire safety
The EIS acknowledges an increased risk of pipeline fires due to the proximity of the proposed poles and
excavation of large holes next to the existing Olympic pipelines. Renton already survived a close call in
an accident involving these same pipelines.
On the morning of May 23, 2004, an explosion occurred at a Renton facility owned by Olympic
Pipeline.13 Approximately 50 firefighters arrived on the scene, where 20-foot flames erupted from a
pinhole leak in the pipeline. Thousands of gallons of gasoline were released, and it took three hours to
extinguish the fire.
Renton facility damaged by a pipeline explosion in 2004
Compared to the fatalities and 1.5-mile path of destruction that occurred in the Bellingham pipeline fire
five years earlier, Renton was fortunate to escape with relatively minor injuries that sent three
emergency responders to the hospital.
In Renton, the Sierra Heights Elementary School is located 225 yards from the Olympic pipelines, less
than half the distance California safety codes require between schools and hazardous liquid pipelines.14
PSE proposes to install a new pole approximately 7 feet from one of the pipelines at this location. This is
less than the minimum separation of 13 feet recommended by PSE’s pipeline safety consultant, DNV-GL.
13 https://response.epa.gov/site/site_profile.aspx?site_id=864
14 https://www.cde.ca.gov/ls/fa/sf/title5regs.asp, Article 2, Section 14010(h)
12
The consultant says the risk might be mitigated by installing arc shielding protection.15 However,
another consultant, Stantec, does not agree that this recommendation would ensure protection from
arcing and accelerated corrosion of the pipeline that could lead to a breach:16
In Stantec’s opinion, although the [DNV-GL] study and modeling performed is sufficient as a
sensitivity analysis, it cannot be used to determine the mitigation requirements for the pipelines
related to the final design of the powerlines. …
As such, we recommend the following be performed in the detailed design stage of the project: …
• Reassess the safe separation distance to minimize arcing risk based on NACE SP0177 and
considering the findings in CEA 239T817.
• Ensure that the separation distance between the pipelines and the powerline structures
exceeds the safe distance required to avoid electrical arcing.
• Design monitoring systems to monitor the AC corrosion risks along the pipelines.
• Install and commission the AC mitigation and monitoring systems prior to energization of the
230 kV powerline.
Neither PSE nor the Olympic Pipeline Company have responded to these recommendations with
detailed proposals to reassure the community that Energize Eastside will operate safely near these
pipelines for decades.
If an accident were to happen in this location, leaking fluid would likely flow downhill and potentially
ignite nearby trees. An unbroken path of dense vegetation leads from the pipeline location to
approximately 40 yards from the school.
The EIS analyzed a theoretical accident of more than 300,000 gallons of fuel spreading and burning on
flat ground, as shown in the following diagram:17
15
https://energizeeastside2.blob.core.windows.net/media/Default/Safety/PSE_AC_Analysis_Bellevue_WA_FINAL_P
P16591_12132016.pdf, p. 30
16
http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/stantec_peer_review_of_corrosion_report_05_0
2_2017.pdf, p.2
17 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_4.9_pipeline_safety.pdf, p. 4.9-16
13
The EIS warns that the diagram is a “simplistic representation and does not show site-specific
conditions.”
This insufficient analysis of pipeline fire risk in the EIS was noted by the City of Newcastle in its council
agenda for June 20, 2017:18
While the DEIS characterizes the hypothetical pool fire as a “worst case” scenario, it also
acknowledges that if “hilly conditions, waterbodies, or catch basins were present, the pipe
contents could flow away from the site of the release … The City’s elevation and topography are
strikingly different from the “pool fire” scenario discussed in the DEIS (pages 3.9-28 – 3.9-29).
The DEIS should evaluate the impacts of a potential release or rupture under scenarios where
actual hilly conditions, waterbodies or catch basins are present to better understand the
potential impacts in all of the partner cities.
A hill near the Sierra Heights Elementary School and abundant vegetation invalidate simplistic
assumptions made in the EIS risk analysis.
18 https://newcastle.civicweb.net/filepro/document/14614/AB%2017-39_Energize%20Eastside.pdf
14
1.7 Pole safety
PSE suggests that steel poles will be safer for nearby homes than aging wooden poles. According to an
industry website, “Whether made of wood, light-duty steel, concrete, fiberglass or composite materials
like resins and glass, all utility poles and towers can bend, break and bob when Mother Nature kicks up
her heels.” 19
During the past decade, steel poles have failed due to accident, corrosion, weld failures, ice loading, and
extreme winds.
Seventeen steel poles fell in Teton Village, Wyoming, 2/8/1720
19 https://www.power-grid.com/1999/01/01/wood-steel-concrete-mother-nature-can-bring-em-all-down/
20 https://www.wyomingnews.com/news/teton-village-without-power-after-storm-downs-power-
lines/article_0aee7dce-ee57-11e6-8017-eb7fa13cd38b.html
Weld failure Corrosion
15
Contrary to PSE’s implication that steel poles would be safer than aging wooden poles, H-frame wooden
structures of the type that currently support the power lines are resilient and have remained standing in
challenging circumstances.
At least ten Renton homes and other community buildings are located within the fall radius of PSE’s
proposed poles:
• 1074/1078 Lynnwood Ave. NE
• 859/863/867/1005 Monroe Ave. NE
• 154/160/166/174 Glenwood Pl. NE
• Renton Seventh-day Adventist Church
• Highlands Preschool
• Renton Technical College (Building A)
This photo shows the strike zone of a proposed 113-foot pole in Renton that could fall on any of four
nearby homes:
Four homes are within the fall radius of a proposed 113-foot pole
16
2. Assumptions used to justify Energize Eastside
To justify building Energize Eastside, PSE commissioned Quanta to perform two studies in 2013 and
2015. The primary purpose of the project was to serve growth in downtown Bellevue and the
developing Spring District in Bellevue. In Renton, growth has been less vigorous.
Quanta’s assumptions have not stood the test of time:
1. Quanta assumed winter peak demand would increase rapidly. It has fallen.
2. When analyzing a peak demand scenario in summer, Quanta ignored critical details of where
electricity is produced and consumed.
3. Quanta did not consider technology that can address summer demand.
2.1 Incorrect winter demand trends
The peak winter demand scenario studied by Quanta is not well understood by the public or the
businesses that PSE scares with warnings of impending blackouts.
Here are all the conditions that must occur simultaneously to cause a blackout:
• An arctic weather system settles on the Puget Sound area, plunging temperatures below 23° F
for more than a day.
• During peak hours on a weekday (6-9 AM or 5-9 PM), electricity consumption spikes.
• Two of the four 230 kV transformers that supply electricity to the Eastside fail.
• Half a dozen gas peaker plants whose main function is to serve peak demand in PSE’s service
territory are inexplicably offline.
• The Northwest is sending 1,500 MW to Canada, some of which flows through the Eastside and
increases load on PSE’s remaining transformers.
• Peak demand on the Eastside has increased at an annual rate of 2.4%, year over year, eventually
straining the limits of the system to handle all these stresses.
Even under this extremely unlikely set of circumstances, there would be no blackouts. PSE claims it
would have to change operational parameters for the Eastside grid, and the grid would become
vulnerable to a blackout if an additional failure or emergency occurred.
PSE has admitted that this confluence of events is unlikely to occur, but the company claims federal
NERC standards require Energize Eastside to be built anyway. CENSE agrees that federal standards
require PSE to anticipate the first three events (cold, peak demand, and failure of two critical
components). However, the subsequent items go well beyond what PSE is required to handle.
In a letter to PSE dated June 19, 2018, the Utilities and Transportation Commission (WUTC), expressed
similar concerns about the offline peaker plants, impact of regional flows, and aggressive demand
forecasts.21 PSE did not respond for over 16 months. On November 4 ,2019, five members of PSE’s
21
https://www.utc.wa.gov/_layouts/15/CasesPublicWebsite/GetDocument.ashx?docID=1760&year=2016&docketN
umber=160918, p. 10
17
Technical Advisory Group sent PSE a letter, asking if the company would ever answer WUTC’s four
questions.22 PSE responded on November 27, 2019.23 In short, the answer was “No.”
Although each of these questions deserves a thorough answer, this document will focus on Quanta’s
2015 winter demand forecast, which was simplified and published on PSE’s website in June 2015:24
PSE’s 2015 forecast of Eastside omits historical data and increases 2.4% per year
The graph shows demand rising quickly (2.4% per year) and exceeding the “system capacity range” by
the winter of 2018. CENSE added the orange arrow to call attention to the lack of historical data that
might help the public understand how these trends have developed over time. Members of the public
also wondered why the forecast rate of growth was more than double the rate of population growth.
Where would all that electricity go?
PSE reports peak demand annually to the Federal Energy Regulatory Commission (FERC). During the
past 15 years, peak demand has been declining throughout PSE’s service territory:
22
https://oohpseirp.blob.core.windows.net/media/Default/Action_Items/2019_1104_CENSE_Vashon_CAG_Bridle_T
rails_Energize_Eastside.pdf
23
https://oohpseirp.blob.core.windows.net/media/Default/Comment_Reports/2019_November_IRP_CommentSum
mary_WEB.pdf, p. 10
24 https://web.archive.org/web/20150623080514/http://www.energizeeastside.com:80/need
No historical
data 2004-2014!
18
PSE’s annual peak demand and extrapolated trends
The orange line shows peak demand as reported to FERC. The dashed blue lines show a range of trends
that can be extrapolated from the peak demand data. Standard statistical analysis finds with 95%
certainty that peak demand levels are falling in PSE’s service area at a rate between 0.1% and 1.0% per
year. The red dashed line shows the system-wide “Overload Level” of 5205 MW that Quanta identified
in the Eastside Needs Assessment.25 Exceeding this level might require a project like Energize Eastside.
(Note that the previous graph showed Eastside “system capacity” at 700 MW, only part of the system-
wide peak of 5205 MW shown here.)
For many people, declining demand comes as a surprise, especially because PSE’s customer base grew at
an annual rate of 0.8% during this same time period. There are several factors driving declines for
utilities in the Puget Sound region and across the country. Technology like LED lighting, smart
thermostats, and efficient heat pumps became widely available during the past decade. Growing
concern for the climate has focused efforts to reduce energy consumption in homes and businesses. At
the same time, winters are becoming warmer in the Pacific Northwest, requiring less use of electricity
for heating.
Demand trends are falling progressively farther away from the “Overload Level.” It is not apparent that
Energize Eastside will ever be needed to serve winter peak demand on the Eastside.
25
https://energizeeastside2.blob.core.windows.net/media/Default/Library/Reports/Eastside_Needs_Assessment_Fi
nal_Draft_10-31-2013v2REDACTEDR1.pdf, p. 9
19
2.2 Incomplete summer analysis
Quanta analyzed both winter and summer peak demand scenarios. The summer scenario is much like
the winter scenario (two transformers failed, peaker plants offline), with a few key differences:
• The highest levels of summer demand occur when weather is hot and air conditioners are
running continuously.
• The highest recorded summer peak (3508 MW in July 2009) was 29% lower than the highest
winter peak (4911 MW in December 2009).
• Transformers and wires are less efficient in hot weather.
• Regional transfers reverse direction in summer, and 2,850 MW is sent to California (instead of
Canada).
Unlike the winter scenario, peak demand data reported to FERC shows summer peak demand is
gradually increasing:
Growth of summer demand appears to match customer growth
The solid orange line shows peak demand as reported to FERC. The orange dashed line shows a best-fit
trend line increasing at 0.84% per year. The shaded area of the graph represents the number of
customers reported by PSE. The gray dashed line shows the growth trend for customers, which also
increases at 0.84% per year.
20
The rising trend for summer peaks exceeds PSE’s “Level of Concern” in 2009, 2017, and 2018. This may
appear to justify PSE’s case in favor of building Energize Eastside. However, it is important to
understand three mitigating factors before drawing conclusions:
1. The “Level of Concern” line is misleading.
2. The large regional flow of electricity to California is not apparent in this graph.
3. Sources of electricity are not identified.
At 3350 megawatts, the system-wide “Level of Concern” documented in the 2013 Eastside Needs
Assessment is 36% lower than the winter “Overload Level” of 5205 megawatts. Although wires and
transformers are somewhat less efficient in the summer heat, the difference is usually 20% at most.
Why is the summer level so much lower?
The difference may be due to the amount of regional electricity flowing through Eastside power lines at
the same time peak demand is being served. These regional transfers do not show up in the orange
peak demand line, because the electricity is not consumed by PSE customers. Instead, the regional flow
pushes the “Level of Concern” lower, raising the urgency of a summer solution.
The effect of the California flow is documented in a 2015 study by Bellevue’s independent analyst, Utility
System Efficiencies.26 The analyst predicted that regional flow of this magnitude would cause six
different grid elements to overload in the summer of 2020. However, if the regional flow is reduced, all
six overloads disappear, leaving the system in good working order for Eastside customers.
Regional grid operators can curtail large transfers to California within 15 minutes if equipment outages
threaten service on the Eastside. To defend its project, PSE insists that large regional transfers must be
maintained under all circumstances. In other words, PSE would require its customers to pay hundreds
of millions of dollars to maintain these large transfers to California. No federal standard requires PSE’s
customers to overbuild local infrastructure to guarantee California receives electricity during an
unprecedented emergency on the Eastside. If Californians want guaranteed delivery of electricity from
the Northwest, they should pay for the larger transmission lines needed to deliver it. Those lines do not
need to run through Eastside neighborhoods.
2.3 Omitted analysis of alternatives
PSE did not ask Quanta to evaluate alternatives to PSE’s desired transmission line upgrade. The EIS
should have considered realistic alternatives for both winter and summer scenarios, but it shortchanged
the summer analysis. Now that the summer peak has become PSE’s main justification for Energize
Eastside, no one knows if alternatives would be more effective than the transmission line.
For example, electricity produced by rooftop solar panels is increasing rapidly, as shown in the following
graph from the public utility serving Snohomish county (PSE refused to provide equivalent data for its
service territory, see Addendum B).
26 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/cob_independent_technical_analysis_1-3.pdf,
p. 67
21
Local solar production is climbing rapidly
As rooftop solar energy becomes more prevalent, stress on electrical infrastructure could decline even if
peak demand increases. Locally produced electricity does not run through the transformers and
transmission lines that PSE has identified as a bottleneck in peak demand scenarios.
Although the above graph shows data from Snohomish, the overall trend is likely to be similar in PSE’s
service territory. The future promises broader use of solar panels because their cost is rapidly declining
while PSE’s electric rates are increasing. Also, greater use of solar energy is needed to meet the clean
energy goals adopted by our state (CETA).
Skeptics may argue that midday peak solar production does not align with peak consumption occurring
at 5-6 PM. However, recent solar panel installations are being paired with batteries, and batteries can
store solar energy to help meet peak demand later in the day. Like solar panels, electricity provided by
batteries adds no stress to transformers or transmission lines. Battery costs are declining as well:27
Solar and battery prices continue to decline
27 https://www.nrel.gov/docs/fy19osti/72399.pdf, p. viii, and https://about.bnef.com/blog/behind-scenes-take-
lithium-ion-battery-prices/
0
2
4
6
8
10
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018MegawattsSnohomish Local Solar Peak Production
$0.00
$2.00
$4.00
$6.00
$8.00
2010 2011 2012 2013 2014 2015 2016 2017 2018
Cost (2018 adjusted US dollars)Cost of solar and batteries
Solar (2018$/W)Battery (2018$/Wh)
22
The inadequate analysis of solar energy to meet summer need is demonstrated in this quote from the
EIS: “Solar could help reduce summer peak loads but because additional capacity would continue to be
needed for winter, the use of solar generation to address the transmission capacity deficiency would
need to be matched by winter generation capacity and therefore would be redundant.”28 Feasibility of
batteries in the summer was also not considered in the EIS: “Summer requirements were not evaluated
because the limitations identified during the winter study indicated that energy storage would not be a
feasible stand-alone alternative.”29 Now that the summer scenario has become the main justification
for the project, solar and batteries should be carefully studied to see if they provide a less expensive,
less damaging, and less risky solution to Eastside energy needs.
One other significant change has occurred since alternatives were last considered: the scope of the
project has been significantly reduced.
In 2016, the Phase 1 Draft EIS stated the whole 16-mile project was necessary to meet the
perceived need: “The area identified by PSE as having a transmission capacity deficiency is
situated between the Sammamish substation on the north end (Redmond/Kirkland area) and
the Talbot Hill substation on the south end (Renton area). Transmission improvements would
need to be tied to these two substations in order to address the need for the project.”30
In 2019, the Bellevue City Staff Report states: “The full buildout of the Energize Eastside project
will include a similar connection from the Sammamish substation in the north to provide
redundancy, but the south portion of the Project … can function independently.”31
The only way these seemingly contradictory assessments can both be true is if new assumptions have
been made in the intervening three years. However, PSE has not disclosed any changes in assumptions
or parameters. If assumptions have changed, it is possible that alternatives would be feasible that were
previously on the cusp of feasibility.
If a single segment is now sufficient to meet the need, the northern segment should also be studied.
The northern segment would run through Bellevue and less than a mile in Redmond. Building the
northern segment would leave existing lines in Renton and Newcastle undisturbed. Only through
transparent studies can the public weigh the merits of each alternative.
2.4 Unforeseen alternatives
In addition to solar panels and batteries, new options have become available to serve the Eastside’s
energy future.
A September 2019 report found that a “Waste-To-Energy” processing plant would be more economical
to process waste from King County than exporting the waste to remote landfill locations by railroad. It
would also become a local source of electricity that would not be dependent on wind or sunshine. The
28 Ibid., p. 2-39
29 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/02_chapter_2_project_alternatives.pdf, p. 2-
40
30
http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/00_cover_letter_fact_sheet_table_of_contents_
glossary.pdf, p. FS-i
31 https://bellevuewa.gov/sites/default/files/media/pdf_document/Staff%20Report%20FINAL%201242019.pdf, p.
111
23
report concludes, “[A Waste-To-Energy plant] will provide a gross savings of approximately $4.3 to $7.2
billion … when compared to [shipping waste by rail] over the 50-year planning period and [Waste-To-
Energy] has a significant advantage on improving recycling rates and energy recovery.”32
With these positive findings, the county appears poised to evaluate a plant sited at the Cedar Hills
Regional Landfill located about six miles east of Renton. This is the same location PSE considered for a
natural gas-powered plant to generate electricity as an alternative to Energize Eastside, but the
company determined the plant could not resolve the original deficiencies. However, with altered
assumptions and some help from solar panels and batteries, a Waste-To-Energy plant might solve both
waste issues and electricity issues with one facility, saving customers even more money over several
decades. CENSE believes this significant opportunity warrants a closer look requiring updated
disclosures from PSE.
3. Winners and losers created by the project
Energize Eastside has been a divisive project because PSE has promoted the idea that businesses and
developers in downtown Bellevue would benefit, while simultaneously minimizing the economic, safety,
and aesthetic burdens that would be borne by families and neighborhoods located near the taller poles
and higher voltages. The name itself, “Energize Eastside,” is a marketing term intended to unify support
for the project in the impacted cities. “Energize Downtown Bellevue” might be a more accurate name.
In 2015, the City of Bellevue engaged Stantec, an energy consulting firm, to evaluate the need for
Energize Eastside to support conclusions in the EIS. Stantec states, “For the Eastside the highest load
densities are north of I-90 and west of Lake Sammamish.”33 The identified area is mostly in Bellevue.
Here is a list of the winners and losers created by Energize Eastside.
Winner: Bellevue developers. PSE’s marketing machine has created an impression that the city is
headed for frequent blackouts if Energize Eastside is not built. This is a marketing strategy and a scare
tactic, not a fact. PSE’s technical studies show that “the peaks occur for just a few hours per year,”34 and
rolling blackouts would only be necessary if an extraordinarily unlikely set of circumstances occurs
during those few hours (half of the 230 kV transformers serving the Eastside fail, half a dozen generation
plants are offline, and large amounts of electricity are being transmitted to California or Canada).
But Bellevue likes to be known as a city “open for business.” By demonstrating its willingness to ignore
the concerns of its residents in order to keep downtown businesses awash in electricity (even if no
realistic threat exists), Bellevue confirms its commitment to commercial developers.
32 https://mkcclegisearch.kingcounty.gov/View.ashx?M=F&ID=7759006&GUID=168AF89C-8137-4EE8-B95C-
D4135F9FA486, p. 6-1
33
http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/stantec_review_memo_eastside_needs_assessm
ent_report.pdf, p.8
34
https://energizeeastside2.blob.core.windows.net/media/Default/Library/Reports/SupplementalNeedsAssessment
Report_Redacted_April2015.pdf, p. 38
24
Loser: Renton. Not only will Renton have more miles of the new transmission line than any other city (4
miles vs. 3.3 miles in Bellevue), Renton will receive the least benefit. A map in the 2013 Eastside Needs
Assessment shows shaded areas where PSE would enact rolling blackouts if the company’s highly
unlikely scenario were to occur.35
PSE’s map shows 66,000 customers “at risk” of rolling blackouts. (Without explanation, PSE later
inflated the number to 130,000 “at risk” customers.) PSE does not clarify that a blackout would not
affect all these customers simultaneously. Perhaps less than 10,000 customers would lose power for
half an hour before the rotation advances to the next group. In fact, only a small portion of North
Renton bordering Lake Washington would be affected. However, these customers are much less likely
to experience such a blackout as opposed to other outages that affect PSE’s distribution system (such as
tree limbs falling on neighborhood distribution lines, non-peak equipment failure in local substations,
and animal incursions).
35
https://energizeeastside2.blob.core.windows.net/media/Default/Library/Reports/Eastside_Needs_Assessment_Fi
nal_Draft_10-31-2013v2REDACTEDR1.pdf, p.35
A sliver of Renton customers is included in PSE’s rolling blackout map
25
Loser: Newcastle. The combination of pipelines and transmission lines passes closer to Newcastle’s
downtown core than any other city. The utility corridor passes less than 75 feet from Newcastle’s City
Hall. An economic analysis in the EIS considers what could happen if the project reduces assessed
property values fall by $10 million: “… the City would need to reduce its budget (for items covered by
property tax) by approximately $20,000.”36 This would be a challenge for a city currently struggling with
budget issues.
Winner: PSE’s investors. PSE is owned by Canadian and Dutch private equity funds, most of which
participated in the acquisition of PSE in 2009. The investors are keen to reverse a dramatic decline in
PSE’s operating revenues during the past decade:
While electricity consumption has been flat for the last 15 years, PSE’s gas business has suffered from
low gas prices and decreasing gas consumption. Energize Eastside provides some relief for PSE’s bottom
line. A transmission line is particularly profitable, because PSE doesn’t have to engage in competitive
bidding to build the project. The cost is whatever the company says it is (within reason). The higher the
cost, the higher future revenues will be due to the generous interest rate PSE collects over decades.
Loser: PSE’s customers. All 1.1 million of PSE’s customers will pay the initial cost of Energize Eastside,
plus a 9.8% rate of interest for 50 years or more. The total could exceed $1 billion. Less expensive
alternatives were improperly dismissed by the company and the EIS, which failed to evaluate solar
panels and batteries for the summer scenario that PSE says has become the main reason to build the
project.
Winner: businesses in downtown Bellevue. By overbuilding transmission capacity, Bellevue businesses
have an energy solution that requires little effort from them. No poles or wires will be installed in their
section of the city, stricter building codes may be delayed, and increased energy efficiency becomes an
optional element in Bellevue’s energy future.
36 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/section_3.10_economics.pdf, p. 3.10-9
26
Loser: residential neighborhoods and the environment. Both neighborhoods and the environment
would incur uncompensated costs. Residential neighborhoods would experience higher voltage,
industrial infrastructure, negative aesthetic impacts, reduced property values, increased risk of fires and
pipeline accidents, and loss of valuable trees. The environment would lose carbon storage, wildlife
habitat, and financial resources to pursue smart energy programs.
Loser: transparency and local accountability. If PSE is permitted to build this project without providing
evidence that electric demand is increasing on the Eastside, an unfortunate precedent will be set. PSE
has refused to answer reasonable questions about Energize Eastside from ratepayers, the Utilities and
Transportation Commission, and the company’s self-selected Technical Advisory Group. It is alarming
that a profit-oriented corporation can thwart inquiries from regulators, advisors, and the public.
Questions and Answers
Q: What about electric cars? Won’t they increase consumption of electricity?
A: Yes, increasing electrification of our economy is likely to increase total consumption. But for Energize
Eastside, the main question is when the electricity is consumed, not how much. Like most utilities, PSE
serves varying demand throughout the day. Demand is low from 10 pm to 6 am. If customers are
educated and financially incentivized to charge their cars during these hours, peak demand will not
increase. There are many benefits to customers, PSE, and the environment if we use smart technologies
and policies to keep peak demand from growing.
Seattle is anticipating lots of electric cars and buses, but Seattle City Light is forecasting falling peak
demand for at least two decades:37
Seattle City Light’s 2018 forecast of average load and peak demand
37 https://www.seattle.gov/light/IRP/docs/2018_Integrated_Resource_Plan_Progress_Report.pdf, p. 10
27
Q: You are worried about the large fall zone of tall poles, but high-voltage wires on short poles raise
different safety concerns. Which do you prefer?
A: The problem is the voltage. Residents have lived with 115 kV lines for decades, and we understand
the risks. Doubling the voltage should be the last solution considered from a safety standpoint.
Q: The current poles are so old. Wouldn’t new poles be safer?
A: We support robust maintenance and replacement of any old poles that are becoming unsafe. PSE
hasn’t proven that it’s necessary or desirable to double the voltage in the corridor. We support
investments that make our service more reliable, safer, and better for the environment.
Q: Maybe there isn’t a need for Energize Eastside now, but isn’t it a good idea to build it, just in case?
A: It’s true that transmission lines take a long time to build. However, there are many new technologies,
like batteries, that can be installed within a few months if the need arises. Elon Musk bet he could
install a utility-scale battery in Australia in less than 100 days, and he did it.38 There are lots of smart
things we can do if a problem develops, but it is very unlikely that we will face this kind of peak demand
reliability issue any time in the next decade.
Conclusion
Here are nine facts we would like you to remember:
1. Energize Eastside would impact safety, aesthetics, property values, and environment in Renton.
2. The winter scenario that PSE initially warned about has not materialized.
3. PSE has shifted focus to a summer scenario, but the EIS did not evaluate rooftop solar panels
and batteries to serve summer demand.
4. New alternatives like a King County Waste-To-Energy plant can save customers money.
5. If a transmission line is proven to still be the best solution, a northern segment affecting only
Bellevue and less than a mile in Redmond would leave lines undisturbed in Renton and
Newcastle. This option has not been studied.
6. The EIS assumes the utility corridor would be widened to maintain safety as 230 kV transmission
lines and two petroleum pipelines pass by homes, schools, churches, businesses, and parks. PSE
is not planning to widen the corridor.
7. The EIS did not properly evaluate the site-specific risk of a pipeline fire on a hill surrounded by
vegetation (a concern for Sierra Heights Elementary School).
8. Energize Eastside would soon become redundant with efforts PSE must take to comply with
Washington’s new Clean Energy Transformation Act (CETA), but ratepayers will continue to pay
9.8% interest on the cost of the project for decades.
9. PSE has significant financial incentives to pursue a no-bid transmission project at the expense of
its customers and the environment.
38 https://www.engadget.com/2017/11/23/tesla-australia-powerpack-100-day-bet/
28
Addendum A: PSE refuses to provide Eastside peak demand data
(Donald Marsh is a member of PSE’s Technical Advisory Group and has security clearance from FERC)
Via Electronic Mail
May 13, 2016
Mr. Donald Marsh
4411 137th Avenue SE
Bellevue, WA 98006
Re: CEII Information Request
Dear Mr. Marsh:
By way of a recap, you submitted a CEII request to Puget Sound Energy, Inc. (PSE) that we received on March 14,
2016. Your request asked for, among other things, historical loading, peak load information and load flow
information related to the Energize Eastside Project.
We responded to your request on April 15, 2016 and provided some of the information you requested.
Additionally, we asked you to provide additional information to support your request so that we could evaluate
your eligibility to receive CEII, a legitimate need for CEII and ability to protect the confidentiality of CEII.
You responded to our request for additional information in your letter dated April 27, 2016. This letter was very
informative in helping us better understand what information you were looking for and we appreciate your clarity.
By our count, you asked for four things in your letter: (1) historical loading on each of the 230/115 kV substations
you consider to be on the Eastside as well as each of the 115/12 kV substations you consider to be on the Eastside;
(2) the amount of electricity being transmitted to Canada; (3) the ratings of the transformers that are overloading
in the simulation; and (4) whether the simulation was run in DC mode.
Historical loading on individual substations is confidential in order to protect customer sensitive information so this
request is denied. The remaining requests are not considered CEII and our responses are as follows. Power flows
between the Northwest and Canada can be found to be 1500 MW in the south to north direction for winter
scenarios and 2850 MW in the north to south direction for summer scenarios. Ratings on transformers that are
overloading in the winter simulation are 484 MV A for both Talbot Hill transformer banks and ratings on
transformers that are overloading in the summer simulation are 429 MVA for Sammamish Transformer #1 and 410
MV A for Sammamish Transformer #2. Finally, the simulation was not run in DC mode.
Your letter also mentions the CEII clearance you received from FERC, as well as that received by Mr. Lauckhart.
Please note that FERC approval does not constitute PSE approval. FERC jurisdictional entities such as PSE have their
own CEII processes and procedures that are meant to function and be applied for separately and independently
from those of FERC.
Lastly, you state in your letter that you are not planning to run a simulation. Based on that acknowledgment, the
technical data you asked for in your original request that we received on March 14, 2016 does not fulfill a
legitimate need and that request is therefore denied.
Sincerely,
Puget Sound Energy, Inc.
By George Marshall
Its: Manager Transmission Policy and Contracts
29
Addendum B: PSE refuses to provide solar peak data
(Donald Marsh requested solar peak data as a member of PSE’s Technical Advisory Group)
From: Netik, Irena <irena.netik@pse.com>
Sent: Monday, December 23, 2019 10:27 AM
To: Don Marsh <don.m.marsh@hotmail.com>
Cc: Kvam, Michele <michele.kvam@pse.com>
Subject: RE: Solar output for PSE customers
Don
Unfortunately, I have not been able to track down the information you requested. The solar capacity
installed on our system is about 60 MW currently.
Thank you,
Irena Netik
D: 425.462.3671 M: 206.434.2336
From: Don Marsh <don.m.marsh@hotmail.com>
Sent: Saturday, December 14, 2019 4:14 PM
To: Netik, Irena <irena.netik@pse.com>
Cc: Kvam, Michele <michele.kvam@pse.com>
Subject: Solar output for PSE customers
CAUTION: This email originated from outside of the organization. Exercise extra caution when
responding, opening attachments, and clicking links.
Hi, Irena.
As a member of PSE’s Technical Advisory Group, I am trying to understand how photo-voltaic solar
panels are contributing to our energy supply in the Puget Sound. If possible, I would like to know the
peak energy generated in megawatts for each year 2009-2018 in PSE’s service area. It would also be
helpful to know how many solar panel systems were operating for each of those years.
Can PSE provide this information, or put me in touch with someone who can?
Sincerely,
Don Marsh
LAW OFFICES OF J. RICHARD ARAMBURU PLLC
720 Third Avenue, Suite 2000 www.aramburulaw.com
Seattle, WA 98104 www.aramburu-eustis.com
Telephone 206.625.9515
Facsimile 206.682.1376
January 8, 2020
Honorable Phil Olbrechts
Renton Hearing Examiner
City of Renton
1055 S Grady Way
Renton, WA 98057
Re: Application of Puget Sound Energy for Conditional Use Permits for Four Miles of
230 kV Transmission Lines: Application LUA18-000055,CUP-H,SME
Dear Examiner Olbrechts:
This office represents the Coalition of Eastside Neighbors for Sensible Energy
(CENSE), a non-profit corporation formed on August 13, 2014, to foster and promote
the welfare and safety of communities on the Eastside, including the City of Renton,
impacted by the proposed construction and operation of new 230 kV electric
transmission lines by Puget Sound Energy (PSE). Approximately four miles of those
lines would be located in the City of Renton.
We write to the Examiner to recommend denial of the proposal as inconsistent with
applicable Renton code criteria. In the alternative, we ask that the Examiner remand
this matter to city staff for preparation of a supplemental draft and final environmental
impact statement because of the failure to consider the actual project proposal or
reasonable alternatives. The basis for this request is set forth herein.
1. PROJECT HISTORY.
Beginning in December, 2013, PSE began promoting its “Energize Eastside”
proposal. That proposal was for the installation and operation of new 230 kV
transmission lines running between two substations on the Eastside: the Sammamish
substation (in Redmond) and the Talbot Hill substation (in Renton), and connection with
a new substation to be constructed in Bellevue just north of I-90 (Richards Creek). A
drawing showing the PSE’s original plan is Figure 1-1, page 1-2 of the FEIS for the
project. A copy of that figure is Attachment A to this letter. The proposal included
approximately 16 miles of transmission lines running through five cities on the eastside,
Redmond, Kirkland, Bellevue, Newcastle and Renton, as shown on Figure 2-1 of the
January 8, 2020
Page 2
FEIS, at page 2-8. See Attachment B to this letter. This diagram shows about 7.24
miles of the proposed line north of the proposed Richards Creek substation and 8.78
miles to the south, a total of 16.02 miles. Id.
PSE claims that the “Energize Eastside” proposal is necessary to address
deficiencies in its electric system, principally the overloading or failures of the existing
Sammamish and Talbot Hill substations during times of peak demand on the PSE
system. The cost of the proposal, to be paid for entirely by ratepayers, is vague; PSE
indicates the cost as between $150,000,000 and $300,000,000.
In December, 2014, the five cities through which the transmission lines were
proposed entered into an “Interagency Agreement” (the “IAA”) regarding SEPA
compliance for the PSE proposal. See Attachment C. The Cities agreed that an EIS
would be prepared for the proposal (Section 1.2) with the City of Bellevue as the
“nominal lead agency” and the other cities as “co-lead agencies.” Each City, however,
would process an individual project application for the portion of the line within its
jurisdiction based on its own land use and environmental regulations. IAA at page 3. In
Attachment A to the IAA setting forth the “Project Description,“ the “New Transformer
and Transmission Line” was described as follows:
The most viable solution considered was a combination of adding a new
substation with a 230 kV transformer connecting it with the Talbot and
Sammamish substation (sic) via a new 230 kV transmission line.”1
In an unusual procedure, PSE and the Cities agreed to prepare two draft environmental
impact statements (Phases 1 and 2), solicit comments on each, and then prepare a
final EIS, each of which is part of the record here. Also in an unusual move, PSE did
not submit a permit application prior to the initial SEPA review; the DEISs were
prepared on a concept of a new substation plus the 16 miles of transmission.
The Phase 1 DEIS was issued in January 2016. On page 1-4 it stated that:
The Phase 1 Draft EIS broadly evaluates the general impacts and implications
associated with feasible and reasonable options available to address PSE ‘s
identified objectives for the proposal. The evaluations conducted during Phase 1
will be used to narrow the range of alternatives for consideration in the Phase 2
1Under the terms of the Energy Facilities Siting Act, chapter 80.50 RCW, adopted in 1970, the
Washington Energy Facilities Site Evaluation Council (EFSEC) has authority to act on PSE’s transmission
proposal under RCW 80.50.060(3) if PSE requests certification. PSE acknowledged the authority of
EFSEC to approve the project, but has not requested certification. See FEIS, Appendix J, page J1-11.
Even if one of the jurisdictions currently considering the PSE applications denies approval, PSE could still
seek EFSEC certification to override such disapproval.
January 8, 2020
Page 3
Draft EIS. The Phase 2 Draft EIS will be a project-level evaluation, describing
impacts at a site-specific and project-specific level.
On page 1-1 of the Phase 1 DEIS, the question was asked: “What is the Project
that is being evaluated in this draft EIS?” The answer was:
PSE is proposing to construct and operate a new 230 kV to 115 kV electrical
transformer served by approximately 18 miles of new high-capacity electric
transmission lines extending from Renton to Redmond.
At page 1-15, the “major steps to develop the Phase 1 DEIS” were described:
Programmatic alternatives were defined through an iterative process with input
by the EIS Consultant Team, PSE, City of Bellevue and other partner cities.
After examining the materials provided by PSE regarding its planning process for
the project, alternatives were selected that would broadly define different ways of
approaching the deficiency in transmission capacity, identified by PSE. One
approach would use 230 kV transmission as PSE proposes, one would use
alternative methods that would minimize the need for new transmission lines;
and one would use 115 kV transmission lines along with substation upgrades.
No alternatives were identified that might use a shorter 230 kV transmission line or
dead-end the line somewhere along its 16 mile length. There was certainly no
discussion of only a Talbot Hill to Richards Creek connection.
During scoping for the Phase 1 DEIS, comments were received under the
heading of “Upgrade/Adjust Existing Electrical System,” including: “Several changes
and adjustments to the electrical system were proposed as potential solutions.” Phase
1 DEIS at 2-50. One was the possibility of disconnecting the line in central Bellevue to
assure that the new lines would not be used to transmit power to Canada. At page 2-
51 the Phase 1 DEIS said such break in the lines was “not considered viable for several
reasons: . . .” One was:
Being interconnected also allows economies of scale of both transmission and
generation facilities. Finally, the solution could reduce the supply of power to the
Eastside, necessitating additional conservation, generation or storage beyond
that considered in other alternatives in the EIS.
The next bullet point on the same page said:
Disconnecting the north and south sections of the route at a central Bellevue
substation to prevent non-Eastside load from being carried on this line during
peak period of demand on the Eastside would deprive the Eastside of power
supply needed during these (peak) periods. Separating the system in central
January 8, 2020
Page 4
Bellevue from the regional grid would also not meet FERC mandatory reliability
standards.2
(Emphasis supplied.) Based on these statements, the alternative of separating the
north and south systems was not included in the Phase 1 DEIS. See page 2-50 in
Attachment D to this letter.
Following a comment period of the Phase 1 DEIS, the Phase 2 DEIS was issued
in May 2017. The project description was carried over, word-for-word, from the Phase
1 DEIS. See Fact Sheet, page 1. On page 1-1, the “Energize Eastside” project was
further defined as follows:
PSE’s analysis concluded that the most effective solution was to add a 230-115
kV transformer within the center of the Eastside to relieve stress on the existing
230-115 kV transformers that currently supply the area. This would need to be
fed by new 230 kV transmission lines from the north and south. By having lines
from two different directions, a substation can continue to be supplied even if
one line goes down.
(Emphasis supplied.) This exact language was carried over to the Final DEIS issued in
March, 2018. See page 1-3. As noted above, this was nearly the exact project
description found in the December, 2014 Interagency Agreement.
On page 1-4, the FEIS emphasized the importance of “ensuring that a proposal
that is the subject of environmental review is properly defined.” This page goes on to
say:
The process of defining the proposal includes an understanding of the need for
the project, to enable a thorough understanding of the project’s objectives (see
Section 1.8 of the Phase 1 DEIS) and technical requirements and to accurately
identify feasible and reasonable project alternatives for consideration in the EIS.
Section 1.8.2 of the FEIS stated that PSE’s “proposed project” includes two main
components, the first of which was:
New 230 kV overhead transmission lines, connecting the Sammamish
substation in Redmond and the Talbot Hill substation in Renton, a distance of
approximately 16 miles.
2In the past, PSE has contended that an Order from the Federal Agency Regulator Commission
dated October 13, 2015 approved the project as consistent with planning requirements. While that is
inaccurate, the proposal before FERC was the entire 16 miles proposal, not the current proposal that
dead-ends just north of I-90. See the letter from Pterra Consulting discussed later in this letter.
January 8, 2020
Page 5
At the same time the Phase 2 DEIS was being prepared, PSE also submitted an
“alternative siting analysis” to the City of Bellevue. In various places, this document
confirmed that the project under consideration was the 16 mile Sammamish/Talbot Hill
line and continuously asserted that this “bookend” connection was essential to the
project. The following are several references in that document to the 16 mile line:
Page 2:
After extensive study, PSE determined that the most effective solution to meet
increased electricity demand and to comply with federal performance
requirements is the addition of a 230 kV/115 kV substation in the center of the
Eastside load area – the Richards Creek substation – and the upgrading of 115
kV transmission lines with 230 kV transmission lines constructed between the
Sammamish (Redmond) and Talbot Hill (Renton) substations.
(Emphasis supplied.)
Page 3:
To limit the need to construct new facilities (and the associated environmental
impacts), when looking at the entirety of the Energize Eastside Project, all
transmission line route alternatives start at PSE’s Sammamish substation in
Redmond and end at the Talbot Hill substation in Renton. PSE considered
various routing options for the entire line, including five route options in the South
Bellevue Segment.
(Emphasis supplied.)
Page 5:
The Project is needed because cumulatively, demand on the Eastside is
increasing, including in areas along the South Bellevue Segment. The
transmission line component of the project must run between the Sammamish
and Talbot Hill substations. It must also connect with the proposed Richards
Creek substation.
(Emphasis supplied.)
Page 5:
Based on operational best practices, the ideal location for the new 230 kV
substation is located in close proximity to PSE’s existing 115 kV Lakeside
substation. In addition, operationally, the transmission line must transverse
through the City of Bellevue from the north to the south, making it impossible to
completely avoid areas of residential zoning.
(Emphasis supplied.)
Page 13:
Three 230-115 kV substation sites were considered for the Energize Eastside
Project - referred to as Westminster, Vernell, and Richards Creek. These sites
were selected for consideration because they are all owned by PSE; meet the
January 8, 2020
Page 6
objectives to site the 230 kV transformer at a central location between the
existing 230 kV power sources at Sammamish substation in Redmond and
Talbot substation in Renton; accommodate the necessary improvements to
serve the required 230 kV transmission lines to bring power to the centralized
transformer; and distribute power to the existing network of 115 kV transmission
lines.
Page 23:
The new 230 kV to 115 kV transformer is the principal component that will allow
the Eastside electrical system to reliably operate and meet Federal Planning
standards. To operate the new transformer it must be served by approximately
18 miles of new high-capacity electric transmission lines (230 kV) extending from
Redmond in the north and Renton to the south.
(Emphasis supplied.)
As noted above, the analysis contains multiple imperatives, i.e. that the proposal
“must” connect the bookend substations. There was no discussion, or even a passing
reference, to an alternative that would dead end in Bellevue and not complete the
“electrical circuit” between the Sammamish and Talbot Hill substations. The cited
pages are attached hereto as Attachment E.
2. APPLICATION FOR THE DEAD-END SOUTH SEGMENT.
As described above, in the period from December 2013 to August 2017, PSE
insisted in multiple forums that the project must include not only the new substation at
Richard Creek, but connections to the bookend substations at Sammamish and Talbot
Hill. Thus it was a surprise to all concerned, that when it actually filed an application in
Bellevue, it was only for the short, 3.3 mile segment from the proposed Richards Creek
substation south to the Newcastle city limits, a dead-end transmission line, the “South
Bellevue Segment” shown on Figure 2-1 (Attachment B). Applications for the lines in
Newcastle and Renton were also filed; the combined portion of the proposal between
the Richards Creek and Talbot Hill substation is referenced herein as the “South
Segment.”
The explanation offered for the shortened proposal was that PSE was intending to build
the line in segments and the South Segment was the first to be built. The application
was submitted after the comment period for the Phase 2 DEIS ended in July, 2017 so
there was no opportunity to provide comment on whether the SEPA analysis previously
prepared was sufficient for the South Segment.
In response to claims that it was seeking a strategic advantage by retreating to a
more bite-size, easy to swallow segment, PSE claimed that the application for the rest
of the project was coming along right away, i.e. by the end of the year (2017). But
when that time came and went, PSE backtracked and said the north application would
January 8, 2020
Page 7
be filed in early 2018. When no application was filed then, PSE finally stated that they
were busy with the south segment and that there was really no timetable at all for the
north application. To date, there has been no application for the North Segment in
Bellevue or otherwise and no indication when it might be submitted.
The application for the South Segment made to Bellevue did not provide any
analysis of how the abbreviated line would meet project objectives and needs that were
identified in the two DEISs that had been prepared.
The Final EIS was issued in March, 2018. However that document continued to
identify the proposal as the entire original project “connecting the Sammamish
substation in Redmond and the Talbot Hill substation in Renton, a distance of 16 miles.”
Page 1-10. The FEIS reiterated that the new substation “would need to be fed by new
230 kV transmission lines from the north and south.” See Pages 1-3 and 1-5.
Amazingly, the FEIS did not provide analysis of the South Segment, only mentioning
submission of “applications for the first phase of the project, including Renton,
Newcastle, and the southern portion of the project in Renton.” FEIS at page 1-11. That
information is repeated at FEIS page 2-5.
The South Bellevue Segment was reviewed by the Bellevue Development
Services Department during 2018 and into 2019. On January 24, 2019, Bellevue issued
its Staff Report dealing with what it called the “South Bellevue Segment,” the 3.3 mile
dead-end line. However, in response to a question of whether the South Segment
would be functional if only one (south) segment was permitted without the other (the
north) segment; the Staff Response was:
The south segment of the Project provides additional capacity that addresses the
Project need and could function whether or not the north segment is built. The
north segment would provide redundancy in the supply of 230 kV power to the
substation.
Staff Report at 100 (Attachment H hereto). On page 111, the Staff Report discusses the
3.3 mile South Bellevue Segment and states:
PSE’s analysis supported and demonstrated that operationally the Project must
include 230 kV lines connecting the Talbot Hill substation to the south to a new
transformer in central Bellevue. The full build out of the Energize Eastside
project will include a similar connection from the Sammamish substation in the
north to provide redundancy, but the south portion of the Project that is the
subject of PSE’s current proposal can function independently.
Attachment H (emphasis supplied). No citation or reference was provide to “PSE’s
analysis” discussed in the Staff Report.
January 8, 2020
Page 8
As described above, the conclusions reached by the Bellevue staff were at odds
with analysis that was previously prepared for the proposal. Both the Phase 1 DEIS
and Phase 2 DEIS were very clear that the project “must” include connections to the
north and south. Indeed, the Phase 1 DEIS made clear that a separation of the project
in central Bellevue “would not meet FERC reliability standards.” It appears that PSE
knew all along that a truncated version of its proposal would meet need and that the
portion of the project to the north was only redundant.
The South Bellevue Segment proceeded to hearing before the Bellevue Hearing
Examiner, who approved the South Bellevue Segment, which decision was affirmed by
the Bellevue City Council.
In making its Decision on appeal, the Bellevue council made it very clear that it
was not considering or approving future additions to the south segment, determining in
Ordinance 6494 that “the only conditional use permit before the Hearing Examiner was
for the South Bellevue Segment.” See Attachment G.
3. SEPA REVIEW INSUFFICIENT WITHOUT CONSIDERATION OF THE SOUTH
SEGMENT AS A PROPOSAL OR ALTERNATIVE.
As described above, elaborate and expensive environmental review has taken
place over more than three years that identified the proposal as a 16 mile transmission
line. Moreover, PSE’s submissions insisted the project “must” provide connections
between the bookend substations at Sammamish and Talbot Hill and that anything less
than the full project would be unacceptable. On that basis, multiple alternatives
proposed by CENSE and others were rejected as not fulfilling the Project need.
Though PSE claimed that the South Segment is actually the first phase of its
proposal, that claim cannot be accepted. First, it has been two and a half years since
the South Bellevue Segment application was made, and there is still no application for
any other segment of the proposal. Indeed this delay indicates that PSE’s claim that
the full transmission corridor is urgently needed (as early as the winter of 2017-18 or by
summer of 2018, FEIS at 1-5) cannot be accepted.
Second, even if permit applications for the north segments are received
tomorrow, the fact remains that this connection is actually only for “redundancy.” That
the South Segment is an “independent” feature requires an inquiry into what features of
that project result in its independence, which features make the North Segment
“redundant” and whether additional alternatives exist. To answer this question, CENSE
has retained Pterra Consulting to review the transmission proposal made by PSE, and it
has provided a letter to the Examiner dated January 7, 2020 which is included as
Section 5.2 in the CENSE Notebook. As shown by its resume attached to its letter,
Pterra has over 35 years of experience in electric power transmission planning,
operation design and engineering.
January 8, 2020
Page 9
Pterra has been involved in the review of PSE's needs analysis using power flow
models. Letter at 1. However, Pterra notes that PSE has revised its project to upgrade
only the "South Segment" as previously described herein. Though noting the South
Segment will use some components of the original 16 mile proposal, Pterra concludes:
it is necessary to re-demonstrate performance since the electric grid operates in
an integrated fashion and removing one planned element (in this case the
northern section of EEP3) represents a different design with a unique set of
reliability impacts.
Furthermore, Pterra states:
Since the revised EEP plan include a single source of 230 kV power to
energize the proposed Richards Creek substation, any analysis should include
the alternative of energizing the new substation with new transmission from the
Sammamish substation to the north.
Indeed, Pterra concludes that the alternatives to transmission may be different between
the original EEP and the revised EEP, including possible non-wires alternatives or
"transformer replacements” rather than line upgrades. See page 2. As noted previously,
the existing record contains no power flow or other transmission analysis of the South
Segment or a possible "North Segment."
Relevant to review of the four miles of proposed transmission in Renton is
whether a connection from the Sammamish substation to the proposed new substation
at Richards Creek will resolve PSE’s transmission needs without construction in
Renton. Also relevant is whether the reduced scale of the project opens the opportunity
for other alternatives which do required new transmission. These would include energy
storage, demand response and other options that would focus new resources where
demand is increasing, the downtown areas of Bellevue.
The last minute disclosure that in fact project need could be met by a dead-end
line, with the remainder of full line providing “redundancy,” calls out for additional review
and analysis for two reasons.
A. NEW PROPOSAL.
As noted above, the requirement that a proposal be “properly defined” is a critical
element in the environmental review process under W AC 197-11-060(3)(a). See FEIS
at page 1-5: “the process of defining a proposal includes an understanding of the need
for the proposal, to enable a thorough understanding of the project’s objective and
3 “EEP” is the Energize Eastside full 16 mile proposal.
January 8, 2020
Page 10
technical requirements and to accurately identify feasible and reasonable project
alternatives for consideration in the EIS.” (Emphasis supplied.) The FEIS goes on to
say (page 1-5): “An understanding of the need for the project helps to clarify the
objectives used to develop project alternatives.”
In fact, the proposal has changed from that defined in December, 2014. The
four-mile Renton line is now part of the South Segment, which was never identified as
the proposal in the Phase 1 DEIS and Phase 2 DEIS. Interested citizens, public
agencies and others commented based on the proposal defined as: “a new 230 kV
transformer in the center of the Eastside, which would be fed by new 230 kV
transmission lines for the north and south (Stantec).” Importantly, none of the technical
reports cited by PSE considered, much less even mentioned, an independent South
Segment. As the Pterra letter indicates, the South Segment "represents a different
design with a unique set of reliability impacts" which has not been studied.
Remand for providing analysis of the South Segment should be ordered to
comply with SEPA.
Analysis of the actual proposal is critical for Renton as well. If there are
alternatives identified that do away with the need for the South Segment, the
environmental and community impacts of the four miles of line in Renton will be
eliminated.
B. NEW AND NOT PREVIOUSLY CONSIDERED ALTERNATIVE.
Even if remand is not necessary to analyze the proposal actually before the
Examiner, it is necessary to require SEPA analysis of a reasonable alternative not
previously disclosed by the applicant.
As stated very well in the FEIS:
The process of defining the proposal includes an understanding of the need for
the project, to enable a thorough understanding the project’s objectives (see
Section 1.8 of the Phase 1 Draft EIS) and technical requirements, and.
According to WAC 197-11-060(3)(a)(iii), proposals should be described in ways
that encourage considering and comparing alternatives, and agencies are
encouraged to describe proposals in terms of objectives rather than preferred
solutions. An understanding of the need for the project helps to clarify the
objectives used to develop project alternatives.
FEIS pages 1-4 and 1-5 (copies of these pages are Attachment F hereto).
Under SEPA, a "reasonable alternative" means:
January 8, 2020
Page 11
an action that could feasibly attain or approximate a proposal's objectives, but at
a lower environmental cost or decreased level of environmental degradation.
Reasonable alternatives may be those over which an agency with jurisdiction has
authority to control impacts, either directly, or indirectly through requirement of
mitigation measures.
WAC 197-11-786. Indeed SEPA itself requires consideration of alternatives:
The State Environmental Policy Act of 1971 (SEPA) directs that "alternatives to
the proposed action" be included in an EIS. RCW 43.21C.030(c)(iii). Under the
Washington Administrative Code, consideration by the County Council of
reasonable alternatives is mandatory. WAC 197-11-440(5)(b). SEPA rules define
"reasonable alternatives" as less environmentally costly action that "could
feasibly attain or approximate a proposal's objectives." WAC 197-11-786.
King County v. Central Puget Sound Growth Management Hearings Bd., 138 Wn.2d
161, 182, 979 P.2d 374 (1999) (emphasis supplied).
In this regard, the EIS Consistency Analysis prepared for the City does not
forestall the need for a remand. Though the purpose of that analysis is not clear, it does
not deal with the question of whether the South Segment is appropriate for analysis.
Indeed, it does not even recognize the South Segment, continuing the mantra that the
project is the entire original proposal:
The Renton PSE upgrade is part of the larger Energize Eastside Project
that would also occur in the cities of Bellevue, Redmond, and Newcastle,
and in unincorporated King County (see Figure 1-1,Regional Map, and
Figure 1-2, Entire Energize Eastside Project).
See page 1-1.
As described above, the PSE proposal, since its inception in 2013, has been the
construction of “a new 230 kV transformer in the center of the Eastside, which would be
fed by new 230 kV transmission lines from the north and south.” FEIS at page 1-5 (see
Attachment F). No shorter alternative was considered or included in any environmental
review.
However, during review in Bellevue, it was concluded by Bellevue staff that:
The south segment of the Project provides additional capacity that addresses the
Project need and could function whether or not the north segment is built.
Plainly this admission from the Lead Agency for the project indicating that the South
Segment would “attain or approximate [the] proposal’s objectives” accordingly makes
January 8, 2020
Page 12
the South Segment a “reasonable alternative.”
WAC 197-11-440(5)(c)(v)” requires the EIS to:
Devote sufficiently detailed analysis to each reasonable alternative to permit a
comparative evaluation of the alternatives including the proposed action.
As noted, it was never disclosed in the environmental impact statements prepared that
the South Segment as a standalone project could meet “Project need.” Important to
project review, as found in the “Proposal Description” in Attachment A to the IAA, is the
identification of “Viable Solutions” as follows:
Viable solutions have to solve the various power flow issues in the Eastside as
well as satisfying longevity criteria, be constructable, and cost effective. A ten
year study horizon was used between 2012 and 2022. To develop the potential
solutions, the following categories were identified: demand side reductions;
generation transformer additions with minimal reinforcement, and transformer
with new transmission line. Each solution type was then subjected to power flow
analysis using the base cases described in the Needs Report as well as an
extensive list of contingencies.
(Emphasis supplied.) However, as confirmed by Pterra, the “South Segment” has
never been “subjected to power flow analysis,” considered essential in the IAA. All of
the studies conducted by either PSE or the City of Bellevue have analyzed the entire 16
mile proposal, not the South Segment. “Power flow analysis” is one of the “technical
requirements” that the FEIS (at page 1.4) considers important to “accurately identify the
feasible and reasonable project alternatives for consideration in the EIS.” With
something substantially less than the full 16 mile project now able to “address project
need,” an understanding is needed of what changes have occurred in project analysis
and whether other non-wires alternatives might address project need.
4. A SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT SHOULD BE
ORDERED BY THE EXAMINER.
As described above, SEPA compliance to date is inadequate and incomplete
because of the failure to review the South Segment as either the proposed project or an
alternative. To resolve this insufficiency, a Supplemental Environmental Impact
Statement (SEIS) should be ordered.
Washington caselaw and regulations address when an SEIS is required:
WAC 197-11-600(3)(b) provides that a supplemental EIS is required if there are
either: "Substantial changes to a proposal so that the proposal is likely to have
significant adverse environmental impacts ...; or New information indicating a
January 8, 2020
Page 13
proposal's probable significant adverse environmental impacts. (This includes
discovery of misrepresentation or lack of material disclosure.)" (italics ours). See
also Citizens for Clean Air v. City of Spokane, 114 Wash.2d 20, 34, 785 P.2d
447 (1990); West 514, Inc. v. Spokane County, 53 Wash.App. 838, 845, 770
P.2d 1065, review denied, 113 Wash.2d 1005, 777 P.2d 1050 (1989).
Kiewit Const. Group Inc. v. Clark County, 83 Wn.App. 133, 142, 920 P.2d 1207, (Div. 2
1996). See also Citizens for Clean Air v. City of Spokane, 114 Wn.2d 20, 34, 785 P.2d
447 (“Substantial changes in a proposal or new information about adverse
environmental impacts may create a need for a SEIS. See WAC 197-11-600(4)(b).”).
Similarly in West 514, Inc. v. County of Spokane, 53 Wn.App. 838, 845, 770 P.2d 1065
(1989), the court addressed requirements for a supplemental EIS.
WAC 197-11-600(4)(d)(ii) states a supplemental EIS should be prepared if there
is "[n]ew information indicating a proposal's probable significant adverse
environmental impacts". (Italics ours.) While "probable" is used to distinguish
likely impacts from those that are remote or speculative, it "is not meant as a
strict statistical probability test". WAC 197-11-782. "Significant" involves context
and intensity. "An impact may be significant if its chance of occurrence is not
great, but the resulting environmental impact would be severe if it occurred."
WAC 197-11-794(2).
In Barrie v. Kitsap Cy. Boundary Review Bd., 97 Wash.2d 232, 235, 643 P.2d
433 (1982), the court noted that passage of time alone is not "significant new
information", and the lead agency must determine whether the new information
is significant. It quoted the discussion of what is significant contained in National
Indian Youth Coun. v. Andrus, 501 F.Supp. 649, 663-64 (D.N.M.1980), aff'd sub
nom. National Indian Youth Coun. v. Watt, 664 F.2d 220 (10th Cir.1981):
Any project ... will, undoubtedly, generate "information" as it progresses....
[I]n order for "new circumstances or information" to attain the status of
"significant" these must reach that level where, reasonably, it becomes
necessary to focus attention once more upon the environmental aspects
of a project.... An otherwise unguarded reading of this subpart could
unleash a procedural plague ...
Barrie, 97 Wash.2d at 235-36, 643 P.2d 433. Further, "every remote and
speculative consequence of an action [need not] be included in the EIS." Cheney
v. Mountlake Terrace, 87 Wash.2d 338, 344, 552 P.2d 184 (1976).
Is the change in the proposal from a 16 mile line to an 8.78 mile line a significant
change? Is the eleventh hour revelation that the South Segment can “operate
independently” and that the remainder of the line only provides “redundancy”
significant? These are major changes in the proposal requiring additional review.
There is a question of whether these circumstances amount to a “lack of material
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Page 1
Energize Eastside
Interagency Agreement
Version Edited December 15, 2014
INTERAGENCY AGREEMENT BETWEEN THE
CITIES OF BELLEVUE, KIRKLAND,
NEWCASTLE, REDMOND, AND RENTON
REGARDING COORDINATED
ENVIRONMENTAL REVIEW OF PUGET SOUND
ENERGY’S PROPOSED ENERGIZE EASTSIDE
230 kV TRANSMISSION LINE PROJECT
This INTERAGENCY AGREEMENT is entered into by the cities of Bellevue, Kirkland,
Newcastle, Redmond, and Renton (collectively “PRINCIPAL JURISDICTIONS”).
RECITALS
1.1 WHEREAS, Puget Sound Energy (“PSE”) has represented that there is a need to
construct a new 230 kV bulk electrical transmission corridor and associated electrical
substations (the “Proposal”) through the Principal Jurisdictions connecting two existing bulk
energy systems as necessary to supply future electrical capacity and improve eastside electrical
grid reliability; and
1.2 WHEREAS, preliminary discussion between the Principal Jurisdictions and PSE has
identified that the Proposal is likely to have probable significant adverse environmental impacts
and issuance of a State Environmental Policy Act (“SEPA”) Threshold Determination of
Significance (“DS”) is appropriate as outlined in WAC 197-11-360 ; and
1.3 WHEREAS, PSE has made application to Bellevue under file number 14-139122-LE
for review and processing of an Environmental Impact Statement (“EIS”) under SEPA codified
at Chapter 43.21C of the Revised Code of Washington (“RCW”); and
1.4 WHEREAS, Bellevue was identified as the lead agency under section 197-11-932 of
the Washington Administrative Code (“WAC”), and issued a letter of lead agency status to the
Principal Jurisdictions on September 15, 2014; and
1.5 WHEREAS, the members of the Principal Jurisdictions are agencies as defined in
WAC 197-11-714 and 762. SEPA allows agencies to enter into interagency agreements to
share or divide responsibilities of the SEPA lead agency under WAC 197-11-944. The
Principal Jurisdictions desire to collaboratively manage environmental review of the Proposal
through the EIS process; and
1.6 WHEREAS, the Principal Jurisdictions have determined that it is in the best interest
of their respective jurisdictions to collectively study siting and development of the Proposal,
including determining if reasonable alternatives to the Proposal exist that may include, but are
not limited to different modes, alignments and infrastructure sites throughout the Principal
Jurisdictions; and
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Effective February 20, 2015
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Energize Eastside
Interagency Agreement
Version Edited December 15, 2014
NOW, THEREFORE, in consideration of the terms and provision contained herein, the
Principal Jurisdictions agree as follows:
AGREEMENT
1.0 Purpose of the Agreement
The purpose of this Agreement is to establish how the Principal Jurisdictions will work
cooperatively to review and respond to the Proposal under SEPA.
1.1 Cooperation and Good Faith Efforts
The Parties understand and agree that the processes described in this Agreement depend upon
timely and open communication and cooperation between the Parties. In this regard,
communication of issues, changes, or problems that arise with any aspect of the performance of
terms of this Agreement should occur as early as possible in the process rather than before explicit
due dates or deadlines. Each Party agrees to work cooperatively and in good faith toward
resolution of any such issues and agree that time is of the essence in resolving issues among the
Parties.
1.2 Production
The Parties acknowledge that this Agreement contemplates the execution and delivery of a
number of documents, the final form and contents of which are not presently determined. The
parties agree to provide the necessary resources and to work in good faith to diligently and timely
develop the final form and contents of such documents.
2.0 Associated Projects
The Principal Jurisdictions agree to work cooperatively and collaboratively towards processing of
an EIS and researching issues associated with the Proposal. To assist in this process, the Principal
Jurisdictions agree that it is in the best interests of their respective communities to collectively
engage consultants to assist with the research, development and analysis of an EIS addressing the
Proposal.
2.1 Processing of EIS
The Principal Jurisdictions will work together, under Bellevue’s lead, to complete the necessary
steps of a phased EIS as detailed in Chapter 197-11 WAC. The first phase of the Proposal to be
analyzed in a Draft Environmental Impact Statement (“DEIS”) shall include analysis of the need,
methods, and general feasibility of the Proposal. The second phase of the Proposal to be analyzed
in a DEIS shall be the construction level impacts of the Proposal. Following the completion of
both phases of the DEIS, a Final Environmental Impact Statement shall be issued. The Principal
Jurisdictions shall cooperate jointly and with PSE to identify a reasonable number and range of
alternatives. The list of alternatives to be analyzed shall include those agreed to by PSE, as well
as those alternatives proposed by at least two Principal Jurisdictions.
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Energize Eastside
Interagency Agreement
Version Edited December 15, 2014
After publication of the DEIS and the opportunity for public comment, the Parties shall consult
as to identification of a preferred alternative and as to the alternatives to be included in the FEIS.
Consensus shall be the preferred method to select a preferred alternative. Designation of a
preferred alternative shall require approval of (i) Bellevue and (ii) any other Principal
Jurisdiction where the preferred alternative would be located. If no proposed preferred
alternative obtains such approval, the FEIS may be issued without a preferred alternative.
3.0 Definitions
The following capitalized terms used in this Agreement have the meanings set forth in this
Section:
Co-Lead Jurisdiction: Each Principal Jurisdiction except the City of Bellevue.
Nominal Lead Jurisdiction: The City of Bellevue.
DEIS: Draft Environmental Impact Statement for the Proposal under SEPA.
FEIS: Final Environmental Impact Statement for the Proposal under SEPA.
Principal Jurisdictions: All of the Jurisdictions listed on Exhibit A to this Agreement, which is
incorporated herein by reference. Principal Jurisdictions are generally known to be the cities of
Bellevue, Kirkland, Newcastle, Redmond, and Renton; provided the jurisdiction remains a
party to this Agreement.
Participating Jurisdiction: Any Principal Jurisdiction that is added to this Agreement by
amendment, so long as it remains a Party.
Parties or Party: The “Parties or Party” include all Principal Jurisdictions and any other
Jurisdictions that have become Participating Jurisdictions by amendment as provided in this
Agreement, except that “Parties or Party” shall not include any Principal Jurisdictions that have
withdrawn from this Agreement.
Proposal: The reasonable alternatives for the actions necessary to establish a new Puget Sound
Energy 230 kV electrical transmission corridor and associated electrical substation
infrastructure with capacity to serve the Principal Jurisdictions, within the range of alternatives
identified by the PSE and the Principal Jurisdictions for study under SEPA. A complete
description of the Proposal is included with this Agreement as Attachment A.
SEPA: The Washington State Environmental Policy Act and its implementing regulations.
Alignment: A potential location for the Proposal.
Site(s): The potential location(s) for the Proposal.
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Interagency Agreement
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Working Day: A day that is not a Saturday, Sunday, or City of Bellevue legal holiday.
4.0 Co-Lead Agencies
Each Principal Jurisdiction is a co-lead agency for the Proposal as permitted pursuant to WAC
197-11-944. Bellevue is designated the nominal lead agency for the Proposal. Each Principal
Jurisdiction shall have responsibility, in reliance on the work of consultants and experts retained
by Bellevue under this Agreement, for content of environmental documents. Bellevue’s “SEPA
responsible official” shall have the duty to determine the adequacy of the DEIS and FEIS under
SEPA.
4.1 Designated Representatives
A. Designated Representatives. Each Principal Jurisdiction shall designate the name, title,
address and electronic contact information for: (i) a staff representative who will serve as the
primary contact person for purposes of this Agreement; (ii) the official(s) authorized to approve
matters under this Agreement for that jurisdiction; (iii) the representatives who will serve on the
project EIS Steering Committee for that jurisdiction; and (iv) the representative who will serve on
the EIS Collaboration Team for that jurisdiction, subject to any limitations on authority imposed
by that jurisdiction. The designee for each Principal Jurisdiction is contained below as the
signatory to this Agreement. A Principal Jurisdiction may designate, by written notice to all
Parties, an alternate staff representative or official to act instead of the designated person if that
person is unavailable or if so desired by the Principal Jurisdiction. A Principal Jurisdiction may
designate the same person for different purposes as identified in this subsection. A Principal
Jurisdiction may change the designated person for these purposes by written notice to all Parties.
B. Committees. The following committees shall be formed and charters developed to assist with
processing the EIS:
(i) EIS Steering Committee
a. Purpose: Represent the respective jurisdiction by providing guidance to the EIS
Collaboration Team in the development of the project EIS and study of other
Proposal issues and topics.
b. Membership: Department Directors and management staff with appropriate level
of decision making authority, access to elected officials, and access to
jurisdiction resources
c. Responsibilities: Provide general project oversight, maintain communication
across jurisdictions, meet to address issues raised by the EIS Collaboration
Team, and report on EIS progress to elected officials, appointed officials, and
jurisdiction management.
d. Conflict Resolution: The EIS steering Committee will engage to resolve inter-
jurisdictional conflicts and conflicts with PSE in accordance with Section 10.0.
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Interagency Agreement
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(ii) EIS Collaboration Team
a. Purpose: The purpose of the EIS Collaboration Team is inter-jurisdictional
collaboration in the development of the EIS under SEPA rules for the Proposal,
including information collection, scoping, consultant selection, consultant
management, document development and editing, process implementation,
public outreach, and quality control.
b. Membership: Senior level planning and development department or utilities and
engineering staff with experience in SEPA and EIS process and with knowledge
specific to the Proposal.
c. Responsibilities: EIS Collaboration Team members will commit time to regular
meetings and can oversee development of the EIS for their respective
jurisdiction, including information collection, scoping, consultant selection,
consultant management, document development and editing, process
implementation, public outreach, and quality control. Team members will
provide the necessary resources and to work in good faith to diligently and
timely develop the final form and contents of the Proposal EIS.
d. Conflict Resolution: Unresolvable conflicts identified by the EIS Collaboration
Team will be elevated to the EIS Steering Committee for resolution in
accordance with Section 10.0.
4.2 Bellevue Responsibilities
A. Bellevue shall designate a single staff person who will serve as the primary point of contact
between Bellevue and the other Primary Jurisdictions. Bellevue will also designate an alternate
staff person who will serve as the point of contact if the primary staff contact is unavailable.
B. As the nominal lead agency, Bellevue shall be responsible for the following SEPA
activities with respect to the Proposal:
(i) Providing all notices required by SEPA and Bellevue ordinances and regulations,
and any additional notice requirements under ordinances and regulations of the Co-
Lead Jurisdictions that are identified by Co-Lead Jurisdictions by written notice to
Bellevue;
(ii) Holding public meetings required by SEPA;
(iii) Providing required opportunities to comment on SEPA documents;
(iv) Causing the preparation of environmental documents required by
SEPA;
(v) Making all filings and publications required by SEPA;
(vi) Defending any administrative and/or court challenge to the adequacy of
the environmental documents, subject to the terms of this Agreement; and
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(vii) Identifying the actions, as defined in SEPA that would be necessary to establish
the Proposal, except for actions under the planning documents, ordinances or
regulations of local jurisdictions other than Bellevue; and
(viii) General SEPA process administration, project management, and project
oversight.
C. Bellevue shall contract with consultants, environmental scientists, engineers, and others for
the preparation of the DEIS, FEIS, and related technical reports and for the other work
contemplated by the anticipated project scope. Bellevue shall solicit, consistent with State law,
the services of a qualified professional in the preparation of an EIS consistent with the
determinations as to the scope and coverage of the DEIS and FEIS. Bellevue shall also contract
with an independent third-party consultant for the completion of preliminary analysis supporting
the Proposal need and method in advance and parallel to the EIS work requested under this
Agreement.
D. Bellevue further agrees, regarding circulation of drafts of SEPA documents, to:
(i) Provide each Co-Lead Jurisdiction a draft of the scoping notice 15 working
days prior to issuance;
(ii) Issue the scoping notice only with the approval required in Section 5.0;
(iii) Provide the Parties with a draft of the proposed first and second phases of the
DEIS and supporting technical memoranda and discipline reports no less than 30
working days prior to scheduled issuance of each phase of the DEIS;
(iv) Coordinate any comments or requested changes to the proposed DEIS from the
Parties that are received within 20 working days after the proposed DEIS was sent to the
Parties, and bring the comments and requested changes to the Co-Lead Jurisdictions for
discussion and recommendation;
(iv) Issue the DEIS only after approval as required under Section 5.0 except that the
published DEIS may include corrections and changes not so approved and not previously
provided to the Parties if they do not fundamentally alter conclusions in the DEIS and do
not materially change information with respect to any Site;
(v) Provide the Parties with copies of comments received on the DEIS;
(vi) Provide the Parties a draft of the proposed FEIS, including its technical memoranda
and discipline reports and response to DEIS comments;
(vii) Coordinate any comments or requested changes to the proposed FEIS from the
Parties that are received within 15 Working days after the proposed FEIS was sent to the
Parties, and bring the comments and requested changes to the Co-Lead Jurisdictions for
discussion and recommendation; and
(viii) Determine adequacy and issue the FEIS, and any supplement or addendum to the
FEIS, only after approval under Section 5.0 provided that the published FEIS and any
supplement or addendum may include corrections and changes not so approved and not
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previously provided to the Parties if they do not fundamentally alter conclusions in the
FEIS and do not materially change information with respect to any Site.
(ix) Bellevue reserves the right to issue any documents in electronic format.
E. Bellevue shall provide the Parties with an estimated schedule consistent with the time
periods identified in subsection D of this Section.
F. Bellevue shall be responsible for development of project messaging through development of
one common message regarding the status of the EIS process, including development of common
literature generic to the project.
G. Bellevue shall be responsible for development and maintenance of a consolidated website to
host the multijurisdictional EIS process. This website will serve as the primary portal to the
project for public information and project management, including information and document
sharing.
I. Bellevue shall be responsible for development of a project outreach strategy, including use of
consultants; and the number and location of open houses, community meetings, or other events.
4.3 Co-Lead Jurisdiction Responsibilities
Each Co-Lead Jurisdiction agrees that it shall:
A. Provide technical support and staff at a level sufficient to meet project deadlines;
B. Dedicate staff resources to regularly attend scheduled EIS Steering Committee and
EIS Collaboration Team meetings;
C. Review the draft scoping notice and provide comments or notify Bellevue of its
approval within 10 working days of receipt of the draft;
D. Review preliminary draft discipline reports and technical memoranda and provide comments
to Bellevue within 30 working days, the review time for subsequent drafts shall be 15 days;
E. Review preliminary drafts of the phases of a DEIS or portions thereof, and any supplement
or addendum thereto, and provide comments or approval within 30 working days, the review
time for subsequent drafts shall be 15 days;
F. Review drafts of a FEIS or portions thereof, and any supplement or addendum thereto, and
provide comments or approval within 30 working days, the review time for subsequent
drafts shall be 15 days;
G. Promptly provide access to data and studies reasonably available to the Co-Lead Jurisdiction
with respect to any Site within its boundaries, and promptly provide the cooperation of experts
on the staff of relevant Jurisdiction departments, to Bellevue and to consultants;
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H. Identify, and consult with Bellevue and consultants with respect to, (i) all actions, within the
meaning of SEPA, that would be required of the Co-Lead Jurisdiction for purposes of
participating in the review of the Proposal that is included in the DEIS, and (ii) all notice
requirements under the ordinances and regulations of that Jurisdiction; and
I. Any other provision notwithstanding, if the Principal Jurisdictions determine that the FEIS
shall be part of a phased review, then the Co-lead Jurisdictions shall not have any obligations
under this Agreement for any phase after the FEIS.
5.0 Approvals
A. Except as otherwise stated in this Section, the approval of a majority of Principal
Jurisdictions, one of which must be Bellevue, is required and is sufficient for any of the
following:
(i) Issuance of the determination of significance and scoping notice;
(ii) Determination of whether and to what extent SEPA review for the Proposal will
be phased, and of the types of impacts to be analyzed in detail in the DEIS and FEIS;
(iii) Issuance of the DEIS, and any supplement or addendum to the
DEIS;
(iv) Issuance of the FEIS, and any supplement or addendum to the FEIS;
(v) Any decision with respect to the settlement of any appeal or with respect to action to
be taken upon any adverse decision or remand resulting from any appeal;
(vi) Amendments adding Participating Jurisdictions as Parties to the Agreement; and
(vii) Selection of a consultant or consultants to assist with the performance of this Agreement.
B. If at any time there shall be three or fewer Principal Jurisdictions that remain Parties to this
Agreement, the approval of two Principal Jurisdictions, one of which must be Bellevue, shall be
necessary and sufficient for any of the actions listed in subsection A of this Section.
C. Approval for designation of a preferred alternative in the FEIS is governed by subsections 2.1
and 5.0 of this Agreement.
6.0 Costs
A. Consultant costs associated with developing the EIS shall be funded by PSE and paid
through the City of Bellevue Development Services Department permit fee structure. The City of
Bellevue shall have the sole responsibility of negotiating PSE’s payment of EIS consultant and
processing costs.
B. Each Principal Jurisdiction shall have the responsibility of coordinating and negotiating
reimbursement from PSE for their own respective staff resource costs incurred with project and
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EIS analysis.
7.0 Appeals
A. Unless otherwise provided by applicable law, timely appeals of the adequacy of the FEIS
and compliance with applicable SEPA procedural requirements shall be heard by the
Washington State Superior Court in accordance with Chapter 22.02 Bellevue City Code.
Bellevue shall have sole responsibility to defend the adequacy of the FEIS, as to the actions
covered by the FEIS, in any appeal before a court with jurisdiction, to the extent such appeal
relates to the adequacy of the FEIS or compliance with the applicable SEPA procedural
requirements.
B. The costs of such defense including any appeal of a decision by a court on the adequacy
of the FEIS, including without limitation costs of in-house attorneys, outside counsel if deemed
necessary by Bellevue, staff support and costs of experts, shall be considered costs allocable
hereunder.
C. Prior to the commencement of any appeal proceedings, the Principal Jurisdictions shall
enter into agreement stipulating proportional cost sharing related to legal defense not
recoverable from PSE. Costs shall be distributed among those Principal Jurisdictions to which
the issues raised in the appeal pertain. Where the issues pertain to more than one Principal
Jurisdiction, costs shall be distributed among the affected Principal Jurisdictions based on the
proportional distribution of EIS alternative alignments located within each Principal Jurisdiction
to which the issues raised in the appeal pertain.
D. Subject to the execution of a satisfactory common interests and confidentiality agreement,
Bellevue shall keep the Co-lead Jurisdictions reasonably informed of the status of the appeal and
shall consult with them regarding any major decisions.
E. Any administrative appeal or court challenge to a substantive action, including without
limitation a change in development regulations or project permit decision, whether or not joined
with a challenge to be defended under subsection A and whether or not involving issues of SEPA
compliance or exercise of SEPA authority, is outside the scope of this Agreement.
8.0 Effectiveness; Additional Parties; Termination; Withdrawal of a Party
A. Effective Date. This Agreement will become effective upon signing and delivery of the
Agreement by all Principal Jurisdictions.
B. Change of Party Status. Any Principal Jurisdiction may become a Participating
Jurisdiction under this Agreement by amendment approved under Section 12.0, without need
for action of the legislative bodies of the existing Parties. Participating Jurisdictions will not
have authority over decisions under this Agreement, but will have the same rights and
responsibilities for review and comment on draft documents as Co- Lead Jurisdictions.
C. Termination. This Agreement shall remain in effect until the FEIS, and any supplements or
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addenda to the FEIS that may be required as a result of any appeal proceeding, have been issued,
and either the time for any appeal of Bellevue’s decision on the adequacy of the FEIS shall have
expired or a final decision on an appeal of that determination, in which Bellevue has
responsibility for defense under Section 7.0 of this Agreement, shall have been issued by a court
or other administrative tribunal with jurisdiction to hear an initial appeal on the adequacy of the
FEIS.
D. Withdrawal. Any Party, may, upon thirty (30) days written notice to the other Parties,
withdraw from this Agreement without cause. If a Co-Lead Jurisdiction or Participating
Jurisdiction withdraws from this Agreement, then the Agreement shall remain in effect among
the remaining Parties.
(i) The withdrawing Party, as of the date of termination, shall not have any rights of a
Party, or of a Principal Jurisdiction or Co-Lead Agency, under this Agreement, and
no consent of that Party shall be required for any purpose under this Agreement. The
withdrawing Party is released from any obligation to perform its obligations pursuant
to the Agreement..
(ii) Any Party that withdraws from this Agreement shall remain obligated for its
share of costs allocable under this Agreement that are incurred through the date of
termination of this Agreement.
(iii) If a Co-Lead Jurisdiction withdraws from the Agreement, any Site in that
Jurisdiction shall remain among the alternatives for the Proposal unless and until
the remaining Parties unanimously agree otherwise, and the withdrawing Party
shall remain obligated to cooperate in providing information required for
environmental review with regard to that Site.
(iv) If Bellevue withdraws from this Agreement, then this Agreement shall terminate
on the effective date of withdrawal.
9.0 Remedies
Except as provided in Sections 7.0 above, this Agreement shall not result in any monetary
liability, in damages or otherwise, from any Party to another. No Party shall be liable for any
damages to, or costs incurred by, other Parties resulting from any actual or alleged error,
misstatement or omission in any SEPA document or related to any SEPA process, or any ruling
regarding failure to comply with SEPA, whether or not the result of the negligence of a Party.
Except for monetary obligations under Section 6.0 of this Agreement, any suit to enforce the
terms of this Agreement or any obligation under this Agreement shall be limited to equitable
remedies not involving payment of money.
10.0 Dispute Resolution
A. The Parties agree that cooperation and communication are essential to resolving issues
efficiently. The Parties agree to exercise their best efforts to resolve any disputes that may
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arise through this dispute resolution process. In the event of a dispute between the Parties
regarding this Agreement, the Parties shall attempt to resolve the dispute informally and
resolve potential sources of conflict at the lowest level. All parties to the dispute shall
participate in a good faith mediation effort to resolve their differences before bringing any
legal action.
B. The Parties agree to use their best efforts to resolve disputes arising out of or related to
this Agreement using good faith negotiations by engaging in the following dispute
escalation process should any such disputes arise:
(a) Level One – The EIS Collaboration Team designated representatives shall meet to
discuss and attempt to resolve the dispute in a timely manner. If they cannot resolve the
dispute within fourteen (14) calendar days after referral of that dispute to Level One,
either party may refer the dispute to Level Two.
(b) Level Two – The EIS Steering Committee shall meet to discuss and attempt to
resolve the dispute, in a timely manner. If they cannot resolve the dispute within
fourteen (14) business days after referral of that dispute to Level Two, either party may
refer the dispute to Level Three.
(c) Level Three – The services of an independent facilitator provided by the EIS
consultant shall be engaged to resolve or adjudicate the dispute in a timely manner.
C. If the dispute involves a claimed breach of this Agreement and the Parties are not able to
resolve the dispute informally, then the Party may bring suit against the other Party in King
County Superior Court.
D. As an alternative to the above, the Parties may agree in writing to mediation, or some other
alternative dispute resolution process.
E. If the dispute includes PSE, the issue(s) shall be taken to an independent project facilitator
provided by the EIS consultant who will seek resolution with PSE.
11.0 Notices
The Parties’ addresses for notices under this Agreement shall be the physical and electronic
addresses of the primary contacts as set forth below the signature of each Party on this
Agreement or on the amendment adding that Party, as the case may be, in each case until a Party
shall have provided written notice of substitute primary contact information to the other Parties
hereunder.
Notice and copies of documents may be provided by email, and if so provided shall be effective
on the day received if received on a Working Day by 5:00 PM Pacific time, and if later then
effective on the next Working Day. If provided by U.S. mail, any notice or other communication
shall be effective on the second Working Day after deposit in the U.S. mail, postage prepaid,
addressed in accordance with this Section.
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18.0 Miscellaneous
A. This Agreement is for the benefit only of the Parties, and shall not give rise to any claim or
remedy for any other person.
B. Nothing in this Agreement shall delegate, diminish or modify the statutory or regulatory
authority of the Parties.
C. Time is of the essence of the terms of this Agreement.
[signature pages follow]
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ATTACHMENT A PROPOSAL DESCRIPTION
Proposal Description
PSE has determined that projected electrical load growth in the Eastside area of Puget Sound
Energy’s operating system is outstripping the capacity to deliver reliable sources of electricity to
the region. This encompasses the area east of Lake Washington between the cities of Redmond and
Renton. A detailed description of the electrical system problem is provided in PSE’s Needs Report
(2012). PSE’s transmission system backbone in the Eastside area comprises four 230 kV – 115 kV
transformers. These transformers, under certain operational conditions (i.e., cold winter days), are
operating near capacity and system studies and models have shown that they are expected to exceed
that capacity as early as the winter of 2017/2018. In addition to these transformers at PSE’s Talbot
Hill and Sammamish substations, several 115 kV lines are also subject to overloading. These
overloads show that there is a need for additional 230 kV transmission supply to support the
Eastside area. This situation creates operational conditions that do not comply with mandatory
reliability requirements. Furthermore, electric generation facilities located in this area of King
County provide less than 10% of the peak electric load; therefore, the area is quite dependent on the
electric transmission system. Electrical system studies performed independently and by PSE have
demonstrated that different parts of the transmission system will not meet minimum mandatory
reliability requirements for given system conditions under contingent operation. These minimum
reliability requirements are mandated by the North American Electric Reliability Corporation
(NERC) and Western Electricity Coordinating Council (WECC).
A number of solutions were identified and analyzed to assess viable ways of solving the
transmission supply problem. Viable solutions have to solve the various power flow issues in the
Eastside area as well as satisfying longevity criteria, be constructible, and cost effective. A ten year
study horizon was used between 2012 and 2022. To develop the potential solutions, the following
categories were identified: demand side reductions; generation; transformer additions with minimal
reinforcement, and transformer with new transmission line. Each solution type was then subjected
to power flow analysis using the base cases described in the Needs Report as well as an extensive
list of contingencies. Based on the results of the power flow analysis, the most promising solutions
were further evaluated from the perspective of overall system performance, operational flexibility,
and longevity. Additional details regarding the solutions considered to solve the problem are
provided in PSE’s Solutions Report (2012) and other supporting documents.
Demand Side Reduction/Non-Wire Technologies
Description: The addition of demand side reduction or conservation measures was evaluated by
PSE’s Energy Efficiency Group. These include energy efficiency, demand response, and
distributed generation measures. Energy efficiency measures include things such promoting the
installation of more efficient appliances, changing out incandescent light bulbs for LED, updating
windows and insulation, as well as numerous others. PSE has extensive programs to promote such
efficiency improvements, but cannot require that customers implement them. Demand response
entails energy reduction programs where specialized devises are installed that can be used to
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Effective February 20, 2015
control users electrical uses to better accommodate and manage peak usage. PSE has run pilot
projects using this technology, but such programs have not been popular and cannot be required by
the utility. Installing roof top solar panels, small scale wind turbines, and waste digesters are all
forms of distributed generation, again all which cannot be required by a utility’s customers.
These solutions do not represent a permanent alternative to avoid the need for infrastructure
improvements and upgrades necessary to operate the system at the required reliability levels;
however they are a necessary component of the solution (PSE Screening Study 2014).
Generation
Description: It has been determined that a 300 MW natural gas fired power plant located within the
Eastside could potentially solve the identified problem. This size plant would be comparable to the
325 MVA nameplate capacities of PSE’s 230 kV – 115 kV transformers. In addition to the
construction of the power plant, more than 30 miles of new and upgraded 115 kV transmission lines
would be required as would possibly a new natural gas pipeline and/or water pipeline. The number
and length of supporting infrastructure transmission lines and pipelines would be dependent upon
where a generation facility could be developed. Other generation technologies were evaluated, but
determined to be inadequate or inappropriate for the project area. New generation would have to be
sited so that it could relieve the 230 kV – 115 kV substation transformers and 115 kV transmission
lines that were identified as being at risk of overload in the 2013 PSE Eastside Needs Assessment
Report.
New Transformer – Existing Substation
Description: The PSE planning team evaluated installing only a new 230 kV – 115 kV transformer
at an existing substation, such as the existing Sammamish substation, Talbot Hill substation, and
Lake Tradition substations. It is anticipated that this alternative would not require the installation
of new 230 kV transmission lines since all three sites considered currently have nearby 230 kV
sources. However, when electric system models and studies were performed, this scenario showed
numerous 115 kV transmission system overloads, which indicated that a substantial amount of new
115 kV lines would need to be constructed and still with less than ideal system operational results.
New Transformer and Transmission Line
Description: The most viable solution type considered was a combination of adding a new
substation with a 230 kV transformer and connecting it with the Talbot and Sammamish substation
via a new 230 kV transmission line. This solution would provide a new 230 kV transmission
source and improve reliability for the Eastside area. To provide the greatest system efficiency, the
new transformer would need to be located somewhere between SR520 and I-90.
No Action
Description: Under the SEPA rules, when evaluating alternatives, the “no action” alternative also
needs to be considered and compared to the other reasonable alternatives (WAC 197-11-
440(5)(b)(ii)). In this instance, the no action alternative equates to not making improvements to the
electrical transmission system. This would put the operation of the transmission system as risk and
PSE out of compliance with FERC and NERC requirements.
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2.4 ALTERNATIVES CONSIDERED BUT NOT INCLUDED
The following alternatives were identified through scoping but are not included for analysis
in the Phase 1 Draft EIS for reasons explained below.
2.4.1 Use Existing BPA High-Power Transmission Line
Using the existing BPA line east of Lake Sammamish instead of installing a new 230 kV line
in the Eastside is not being included in the Phase 1 Draft EIS because this source is outside
the area that PSE has identified as being in need of more electrical power. To connect this
source to the deficiency area would require new 115 kV line construction to marginally
support the area. PSE considered several scenarios examining this potential solution. These
included the following:
x Tapping the BPA Maple Valley – Sammamish 230 kV line and the SCL SnoKing –
Maple Valley 230 kV line, and looping a new 230–115 kV Lakeside substation
between the tapped lines.
x Using the 230 kV BPA Maple Valley – Sammamish Line to loop into Lake Tradition
and installing a new 230–115 kV transformer at Lake Tradition to serve 115 kV load.
The solution also included re-conductoring the SCL Maple Valley – SnoKing 230 kV
with high-temperature conductors.
x Adding a 230–115 kV transformer at Lake Tradition and looping in BPA Maple
Valley –Sammamish 230 kV line. Adding a third 230–115 kV transformer at
Sammamish substation and assuming no new 115 kV lines are added to either
substation.
x Adding a 230–115 kV transformer at Lake Tradition, looping in BPA Maple Valley –
Sammamish 230 kV line, and adding a third 230–115 kV transformer at Talbot Hill
substation. It was assumed that no new 115 kV lines were added to either substation.
x Adding a 230–115 kV transformer at Lake Tradition, looping in BPA Maple Valley –
Sammamish 230 kV line, and adding a third 230–115 kV transformer at Sammamish
substation. This assumed new 115 kV lines would be constructed to both substations.
x Adding a 230–115 kV transformer at Lake Tradition and looping in BPA Maple
Valley –Sammamish 230 kV line, and adding a third 230–115 kV transformer at
Talbot Hill substation. This assumed new 115 kV lines would be constructed to both
substations.
All of these solutions were found to overload either transmission lines or transformers and
therefore would not address all relevant PSE equipment violations (electrical criterion #13).
See Eastside Transmission Solutions Report, October 2013 (updated February 2014), Tables
4.1 and 4.2, and Sections 4.6.3, 4.6.6, 4.6.8, 5.1.1, and 5.1.2 for more information (Gentile et
al., 2014).
2.4.2 Upgrade/Adjust Existing Electrical System
Several changes and adjustments to the electrical transmission system were proposed as
potential solutions. Several related to discontinuing the flow of electricity through the
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Eastside to Canada during some peak demand periods. These were described in comments
received during scoping regarding renegotiation of the Columbia River Treaty (which relates
to river flows and electrical supply across the U.S. - Canada border), diverting power flowing
from the south toward Canada to other transmission lines, or simply cutting off power flow to
Canada altogether. Disconnecting the system from the region or not providing power to the
rest of the region during peak periods is not included as an alternative because it was not
considered viable for the following reasons:
x PSE has statutory and regulatory obligations that require being interconnected to the
electric grid and that cannot be violated without penalties. Those obligations are with
the FERC, NERC, WECC, ColumbiaGrid, and UTC (electrical criterion #1).
x This solution would also compromise PSE’s ability to supply power and maintain
reliability in an efficient and cost-effective manner; the generation that is owned and
contracted for by PSE is generally outside PSE’s service area and requires
transmission lines to transport that power to PSE’s service area. The diversity of the
generation mixture provides security in the event that one kind of generation becomes
limited (e.g., hydroelectricity in a year with low snowmelt or rainfall). Being part of
the regional grid allows the dispatch of the least costly generating units within the
interconnected area, providing an overall cost savings to PSE customers. Planned
outages of generating and transmission facilities for maintenance can be better
coordinated so that overall cost and reliability for the interconnected network is more
efficient. Being interconnected also allows economies of scale for both transmission
and generation facilities. Finally, this solution could reduce the supply of power to
the Eastside, necessitating additional conservation, generation, or storage beyond that
considered in the other alternatives in the EIS (electrical criteria #1 and 7).
x Disconnecting the north and south sections of the route at a central Bellevue
substation to prevent non-Eastside load from being carried on this line during peak
periods of demand on the Eastside would deprive the Eastside of power supply
needed during these periods. Separating the system in central Bellevue from the
regional grid would also not meet FERC mandatory reliability standards. This could
be a CAP, which is temporary in nature and not a long-term solution, and does not
bring a new source or new generation into the deficiency area (electrical criteria #1
and 7).
x Relying on BPA projects would not deliver the appropriate amount of power to the
Eastside area because the BPA sources are outside the deficiency area and would
address only wider regional problems, leaving a deficiency on the Eastside (electrical
criterion # 7).
x Renegotiating the Columbia River Treaty is outside the purview of PSE and the
Eastside Cities and would not help solve the problem as described previously
(electrical criterion #1).
Other suggested solutions made during scoping include converting an existing alternating
current (AC) line to a direct current (DC) power line, using “self-healing” lines, and changing
conductor types and sizes.
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Although switching to DC could potentially address the problem by marginally increasing the
capacity of the lines, it would add complexity to the system that would reduce operational
flexibility, which could have adverse impacts to the reliability and the operating
characteristics of PSE’s system. For example, if there was a problem within the DC portion
of the system, it would not be possible to switch among other sources, as it is when the entire
system is on AC. This alternative has not been included because avoiding such adverse
impacts to reliability is one of PSE’s stated electrical criteria (electrical criterion #1).
Suggested upgrades to the system (such as self-healing lines, up-conductoring, and installing
transformers and inductors) would not improve reliability but would shift electrical load onto
other components of the system, causing new deficiencies without addressing the
transmission problem. Self-healing lines are automated switching systems that are triggered
by adverse events in the system. They do not add capacity to the system, just speed in
recovery from an adverse event. Inductors perform similarly, shifting load but not adding
capacity. PSE examined up-conductoring in its solutions report and found that increasing
capacity of 115 kV conductors led to transformers being overloaded (Gentile et al., 2014).
Conversely, adding transformer capacity led to overloading lines. These solutions either do
not meet the project objectives, or they offer a short-term solution that would not meet PSE’s
performance criteria for serving 10 years or more after construction (electrical criterion #1).
2.4.3 Larger Generation Facilities
Adding a large generation facility is not included as an alternative. To be effective, PSE
found that the facilities would have to be located near the center of the Eastside area, such as
near the Lakeside substation. This alternative is not included because the Cities determined
that it does not meet SEPA requirements to provide a reasonable alternative that could
feasibly attain or approximate a proposal’s objectives at a lower environmental cost or
decreased level of environmental degradation (WAC 197-11-440(5)(b)). Such a facility
would likely have to be gas-fired to be capable of producing power reliably whenever it is
needed.
PSE determined that at least 300 MW of power generating capacity would be needed and the
most cost-effective way to generate that amount of power would be in a single plant. The
2013 Solutions Report (Gentile et al., 2014) found that small distributed generation and
energy storage would have little impact on the problem unless a large number were
developed, as described in Alternative 2, Integrated Resource Approach. Generation facilities
at the 300 MW size would require gas and/or water infrastructure that is presently
unavailable. These types of facilities also generate “atmospheric emissions and noise [that]
would be extremely challenging” to permit in a feasible location that would not also require a
significant new transmission line (Gentile et al., 2014).
Even if it were economically feasible to create multiple generation facilities of less than 300
MW, such as a series of plants generating 10 MW or more, they would need to be clustered
close to the center of the Eastside to be effective, and would likely impose noise, air, and
utilities impacts similar to or even greater than a single plant. Therefore multiple generation
facilities of greater than 10 MW were not included for the same reason a single large
generation plant was not included.
CHAPTER 2 January 2016
2-52 PROJECT ALTERNATIVES
PHASE 1 DRAFT EIS
CHAPTER 2 January 2016
2-52 PROJECT ALTLTTERNATATTIVES
PHASE 1 DRAFT EIS
DSD 011207
011285
Smaller backup generators within the Eastside could potentially solve the peak demand;
however, PSE did not find that there are currently enough generator owners willing to
connect to the network to meet the project objectives (Gentile et al., 2014). PSE cannot
compel owners of generators to connect to a network. In addition, increased usage of diesel
generators would not meet present clean air regulations, and such facilities often have
considerable noise impacts. This is not included as a stand-alone alternative because it does
not meet PSE’s performance criteria of serving 10 years or more after construction (electrical
criteria #5, 6, and 15 and non-electrical criterion #3). However, providing a portion of the
projected load by this method is examined as part of the distributed generation component of
Alternative 2.
Generating more power outside of the Eastside area during peak periods, such as at PSE’s
existing peak generator plants, would not address the project objectives, because that would
still require transmission to deliver power to the load area without risking damage to
transmission equipment. This alternative is not included because it would not address the
deficiency in the Eastside (electrical criteria #5, 6 and 14). Peak generator plants providing a
portion of the projected load within the Eastside are considered under Alternative 2.
2.4.4 Submerged 230 kV Transmission Line in Lake Sammamish
The option of using a submerged line in Lake Washington is included in the Phase 1 Draft
EIS. Scoping comments also suggested using Lake Sammamish for a submerged line.
However, there are a number of technical issues that constrain the feasibility of a Lake
Sammamish submerged line. These include the following:
x Submerged cables are typically delivered to a site by ship or barge. Large barges
cannot access Lake Sammamish due to the weir at the outlet.
x Weight limits on highways would limit the length of cable reels to 1,100 feet, which
would mean approximately 34 splices to reach the length of the lake.
x Highway transport may also be limited due to the 14-foot reel diameter.
x Underwater splices increase the risk of cable failure, while splices on land require
construction of a vault at each splice. (Strauch, personal communication, 2015b)
Given these constraints, placing a cable in Lake Sammamish was deemed to not be a viable
option.
2.4.5 Other Approaches
An alternative addressing a phased approach is not included because it would not address the
quickly approaching transmission capacity deficiency during peak periods identified in the
Eastside (electrical criterion #10).
Combining alternatives that provide partial solutions was suggested during scoping.
Combinations of various solutions were considered. Alternative 2 includes suggested
components that would directly address the transmission capacity deficiency in the Eastside
that has been identified by PSE. Combinations with other components that would either
increase the problem or have little or no effect, such as those listed above, were not carried
forward.
January 2016 CHAPTER 2
PROJECT ALTERNATIVES 2-53
PHASE 1 DRAFT EIS
January 2016 CHAPTER 2
PROJECT A LTLTTERNATATTIVES 2-53
PHASE 1 DRAFT EIS
DSD 011208
011286
Solving the Eastside deficiency requires a reliable alternative composed of one or more of the
following:
x A new high-voltage energy source from the outside brought into the deficiency area;
x A new generation source or energy storage of sufficient size and duration installed
within the deficiency area; and/or
x Reduction in electrical load during peak demand periods.
Alternatives that would violate PSE’s Planning Standards and Guidelines (such as changing a
transmission line from AC to DC) or that could harm other utilities in the region (such as
disconnecting the Eastside from the regional grid during peak periods) would not become
compliant by combining them with other alternatives (electrical criterion #1). Alternatives
that would reduce the availability of power to the Eastside (such as limiting the flow of
power from sources outside of the Eastside) would require even greater measures to
compensate for the reduced power supply to the Eastside (such as new generation or storage,
more conservation, or new transmission capacity) and as such would likely have greater
impacts than the alternatives that are evaluated in the EIS (electrical criteria #1, 5, 6, and 14).
Among the alternatives suggested, this leaves only the alternatives that will be studied and a
few alternatives that provide temporary solutions, such as increasing the capacity of wires
and transformers, or temporary rerouting of power during peak periods. Combining
temporary solutions with the alternatives included in the EIS does not materially change the
range of alternatives for the EIS, although such measures could reduce the severity or risk of
impacts under the No Action Alternative.
Reducing the scope to include only Bellevue would require a generation facility within the
Bellevue city limits, which is not included for the same reasons as indicated earlier under
Larger Generation Facilities, or a solution similar to the Integrated Resource Approach
(Alternative 2). Therefore, narrowing the scope to include only Bellevue will not be
considered as a separate alternative.
2.5 BENEFITS AND DISADVANTAGES OF DELAYING
THE PROPOSAL
Delaying the project would have the benefit of avoiding the impacts in the near future for the
action alternatives described in the EIS. It is possible that by delaying the project, some of the
expanded conservation measures described in Alternative 2 would be incorporated into
development, reducing energy demand further than PSE has projected. Additional
conservation could have the benefit of reducing greenhouse gas generation from electrical
consumption on the Eastside. Delaying the project could allow technological advancements
to occur in areas such as battery storage or generation, providing additional feasible
alternatives to increased transmission capacity in the near term.
The disadvantages of delaying the project are that the risks of power outages (described in
Chapter 1) that would be associated with the No Action Alternative could develop over time.
It is also possible that the awareness of such risks would discourage development within the
Eastside.
CHAPTER 2 January 2016
2 -5 4 PROJECT ALTERNATIVES
PHASE 1 DRAFT EIS
CHAPTER 2 January 2016
2 -5 4 PROJECT ALTLTTERNATATTIVES
PHASE 1 DRAFT EIS
DSD 011209
011287
Alternative Siting Analysis
So uth Bellevue Segment
LUC 20.20.225.D
September 2017
000222
September 2017 2
The Alternative Siting Analysis that follows summarizes the years of study (including dozens of
technical studies and two-phases of review under the State Environmental Policy Act (SEPA))
required to reach a decision point on how to best meet growing demand and ensure PSE’s
compliance with federal performance standards.
PSE proposes the Energize Eastside Project--the upgrading of 115 kV transmission lines to 230
kV lines in an existing transmission line corridor and the construction of the Richards Creek
substation. In the Bellevue Comprehensive Plan, PSE’s proposed route is on a “sensitive site.”
See Map UT-7. For new or expanded utility facilities on sensitive sites, an Alternative Siting
Analysis is required in conjunction with the Conditional Use Permit process. See LUC
20.20.255.D.
Under the City’s land use code, an Alternative Siting Analysis must: 1) identify, describe and
map three alternative site options; 2) analyze whether each alternative site is feasible; 3)
describe the technologies considered and how the proposed facilities will improve system
reliability; and 4) describe community outreach related to the new or expanded facilities. See
LUC 20.20.255.D. Where proposed sites are located within a Neighborhood Business or
Residential Land Use District, the applicant must 1) describe whether the proposed location is a
consequence of demands from customers within the district and 2) describe whether operational
need requires locating the proposed facility in the district. Id. Using the location selection
hierarchy, the applicant must then identify the preferred site alternative. Id. Finally, where the
preferred site is in a Residential Land Use District, the applicant must demonstrate that the
siting causes fewer site compatibility impacts than a nonresidential siting. Id.
2.0 ALTERNATIVES ANALYSIS
After extensive study, PSE determined that the most effective solution to meet increased
electricity demand and to comply with federal performance requirements is the addition of a 230
kV/115 kV substation in the center of the Eastside load area -- the Richards Creek substation --
and the upgrading of 115 kV transmission lines with 230 kV transmission lines constructed
between the Sammamish (Redmond) and Talbot Hill (Renton) substations.1 These facility
upgrades, combined with continued aggressive conservation measures, is the Energize
Eastside Project.2 As confirmed by the City’s independent consultants, this Project will improve
1 The existing transmission lines were last upgraded in the 1960s and are located in
PSE’s Sammamish – Lakeside – Talbot Hill transmission line corridor, which was established in
the late 1920s and early 1930s.
2 Notably, the City’s Phase 2 DEIS concluded that “Under the No Action Alternative, PSE
would continue to manage its system in largely the same manner as at present. This includes
000227
September 2017 3
reliability for Eastside communities and supply the needed electrical capacity for growth and
development on the Eastside.
Siting of electrical transmission infrastructure through urbanized areas presents unique
challenges. Finding the best way to route a transmission line is complex, as dozens of
elements of both the natural and built environments need to be considered. This is especially
true here as the proposed Project traverses the City from north to south.
The Project will be constructed in two phases, with the southern phase of the transmission line
traversing 3.3 miles of the City. As a linear project, it necessarily travels through many land use
districts. To limit the need to construct new facilities (and the associated environmental
impacts), when looking at the entirety of the Energize Eastside Project, all transmission line
route alternatives start at PSE’s Sammamish substation in Redmond and end at the Talbot Hill
substation in Renton. PSE considered various routing options for the entire line, including five
route options in the South Bellevue Segment.
PSE determined that the best approach to route selection would be to use a modern tool that
employed a graphical information system (GIS)-based Linear Routing Tool (LRT) to conduct a
broad evaluation of possible transmission line routes.
To further evaluate the Transformer plus Transmission Line solution, PSE contracted Tetra
Tech, a consulting and engineering firm, who has developed an LRT. Details of the LRT
assessment can be found in the Eastside 230 kV Project Constraint and Opportunity Study for
Linear Site Selection (December 2013) (Attachment C). The LRT is a tool developed by Tetra
Tech based on commercially-available geospatial technology and Tetra Tech’s linear routing
experience. It is a collaborative process that combines powerful analytical software with project
experience, system planning, engineering, land use and local knowledge considerations. The
LRT’s innovative geospatial tool identifies the most suitable route alternatives based on
modeled environmental and infrastructure factors and constraints.
maintenance programs to reduce the likelihood of equipment failure, and stockpiling additional
equipment so that in the event of a failure, repairs could be made as quickly as possible.
Implementation of the No Action Alternative would not meet PSE’s objectives for the proposed
project, which are to maintain a reliable electrical system and to address a deficiency in
transmission capacity on the Eastside. Implementation of the No Action Alternative would
increase the risk to the Eastside of power outages or system damage during peak power
events.” Phase 2 DEIS at 2-3.
000228
September 2017 5
Willow 1 route to limit environmental impacts and new impacts to adjacent uses. In addition,
pipeline safety experts concluded that the Willow 1 route gives PSE the greatest assurance that
the Energize Eastside Project will operate safely in the same corridor as BP’s Olympic Pipeline.
LUC 20.20.255D.2.a. Describe the sites identified in subsection D.1 of this section and the land
use districts within which the sites are located.
[...]
LUC 20.20.255D.2.c. Describe which of the sites analyzed are considered practical or feasible
alternatives by the applicant, and which of the sites analyzed are not considered practical or
feasible, together with supporting information that justifies that conclusions reached. For sites
located within a Neighborhood Business Land Use District, Residential Land Use District, and/or
Transition Area (including the Bel-Red Office/Residential Transition (BR-ORT), the applicant
shall:
i. Describe whether the electrical utility facility location is a consequence of needs
or demands from customers located within the district area; and
ii. Describe whether the operational needs of the applicant require location of the
electrical utility facility in the district or area.
The Energize Eastside Project serves all of the potentially impacted land uses as in general, all
land uses require electricity. The Energize Eastside Project will provide an upgraded, reliable
transmission system serving the Eastside generally and adjacent uses specifically. The Project
is needed because cumulatively, demand on the Eastside is increasing, including in areas along
the South Bellevue Segment. The transmission line component of the project must run between
the Sammamish and Talbot Hill substations. It must also connect with the proposed Richards
Creek substation. The location of the substation is not dependent on being sited in a specific
district; however, it does need to be situated in a location that the most reliable operation. Based
on operational best practices, the ideal location for the new 230 kV substation is located in close
proximity to PSE’s existing 115 kV Lakeside substation. In addition, operationally, the
transmission line must transverse through the City of Bellevue from the north to the south,
making it impossible to completely avoid areas of residential zoning. The existing corridor
(Willow 1) provides the shortest distance through the city and therefore, crosses the least
amount of residential zoning.
As required under LUC 20.20.255.D.1 and LUC 20.20.255.D.2.c.i-.ii, all siting alternatives are
located in land use districts served by the South Bellevue Segment. T he City of Bellevue's and
000230
September 2017 13
The subarea plan policies of each of the subareas within the Oak 1 Option support
growth in similar land use patterns as those that currently exist.
There are 212 single-family and 287 multi-family residences within this option.
Phase 2 DEIS at 3.1-13. Approximately 18% of the Oak 1 route would impact Single and
Multi-Family uses.
Consistent with the City’s Phase 2 DEIS, PSE considers this route to be feasible. See LUC
20.20.255.D.2.c. PSE ultimately eliminated this route from consideration, however, because
from a safety perspective, the Willow 1 route has the lowest potential AC interaction with the
petroleum pipelines that share the corridor. Additionally, the Willow 1 route requires the fewest
number of trees to be removed in order to comply with NERC standards and uses an existing
transmission line corridor. The use of an existing corridor does not impose a new transmission
line on new areas, does not require the acquisition of new easements, and is specifically
identified on Bellevue’s Comprehensive Plan UT-7 map as being expanded to 230 kV.
The substation yard needs to be large enough to accommodate a new 230 kV-115 kV
transformer and associated electrical equipment such as circuit breakers, electrical bus, and
connections to the new transmission lines. It is expected that the substation’s fenced yard will
be approximately 2 acres. The main function of the substation is to step down the 230 kV
voltage (bulk power) from the new transmission lines to 115 kV needed for use by the local
distribution system. All substation locations are considered to be feasible. LUC
20.20.255.D.2.c.
Three 230-115 kV substation sites were considered for the Energize Eastside Project - referred
to as Westminster, Vernell, and Richards Creek. These sites were selected for consideration
because they are all owned by PSE; meet the objectives to site the 230 kV transformer at a
central location between the existing 230 kV power sources at Sammamish substation in
Redmond and Talbot substation in Renton; accommodate the necessary improvements to serve
the required 230 kV transmission lines to bring power to the centralized transformer; and
distribute power to the existing network of 115 kV transmission lines.. Of the three substation
sites, only Richards Creek is located within the Southern Phase; however, since the primary
objective of the Energize Eastside Project is to install a new transformation source in the central
Bellevue area, their inclusion is relevant.
000238
September 2017 23
during PSE’s 2009 annual reliability assessment, that if one of the Talbot Hill Substation
transformers failed, it would significantly impair reliability on the Eastside. Replacement of a
failed 230 kV transformer can take weeks, or even months, to complete depending on the level
of failure and other site specific parameters. Since 2009, other reliability deficits have been
identified. These include concerns over the projected future loading on the Talbot Hill Substation
and increasing use of Corrective Action Plans (CAPs) to manage outage risks to customers in
this portion of the PSE system.
In total, since 2009, five separate studies6 (Attachment C) performed by four separate parties
have confirmed the need to address Eastside transmission capacity:
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)
Review Memo by Stantec Consulting Services Inc., 2015 (EIS consultant).7
The studies performed by PSE in 2013 and 2015 confirmed that the Eastside’s existing grid will
not meet federal reliability requirements by the winter of 2017/2018 and the summer of 2018
without the addition of 230 kV to 115 kV transformer capacity in the Eastside area.
LUC 20.20.255.D.3c. Describe components of the proposed electrical utility facility that relate to
system reliability.
PSE’s proposal is to install and operate a new 230 kV to 115 kV electrical transformer in the
center of the Eastside load area. The ideal location for the new transformer is in close proximity
to PSE’s existing Lakeside 115 kV substation, which provides the connection to the existing 115
kV electrical system that serves the surrounding distribution substations. The new 230 kV to
115 kV transformer is the principal component that will allow the Eastside electrical system to
reliably operate and meet Federal P lanning standards. To operate the new transformer it must
be served by approximately 18 miles of new high-capacity electric transmission lines (230 kV)
extending from Redmond in the north and Renton to the south. The transformer would be
6 These studies provide evidence relevant to the City’s review under LUC 20.20.255.E.4
and LUC 20.20.255.D.3.b & c.
7 The City’s consultants evaluation concluded as follows: “...PSE[‘s] 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.” (DeClerck, Review Memo by Stantec
Consulting Services Inc., July 31, 2015).
000248
Energize Eastside Project
Final Environmental Impact Statement
VOLUME 1
MARCH 2018
PREPARED FOR:
The Cities of Bellevue, Newcastle,
Redmond and Renton
PREPARED BY:
ESA
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D 7RDGGUHVVWKLVULVNLQWKHQHDUWHUP36(ZRXOGFRQWLQXH
WRGHSOR\DQGH[SDQGWKHXVHRIDVHULHVRIRSHUDWLRQDOVWHSVWR
SUHYHQWV\VWHPRYHUORDGVRUODUJHVFDOHORVVRIFXVWRPHUV¶SRZHU
WKHVHVWHSVDUHUHIHUUHGWRDVCorrective Action Plans (CAPs).
&$3VJHQHUDOO\LQYROYHVKXWWLQJRIIRUUHGXFLQJORDGRQ
RYHUORDGHGHTXLSPHQWDQGUHURXWLQJWKHORDGWRRWKHUHTXLSPHQW
7KH&$3VDUHVHHQDVWHPSRUDU\PHDVXUHVWRNHHSWKHHQWLUH
V\VWHPRSHUDWLQJEXWWKH\FDQSODFHODUJHQXPEHUVRIFXVWRPHUV
DWULVNRIDSRZHURXWDJH HJUROOLQJEODFNRXWSODQ LIDQ\WKLQJ
HOVHRQWKHV\VWHPEHJLQVWRIDLO&$3VDUHGHVFULEHGLQPRUH
1 See U.S. - Canada Power System Outage Task Force Final Report on the August 14, 2003 Blackout in the United
States and Canada: Causes and Recommendations, April 2004.
2 PSE annually updates projected electrical demand systemwide; however, it does not develop annual estimates for
the Eastside only.
Block loads are substantial
increases in expected
electrical demand from
individual customers, typically
industrial, commercial, or
institutional customers. PSE
regularly communicates with
large customers to estimate
upcoming block load to
ensure that their supply and
distribution system will be
capable of serving the need.
DSD 005414
005492
1
Ordinance No. 6494
CITY OF BELLEVUE, WASHINGTON
ORDINANCE NO. 6494
AN ORDINANCE denying appeals of the Hearing
Examiner’s decision approving a Conditional Use Permit
with conditions, on the application of Puget Sound Energy
for the South Bellevue Segment of the Energize Eastside
Project located at 13625 SE 30th Street and south to the
Bellevue city limits at 6927 128th Place SE, Application No.
17-120556-LB; approving said Conditional Use Permit;
and establishing an effective date.
WHEREAS, on September 8, 2017 Puget Sound Energy (PSE) submitted an
application for a Conditional Use Permit (CUP) for the construction of a new substation
and 230 kilovolt (kV) transmission lines located within the Bellevue City limits (the
“South Bellevue Segment of the Energize Eastside Project”); and
WHEREAS, a Notice of Application was published on October 12, 2017 and
public meetings were held on November 14, 2017 and September 6, 2018; and
WHEREAS, on January 24, 2019, the City’s Land Use Director recommended
approval of PSE’s CUP application; and
WHEREAS, on March 28, 2019, March 29, 2019, April 3, 2019, and April 8,
2019, the Bellevue Hearing Examiner conducted a public hearing on the CUP
application, pursuant to notice as required by law; and
WHEREAS, on June 25, 2019, the Hearing Examiner issued his Findings of
Fact, Conclusions, and Decision approving the CUP for the South Bellevue Segment
of the Energize Eastside Project with conditions , on July 3, 2019 issued an Errata
correcting typographical errors, and on August 13, 2019, issued an Errata Correcting
Exhibit List (hereafter collectively referred to as the “Hearing Examiner’s Decision”);
and
WHEREAS, on July 9, 2019 Citizens for Sane Eastside Energy (CSEE),
Coalition of Eastside Neighbors for Sensible Energy (CENSE), Norm Hansen, Lorretta
Lopez, and Warren Halverson filed appeals of the Hearing Examiner’s Decision; and
WHEREAS, following a limited appeal hearing in front of the City Council on
October 16, 2019, and further discussion and deliberation by Council, at its November
14, 2019 meeting, the City Council directed staff to draft an ordinance denying the
appeals, incorporating and adopting the findings of fact and conclusions of law from
the Hearing Examiner’s Decision, and approving PSE’s CUP application, as approved
by the Hearing Examiner, now, therefore,
2
Ordinance No. 6494
THE CITY COUNCIL OF THE CITY OF BELLEVUE, WASHINGTON, DOES ORDAIN
AS FOLLOWS:
Section 1. The City Council concludes that appellants CSEE, CENSE, Norm
Hansen, Lorretta Lopez, and Warren Halverson have failed to meet their burden to
prove that the Hearing Examiner’s Decision was not supported by material and
substantial evidence in the record and their appeals are hereby denied.
Section 2. The City Council concludes it has no jurisdiction to decide the
constitutional due process claims, claims of bias by the Hearing Examiner, or
challenges to the adequacy of the SEPA Environmental Impact Statement raised in
the appeals.
Section 3. The City Council concludes that the City’s Land Use Code does not
require PSE to submit one CUP application for both the North and South segments
and that the only CUP application before the Hearing Examiner was for the South
Bellevue Segment.
Section 4. The City Council adopts the Hearing Examiner’s Findings of Fact
and Conclusions.
Section 5. Based on the foregoing Findings of Fact and Conclusions, and as
conditioned by the Hearing Examiner, the City Council hereby approves the
Conditional Use Permit application of PSE for the South Segment of the Energize
Eastside Project, Application No. 17-120556-LB.
Section 6. This ordinance shall take effect and be in force five (5) days after
passage and legal publication.
3
Ordinance No. 6494
Passed by the City Council this _____ day of , 2019
and signed in authentication of its passage this ______ day of ,
2019.
(SEAL)
John Chelminiak, Mayor
Approved as to form:
Kathryn Gerla, City Attorney
Kathleen Kline, Assistant City Attorney
Attest:
Charmaine Arredondo, City Clerk
Published
000001
000002
000100
000111
1
CENSE TECHNICAL REPORT / Jeanne DeMund
Description of Applicant
Abstract
Puget Sound Energy (PSE) is a privately-held, foreign-owned imperfectly-regulated monopoly utility
providing electric service to approximately 1.1 million ratepayers in Kitsap, Skagit, Thurston and Whatcom
counties and parts of Island, King, Kittitas and Pierce counties, and natural gas service to approximately
790,000 ratepayers in parts of King, Kittitas, Lewis, Pierce, Snohomish and Thurston counties.
Some aspects of Puget Sound Energy’s utility activities are regulated by the Washington State Utilities
Commission (WUTC). The WUTC has regulatory authority over the sale and purchase of privately held
utilities as well as over electricity rate changes requested by PSE and the profit, or ‘return on equity (ROE)’
of any infrastructure investments made by PSE. However, the WUTC does NOT have regulatory authority
to permit or deny an infrastructure project before it is built.
PSE’s 16-mile Energize Eastside project was estimated to cost between $100-300M to build. With the
anticipated profit rate of 9.8%, PSE’s total dollar profit will be $479M - $2.1B, depending on initial cost and
project life.
No cost estimates have been provided for PSE’s new truncated 8.78-mile project, the Talbot Hill/Lakeside
Transmission Line (THLTL).
PSE’s investor owners’ interests are more closely tied to returns on investment for their shareholders than
the interests of local ratepayers. In addition, the current downturn in the economic environment for electric
utilities provides a powerful motivation for PSE to downplay technical, environmental and community
considerations in favor of building the project for huge profits.
Table of Contents
1. PSE Ownership – Foreign Investors
2. PSE - regulated by the Washington Utilities and Transportation Commission (WUTC)
3. Energize Eastside intended for profit
• Energy conservation reducing PSE profit (10K report)
• Request for a 9.8% annual return on infrastructure investment from ratepayers
• Why Energize Eastside would be profitable
• Why PSE needs EE
4. Conclusion
2
1. PSE Ownership
In 2009, a consortium of private, non-US investors including investment arms of Macquarie Group (an
Australian bank), and three Canadian pension funds: the Canadian Pension Plan Investment Board
(CPPIB), the British Columbia Investment Management Corp., (bcIMC) and the Alberta Investment
Management Corp. (AIMCo), acting as Puget Holdings LLC1, finalized the $7.4 billion acquisition of Puget
Holdings, the parent company of PSE.
In 2019 the WUTC approved Macquarie Infrastructure Partners, Inc., and Macquarie-owned Padua MG
Holdings LLC sale of its 43.99% ownership to four investment firms: Alberta Investment Management
Corporation (Canada), British Columbia Investment Management Corporation (Canada), OMERS
Administration Corporation (Canada) and PGM Vermogensbeheer B.V. (Holland).2
The figures below show the 2018 ownership structure. The new ownership structure has not yet been
disclosed. Puget Sound Energy will remain wholly foreign-owned.
1 https://archive.is/20130204065221/http://www.thenewstribune.com/2008/12/31/581321/puget-sound-energy-sold-
to-foreign.html (https://archive.is/IffcC)
2 https://www.pggm.nl/english/who-we-are/press/Pages/Puget-Sound-Energy-welcomes-new-investment.aspx
3
Figure 1: Puget Sound Energy Ownership Structure 3
3 http://www.pugetenergy.com/past_events_pdfs/2017_April_Bondholder_Presentation.pdf (page 40)
4
The precise ownership structure of the new shareholders has not been publicly announced. The assets and
activities of each of the five current consortium members and the percentage of Puget Energy held by each
are summarized in Figure 2. Nevertheless, the new shareholders will all have a primary fiduciary duty to
their investors, none of whom are locally-based. They serve the ratepayers of Washington State insofar as
it benefits their investors.
Figure 2: Investment consortium members: Assets, activities and percent Puget Energy
Ownership4
4 http://www.pugetenergy.com/past_events_pdfs/2017_April_Bondholder_Presentation.pdf (page 41)
5
Of the twelve board members currently serving on both the Puget Energy and Puget Sound Energy Boards,
six represent consortium investors.
Representing Canadian Pension Funds:
• Kenton Bradbury, managing director, OMERS Infrastructure Management
• Richard Dinneny, Senior Portfolio Manager, Infrastructure and Renewable Resources for bcIMC
• Christopher Hind, senior principal, private infrastructure with CPPIB
• Chris Trumpy, chair Pacific Carbon Trust and former chair of the bcIMC and Land and Water BC
• Steven Zucchet, managing director, OMERS Infrastructure Management
Representing PGGM, Netherlands second largest Pension Fund:
• Martijn Verwoest, Senior Director, Infrastructure team
Of the 7 board members not directly representing consortium investors, Paul McMillan is a Canadian, with
diverse energy-related interests. Of the 5 board members with ties to Washington State, only Kimberly
Harris, PSE President and CEO has a utility industry background. The other 4 have the following
backgrounds:
• Steven W. Hooper (Chair), co-founder and partner of Ignition Partners, a venture capital firm
focusing on enterprise software and technology.
• Scott Armstrong, former President and CEO of Group Health Cooperative.
• Barbara J. Gordon, retired VP and Chief Customer Officer, Apptio, technology business
management software.
• Kimberly J. Harris, CEO of Washington state-based Puget Sound Energy, a subsidiary of Puget
Energy
• Mary O. McWilliams, former Executive Director of Washington Health Alliance, a health care
community collaborative non-profit.
• Tom King, operating executive with AEA Investors, a middle market private equity firm5
It is hard to imagine these 4 non-industry, local directors having substantial influence on the decisions of
the consortium investor directors.
5 https://www.pugetenergy.com/pages/board.html
6
2. Regulated by the Washington Utilities and Transportation
Commission (WUTC)
The Regulatory Services Division of the WUTC describes its regulatory scope as it relates to electric
providers as, “Energy Section Staff review rates, revenues, expenses and programs of investor-owned
electric companies. In a rate-setting process, Staff may act as a litigant in the proceedings, seeking a fair
balance between corporate needs, ratepayer needs, and the public interest.”6
The WUTC also has a legal responsibility to be involved in the utility’s planning process and requires each
utility to develop an “Integrated Resource Plan” or IRP.7 For the first time in 2017, long after the beginning
of planning for Energize Eastside, PSE’s recently completed IRP has a descriptive chapter concerning
transmission planning. The WUTC had the following criticisms of PSE’s transmission planning efforts
relative to Energize Eastside:
“In describing the status of the Energize Eastside Project with respect to its 2017 IRP, PSE states,
“the needs assessment and solution identification phases of this project have been completed.
Currently, the project is in the route selection and permitting phases.” (footnote #40 in UTC
document Page 8-30 of PSE’s 2017 IRP). WAC 480-100-238(3)(d) requires an integrated resource
plan to include “[a]n assessment of transmission system capability and reliability, to the extent such
information can be provided consistent with applicable laws.” The Company has an obligation to
bring major transmission investments into the IRP for examination. The Company complied with
the letter of the law in Chapter 8 where it provided a history of its Needs Assessment Reports.
However, the Plan did not answer many questions that are needed for determining if the
Company’s conclusions are justified. For instance, it is still not clear if a joint utility analysis of all
available transmission and potential interconnections in the Puget Sound region might solve the
Energize Eastside reliability issues. Whether PSE has engaged in such analysis or discussions
remains unclear and would have been better answered in the IRP.”8
It is important to note that these criticisms relate only to the original proposed Energize Eastside project.
The truncated THLTL was not discussed at any time during the IRP process, nor has it been presented in
any of the Columbia Grid planning documents, discussed in Section 7 of this document.
Unfortunately, the WUTC cannot compel PSE to take any action in response to its criticisms of the 2017
IRP. The WUTC has no regulatory or legal ability to analyze, assess, evaluate, permit, approve or deny
transmission or other infrastructure projects prior to their construction by utilities, as described by Simon J.
ffitch, Senior Assistant Attorney General, Public Counsel Division in a 2014 letter regarding Energize
Eastside:
6 https://wwwpre.utc.wa.gov/aboutUs/Pages/divisions.aspx
7 http://apps.leg.wa.gov/wac/default.aspx?cite=480-100-238
8 Acknowledgment Letter Attachment, Puget Sound Energy’s 2017 Electric and Natural Gas Integrated Resource
Plan, Dockets UE-160918 and UG-160919, page 10.
7
“Under Washington’s regulatory framework, the UTC does not pre-approve construction of utility
plants or facilities…In a situation such as the “Energize Eastside” project, the UTC regulatory
function is triggered when PSE seeks cost recovery from customers. This normally takes place in a
rate case after the investment has been made and the utility plant has been placed in service.”9
Their entire ability to exercise any control over utility infrastructure projects is through rate-setting rulings.
The WUTC has the power to set the cost recovery and rate of return allowed on a specific project via rates
charged to consumers, or to dis-allow cost recovery and profit on a particular project.
However, during a City of Bellevue City Council Study Session in 2014 Councilmember Chelminiak
“questioned whether anyone has ever built a transmission line and had the WUTC question the ability of
the utility to get their money back.”10 Mark Vasconi, Director of Development Services Department of the
WUTC, responded that, “he was not aware of such a situation.”11
Under the current regulatory structure Energize Eastside, or the shorter THLTL, is a multi-million or billion-
dollar regional project that will be built with only ordinary land use permit approvals by local jurisdictions
who have no electric utility specialists on staff, and without any outside analysis, evaluation, or approval by
any state, regional or federal utility regulatory agency.
3. Energize Eastside intended for profit
3.a. Energy conservation reducing PSE profit (10K report)
PSE recognizes that increasing efficiency and conservation efforts are reducing electricity consumption,
and profits are at risk, and these decreases are not recoverable through increased rates or the recently
developed decoupling mechanism:
“Washington state law also requires PSE to pursue electric conservation that is cost-effective,
reliable and feasible. PSE’s mandate to pursue electric conservation initiatives may have a
negative impact on the electric business financial performance due to lost margins from lower sales
volumes as variable power costs are not part of the decoupling mechanism”12
Attempting to install more transmission capacity in a stable or declining electricity consumption environment
is like a gas station owner who, facing declining gasoline sales, invests in new pumps.
9 http://e-dataevidence.com/simon%20ffitch%20letter.pdf
10 City of Bellevue, City Council, Summary Minutes of Study Session, July 7, 2014, page 5.
11 City of Bellevue, City Council, Summary Minutes of Study Session, July 7, 2014, page 5.
12 PSE United States Securities and Exchange Commission Form 10-K Annual Report Pursuant to Section 13 or
15(d) of the Securities Exchange Act of 1934, for the fiscal year ended December 31-20176. Page 35.
8
3.b. Energize Eastside Potentially Profitable because of 9.8% annual return on infrastructure
investment from ratepayers.
Puget Sound Energy (PSE) as an investor-owned utility operating in the State of Washington, requests rate
adjustments from the Washington Utilities and Transportation Commission (WUTC); for this proposal PSE
would request WUTC to enable a 9.8% profit, or ‘return on equity (ROE)’. The fact that PSE intends to
request this 9.8% ROE is indicated by PSE’s April 2017 Bondholder Presentation, entitled, “Puget Energy
and Puget Sound Energy 2016 Year End Update, April 2017, on page 27 (see Figure 3).
Figure 3: PSE Return on Equity 13
13 http://www.pugetenergy.com/past_events_pdfs/2017_April_Bondholder_Presentation.pdf (page 27)
9
Given that PSE is promoting the 9.8% prospective return on equity (profit) to bondholders (investors), it can
be safely assumed PSE intends to ask the WUTC to approve this level of ROE.
In fact, in the Frequently Asked Questions (FAQ) segment of the PSE Energize Eastside website,
PSE confirms its intent to include the project in future annual capital budgets and cover the cost
“like most transmission and distribution projects.”
“Will I see an increase in my bill or "line item" charge on my bill to pay for Energize Eastside?”
No. Customers will not see an increase in their monthly bill or “line item” charge on their bills as a
direct result of Energize Eastside. PSE funds electric infrastructure upgrades and additions through
its annual capital budget, which is already covered in current customer rates. PSE plans its capital
investments several years in advance and spreads them out so the annual capital budget covers
numerous projects each year.
PSE will include the cost of Energize Eastside in future annual capital budgets. Once the project is built and
added to the annual capital budget, we expect that $1 to $2 of the average monthly bill for residential
customers will go towards paying for the project.“14
In spite of PSE’s initial denial that customers will see an increase in their monthly bills, it is clear that PSE
anticipates the cost of the project will be covered by ratepayers, via the 9.8% return on equity rate increase
“like most transmission and distribution projects.” The Energize Eastside project is specifically envisioned
as one of PSE’s “Major Strategic Capital Projects.” (See Figure 4)
14 https://energizeeastside.com/faqs
10
Figure 4: Energize Eastside is a major strategic capital project 15
The Bondholder Presentation highlights Puget Energy’s compounded annual Earnings Before Interest,
Taxes, Depreciation and Amortization (EBITA) growth of 5% between 2007-201616 and predicts growth
from strategic investments in “strategic capital projects focused on customers, core operations and system
reliability,” including Energize Eastside. The importance of this project to Puget Energy’s revenue forecasts
is evident, and there is considerable incentive to build expensive projects to increase revenue from the
allowed 9.8% ROE, rather than to seek the most economical solution.
15 http://www.pugetenergy.com/past_events_pdfs/2017_April_Bondholder_Presentation.pdf (page 13)
16 http://www.pugetenergy.com/past_events_pdfs/2017_April_Bondholder_Presentation.pdf (page 33)
11
3.d. Why PSE needs EE
At the time of the purchase, staff at the WUTC expressed concern that, “the bid offered by Macquarie-led
consortium to buy Puget Sound Energy through debt financing was too highly leveraged. He warned that
the deal would significantly lift the debt level of the utility's books to an unacceptable level of $4.2 billion.”17
The Public Counsel Section of the Attorney General’s Office recommended that the WUTC not approve the
acquisition, saying that the deal,
“Simply exposes PSE's customers to an undue level of financial risk by undertaking too much
debt," Public Counsel Chief Simon ffitch said. "At the same time, customers have no assurance
that capital for infrastructure will be any more available or affordable than without the merger.
Consumers appear to get little or nothing in return for the increased financial risk.
"Macquarie and PSE commit to provide customer benefits related to service quality, environmental
impacts, local presence and other areas. However, these commitments don't provide new benefits,
but simply restate existing PSE obligations," ffitch added.”18
2019 was a pivotal year for PSE finances. The urgency to complete Energize Eastside was driven by the
need to recognize revenue from this project by [the end of] 2019:
• PSE’s credit facility expired in 2019. The cost of borrowing for PSE will increase dramatically
• In PSE’s 2009 IRP, PSE set forth a plan to retire the Colstrip coal-burning power plant in stages –
2 older units would go offline in 2019. In more recent IRPs, PSE has backtracked on Colstrip
retirement – pushing out to 2022.
• Macquarie’s acquisition of PSE was via a 10-yr closed fund, in 2009. On June 15, 2017 Macquarie
announced plans to sell a 42% stake in PSE.19 The new owners of PSE are listed on page 5.
• PSE is pushing an aggressive schedule to get Energize Eastside approved. Construction was to
begin in 2018, with the goal to generate revenue by 2019.
17 https://www.forbes.com/2008/06/20/puget-energy-macquarie-markets-equity-cx_vk_0620markets03/
18 https://www.forbes.com/2008/06/20/puget-energy-macquarie-markets-equity-cx_vk_0620markets03/
19 https://www.pionline.com/article/20170616/ONLINE/170619905/canadian-funds-part-of-consortium-ready-to-sell-
stake-in-puget-energy
12
PSE’s Balance Sheet reveals the following:
• Short Term Debt $53.8 Million.
• Long Term Debt $3.8 BILLION (51.3% debt ratio).
• PSE’s Debt Financing is Credit Negative (credit rating is “junk bond” status, Baa3).20
• PSE’s credit facility expires in 2019.21 The cost of borrowing for PSE will dramatically increase by
2019.
• PSE is unable to refinance variable-rate debt now, because their terms are unattractive to
investors.22, 23, 24
• Macquarie’s acquisition of PSE was via a 10-yr closed fund. June 15, 2017 Macquarie announced
desire to sell 42% stake in PSE.25
• The WUTC needs PSE to be financially viable to provide service to 1.1 million Washington
customers.
• PSE’s Energize Eastside project will result in approximately $1.5 Billion in revenue for PSE over 40
years or more, garnering a guaranteed rate of return of approximately 10% annually.
The critical importance of this project to PSE is demonstrated by the massive promotional campaign they
have undertaken to sell it to the public, discussed in Section 5 of this document.
20 https://www.moodys.com/research/Puget-Energy-Debt-Financing-is-Credit-Negative--PR_324799
21 http://www.sec.gov/Archives/edgar/data/81100/000108539214000021/pe-
2014630x10q.htm#sECEFE0B0BBD3EE26F216FC9CD7981795
(pg. 32: “PSE’s credit facilities expire in 2019 and Puget Energy’s senior secured credit facility expires in 2018.”)
22 https://www.prnewswire.com/news-releases/puget-sound-energy-inc-announces-tender-offer-300265861.html
23 http://www.bloomberg.com/news/articles/2016-05-19/puget-sound-said-facing-investor-pushback-on-debt-
buyback-deal
24 http://www.bloomberg.com/news/articles/2016-06-09/puget-sound-said-to-drop-buyback-deal-as-investors-
withhold-
25 https://www.bloomberg.com/news/articles/2017-06-15/macquarie-said-to-explore-sale-of-stake-in-utility-puget-
energy
13
4. Conclusion
PSE is a wholly-foreign-owned utility whose purchase was highly leveraged and whose debt level was a
concern to state regulators at the time of purchase. to sell their current 43.99% share to two current and
two new foreign-owned investors. The profits from Energize Eastside are featured as a major selling point
in shareholder communications filed with the SEC, as conservation and other trends show that electricity
consumption is flat or declining. Thus, Energize Eastside’s future profits provide an enormous incentive to
build the project. Where else in the US, Canada or the European Union, could an investor make a
guaranteed 10% annual profit on a capital investment? And all this profit will flow to the foreign pension
fund investors. The WUTC has raised serious questions about the need for the project in their comments
on PSE’s most recent Integrated Resource Plan, although the WUTC does not have the authority to
approve or deny infrastructure projects prior to construction. The newly-truncated 8.78-mile Talbot
Hill/Lakeside Transmission Line proposal was not presented to the WUTC in the most recent IRP process.
Until questions about the underlying need for the original project, the new, shorter project and possible
alternative solutions for both projects are answered, permits for Energize Eastside or the shorter Talbot
Hill/Lakeside Transmission Line should be denied.
SECTION 4: INTRODUCTION
Cost of Project
The documents in this section compare the life-cycle cost of the proposed transmission line project with
the costs of alternatives rejected by PSE.
Table of Contents
4.1 Lifetime Cost Analysis for Energize Eastside
Jeffrey King, Economist
4.2 Cost of Talbot Hill/Lakeside Transmission Line Project
Jeanne DeMund, CENSE
Lifetime cost analysis for Energize Eastside
What will Energize Eastside cost customers over its lifetime?
February 17, 2016
If those numbers seem large, it’s mostly
because state policy guarantees PSE
a return on investment of 9.8% per year
for infrastructure projects.
Interest adds up quickly at that rate.
What will Energize Eastside cost customers over its lifetime?
CENSE engaged Jeffrey King, a utility financing expert, to give us better answers to this
question. Mr. King worked as a Senior Resource Analyst for the Northwest Power Planning
Council for nearly 30 years.
Mr. King used MicroFin modeling software to come up with three different lifetime scenarios
(45, 55, and 65 years) using a project base cost of $100 million. The details of his analysis can
be found in the following pages of this document.
A base cost of $100 million is considerably less than PSE’s cost estimates, but the results of the
model can simply be scaled by the ratio of the actual cost to the base cost. For example, if the
cost were to be $300 million (three times the base cost), the results from Mr. King’s analysis
could simply be multiplied by a factor of 3.
PSE has not updated cost estimates for Energize Eastside, and the EIS contains no reference to
the project’s cost. Our best guess is that it will cost at least $250 million. We scaled the results
of Mr. King’s analysis by a factor of 2.5 to arrive at the following lifetime costs:
Lifetime of Energize Eastside
transmission line Total cost to ratepayers
45 years $1.45 billion
55 years $1.74 billion
65 years $2.03 billion
If those numbers seem large, it’s mostly because state policy guarantees PSE a return on
investment of 9.8% per year for infrastructure projects. Interest adds up quickly at that rate.
Revenue collected by PSE for this level of investment would be approximately $32 million per
year. This is an important number, because it is possible to buy quite a bit of technology to
implement alternative solutions with expenditures of that size. Because alternative solutions
can be built incrementally as the need arises, we probably wouldn’t need to continue that
level of investment for 45-65 years.
We see an opportunity to build a solution of just the size we need and save a lot of money for
ourselves, our children, and our grandchildren.
Estimation of the fixed charge rate and revenue requirements
for the proposed Energize Eastside transmission project
Prepared for CENSE.org by Jeffrey C. King & Associates
February 10, 2016
The Energize Eastside transmission project is intended to reinforce the Puget Sound
Energy electrical distribution system on the east side of Lake Washington in King County,
Washington, an area that has experienced significant growth over the past several decades
without concurrent expansion of the local transmission system. The Energize Eastside project
is proposed to be an overhead single-circuit 230 kV transmission line1 extending from the
existing Talbot Hill substation in Renton approximately 18 miles north and east to the existing
Sammamish substation in Redmond, passing through Bellevue, Kirkland and other Eastside
communities. The line would feed, from both ends, a new or expanded substation in the
Bellevue vicinity. Preconstruction fieldwork commenced in January 2015 and construction is
proposed to commence in the second quarter of 2017 for fourth quarter 2018 energization.
The purpose of the work described in this paper is to estimate the levelized fixed charge
rate (FCR)2 and revenue requirement3 of the proposed Energize Eastside project. Revenue
requirement can subsequently be used to estimate the rate impact of the proposed project.
The MicroFin Levelized Project Revenue Requirements model, developed by the Bonneville
Power Administration and the Northwest Power and Conservation Council is used to calculate
project FCRs and revenue requirements. MicroFin uses normalization accounting4 to simulate
investor-owned utility financing of electric power projects. MicroFin calculates total project
investment costs using a construction cost estimate, construction cash flows and financing
information. Annual cash flows over the forecast service life of the project are then calculated.
Components of annual cash flows for transmission projects include debt service, debt
interest, return on equity, equity recovery, income and property taxes, insurance, operation
and maintenance expenses, interim capital replacement costs and the cost of losses. The net
1 The project may use towers capable of carrying a future second 230KV line.
2 The Fixed Charge Rate is the levelized annual cost of financing the construction of a project over the economic life of the project,
expressed as a percentage of total investment cost. The total investment cost is the cost of developing and constructing a project
(capital cost), including price escalation and interest incurred during the construction period.
3 Project Revenue Requirements are the annual costs of constructing and operating a project. Revenue requirements consist of the
annual financing costs (Fixed Charge Rate x Total Investment Cost) plus annual operation and maintenance costs (expensed and
capitalized).
4 Normalization accounting shifts a portion of the benefit of accelerated tax depreciation to later years of the life of a project.
Normalization accounting is mandated by the Internal Revenue Service for investor-owned utilities.
of these comprise annual revenue requirements. Annual revenue requirements may vary
over the life of a project due to factors such as cost escalation and a service life that exceeds
the financing life. A levelized revenue requirement (an equivalent constant value) is then
calculated by taking the net present value of the series of annual revenue requirements, then
calculating a constant series of annual payments with equivalent net present value.
For calculating the FCR and revenue requirements of a transmission project, MicroFin requires
information regarding project capital costs, operation and maintenance (O&M) costs, interim
capital replacement costs; construction cash flows; the project owner’s financial structure,
tax obligations and incentives, if any; forecast general inflation and escalation rates of
capital and O&M costs; and electrical losses. Other MicroFin input data such as fuel cost
and emission costs are not applicable to a transmission project. The information needed by
MicroFin to calculate a fixed charge rate and revenue requirement for a transmission project
is shown in Table 1 with the known or assumed values for the Energize Eastside project and
sources of this information. Additional information regarding the derivation of certain input
assumptions is provided in the Appendix.
Capital costs for transmission projects vary widely and the capital cost estimates for the
proposed Energize Eastside project were not available for this analysis. $100 million is used
as a placeholder. $100 million is substantially greater than typical cost for a 230kV project of
this size, however the congested nature and environment of the proposed corridor will likely
increase construction cost well above typical costs. Once construction cost estimates are
available, revenue requirements can be calculated by taking ratios of $100 million. Because
all cost input assumptions for this project are a constant percentage of the capital cost and all
input costs are independent of the load factor of the line, the relationship of overnight capital
to revenue requirements is linear.
An uncertainty of some importance is the assumed service life of the project. PSE estimates
that the service life of transmission facilities will range from 45 to 65 years. For this reason, FCR
and revenue requirements calculations were run for 45, 55 and 65 year service lives.
The estimated fixed charge rates and levelized annual revenue requirements for a $100
million overnight capital cost investment in a project with the characteristics of the proposed
Energize Eastside project are shown in Table 2 for 45, 55 and 65 year service lives. Also shown
is the AFUDC ratio, to calculate total plant investment (basis of the fixed charge rate) from
the overnight construction cost. All values are “nominal”, e.g., include the effects of forecast
general inflation, and therefore represent the actual dollar impact on rates.
Table 1: Modeling input data values and sources
Input Value Source Note
Plant Data:
Start of construction 1/1/2017 Approximation of PSE
Q2 2017
Closest MicroFin time series increment.
Service date 1/1/2019 Approximation of PSE
end of Q3 2018
Closest MicroFin time series increment
Service life 44, 55 and 65 years PSE 2014 FERC Form
1 page 123.14
Overnight capital cost 100 million Placeholder
Annual construction cash flow 50%/yr JCK assumption
Capital cost real escalation Zero JCK assumption Reflects currently low rates of labor and
equipment price escalation.
Annual operation and
maintenance expenses
1.3% of overnight
capital cost
See Appendix Exclusive of property tax and insurance.
O&M cost real escalation Zero JCK assumption Reflects currently low rates of labor and
equipment price escalation.
Generation integration costs n/a No significant generation would be
interconnected to the proposed project.
Control and dispatch costs Zero Project is assumed not to significantly affect the
control and dispatch costs of the PSE system
Cost of losses Zero Project will likely reduce system losses overall
but extent not known w/o load-flow analysis
Interim capital replacement 1.2% of overnight
capital cost
See Appendix Levelized annual cost of replacing major
equipment over the life of the project.
Input price year dollars 2016 Cost estimates are assumed current
Project financing
Debt term 30 years JCK assumption
Equity recovery period 30 years JCK assumption
Debt/Equity ratio 52/48 PSE 2014 FERC Form
1, page 109.2
WUTC approved, effective 1/2014
Debt interest rate (nominal)5.75%See Appendix Average of recent PSE 30-year issues plus
0.25% for Dec 2015 Federal Reserve increase.
Return on equity (nominal)9.8%PSE 2014 FERC Form
1, page 109.2
WUTC approved, effective 1/2014
Debt financing fee 1.0% of issue See Appendix Average of recent PSE 30-year issues.
Discount rate (nominal)6.7%Calculated After-tax cost of capital for the assumed
financial parameters (PSE perspective)
General inflation rate See Appendix NPCC 7th Plan (draft)
Taxes and Insurance
Federal income tax rate 35%PSE 2014 FERC
Form1
FIT recovery period 20 years IRS Pub 946 Recovery period for transmission assets
Federal investment tax credit None
State income tax rate None
State investment tax credit None
Annual property tax rate 0.95% of overnight
capital cost
See Appendix Average King Co. property tax rate x ratio of
assessed to true value for King Co.
Annual property insurance rate 0.06% of overnight
capital cost
See Appendix Average PSE property insurance cost on electric
plant property
3
Table 1: Modeling input data values and sources
Table 2: Estimated AFUDC ratio, fixed charge rates and revenue requirements (Nominal values)
Case AFUDC Ratio Annual FCR Annual Revenue (% Total Plant Investment) Requirement ($/yr)
$100 MM overnight cost; 1.038 9.9% $12,869,000
45-year useful life
$100 MM overnight cost; 1.038 9.7% $12,622,000
55-year useful life
$100 MM overnight cost; 1.038 9.6% $12,505,000
65-year useful life
Appendix: Derivation of certain modeling input assumptions
Operation and maintenance costs: Operation and maintenance costs for this project include
the expensed costs of operating and maintaining the system plus administrative and general
costs. Major equipment replacement costs are normally capitalized and are considered
separately. System control and dispatch costs are not included because it is believed that
PSE control and dispatch costs would not be significantly affected by the proposed project.
Generation integration costs are also excluded because no significant generation would be
interconnected to the proposed project. Operating and maintenance costs were estimated
from PSE operation and maintenance cost data appearing on page 321 of the PSE 2014
Federal Energy Regulatory Commission (FERC) Form 1 annual report. Administrative and
General (A&G) costs (Form 1 page 323), excluding property insurance (entered separately
in MicroFin) were calculated as a percentage of total O&M. That percentage was applied
to transmission O&M, as calculated above, to obtain an estimate of transmission A&G. The
transmission O&M estimate plus the transmission A&G estimate were then divided by total
transmission asset value (Form 1 page 206) to obtain transmission O&M plus transmission
A&G as a percentage of transmission capital cost.
Interim capital replacement cost: Interim capital replacement cost is the annual cost
of replacing major components over the expected service life of the project. Information
regarding utility interim capital replacement costs is scarce – these costs are rolled into
annual capital costs that also include system expansion and disaster recovery expenditures.
Reported interim capital replacement expenditures by North American utilities for substation
and transmission assets are relatively high, about 5% of asset value annually. However, North
American transmission systems are aging - the average age of large power transformers is
reported to be 40 years. Because replacement costs increase with age, the levelized lifetime
replacement rate for a new transmission line will be less than the replacement rate for a 40
year old facility. Assuming an exponential increase in replacement costs over the service life of
a facility, a 5% rate at age 40 yields a levelized lifetime rate of 1.2% of asset value for a facility
with an expected service life of 55 years (midpoint of PSE service life estimates).
Debt interest rate and financing fee: The average interest rate of 30-year PSE bonds issued
from 2009 through 2014 is 5.48% (PSE FERC Form 1 page 256 and 257). To this was added
0.25% to account for the December 2015 Federal Reserve rate increase. The result was
rounded to 5.75%. The same source was used to calculate an average debt placement fee of
1.03% (rounded to 1%) for the same bond issues.
General inflation rate: The forecast general inflation rate used by the Northwest Power &
Conservation Council for its 7th power Plan (draft) was adopted for this study. That series is
1.6% for 2015, 1.7% for 2016, 1.6% for 2017, 1.7 % for 2018-2028 and 1.8% for 2029 and on.
Property tax: An average property tax rate for King County, Washington was calculated as
the product of assessed property value to true property value (Property Tax Ratio) and the
average King County property tax rate, as follows:
Property tax ratio for King Co. 93.800% (WA Dept. of Revenue)
Average property tax rate for King Co. 1.014% (www.smartasset.com)
Average property tax rate on true value 0.950%
Property insurance: Total PSE insurance expenditures (2014 PSE FERC Form 1 page 323) were
divided by total electric plant in-service asset value (Form 1 page 206) to yield a 0.06% rate
based on asset value.
JEFFREY C. KING
3828 N.E. Alameda Street
Portland, Oregon 97212
503-984-0415
jkingeca@gmail.com
January 2016
EXPERIENCE
2011 - Present: President, Jeffrey C. King and Associates. Jeffrey C. King and Associates is a
consulting firm engaged in energy-related analysis for public and private clients. The principal topics of
the firm include energy policy analysis, technical, economic and environmental assessment of electric
power generating technologies and power price forecasting.
2011: Planning Approaches for Water Resource Development in the Lower Mekong Basin. The
purpose of this project, funded by USAID through AECOM International Development and Portland
State University, was to propose and evaluate methods for improving planning for energy development of
the Lower Mekong Basin (LMB). Mr. King was responsible for preparing the assessment of potential
alternatives for power production in the LMB.
1984 - 2011: Senior Resource Analyst, Northwest Power Planning Council, Portland, Oregon. Mr.
King was responsible for assessing the commercial availability, performance, economics, development
potential and issues associated with development and operation of electric power generating resources.
Mr. King was also responsible for the Council’s forecast of wholesale electric power prices, using the
AURORAxmp! Electric Market Model, a proprietary model of the western electric power system. The
model is also used to assess the CO2 production and other effects of regulations and policies affecting the
power system. Mr. King’s activities included assessment and analysis, operation of computer models,
preparation of issue papers, organization and chairing of advisory committees, administration of
contracts, presentations to the Council and interested organizations, and work with utilities, government
agencies, research organizations, resource developers and public interest groups. Information developed
by Mr. King is widely employed by utilities, agencies and others outside the Council.
2008 - 2010: Chief Planner, National Energy Development Framework Project, State of Eritrea.
Mr. King served as the chief planner for preparation of a 20-year energy development framework and
five-year action plan for the State of Eritrea. The framework, funded by USAID, presents a vision for a
future energy supply system for Eritrea to support an adequate, reliable, affordable, and sustainable
energy supply for rural and urban areas, transportation, industry, and water resource, port and tourism
development. Mr. King fashioned the contributions of specialists in various energy resources into a
coherent description of Eritrean energy resource potential, formulated goals and objectives in response to
concepts provided by the State of Eritrea, and lead the development of a proposed Eritrean energy future,
action plan and framework for implementation.
1974 - 1984: Staff Engineer, Energy Systems Department, Battelle, Pacific Northwest
Laboratories, Richland, Washington - Mr. King managed and contributed to projects involving
assessment of the economic and environmental aspects of electric power conservation and supply
resources and application of decision analysis techniques to energy policy and technology issues.
Projects included the first assessment of conservation and generating resources for the newly-formed
Northwest Power Planning Council, assessment of generating resource alternatives for the State of
Alaska, assessment of decommissioning costs and priorities for retired nuclear facilities and analysis of
high-level nuclear waste disposal alternatives.
[Type text]
1964 - 1970: Test Engineer, Nuclear Power Division, Puget Sound Naval Shipyard, Bremerton,
Washington - Mr. King was responsible for the planning and execution of acceptance testing procedures
for the construction, overhaul and refueling naval nuclear power plants.
EDUCATION
Bachelor of Science in Mechanical Engineering, University of Washington, Seattle, Washington. 1964.
Graduate Studies, Zoology, University of Washington, Seattle, Washington. (1970-1972).
Graduate Studies, Regional Planning, University of Pennsylvania, Philadelphia, Pennsylvania.
(1972-1974).
SELECTED PUBLICATIONS
Seventh Northwest Conservation and Electric Power Plan (Document 2015-09). Northwest Power and
Conservation Council. Portland, Oregon. October 2015. (Contributing author)..
Wave Energy Utility Integration. Prepared by Pacific Energy Ventures for the Oregon Wave Energy Trust.
December 2013. (Contributing author)
Planning Approaches for Water Resources Development in the Lower Mekong Basin. Portland State
University, Mae Fah Luang University. July 2011. (Contributing author).
Effects of an Increasing Surplus of Energy Generating Capability in the Pacific Northwest (Document
2011-01). Northwest Power and Conservation Council. Portland, Oregon. March 2011.
Sixth Northwest Conservation and Electric Power Plan (Document 2010-09). Northwest Power and
Conservation Council. Portland, Oregon. January 2010. (Contributing author).
National Energy Development Framework - Part I. Prepared for State of Eritrea, Ministry of National
Development. Asmara, Eritrea. April 2009. (Contributing author).
Carbon Dioxide Footprint of the Northwest Power System (Document 2007-15). Northwest Power and
Conservation Council. Portland, Oregon. November 2007.
Pacific Northwest Wind Integration Action Plan (WIF 2007-15). Northwest Wind Integration Forum.
Portland, Oregon. March 2007. (Contributing author).
1
CENSE REPORT / Karen Esayian
ZONING AND LAND USE
Project Impacts on Public Right of Ways
Abstract
The corridor for the proposed PSE Energize Eastside crosses 62 public streets and roads, totaling 5,617 feet of
public right-of-ways. An illustrated map was created by intersecting the digitized line depicting the powerline with
an underlying ROW layer, as they are represented in the King County parcel layer.
The right-of-ways have been granted to PSE as part of Franchise Agreements with affected cities. In these
agreements, PSE is obligated to comply with the stated land use codes and ordinances of the cities
affected. Cities must use the decision-making authority granted to them by their residents to determine the
appropriateness of the proposed extensive use of the public right-of-ways by PSE. Such decisions should
be supported by the Land Use Codes and Franchise Agreements with PSE.
Table of Contents
1. Data on Powerline Feet in Sections along the Eastside Transmission Corridor
2. Data on Public Right of Ways
3. Conclusion
4. Appendix: Data Methodology and Maps
1. Data on Powerline Feet in Sections along the Eastside
Transmission Corridor
Table 1 illustrates that the proposed Energize Eastside project would cover 78,794 linear feet along the
Eastside transmission corridor.
• Bellevue south: 15,595 linear feet
• Newcastle: 7,171 linear feet
• Renton: 18,658 linear feet
• Bellevue north: 25,590 linear feet
• Redmond: 10,481 linear feet1
1 https://www5.kingcounty.gov/sdc/FGDCDocs/KCA102_PRESENTUSE_PARCEL_faq.htm
2
Table 1 Number of Proposed Powerline Feet by Present Land Use of Parcel
Data provided by Deron Ferguson
Note that three categories of use indicate vacant parcels (vacant single-family, vacant multi-family, and
vacant industrial) and were grouped with other categories for simplified presentation (single-family,
apartment, and industrial park, respectively).2
2. Data on Public Right of Ways
Sixty-two public streets are crossed by the current PSE 115kV transmission line.3
• 19 public streets crossed in Bellevue south (98006)
• 11 public streets crossed in Newcastle (98056)
• 11 public streets crossed in Renton (98058)
• 15 public streets crossed in Bellevue north (98005)
• 6 public streets crossed in Redmond (98033, 98052)
2 https://www5.kingcounty.gov/sdc/FGDCDocs/KCA102_PRESENTUSE_PARCEL_faq.htm
3 : http://powerline-row-intersections.s3-website-us-west-2.amazonaws.com/
Present Use
Count
Parcels
EE
Length
North of
520
Between 520
and I90
South of
I90
Bellevue
North
Bellevue
South Bellevue Newcastle Renton Redmond
King
County
Single family (residential use / zone)256 36,773 11,236 5,150 20,387 14,223 8,679 22,902 4,300 6,110 2,163 1,298
School (Public)5 4,869 1,311 3,559 899 899 2,660 1,311
Utility, Public 7 4,575 3,062 626 888 1,332 1,332 181 3,062
Golf Course 1 3,922 3,922 3,922 3,922
Condominium (Residential)8 3,791 2,622 1,169 1,169 2,622
Park, Public (Zoo \ Abroretum)4 3,726 1,332 2,394 1,332 1,982 3,314 412
Open Space (Curr Use-RCW84.34)6 3,232 1,302 1,931 1,302 1,302 1,931
Unknown 8 3,191 1,322 272 1,597 272 272 1,517 80 1,322
Mortuary / Cemetary / Crematory 2 2,943 2,001 943 2,001 2,001 943
Right of Way / Utility, Road 3 2,153 2,153 2,153
Apartment 5 1,937 663 1,274 791 791 61 1,084
Industrial Park 4 1,778 322 1,456 322 322 1,456
Warehouse 2 1,551 1,551 628 924 1,551
Office building 4 1,264 931 333 931 333 1,264
Sport Facility 2 723 388 335 388 335 723
Single family (C/I Zone)2 496 496 169 327
Retail store 4 472 127 345 127 127 345
Auto Showroom and Lot 1 454 454 454 454
Shopping Center (Neighborhood)1 309 309 309
Church / Welfare / Religious Services 2 247 247 247
Open Space Timber Land / Greenbelt 1 241 241 241
Club 1 134 134 134
Easement 1 12 12 12 12
Total 330 78,794 20,867 17,738 40,190 25,590 15,595 41,186 7,171 18,658 10,481 1,298
Miles 14.9 4.0 3.4 7.6 4.8 3.0 7.8 1.4 3.5 2.0 0.2
3
Figure 1 is an interactive map4 showing the points (red dashes) where the proposed powerline crosses City
right-of-ways (streets) and provides the length of the crossing in feet.
Locations (indicated by red dashes) of Powerline Crossing Cities’ Right of Ways
Figure 1
Land use map depicting right of ways along the entire proposed transmission line project.
4 http://powerline-row-intersections.s3-website-us-west-2.amazonaws.com/
4
The right-of-way (ROW) distance for the public streets crossed along the eastside transmission line corridor
totals 5,617 feet.
• Bellevue south public ROW: 2,128 feet
• Newcastle public ROW: 817 feet
• Renton public ROW: 903 feet
• Bellevue north public ROW: 1,227 feet
• Redmond public ROW: 378 feet
Screenshot Illustrating Length of Transmission Line Crossing ROW (red line)
Figure 2
The length of crossed ROW is indicated by a red line. In this example, the ROW distance is 110.20396 feet.
3. Conclusion
The corridor proposed by PSE for Energize Eastside is not owned solely by PSE. The corridor crosses
public right of ways within predominantly residential land use districts. The PSE proposal does not comply
with land use codes designed to minimize impacts associated with new or expanding electrical utility
facilities. The cities impacted by the project should not allow public streets and other right of ways to be
used for Energize Eastside unless consistent with land use codes.
5
5. Appendix: Data Methodology and Maps
The Interactive Powerline / Right of Way Crossing Map
The Interactive Powerline / Right of Way Crossing Map shows points where the proposed powerline would
cross city right of way (streets) and provides the length of the crossing in feet.
The map was created by intersecting the digitized line depicting the powerline with an underlying ROW
layer. The ROW layer shows Right of Way polygons as they are represented in the King County parcel
layer. This layer does not provide an exact location for ROWs, but provides a reasonable approximation
Table 2 Source Information
Data Element Source File/Variable Source Organization
Right of Way PIN (attribute identifier) ftp://ftp.kingcounty.gov/gis-
web/GISData/row_SHP.zip
Powerline (map layer) Manually digitized* CENSE
* Spatial data is not available from PSE for the proposed power line, so CENSE digitized its route based on
the existing route as determined by aerial imagery and proximity to parcel boundaries, as well as other
published non-spatial data from PSE (the Environmental Impact Statement, permit applications, etc.).
(Data and maps provided by Deron Ferguson)
6
Land Use Map Depicting ROW Distance of Transmission Line Crossing State Route
900 in Renton
Figure 3
Example of one of 15 public streets in Renton that would be crossed by proposed transmission line project.
1
CENSE REPORT / Jeanne DeMund
Cost of PSE’s Talbot Hill/Lakeside
Transmission Line Project
Abstract
In Columbia Grid’s 2011 Transmission Grid Expansion Plan, PSE estimated the cost for Energize Eastside
at $65-$80 million. When announced to the public in 2014, the project was projected to cost between $150
and $300 million. Both of these initial estimates are now woefully out of date. PSE has not provided any
cost estimate for the 8.78-mile Talbot Hill/Lakeside Transmission Line Project (THLTL).
The initial estimates did not include the long-term costs of the project when PSE’s anticipated 9.8% Return
on Equity (ROE) is calculated.
According to CENSE’s consultant’s calculations, using PSE’s original projections, the total cost of the
project over time ranges from $579 million to $2.4 billion, depending on actual initial cost and project
lifespan.
Recent information from PSE shows that $69.5 million has already been spent on the transmission project.
That enormous expenditure at this pre-permit stage of the project indicates that the total costs for the project
before ROI will very likely be at or beyond the high end of either PSE’s or CENSE’s consultant’s estimates.
PSE’s ratepayers will pay for the project, despite misleading statements to the contrary in some of PSE’s
promotional materials. PSE’s analysis of alternative solutions concluded that all of the alternatives were
more costly than transmission lines. CENSE has continued to examine the various alternatives to 18 miles,
or even just 7-8 miles of towers and transmission lines and finds that costs for alternatives have fallen
dramatically since PSE’s initial assessment, and all indications are that costs will continue to fall rapidly.
PSE promised to provide updated project costs following the selection of a preferred route. It has not done so.
Given the scale of the long-term financial obligation for its citizens, Renton cannot approve a project without
accurate, up-to-date cost data.
2
Table of Contents
1. Cost of project
• Original estimates – Columbia Grid
• Current estimates
• Estimate needed for Talbot Hill/Lakeside Transmission Line (THLTL)
• Expenditures to date
2. Cost of project over time – Lifetime Cost Analysis – Jeffrey King
3. Cost of Alternatives
• PSE original estimates
• CENSE estimates
4. Who pays for Energy Eastside?
4. Conclusion
1. Cost of Project
Original estimates – Columbia Grid
Columbia Grid is the non-profit corporation whose mission is to improve reliability and efficient use of the
transmission grid, perform transmission planning and facilitate the development of solutions related to the
operation, use and expansion of the interconnected Northwest transmission system. It lists the project
publicly known as Energize Eastside in each of its currently available Biennial Transmission Grid
Expansion Plan documents: 2009, 2011, 2013, 2015, 2017; and in the three mid-biennium updates: 2010,
2012 and 2016.
The biennial plans indicate some project evolution, and one notable constant. Figures 1A and 1B
summarize the data from these reports. Of note, although changes were made in each biennial plan or mid-
biennium update, once project cost was estimated at $65 – 80 million in 2009, it was not updated until
2018, and then only to $110 million, in spite of the fact that from the first public discussions in 2014, PSE
told the public that project cost would be $150 – 300 million, substantially more than PSE indicates in even
the most recent Columbia Grid estimate.
A notable absence from the Columbia Grid planning process is any mention of the newly-truncated 8.78
mile south-end only Talbot Hill/Lakeside Transmission Line (THLTL) Project.
3
Current estimates
Although PSE still estimates to Columbia Grid that Energize Eastside will cost $65 – 80 million, on the PSE
website the cost estimate has been increased to $150 – 300 million1. This figure is repeated in multiple
locations2. This figure has not changed since 2014, although PSE said, “Once we determine the final
design and alignment, we will have a better idea of the total cost.”3 No PSE updates to total cost are
available on the Energize Eastside website.
Estimate needed for shorter project: Talbot Hill/Lakeside Transmission Line
Although PSE’s website continues to state that the Energize Eastside project “will build a new substation
and upgrade approximately 16 miles of existing transmission lines from Redmond to Renton,”4 PSE has
stated that they do not know when permit applications will be filed for the northern 7.4 miles5, and in fact
the project north of the Lakeside Transmission Substation will be for “redundancy only” and that the THLTL
can “function independently.6
PSE has not provided any cost estimates for the shorter, 8.78 mile, Talbot Hill/Lakeside Transmission Line
project.
Expenditures to date
The Energize Eastside Project has been in the public eye since it was announced in December 2013.
Starting in 2014, the public process began to select a final route, develop draft and final Environmental
Impact Statement and move towards permitting. As of the end of 2018, PSE reported that they spent
$69,530,3547 on the Eastside Transmission Project, also known as Energize Eastside. This is the
expenditure as reported to the Federal Energy Regulatory Commission (FERC), the agency within the U.S.
Department of Energy that, among other responsibilities, administers accounting and financial reporting
rules of its jurisdictional companies.
From City of Bellevue Resolution 9297, stating, “Authorizing execution of an amendment to the
Professional Services Contract with Environmental Science Associates (ESA) by $688,595 for a total
amount not to exceed $3,170,335, plus all applicable taxes, to prepare a Final Environmental Impact
1 PSE. “Who will pay for the project and how much will it cost?” PSE. Access date, December 19, 2018.
https://energizeeastside.com/faq/who-will-pay-for-the-project-and-how-much-will-it-cost
2 PSE. “General” PSE. Access Date December 19, 2018. https://energizeeastside.com/Contents/Item/Display/1256
3 PSE. “Who will pay for the project and how much will it cost?” PSE. Access Date December 19, 2018.
https://energizeeastside.com/faq/who-will-pay-for-the-project-and-how-much-will-it-cost
4 https://www.pse.com/pages/pse-projects/energize-eastside-transmission-line-project
5Email from Keri Pravitz, Community Projects Manager, PSE, to Loretta Lopez, cc: Warren Halvorson, Norm Hansen
and Heidi Bedwell August 13, 2018, 7:17pm
6 City of Bellevue, Development Services Department, Land Use Division Staff Report File numbers 17-120556-LB
and 17-120557-LO, page 111.
7 Stephen J. King, Controller and PAO, Puget Sound Energy, Inc. “FERC Financial Report, FERC Form No. 1:
Annual Report of Major Electrical Utilities, Licensees and Others and Supplemental Form 3-Q: Quarterly Financial
Report” 2017/Q4, resubmitted 6/14/2019, 216.
4
Statement (EIS) for PSE’s proposed Energize Eastside Project.”8 We can see the cost for the EIS, which
may, or may not, have been included in the $54,634,345.00 spent by PSE by end of 2017.
It is clear that having spent over $69.5 million before permits are issued or any work has commenced, the
Energize Eastside cost estimates PSE has provided to Columbia Grid ($65 – 80 million or $110 million) are
not realistic. This level of expenditure at this stage of the project also raises serious questions about PSE’s
public cost projections of $100 - $300 million. The fact that the project may now be only 54% of its original
length, (8.78 miles, not 16 miles) makes the $69.5 million pre-permit expenditure even more questionable.
And none of these estimates consider the overall cost of the project over time, calculating the 9.8%
standard allowable profit (Return on Investment-ROI) discussed in Section 5, and likely to be approved by
the Washington Utilities and Transportation Commission (WUTC) once Energize Eastside is built.
8 City of Bellevue, Resolution 9297, August 7, 2017. https://bellevue.municipal.codes/BCC/RT
5
Figure 1A Evolution of Energize Eastside 2009-2012
A summary of the data contained in ColumbiaGrid’s Biennial Transmission Grid Expansion Plans and
mid-biennium updates
1Columbia Grid, 2009 Biennial Transmission Expansion Plan, (Approved by Columbia Grid Board of Directors, February 18, 2009), 70-71.
2Columbia Grid, 2010 Update to 2009 Biennial Transmission Expansion Plan, (Approved by Columbia Grid Board of Directors, February 17,2010), 62-
63
3Columbia Grid, 2011 Biennial Transmission Expansion Plan, (Approved by Columbia Grid Board of Directors, February 16, 2011), 53-54.
4Columbia Grid, 2012 Update to 2011 Biennial Transmission Plan, (Approved by Columbia Grid Board of Directors, February 15, 2012), 71-72.
Document 2009 PEFA Biennial Plan
Transmission 1
2010 Update 2 2011 Biennial Transmission
Expansion Plan 3
2012 Update 4
Project Name North King County
Capacity Increase
North King County
Capacity Increase
East King County
Transformer Capacity
“ “
Description A 230kV line between
Sammamish Substation
in North King County to
Talbot substation in
central King County.
The project would
involve rebuilding an
existing 115kV line to
230kV.
A 230kV line between
Sammamish Substation
in North King County to
Talbot substation in
central King County.
The project would
involve rebuilding an
existing 115kV line to
230kV.
This project involves
rebuilding the Sammamish-
Lakeside-Talbot 115kV line
to 230kV and installing a
new 230/115kV transformer
at Lakeside.
Rebuild the Sammamish-
Lakeside-Talbot 115kV
lines and energize one at
230kV and install a new
230/115kV transformer at
Lakeside
Sponsor PSE “ ““ ““ “
Parties Impacted In parallel w/Bonneville &
SCL w/impacts to the
Westside Northern
Intertie
“ “BPA, SCL, Northern Intertie “ “
Project Stage Blank Conceptual Project for
future need
Project Under Study Project Identified in
PSAST (Puget Sound
Area Study Team)
Expansion Plan
Project Commitment Level Blank Blank Committed Utilities negotiating cost
allocation
Scheduled Completion 2015-2017 “ ““ “2016
Cost Estimate Blank Blank $65-80M “ “
Project Need/Driver &
Other Notes
Increased capacity
across the Monroe-Echo
Lake cutplane for native
load and transmission
service.
Increased capacity
across the Monroe-Echo
Lake cutplane for native
load and transmission
service.
Additional transformation
capacity for east King
County to meet load
growth.
Load Service, Capacity
Increase, Reliability
Changes from Previous
Plan
Blank Blank Blank Blank
Type of Project Existing Obligation
Project
“ “Single System Project,
possible impacts
Single System Project
Study Team Puget Sound Area Study
Team
“ ““ ““ “
1
6
Document 2013 Biennial
Transmission
Expansion Plan 5
2015 Biennial Transmission
Expansion Plan 6
2016
Update 7
2017 Biennial
Transmission
Expansion Plan 8
2018 System
Assessment 9
Project Name “ “Eastside Project: Lakeside
230/115kV Transformer
and Sammamish-Lakeside-
Talbot Line Rebuilt to
230kV
“ ““ “
Description “ ““ ““ ““ ““ “
Sponsor “ ““ ““ ““ ““ “
Parties Impacted BPA, SCL “ ““ ““ “ not indicated
Project Stage “ ““ ““ ““ “not indicated
Project Commitment
Level
Utilities have
negotiated cost
allocation
“ ““ ““ “not indicated
Scheduled Completion 2017 2018 “ ““ “2020
Cost Estimate “ ““ ““ ““ “$110M
Project Need/Driver &
Other Notes
Load Service, Capacity
Increase, Reliability,
prevent curtailment of
firm transfers
“ ““ ““ “not indicated
Changes from Previous
Plan
Blank Delayed from 2017 Blank Blank not indicated
Type of Project “ ““ ““ ““ “not indicated
Study Team “ ““ ““ ““ “not indicated
2
5Columbia Grid, 2013 Biennial Transmission Expansion Plan, (Columbia Grid, February 2013), 83-84.
6Columbia Grid, 2015 Biennial Transmission Expansion Plan, (Columbia Grid, February 2015), 83-84.
7Columbia Grid, 2016 Update to the 2015 Biennial Plan, (Columbia Grid, February 2016), 79-80.
8Columbia Grid, 2017 Biennial Transmission Expansion Plan, (Columbia Grid, undated), 75-76.
9Columbia Grid, 2018 System Assessment, (Columbia Grid, September 2018), 50.
Figure 1B Evolution of Energize Eastside 2013-2018
A summary of the data contained in ColumbiaGrid’s Biennial Transmission Grid Expansion Plans and
mid-biennium updates
7
2. Cost of Project Over Time – Lifetime Cost Analysis
Puget Sound Energy’s website https://energizeeastside.com/faqs says the following about the total cost of the
project:
“Who will pay for the project and how much will it cost?
“Regular upgrades or additions to the electric infrastructure are shared by all of PSE’s
1.1 million customers and paid for over time. We don’t yet know the total cost of the
project but estimates range from $150 million to $300 million”.9
CENSE engaged Jeffrey King, a utility financing expert who worked as a Senior Resource Analyst for the
Northwest Power Planning Council for nearly 30 years, to analyze the lifetime cost of the project. At the
time of his analysis, the above estimates were not available. Mr. King used a placeholder of $100 million to
conduct the MicroFin Levelized Project Revenue Requirements model calculations. Details of this
calculation are available in the report “Estimation of the fixed charge rate and revenue requirements for the
proposed Energize Eastside transmission project”, February 10, 201610.
Mr. King stated that $100 million “is substantially greater than typical cost for a 230kV project of this size,
however the congested nature and environment of the proposed corridor will likely increase construction
cost well above typical costs.”11 Mr. King goes on to say, “Once construction cost estimates are available,
revenue requirements can be calculated by taking ratios of $100 million”12.
Another variable is the length of useful life. PSE estimates that the service life of transmission facilities will
range from 45 to 65 years.
Therefore, the total cost of the project to local ratepayers over time ranges from $579 million to
more than $2.4 billion, depending on the initial total cost and useful life. See Table 1.
9 PSE. “Who will pay for the project and how much will it cost?” PSE. Access date, December 19, 2018.
https://energizeeastside.com/faq/who-will-pay-for-the-project-and-how-much-will-it-cost
10 Jeffrey King, “Estimation of the fixed charge rate and revenue requirements for the proposed Energize Eastside
transmission project”, February 10, 2016, p. 4-7.
11 Ibid., p.2
12 Ibid., p.2
8
Table 1 Estimated Annual and Lifetime Revenues of Energize Eastside*
CASE Annual Revenue Lifetime Revenue
100 MM overnight cost; 45-year useful life $12,869,000.00 $579,105,000.00
100 MM overnight cost; 55-year useful life $12,622,000.00 $694,210,000.00
100 MM overnight cost; 65-year useful life $12,505,000.00 $812,825,000.00
200 MM overnight cost; 45-year useful life $25,738,000.00 $1,158,210,000.00
200 MM overnight cost; 55-year useful life $25,244,000.00 $1,388,420,000.00
200 MM overnight cost; 65-year useful life $25,010,000.00 $1,625,650,000.00
250 MM overnight cost; 45-year useful life $32,172,500.00 $1,447,762,500.00
250 MM overnight cost; 55-year useful life $31,555,000.00 $1,735,525,000.00
250 MM overnight cost; 65-year useful life $31,262,500.00 $2,032,062,500.00
300 MM overnight cost; 45-year useful life $38,607,000.00 $1,737,315,000.00
300 MM overnight cost; 55-year useful life $37,866,000.00 $2,082,630,000.00
300 MM overnight cost; 65-year useful life $37,515,000.00 $2,438,475,000.00
*Revenues based on initial cost of investment.
If Energize Eastside is built, PSE is virtually assured of receiving WUTC approval for the 9.8% annual
return. In public testimony before the Bellevue City Council, Mr. Mark Vasconi, WUTC Director of
Regulatory Services, stated that he was unaware of any situation in which the WUTC had questioned a
utilities’ request for reimbursement of investment13.
13 City of Bellevue, City Council, Summary Minutes of Study Session, July 7, 2014, p.5.
9
3. Cost of Alternatives
PSE original estimates
In 2015 PSE contracted for a report entitled, “Eastside System Energy Storage Alternatives Screening
Study”, written by Strategen Consulting, LLC. The report concluded, not surprisingly, that based on PSE’s
inflated needs-paradigm, all of the studied alternatives either cost far more than PSE’s preferred pole and
wire configuration or were limited in scope to eliminating only emergency overload situations, and thus
didn’t meet the pre-set requirements. PSE’s low-ball estimates, given the $54 Million spent to date,
exaggerate the cost differences.
Table 2 Energy Storage Configuration Summary14
In 2018, Strategen produced the “Eastside System Energy Storage Alternatives Assessment Report
Update – September 2018,” likely to counter mainstream and industry media reports of battery storage
costs falling rapidly in recent years. The technical details of the various scenarios will be discussed in the
Section 6 of this document. Strategen’s updated cost estimates for battery storage ranged from a low of
$824 Million to a high of $1.455 Billion intending to make the Energize Eastside look like a good deal at an
estimated cost of $150 – $300 Million.
As PSE has now substantially changed the scope of the project to the 8.78 miles between Talbot Hill and
Lakeside Substations any cost estimates previously made for alternatives are meaningless. A new analysis
and cost estimate are necessary to make an informed decision.
14 Mark Higgins, Jim Eyer, Randy Fish, Strategen Consulting, LLC. “Eastside System Energy Storage Alternatives
Screening Study” 2015, 20.
http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/eastside_system_energy_storage_alternatives_screen
ing_study_march_2015.pdf
10
CENSE estimates: alternatives costs decreasing
The technical possibilities for alternative solutions are presented in CENSE consultant EQL’s report in
Section 6 of this document. We do know that costs for alternatives such as battery storage, demand
response and smart grid solutions are decreasing.15 There are many additional sources in the Appendices
to document this trend. In fact, a major planned transmission line between NW Oregon and SW
Washington was canceled in 2017, in favor of “non-wire alternatives, grid management, and energy
storage”16, to quote BPA Administrator and CEO Elliot Mainzer, “embracing a more flexible, scalable, and
economically and operationally efficient approach.”17
Comparing the cost for alternatives is now impossible, because PSE has moved the goalposts in
anticipating a much smaller project, the 8.78-mile Talbot Hill/Lakeside Transmission Line. Not only do we
not have a cost estimate for the shorter project, we have no analysis of or cost estimates for any possible
alternatives.
4. Who Pays for Energize Eastside?
The simple answer is: The costs will be “shared” by all of PSE’s 1.1 million customers18, and paid for over
time, as we have seen in Jeffrey King’s analysis above.
PSE’s shifting explanations are documented by Russell Borgmann in his paper, “Who Pays for Energize
Eastside?”19:
1. “<From PSE’s website from 2014 until August 2016> “Who will pay for Energize Eastside and how
much will it cost? Upgrades or additions to the electric infrastructure are shared by all of PSE’s 1.1
million customers and paid for over time. We don’t yet know the total cost of the project, but
estimates range from $150 million to $300 million. We expect approximately $1 to $2 of the
average monthly bill for residential customers will go towards paying for Energize Eastside.
2. <From PSE’s website from 2014 until August 2016>“Once we determine the final design and
alignment, we will have a better idea of the total cost.”
3. <From PSE’s website, changed in August 2016> “Who will pay for Energize Eastside and how
much will it cost? Regular upgrades or additions to the electric infrastructure are shared by all of
15 Bloomberg NEF, Tumbling Costs for Wind, Solar, Batteries Are Squeezing Fossil Fuels,
https://about.bnef.com/blog/tumbling-costs-wind-solar-batteries-squeezing-fossil-fuels/ , March 28, 2018.
16 Robert Walton, Utility Dive, “BPA turns to non-wire alternatives in cancellation of transmission project”,
https://www.utilitydive.com/news/bpa-turns-to-non-wire-alternatives-in-cancellation-of-transmission-project/443125/ ,
May 19, 2017.
17 Ibid.
18 https://energizeeastside.com/faq/who-will-pay-for-the-project-and-how-much-will-it-cost screenshot 1-5-18.
19 Borgmann, Russell, “Who Pays for Energize Eastside?” March, 2018
11
PSE’s 1.1 million customers and paid for over time. We don’t yet know the total cost of the project,
but estimates range from $150 million to $300 million. Once we determine the final design and
alignment, we will have a better idea of the total cost. We don’t expect customers will see any
changes in their monthly bill to pay for this project.”
https://energizeeastside.com/faqs (screenshots exist of PSE’s older website pages)
4. <From PSE’s recent Energize Eastside flyer received in the mail, 8/11/2017> “How will Energize
Eastside affect rates? Customers will not see an increase in their monthly bill as a direct
result of Energize Eastside. That’s because PSE’s annual capital budget, which funds
infrastructure upgrades is already included in customer rates.”
5. <From PSE’s Docket Nos. ER12-778-000 and EL12-46-000, dated February 14, 2013> “3. Cost of
Capital/Return on Equity: The Settlement describes the Parties’ agreement that PSE shall be
entitled to earn a return on equity (“ROE”) of 9.8% on its transmission rate base, except that with
respect to those transmission facilities identified in the Memorandum of Agreement
between BPA, PSE, and Seattle City Light (BPA Contract No. 11TX-15450) dated January 31,
2012 (“PSANI Facilities”), PSE shall be entitled to an ROE of 10.3%. The ROE provisions of the
Settlement reflect a downward negotiation from the 10.6% ROE originally requested by PSE
in its January 6 Filing. The higher equity return for the PSANI Facilities is reflected in Attachment
7 of the Formula Rate Template attached to the Settlement as Exhibit A. The Settlement also
provides that the equity component of PSE’s capital structure will be capped at 50%.”
http://www.oatioasis.com/PSEI/PSEIdocs/Formula_Rate_Settlement_Package.pdf
6. <From communications with the WA Assistant Attorney General, Public Counsel Unit Chief, dated
September 20, 2017> “…The Utilities and Transportation commission does not pre-approve utility
projects – in other words, ratepayers do not pre-pay for projects. Utilities must first make the
investment, seek rate recovery, prove prudence, then ratepayers pay for the project. It is my
understanding that Energize Eastside is still in the planning phase and has not yet been built….If
the transmission project is built and determined prudent, the amount invested will be included in
rates and all customers will pay for it in rates….In many respects we are a reactionary party – we
react to proposals brought before the Commission by the utilities.”20
Mr. Borgmann further explains there are many unanswered questions about by whom, how and when
Energize Eastside will be paid for:
7. <From the August 2017 mailing from PSE> PSE is leading customers to believe that their rates will
not increase. In fact, their statements lead ratepayers to believe they are already paying for
Energize Eastside. (see #3: “…already included in customer rates…”)
20 Ibid.
12
Statement #4 sounds like PSE may have already pre-negotiated a ROE on Energize Eastside of
10.3% as far back as 2013. The Memorandum of Agreement (MOA) between BPA, PSE, and
Seattle City Light discusses Energize Eastside (nee: Sammamish to Lakeside to Talbot Rebuild
Project and Lakeside 230 kV Transformer Addition Project).
http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/2015-06-01_moa_with_bpa-seattlecitylight-
pse.pdf
Are ratepayers already paying for Energize Eastside when the final EIS was just issued in March 2018? Are
ratepayers already paying for Energize Eastside when the City of Bellevue (lead SEPA agency) has not yet
issued permits? Are ratepayers already paying for Energize Eastside when PSE has not yet applied for
permits on the Northern Segment (Lakeside substation north to Redmond)? Are customers paying for a
project that has not yet gone through a prudency review by the WUTC?”21
And the biggest question of all: Why does PSE find it necessary to offer many different and misleading
answers to a very simple question: Who will pay for Energize Eastside?
Again, the answer is simple. PSE’s 1.1 million ratepayers will pay. The cost will be hidden away, it may not
be noticed, but it will be paid.
5. Conclusion
The estimated costs of Energize Eastside as presented to Columbia Grid even as recently as 2018 are
outdated, vastly understated and do not match what PSE is telling the public and the city councils being
asked to approve this project. As of December, 2018, PSE has spent over $69.5 million on Energize
Eastside. The total cost of Energize Eastside may well exceed PSE’s high-end estimate of $300 million,
made over 4 years ago. A promised update on costs has not been forthcoming. PSE has, over time, given
different and misleading answers about who will pay for the project. Now, on the eve of permitting, PSE is
anticipating a much smaller project. PSE should be required to provide updated information on both
expenditures to date and a cost estimate for the shorter, 8.78-mile Talbot Hill/Lakeside Transmission line
project, including the proposed Richards Road Substation. A permit should not be granted and citizens
should not be obligated to pay for a project for which no one knows the price tag.
21 Ibid.
1
SECTION 5: INTRODUCTION
Rebuttal to PSE’s Assertions
PSE justifies the need for Enegize Eastside by forecasting an annual growth of peak demand of 2.4%.
However there is insufficient data to support this conclusion. PSE refused multiple requests for the
substation peak-load data necessary to document the actual annual growth rate of annual peak demand on
the Eastside.
PSE claims its load flow studies prove that the project would provide reliable electricity. However, the
studies are based on assumptions that far exceed the Transmission Planning requirements of the North
American Electric Reliability Corp (NERC). Therefore, the load flow studies do not realistically demonstrate
that the project is needed for electrical reliability on the Eastside. In addition, the load flow studies on which
the project is based are over five years old, beyond the NERC requirement for updated studies, and NO
load flow studies have been conducted using data for only the South Segment of the proposed project.
PSE mounted an expensive and aggressive public relations campaign to sell Energize Eastside. The ads
are filled with half-truths that raise fear about the adequacy of our electrical grid for future needs.
Table of Contents
5.1 Needs and Costs of Energize Eastside
Robert McCullough, Expert Witness
5.2 Analysis Needed for Project Alteration
Rick Austria, Principal, Pterra Consulting
5.3 How PSE is Selling Energize Eastside
Jan Medley, Russell Borgman - CENSE
5.4 Community Advisory Group (CAG) Dissenting Report
M CCULLOUGH R ESEARCH
ROBERT F. MCCULLOUGH, JR.
PRINCIPAL
Date: January 7, 2020
To: Rick Aramburu
From: Robert McCullough
Subject: Needs and Costs of Energize Eastside
Since 2009 the transmission project known variously as the “North King County Capacity
Increase” (2009), “Sammamish-Lakeside-Talbot Sensitivity” (2010), “Eastside
Transmission Project” (2014-2017), “Lakeside 115 KV Transmission Project” (2014),
“Lakeside Project” (2013), “Lakeside Substation Project” (2012), and since 2013,
“Energize Eastside” has spent $69,530,354 on planning and public relations.1,2 In spite of
the multiplicity of names and corresponding studies, actual details remain sketchy.
Specifically, data on the need for the project and its costs are difficult to find.
More recently, in August 2017, the configuration of this long-awaited project was entirely
changed.3 The new project, the “Talbot Hill/Lakeside Transmission Line”, is now
proposing to replace the “Energize Eastside” proposal with a less ambitious plan that will
only construct 8.8 miles of the original 16 miles originally considered. In February of this
year PSE stated:
“PSE has not completed an application for the transmission line segment
running from the proposed Richards Creek substation north and cannot
accurately estimate the timing of the timing of this submittal until additional
work permitting the Project’s south half is complete.”4
1 2018 Puget Sound Energy FERC Form 1, page 216.
2 $69,530,354 is the figure as of December 31, 2018. A reasonable forecast to year end 2018 would exceed
$75 million.
3 “Progress on Energize Eastside continues with PSE submitting its first permit application to the City of
Bellevue. PSE plans to build and energize the new Richards Creek substation in Bellevue and upgrade the
existing transmission lines in south Bellevue, Newcastle and Renton by the summer of 2018.
Permit applications for the rest of the southern portion of the project in Newcastle and Renton will be
submitted this fall. After that, PSE anticipates submitting permit applications for the northern portion in
Bellevue and Redmond in late 2017 – early 2018.”
https://energizeeastside.com/news, September 18, 2017.
4 Declaration, Daniel Koch, PSE, February 11, 2019.
6123 REED COLLEGE PLACE ● PORTLAND ● OREGON ● 97202 ● 503-777-4616 ● ROBERT@MRESEARCH.COM
M CCULLOUGH RESEARCH
Needs and Costs of Energize Eastside
January 7, 2020
Page 2
For newcomers to electric transmission planning, this seems like a minor adjustment. If a
building is too tall for local zoning standards, a developer can simply agree to build a
building half as tall without refiling the various plans and applications. This is a reasonable
solution in almost all land use cases.
Electric transmission is entirely different. Planning studies in electric transmission
planning must be undertaken on a system level. This is due to the physics of electricity
transmission. While the line itself can be easily plotted on a map, the actual flows often
diverge significantly from our geographic intuitions. This reflects two factors: First, the
flows of electricity are not contract paths, but the results of flows across the entire grid. A
specific line may well have implications on neighboring lines – or even lines at some
distance. Electrons are notoriously uninterested in contracts since they follow the path of
least resistance. Second, contingencies on the system are very different when the line’s
proposed path changes. The new Talbot Hill/Lakeside Transmission Line will be less
vulnerable to contingencies from the north – specifically since it will no longer connect to
the north.
In practice this means that the vintage studies performed in 2012, 2013, and 2015 are no
longer pertinent to the project under discussion and would not be regarded as appropriate
in normal planning discussions.5,6,7,8
Since electrons do not follow maps, the coincidence that part of the new Talbot
Hill/Lakeside Transmission Line coincides with the previously proposed project is not
relevant since electrons may trace entirely different paths under the newly proposed
configurations. This is exacerbated by the fact that all evidence available in state and
federal filings of Puget Sound Energy clearly indicates that the assumed peak loads have
not materialized – and overall electric peak loads on their system are declining.
It is a truism of investor owned utility planning that as the sums increase in the construction
work in progress accounts, defense of the project becomes financially more and more
important. In this case, requests for updated data has been rejected more and more
forcefully as time progresses. The most recent requests for relevant load data have been
refused on the ground that the summary data might expose individual consumer data.9
5 City of Bellevue Electrical Reliability Study Phase 2 Report, Exponent, February 2012.
6 Eastside Needs Assessment Report, Quanta Technology, October 2013.
7 Supplemental Eastside Needs Assessment Report, Quanta Technology, April 2015.
8 Independent Technical Analysis of Energize Eastside, Utility System Efficiencies, April 28, 2015.
9 Marshall, George. Re: CEII Requests dated June 9,2018 and July 8,2018 September 19, 2018.
M CCULLOUGH RESEARCH
Needs and Costs of Energize Eastside
January 7, 2020
Page 3
When the project commenced in 2010, Puget Sound Energy forecasted overall peak loads
for 2017 as 5,843 MW.10 The actual winter peak load in 2017 was 4,206 MW.11 If, as there
is every reason to believe, the lack of load growth over the past decade (and the most recent
forecast indicating a lack of load growth for the next decade) makes the need for a major
infrastructure project on the eastside both speculative and premature.12
Need for the project has changed considerably over the past eight years. Initially, a
significant focus was on the need to deliver the Canadian Entitlement. This shows up in
the documentation available at ColumbiaGrid, a planning body that represents a variety of
pacific Northwest utilities – including Puget Sound Energy.
The focus on the Canadian Entitlement is a bit odd given that British Columbia, the
recipient of the Canadian Entitlement under an agreement dating from 1964, had rejected
depending on U.S. supplies in legislation enacted in 2005.13,14,15
As British Columbia Hydro testified a year ago at the British Columbia Utilities
Commission:
Canadian Entitlement to the Down Stream Benefits under the Columbia
River Treaty: The Canadian Entitlement has been eliminated as an
alternative resource both due to the legislated self-sufficiency requirement
but also given current negotiations between Canada and the US, the current
energy reliance and limited firm transmission availability through the I5
corridor to BC.16
17
BC Hydro has not explicitly relied upon the Canadian Entitlement (CE) to
the Down Stream Benefits (DSBs) under the Columbia River Treaty (CRT)
in developing the portfolios used in this application (except for a short term
bridging or contingency resource). BC Hydro does not believe the CE to be
an appropriate resource to rely upon in its portfolio development for the
following reasons:
10 2009 IRP Addendum, page 8.
11 2017 Puget Sound Energy FERC Form 1, page
12 2019 IRPAG Meeting #2, PSE, August 28, 2018, page 24.
13 McCullough, Robert. Comments on Commission Alternative Resource Portfolios BCUC Site C Inquiry
testimony F35-21, October 18, 2017, page 4.
14 U.S. Benefits from the Columbia River Treaty – Past, Present and Future: A Province of British Columbia
Perspective BC Ministry of Energy and Mines, June 25, 2013. Page 8.
15 Canadian Entitlement, U.S. Entity, April 2013, page 2.
16 BC Hydro Submission to the British Columbia Utilities Commission Inquiry into the Site C Clean
Energy Project, August 30, 2017, page 60.
17 Ibid., Appendix L, page 4.
M CCULLOUGH RESEARCH
Needs and Costs of Energize Eastside
January 7, 2020
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1. The Clean Energy Act requires that BC Hydro be self-sufficient for
energy and capacity by being able to supply mid-level load forecasts
planning to average water from heritage hydro contracted with or own;18
Given British Columbia’s 2005 Clean Energy Act and the ongoing renegotiation of the
Columbian Entitlement, the need for this transmission line to carry energy and capacity
north has been quietly dropped. Even more importantly, the plan to build the transmission
line in stages would make wheeling to Canada over the line impossible.19
This conclusion was underscored by the response to concerns over the use of the line to
wheel the Canadian Entitlement:
As described in the Phase I Draft EIS, transmission of electrical power
outside of PSE' s service territory is not an objective of the project.20
The Canadian Entitlement is one of a number of issues currently under negotiation between
the United States and British Columbia Hydro. The economics of BC Hydro’s new 1,100
MW “mega-dam” at Site C depends on exports to the United States making the prospects
of new imports from the U.S. even more remote.
In recent years, the eastside transmission project has relied on forecasts showing that rapid
growth will create the required need for the project. The Final EIS comments favorably on
the dated studies that use these forecasts:
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.21
The EIS response has missed the point. Even if the studies are well prepared, their
relevance is severely limited when the assumptions used in them have become obsolete.
PSE’s original needs assessment utilized forecasts from 2012.22
Rapid changes in the electric industry have rendered older load forecasts obsolete. The
following chart shows PSE’s official load forecasts against actuals for the past decade:
18 Ibid., Appendix L, page 49.
19 As noted earlier, the remote possibility that changes in British Columbia law and integrated resource
plans might change to include imports from the U.S. would not be relevant to a line that terminates half-
way.
20 Final EIS Appendix J Phase 1 Comments & Responses, March 2018, Page Jl-10.
21 Ibid., page J1-16.
22 Eastside Needs Assessment Report, October 2013, page 7.
M CCULLOUGH RESEARCH
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23
These charts are referred to as “porcupine charts” since the older forecasts stand out like a
porcupine’s quills. The blue boxes represent actual peak data. This is the “body” of the
porcupine. Puget Sound Energy’s actual peaks are declining over time. The dotted line that
decreases over time shows a simple statistical model of Puget’s decline in peak loads.
As can be seen clearly from “quills” of the porcupine, PSE’s peak load forecasts have fallen
sharply over the transmission project’s ten-year life. When the project was first originated,
PSE expected its capacity loads to be 39% higher than the actual peak experienced in the
winter of 2017/2018. Not only have the assumed growth rates for capacity been
unrealistically high, but the actual trend in actual peaks has been negative:
23 Sources for this chart are the PSE IRPs for 2009 through the preliminary materials for 2019. Actual
peaks are from the PSE FERC Form 1s and from the 2018 Form 3-Qs. The fourth quarter of 2018 has been
interpolated from EIA-930 reports.
8,500
8,000
7,500
7,000
6,500
6,000
5,500
5,000
4,500
4,000
53386
y = - MW Actual Peak 2009 2011
2012 2013 2014
2015 2017 2019
Linear (Actual Peak)
M CCULLOUGH RESEARCH
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PSE’s most recent preliminary forecasts released in the advisory committee for the 2019
Integrated Resource Plan effectively estimate no growth rate for the next decade:
Act
Percentage Growth Per Annum
M CCULLOUGH RESEARCH
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January 7, 2020
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24
The load forecasts used in the studies cited in the EIS response are now obsolete. These
older forecasts were used to establish the need for the transmission project.
Reductions in peak loads are now common in the industry. Seattle City Light --Puget Sound
Energy’s closest neighbor sharing similar weather and demographics – has just issued a
new load forecast showing peak load reduction far into the future:
24 2019 IRPAG Meeting #2, PSE, August 28, 2018, page 24.
M CCULLOUGH RESEARCH
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25
Overall, substantial evidence exists that the high growth scenarios presented in early
integrate resource plans did not materialize.
PSE’s continued enthusiasm for this project is more likely to be explained by costs and
their regulatory treatment than engineering.
The cost of Energize Eastside is a mystery. In the beginning, PSE indicated that the project
had a price tag of $70 million.26 For some years, PSE has indicated that the costs are
between $150 and $300 million. 27,28
25 2018 Progress Report, Seattle City Light, September 4, 2018, Page 10.
26 2013 Biennial Transmission Expansion Plan, ColumbiaGrid, February 2013, page 6.
27 “We don’t yet know the total cost of the project, but estimates range from $150 million to $300 million.”
https://energizeeastside.com/faq/who-will-pay-for-the-project-and-how-much-will-it-cost
28 “[Willow] is the least expensive ($154 million total cost; $0.90 estimated monthly increase to an average
residential customer)”, PSE Energize Eastside Community Advisory Group Final Report, January 2015,
page 22.
M CCULLOUGH RESEARCH
Needs and Costs of Energize Eastside
January 7, 2020
Page 9
Utilities are usually very good at cost estimation. A whole industry has grown up around
the estimation and control of construction costs. The “Critical-Path Method” was
introduced in a 1959 article published in 1959 Proceedings of the Eastern Joint Computer
Conference.29 It represented a significant application of the mathematical programming
and computer developments pioneered in the Manhattan Project during the Second World
War. A common tool in the industry to implement this approach is software named
Primavera. This program assembles the relevant data and helps the engineers develop a
logical construction schedule as well as detailed cost estimates.
It is not credible that eight years into the project has been able to use standard industry
tools to generate solid cost estimates.
While we do not know the cost of the project, we can track the project from the
Construction Work in Progress (CWIP) accounting contained in PSE’s FERC Form 1s:
The most recent ColumbiaGrid report indicates an in-service date of 2020 with an
instantaneous cost of $110 million:
29 The term was coined by James Kelley and Morgan Walker in the 1950s and first published in their jointly
authored article: Critical-Path Planning and Scheduling 1959 Proceedings of the Eastern Joint Computer
Conference, pages 160-173.
Eastside Energize
M CCULLOUGH RESEARCH
Needs and Costs of Energize Eastside
January 7, 2020
Page 10
30
At this point, PSE has a $110 million incentive to proceed with the project whether it is
needed or not. When completed, PSE can submit the costs to the Washington Utilities and
Transportation Commission for reimbursement from rate payers – including those in
Renton.
30 2018 System Assessment, ColumbiaGrid, September 2018, page 60.
Robert McCullough – Curriculum Vitae
Principal
McCullough Research, 3816 S.E. Woodstock Place, Portland, OR 97202 USA
Professional Experience
1985-present Principal, McCullough Research: provide strategic planning
assistance, litigation support, and planning for a variety of
customers in energy, regulation, and primary metals
1996-present Adjunct Professor, Economics, Portland State University
1990-1991 Director of Special Projects and Assistant to the Chairman of
the Board, Portland General Corporation: conducted special
assignments for the Chairman in the areas of power supply,
regulation, and strategic planning
1988-1990 Vice President in Portland General Corporation’s bulk power
marketing utility subsidiary, Portland General Exchange:
primary negotiator on the purchase of 550 MW transmission
and capacity package from Bonneville Power Administration;
primary negotiator of PGX/M, PGC’s joint venture to
establish a bulk power marketing entity in the Midwest;
negotiated power contracts for both supply and sales;
coordinated research function
1987-1988 Manager of Financial Analysis, Portland General Corporation:
responsible for M&A analysis, restructuring planning, and
research support for the financial function; reported directly
to the CEO on the establishment of Portland General
Exchange; team member of PGC’s acquisitions task force;
coordinated PGC’s strategic planning process; transferred to
the officer’s merit program as a critical corporate manager
1981-1987 Manager of Regulatory Finance, Portland General Electric:
responsible for a broad range of regulatory and planning areas,
including preparation and presentation of PGE’s financial
testimony in rate cases in 1980, 1981, 1982, 1983, 1985, and
1987 before the Oregon Public Utilities Commission;
responsible for preparation and presentation of PGE’s
wholesale rate case with Bonneville Power Administration in
1980, 1981, 1982, 1983, 1985, and 1987; coordinated activities
at BPA and FERC on wholesale matters for the InterCompany
Pool (the association of investor-owned utilities in the Pacific
Northwest) since 1983; created BPA’s innovative aluminum
tariffs (adopted by BPA in 1986); led PGC activities, reporting
directly to the CEO and CFO on a number of special activities,
including litigation and negotiations concerning WPPSS, the
Northwest Regional Planning Council, various electoral
initiatives, and the development of specific tariffs for major
industrial customers; member of the Washington Governor’s
Task Force on the Vancouver Smelter (1987) and the
Washington Governor’s Task Force on WPPSS Refinancing
(1985); member of the Oregon Governor’s Work Group On
Extra-Regional Sales (1983); member of the Advisory
Committee to the Northwest Regional Planning Council
(1981)
1979-1980 Economist, Rates and Revenues Department, Portland
General Electric: responsible for financial and economic
testimony in the 1980 general case; coordinated testimony in
support of the creation of the DRPA (Domestic and Rural
Power Authority) and was a witness in opposition to the
creation of the Columbia Public Utility District in state court;
member of the Scientific and Advisory Committee to the
Northwest Regional Power Planning Council
Economic Consulting
2018 – present Expert witness in West Moberly v British Columbia
2018 Advisor of a landowner in solar project development
2018 Expert witness for NCEMC
2017 – present Advisor to the Coalition of East Side Neighborhoods on
proposed Seattle area transmission
2017-2019 Advisor to Enpex on power contract litigation
2017-present Advisor to North Pacific Paper Corporation (NORPAC) on
power contracts and business strategy
2017 Advisor to Peace Valley Landowners Association on Site C
2016-2017 Expert witness to the U.S. Department of Justice on nuclear
rate case
2016-present Advisor to the City of Logansport on utility project
development and decision-making
2016 Expert testimony for Gratl and Company before the Supreme
Court of British Columbia on costs of Site C project delay
2015-present Advisor to Huu-ay-aht tribe on Sarita Bay LNG project in
British Columbia
2015-2017 Analysis and expert testimony for Illinois Attorney General in
official FERC complaint against MISO
2015-present Advisor to Calbag Metals on generation project
2015-2016 Advisor to Oregon Department of Justice in the investigation
of taxes owed the state by Powerex Corp.
2015 Economic analysis of the proposed 1100 MW hydro project,
Site C, for the Peace Valley Landowner Association
2014-2015 Market analysis of the NYISO for the New York State
Assembly
2014 Advisor to the Grand Council of the Cree on uranium mining
in Quebec
2014-2018 Support for the investigation of Barclays Bank
2013-2018 Retained to do a business case analysis of the Columbia
Generating Station by the Physicians for Social Responsibility
2013 Advisor to Environmental Defense Fund on gasoline and oil
issues in California
2013 Advisor to Energy Foundation on Ohio competitive issues
2013 Export market review in the Maritime Link proceeding
2011 Consultant to Citizens Action Coalition of Indiana on Indiana
Gasification LLC project
2010 Analysis and expert witness testimony for Block Island
Intervenors concerning Deepwater offshore wind project
2010 Analysis for Eastern Environmental Law Center of 25 closed
cycle plants in New York State
2010 Advisor on BPA transmission line right of way issues
2009-2010 Advisor to Gamesa USA on a marketing plan to promote a
wind farm in the Pacific Northwest
2009-2010 Expert witness in City of Alexandria vs. Cleco
2009 Expert witness in City of Beaumont v. Entergy
2008-2009 Consultant to AARP Connecticut and Texas chapters on the
need for a state power authority (Connecticut) and balancing
energy services (Texas)
2008 Expert witness on trading and derivative issues in Barrick Gold
litigation
2008-2014 Advisor to Jackson family in Pelton/Round Butte dispute
2007-2014 Advisor to the American Public Power Association on
administered markets
2006-present Advisor to the Illinois Attorney General on electric
restructuring issues
2006-2007 Advisor to the City of Portland in the investigation of Portland
General Electric
2006 Expert witness for Lloyd’s of London in SECLP insurance
litigation
2005-2007 Expert witness for Federated Rural Electric Insurance
Company and TIG Insurance in Cowlitz insurance litigation
2005-2007 Advisor to Grays Harbor PUD on market manipulation
2005-2007 Advisor to the Montana Attorney General on market
manipulation
2005-2006 Expert witness for Antara Resources in Enron litigation
2005-2006 Advisor to Utility Choice Electric
2004-2005 Expert witness for Factory Mutual in Northwest Aluminum
litigation
2004 Advisor to the Oregon Department of Justice on market
manipulation
2003-2006 Expert witness for Texas Commercial Energy
2003-2004 Advisor to The Energy Authority
2002-2005 Advisor to the U.S. Department of Justice on market
manipulation issues
2002-2004 Expert witness for Alcan in Powerex arbitration
2002-2003 Expert witness for Overton Power in IdaCorp Energy
litigation
2002-2003 Expert witness for Stanislaus Food Products
2002 Advisor to VHA Pennsylvania on power purchasing
2002 Expert witness for Sierra Pacific in Enron litigation
2002-2004 Advisor to U.S. Department of Justice
2002-2007 Expert witness for Snohomish PUD in Enron litigation
2002-2010 Expert witness for Snohomish in Morgan Stanley
investigation
2001-2008 Expert witness for City of Seattle, Seattle City Light and City
of Tacoma in FERC’s EL01-10 refund proceeding
2001-2008 Advisor to VHA Southwest on power purchasing
2001-2005 Advisor to Nordstrom
2001-2005 Advisor to Steelscape Steel on power issues in Washington
and California
2001 Advisor to California Steel on power purchasing
2001 Advisor to the California Attorney General on market
manipulations in the Western Systems Coordinating Council
power markets
2000-2007 Expert witness for Wah Chang in PacifiCorp litigation
2000-2001 Expert witness for Southern California Edison in Bonneville
Power Administration litigation
2000-2001 Advisor to Blue Heron Paper on West Coast price spikes
2000 Expert witness for Georgia Pacific and Bellingham Cold
Storage in the Washington Utilities and Transportation
Commission’s proceeding on power costs
1999-2002 Advisor to Bayou Steel on alternative energy resources
1999-2000 Expert witness for the Large Customer Group in PacifiCorp’s
general rate case
1999-2000 Expert witness for Tacoma Utilities in WAPA litigation
1999-2000 Advisor for Nucor Steel and Geneva Steel on PacifiCorp’s
power costs
1999-2000 Advisor to Abitibi-Consolidated on energy supply issues
1999 Expert report for the Center Helios on Freedom of
Information in Québec
1999 Advisor to GTE regarding Internet access in competitive
telecommunication markets
1999 Advisor to Logansport Municipal Utilities
1998-2001 Advisor to Edmonton Power on utility plant divestiture in
Alberta
1998-2001 Energy advisor for Boise Cascade
1998-2000 Advisor to California Steel on power purchasing
1998-2000 Advisor to Nucor Steel on power purchasing and
transmission negotiations
1998-2000 Advisor to Cominco Metals on the sale of hydroelectric dams
in British Columbia
1998-2000 Advisor to the Betsiamites on the purchase of hydroelectric
dams in Québec
1998-1999 Advisor to the Illinois Chamber of Commerce concerning the
affiliate electric and gas program
1998 Intervention in Québec’s first regulatory proceeding on
behalf of the Grand Council of the Cree
1998 Market forecasts for Montana Power’s restructuring
proceeding
1997-2004 Expert witness for Alcan in BC Hydro litigation
1997-2003 Advisor to the Manitoba Cree on energy issues in Manitoba,
Minnesota and Québec; Advisor to the Grand Council of the
Cree on hydroelectric development
1997-1999 Advisor to the Columbia River Intertribal Fish Commission
on Columbia fish and wildlife issues
1997-1998 Advisor to Port of Morrow regarding power marketing with
respect to existing gas turbine plant
1997-1998 Expert witness for Tenaska in BPA litigation
1997 Advisor to Kansai Electric on restructuring in the electric
power industry (with emphasis on the California markets)
1996-1997 Bulk power purchasing for the Association of Bay Area Cities
1996-1997 Advisor to Texas Utilities on industrial issues
1996-1997 Expert witness for March Point Cogeneration in Puget Sound
Power and Light litigation
1996 Advisor to Longview Fibre on contract issues
1995-2000 Bulk power supplier for several Pacific Northwest industrials
1995-1999 Advisor to Seattle City Light on industrial contract issues
1995-1997 Advisor to Tacoma Utilities on contract issues
1995-1996 Expert witness for Tacoma Utilities in WAPA litigation
1994-1995 Advisor to Idaho Power on Southwest Intertie Project
marketing
1993-2001 Northwest representative for Edmonton Power
1993-1997 Expert witness for MagCorp in PacifiCorp litigation
1992-1995 Advisor to Citizens Energy Corporation
1992-1994 Negotiator on proposed Bonneville Power Administration
aluminum contracts
1992 Bulk power marketing advisor to Public Service of Indiana
1991-2000 Strategic advisor to the Chairman of the Board, Portland
General Corporation
1991-1993 Chairman of the Investor Owned Utilities’ (ICP) committee
on BPA financial reform
1991-1992 Financial advisor on the Trojan owners’ negotiation team
1991 Advisor to Shasta Dam PUD on the California Oregon
Transmission Project and related issues
1990-1991 Advised the Chairman of the Illinois Commerce Commission
on issues pertaining to the 1990 General Commonwealth Rate
Proceeding; prepared an extensive analysis of the bulk power
marketing prospects for Commonwealth in ECAR and MAIN
1988 Facilitated the settlement of Commonwealth Edison’s 1987
general rate case and restructuring proposal for the Illinois
Commerce Commission; reported directly to the Executive
Director of the Commission; responsibilities included financial
advice to the Commission and negotiations with
Commonwealth and interveners
1987-1988 Created the variable aluminum tariff for Big Rivers Electric
Corporation: responsibilities included testimony before the
Kentucky Public Service Commission and negotiations with
BREC’s customers (the innovative variable tariff was adopted
by the Commission in August 1987); supported negotiations
with the REA in support of BREC’s bailout debt restructuring
1981-1989 Consulting projects including: financial advice for the Oregon
AFL-CIO; statistical analysis of equal opportunity for Oregon
Bank; cost of capital for the James River dioxin review; and
economic analysis of qualifying facilities for Washington
Hydro Associates
1980-1986 Taught classes in senior and graduate forecasting, micro-
economics, and energy at Portland State University
Education
Unfinished Ph.D. Economics, Cornell University; Teaching Assistant in micro-
and macro-economics
M.A. Economics, Portland State University, 1975; Research
Assistant
B.A. Economics, Reed College, 1972; undergraduate thesis,
“Eurodollar Credit Creation”
Areas of specialization include micro-economics, statistics, and finance
Publications
March 21, 2019 “The End of Big Iron” The Public Utility Fortnightly
January 23, 2019 “The End of Big Hydro” The Lawyer’s Daily
December 26, 2017 “Taking the Path Less Followed”, Vancouver Sun
November 21, 2017 “Updating Bonneville’s Strategic Plan”
October 30, 2017 “Site C Proponents Fall Prey to Sunk Costs Fallacy”,
Vancouver Sun
August 22, 2017 “Lessons from Manitoba Hydro’s Financial Problems”
June 22, 2017 “Trump plan to sell BPA lines misguided”
April 11, 2017 “Affordable power or Site C power: British Columbia must
choose”
February 28, 2017 “My View: Trade tariffs would hurt Americans”, The Portland
Tribune
January 8, 2017 “Many lives of Jordan Cove may have come to an end”, The
Oregonian
July 22, 2016 “Balancing an aging Hanford nuke plant against cheaper firm
market power purchases”, The Oregonian
July 7, 2016 “More roads needed to handle growth”, The Portland Tribune
July 7, 2016 “Close the expensive Columbia Generating Station”, The
Oregonian
June 29, 2016 “Our future is in green energy, not aging, costly nuclear
plants”, The Seattle Times
May 12, 2016 “Diesel tax on heavy trucks is the right move”, The Portland
Tribune
May 2016 “Aspirational Planning: A Statistical Model of Hawthorne
Bridge and Tilikum Crossing Bicycle Ride Counts”, Hatfield
Graduate Journal of Public Affairs 1(1).
January 19, 2016 “A good time for a sensibly managed Portland gas tax”,
The Oregonian
October 15, 2015 “A plan to fix Portland's roads”, The Portland Oregonian
June 2015 “Estimating the Longevity of Commercial Nuclear Reactors”,
Public Utilities Fortnightly
December 2014 “Nuclear Winter”, Electricity Policy
July 2013 “Mid-Columbia Spot Markets and the Renewable Portfolio
Standard”, Public Utilities Fortnightly
April 14, 2013 “Selling Low and Buying High”, The Oregonian
December 2012 “Are Electric Vehicles Actually Cost-Effective?”, Electricity
Policy
November 30, 2012 “Portland’s Energy Credits: The trouble with buying ‘green’”,
The Oregonian
July 2009 “Fingerprinting the Invisible Hand”, Public Utilities Fortnightly
February 2008 Co-author, “The High Cost of Restructuring”, Public Utilities
Fortnightly
March 27, 2006 Co-author, “A Decisive Time for LNG”, The Daily Astorian
February 9, 2006 “Opening the Books”, The Oregonian
August 2005 “Squeezing Scarcity from Abundance”, Public Utilities Fortnightly
April 1, 2002 “The California Crisis: One Year Later”, Public Utilities
Fortnightly
March 13, 2002 “A Sudden Squall”, The Seattle Times
March 1, 2002 “What the ISO Data Says About the Energy Crisis”, Energy
User News
February 1, 2001 “What Oregon Should Know About the ISO”, Public Utilities
Fortnightly
January 1, 2001 “Price Spike Tsunami: How Market Power Soaked California”,
Public Utilities Fortnightly
March 1999 “Winners & Losers in California”, Public Utilities Fortnightly
July 15, 1998 “Are Customers Necessary?”, Public Utilities Fortnightly
March 15, 1998 “Can Electricity Markets Work Without Capacity Prices?”,
Public Utilities Fortnightly
February 1998 “Coping with Interruptibility”, Energy Buyer
January 1998 “Pondering the Power Exchange”, Energy Buyer
December 1997 “Getting There Is Half the Cost: How Much Is Transmission
Service?”, Energy Buyer
November 1997 “Is Capacity Dead?”, Energy Buyer
October 1997 “Pacific Northwest: An Overview”, Energy Buyer
August 1997 “A Primer on Price Volatility”, Energy Buyer
June 1997 “A Revisionist’s History of the Future”, Energy Buyer
Winter 1996 “What Are We Waiting for?” Megawatt Markets
October 21, 1996 “Trading on the Index: Spot Markets and Price Spreads in the
Western Interconnection”, Public Utilities Fortnightly
McCullough Research Reports
January 14, 2019 “The End of Big Iron: How Wind and Solar Became Cheaper
than Hydro, Coal, and Nuclear”
December 10, 2018 “Why Have PJM Capacity Markets Decoupled from Actual
Capacity Bids?”
April 20, 2018 “Privatizing BPA’s Assets and Liabilities”
April 12, 2018 “ASC 980 and the Decision to Complete Site C”
March 1, 2018 “Are Bitcoin Miners Suitable Electric Loads?”
February 14, 2018 “FY 2019 Update: Privatization of Bonneville Power
Administration’s Transmission Assets”
January 23, 2018 “Update of the CGS costs and implications”
November 21, 2017 “Updating Bonneville’s Strategic Plan”
November 16, 2017 “Response to Questions Posed by the Deputy Minister of
British Columbia What we have learned from the BCUC’s
Final Report”
November 2, 2018 “What we have learned from the BCUC’s Final Report”
October 23, 2017 “Site C Inquiry Situation Report”
October 10, 2017 “Problems with British Columbia Hydro’s F1.11 Response”
October 10, 2017 “Problems with British Columbia Hydro’s F1.8 Response”
October 10, 2017 “Problems with British Columbia Hydro’s F1.7 Response”
October 10, 2017 “Problems with British Columbia Hydro’s F1.6 Response”
October 2, 2017 “Our answer to BC Hydro’s question 16”
October 2, 2017 “Our answer to BC Hydro’s question 20”
September 28, 2017 “A reflection on sunk costs”
September 28, 2017 “Our answer to BC Hydro’s questions 46 and 47”
September 24, 2017 “Our answer to BC Hydro’s question 22”
September 21, 2017 “British Columbia Utilities Commission’s Preliminary
Findings”
September 13, 2017 “What we have learned about Site C”
September 11, 2017 “Deloitte LLP’s Two Site C Reports”
August 22, 2017 “Lessons from Manitoba Hydro’s Financial Problems”
June 13, 2017 “Privatization of Bonneville Power Administration’s
Transmission Assets”
May 8, 2017 “Response to Public Power Council staff comments on
replacing the Columbia Generating Station with lower cost
renewables”
April 3, 2017 “Who actually pays for the Columbia Generating Station?”
February 15, 2017 “Replacing the Columbia Generating Station with Renewable
Energy”
November 14, 2016 “Review of ‘Economic Analysis of Proposed Changes to the
Single Dwelling Zone Development Standard’”
October 5, 2016 “The Falling Price of Renewable Energy Relative to
Conventional Generation”
October 3, 2016 “Statistical Evidence on the Increase in Portland Home
Values Correlated with Historic Districts”
September 5, 2016 “Why are House Prices so high in the Portland Metropolitan
Area?”
July 8, 2016 “Historic District Econometric Literature Review”
June 21, 2016 “Columbia Generating Station (CGS) Market Update”
November 19, 2015 “Market Cost of the Columbia Generating Station During the
FY 2014/2015 Refueling Cycle”
September 30, 2015 “Decrypting New York’s “Secret” Electric Bids”
September 9, 2015 “Market Power in West Coast Gasoline Markets: September
Update”
September 8, 2015 “August 10, 2015 PADD 2 Gasoline Spike at BP Whiting’s
Pipestill 12”
July 23, 2015 “Market Power in West Coast Gasoline Markets: July Update”
June 23, 2015 “Market Power in West Coast Gasoline Markets: June Update”
May 25, 2015 “Site C Business Case Assumptions Review”
April 7, 2015 “2015 Paducah Update”
April 6, 2015 “Market Power in West Coast Gasoline Markets: April
Update”
March 23, 2015 “Market Power in West Coast Gasoline Markets”
March 20, 2015 “Daniel Poneman and the Paducah Transaction”
January 2, 2015 “Data and Methodological Errors in the Portland Commercial
Street Fee”
December 15, 2014 Report to the Bureau d’audiences publiques sur l’environment
(BAPE), “Uranium Mining in Quebec: Four Conclusions”
February 11, 2014 “Energy Northwest's Revised Analysis of the Paducah Fuels
Transaction”
January 25, 2014 “Energy Northwest Losses in the 2013 Forward Purchase of
Nuclear Fuel”
January 2, 2014 “Review of the November 2013 Energy Northwest Study”
December 11, 2013 “Economic Analysis of the Columbia Generating Station”
February 21, 2013 “McCullough Research Rebuttal to Western States Petroleum
Association”
November 15, 2012 “May and October 2012 Gasoline Price Spikes on the West
Coast”
June 5, 2012 “Analysis of West Coast Gasoline Prices”
October 3, 2011 “Lowering Florida’s Electricity Prices”
July 14, 2011 “2011 ERCOT Blackouts and Emergencies”
March 1, 2010 “Translation” of the September 29, 2008 NY Risk Consultant’s
Hydraulics Report to Manitoba Hydro CEO Bob Brennan
December 2, 2009 “Review of the ICF Report on Manitoba Hydro Export Sales”
June 5, 2009 “New York State Electricity Plants’ Profitability Results”
May 5, 2009 “Transparency in ERCOT: A No-cost Strategy to Reduce
Electricity Prices in Texas”
April 7, 2009 “A Forensic Analysis of Pickens’ Peak: Speculation,
Fundamentals or Market Structure”
March 30, 2009 “New Yorkers Lost $2.2 Billion Because of NYISO Practices”
March 3, 2009 “The New York Independent System Operator’s Market-
Clearing Price Auction is Too Expensive for New York”
February 24, 2009 “The Need for a Connecticut Power Authority”
January 7, 2009 “Review of the ERCOT December 18, 2008 Nodal Cost
Benefit Study”
August 6, 2008 “Seeking the Causes of the July 3rd Spike in World Oil Prices”
(updated September 16, 2008)
April 7, 2008 “Kaye Scholer’s Redacted ‘Analysis of Possible Complaints
Relating to Maryland’s SOS Auctions’”
February 1, 2008 “Some Observations on Societe Generale’s Risk Controls”
June 26, 2007 “Looking for the ‘Voom’: A Rebuttal to Dr. Hogan’s ‘Acting
in Time: Regulating Wholesale Electricity Markets’”
September 26, 2006 “Did Amaranth Advisors, LLC Attempt to Corner the March
2007 NYMEX at Henry Hub?”
May 18, 2006 “Developing a Power Purchase/Fuel Supply Portfolio: Energy
Strategies for Cities and Other Public Agencies”
April 12, 2005 “When Oil Prices Rise, Using More Ethanol Helps Save
Money at the Gas Pump”
April 12, 2005 “When Farmers Outperform Sheiks: Why Adding Ethanol to
the U.S. Fuel Mix Makes Sense in a $50-Plus/Barrel Oil
Market”
April 12, 2005 “Enron’s Per Se Anti-Trust Activities in New York”
February 15, 2005 “Employment Impacts of Shifting BPA to Market Pricing”
June 28, 2004 “Reading Enron’s Scheme Accounting Materials”
June 5, 2004 “ERCOT BES Event”
August 14, 2003 “Fat Boy Report”
May 16, 2003 “CERA Decision Brief”
January 16, 2003 “California Electricity Price Spikes”
November 29, 2002 “C66 and Artificial Congestion Transmission in January 2001”
August 17, 2002 “Three Days of Crisis at the California ISO”
July 9, 2002 “Market Efficiencies”
June 26, 2002 “Senate Fact Sheet”
June 5, 2002 “Congestion Manipulation”
May 5, 2002 “Enron’s Workout Plan”
March 31, 2002 “A History of LJM2”
February 2, 2002 “Understanding LJM”
January 22, 2002 “Understanding Whitewing”
Testimony and Comment
November 26, 2018 Affidavit in FERC ER19-155-000
November 6, 2018 Affidavit in FERC EL16-49-000
June 1, 2018 Four Rebuttal affidavits for West Moberly v British
Columbia.
January 31, 2018 Expert report affidavit West Moberly v British Columbia
November 30, 2017 Presentation to the British Columbia Cabinet on Site C
October 13, 2017 Testimony before the British Columbia Utilities Commission
on Site C
June 7, 2017 Testimony before the U.S. Court of Claims on Nuclear
Storage Costs
December 14, 2016 Testimony to the U.S. Court of Federal Claims on behalf of
the U.S. Department of Justice regarding nuclear rate case
February 10, 2016 Testimony before the Supreme Court of British Columbia on
the costs and benefits of delaying Site C dam
August 24, 2015 Testimony to the New York State Public Service Commission
on behalf of the New York State Legislative Assembly
May 29, 2015 Testimony before the Federal Energy Regulatory
Commission on behalf of Illinois Attorney General Lisa
Madigan
December 15, 2014 Testimony before the Bureau d’audiences publiques sur
l’environment (BAPE) in Quebec, “Uranium Mining in
Quebec: Four Conclusions”
November 15, 2012 Testimony before the California State Senate Select Committee
on Bay Area Transportation on West Coast gasoline price
spikes in 2012
July 20, 2010 Testimony before the Rhode Island Public Utility Commission
on the Deepwater offshore wind project
April 7, 2009 Testimony before the U.S. Senate Committee on Energy and
Natural Resources on “Pickens’ Peak”
March 5, 2009 Testimony before the New York Assembly Committee on
Corporations, Authorities and Commissions, and the
Assembly Committee on Energy, “New York Independent
System Operators Market Clearing Price Auction is Too
Expensive for New York”
February 24, 2009 Testimony before the Energy and Technology Committee,
Connecticut General Assembly, “An Act Establishing a Public
Power Authority” on behalf of AARP
September 16, 2008 Testimony before the U.S. Senate Committee on Energy and
Natural Resources, “Depending On 19th Century Regulatory
Institutions to Handle 21st Century Markets”
January 7, 2008 Supplemental Comment (“The Missing Benchmark in
Electricity Deregulation”) before the Federal Energy
Regulatory Commission on behalf of American Public Power
Association, Docket Nos. RM07-19-000 and AD07-7-000
August 7-8, 2007 Testimony before the Oregon Public Utility Commission on
behalf of Wah Chang, Salem, Oregon, Docket No. UM 1002
February 23 and 26, 2007 Testimony before the Federal Energy Regulatory Commission
on behalf of Public Utility District No. 1 of Snohomish
County, Washington, Docket No. EL03-180
October 2, 2006 Direct Testimony before the Régie de l’énergie,
Gouvernement du Québec on behalf of the Grand Council of
the Cree
August 22, 2006 Rebuttal Expert Report on behalf of Public Utility District No.
1 of Snohomish County, Washington, Docket No. H-01-3624
June 1, 2006 Expert Report on behalf of Public Utility District No. 1 of
Snohomish County, Washington, Docket No. H-01-3624
May 8, 2006 Testimony before the U.S. Senate Democratic Policy
Committee, “Regulation and Forward Markets: Lessons from
Enron and the Western Market Crisis of 2000-2001”
December 15, 2005 Direct Testimony before the Public Utility Commission of the
State of Oregon on behalf of Wah Chang, Wah Chang v.
PacifiCorp in Docket UM 1002
December 14, 2005 Deposition before the United States District Court Western
District of Washington at Tacoma on behalf of Federated
Rural Electric Insurance Exchange and TIG Insurance
Company, Federated Rural Electric Insurance Exchange and
TIG Insurance Company v. Public Utility District No. 1 of
Cowlitz County, No. 04-5052RBL
December 4, 2005 Expert Report on behalf of Utility Choice Electric in Civil
Action No. 4:05-CV-00573
July 27, 2005 Expert Report before the United States District Court Western
District of Washington at Tacoma on behalf of Federated
Rural Electric Insurance Exchange and TIG Insurance
Company, Federated Rural Electric Insurance Exchange and
TIG Insurance Company v. Public Utility District No. 1 of
Cowlitz County, Docket No. CV04-5052RBL
May 6, 2005 Rebuttal Testimony before the Federal Energy Regulatory
Commission on behalf of Public Utility District No. 1 of
Snohomish County, Washington, Docket No.EL03-180, et al.
May 1, 2005 Rebuttal Expert Report on behalf of Factory Mutual, Factory
Mutual v. Northwest Aluminum
March 24-25, 2005 Deposition by Enron Power Marketing, Inc. before the
Federal Energy Regulatory Commission on behalf of Public
Utility District No. 1 of Snohomish County, Washington,
Docket No.EL03-180, et al.
February 14, 2005 Expert Report on behalf of Factory Mutual, Factory Mutual v.
Northwest Aluminum
January 27, 2005 Supplemental Testimony before the Federal Energy
Regulatory Commission on behalf of Public Utility District
No. 1 of Snohomish County, Washington, Docket No. EL03-
180, et al.
April 14, 2004 Deposition by Enron Power Marketing, Inc. and Enron
Energy Services before the Federal Energy Regulatory
Commission on behalf of Public Utility District No. 1 of
Snohomish County, Washington, Docket No.EL03-180, et al.
April 10, 2004 Rebuttal Testimony on behalf of the Office of City and County
Attorneys, San Francisco, California, City and County
Attorneys, San Francisco, California v. Turlock Irrigation
District, Non-Binding Arbitration
February 24, 2004 Direct Testimony before the Federal Energy Regulatory
Commission on behalf of Public Utility District No. 1 of
Snohomish County, Washington, Docket No.EL03-180, et al.
March 20, 2003 Rebuttal Testimony before the Federal Energy Regulatory
Commission on behalf of the City of Seattle, Washington,
Docket No. EL01-10, et al.
March 11-13, 2003 Deposition by IdaCorp Energy L.P. before the District Court
of the Fourth Judicial District of the State of Idaho on behalf
of Overton Power District No. 5, State of Nevada, IdaCorp
Energy L.P. v. Overton Power District No. 5, Case No. OC
0107870D
March 3, 2003 Expert Report before the District Court of the Fourth Judicial
District of the State of Idaho on behalf of Overton Power
District No. 5, State of Nevada, IdaCorp Energy L.P. v.
Overton Power District No. 5, Case No. OC 0107870D
February 27, 2003 Direct Testimony before the Federal Energy Regulatory
Commission on behalf of the City of Tacoma, Washington and
the Port of Seattle, Washington, Docket No. EL01-10-005
October 7, 2002 Rebuttal Testimony before the Federal Energy Regulatory
Commission on behalf of Public Utility District No. 1 of
Snohomish County, Washington, Docket No. EL02-26, et al.
October 2002 Expert Report before the Circuit Court of the State of Oregon
for the County of Multnomah on behalf of Alcan, Inc., Alcan,
Inc. v. Powerex Corp., Case No. 50 198 T161 02
September 27, 2002 Deposition by Morgan Stanley Capital Group, Inc. before the
Federal Energy Regulatory Commission on behalf of Nevada
Power Company and Sierra Pacific Power Company, Docket
No. EL02-26, et al.
August 8-9, 2002 Deposition by Morgan Stanley Capital Group, Inc. before the
Federal Energy Regulatory Commission on behalf of Nevada
Power Company and Sierra Pacific Power Company, Docket
No. EL02-26, et al.
August 8, 2002 Deposition by Morgan Stanley Capital Group, Inc. before the
Federal Energy Regulatory Commission on behalf of Public
Utility District No. 1 of Snohomish County, Washington,
Docket No. EL02-26, et al.
June 28, 2002 Direct Testimony before the Federal Energy Regulatory
Commission on behalf of the City of Tacoma, Washington,
Docket No. EL02-26, et al.
June 25, 2002 Direct Testimony before the Federal Energy Regulatory
Commission on behalf of Public Utility District No. 1 of
Snohomish County, Washington, Docket No. EL02-26, et al.
June 25, 2002 Direct Testimony before the Federal Energy Regulatory
Commission on behalf of Nevada Power Company and Sierra
Pacific Power Company, Docket No. EL02-26, et al.
May 6, 2002 Rebuttal Testimony before the Public Service Commission of
Utah on behalf of Magnesium Corporation of America in the
Matter of the Petition of Magnesium Corporation of America
to Require PacifiCorp to Purchase Power from MagCorp and
to Establish Avoided Cost Rates, Docket No. 02-035-02
April 11, 2002 Testimony before the U.S. Senate Committee on Commerce,
Science and Transportation, Washington DC
February 13, 2002 Testimony before the U.S. House of Representatives
Subcommittee on Energy and Air Quality, Washington DC
January 29, 2002 Testimony before the U.S. Senate Committee on Energy and
Natural Resources, Washington DC
August 30, 2001 Rebuttal Testimony before the Federal Energy Regulatory
Commission on behalf of Seattle City Light, Docket No.
EL01-10
August 16, 2001 Direct Testimony before the Federal Energy Regulatory
Commission on behalf of Seattle City Light, Docket No.
EL01-10
June 12, 2001 Rebuttal Testimony before the Public Utility Commission of
the State of Oregon on behalf of Wah Chang, Wah Chang v.
PacifiCorp in Docket UM 1002
April 17, 2001 Before the Public Utility Commission of the State of Oregon,
Direct Testimony on behalf of Wah Chang, Wah Chang v.
PacifiCorp in Docket UM 1002
March 17, 2000 Rebuttal Testimony before the Public Service Commission of
Utah on behalf of the Large Customer Group in the Matter of
the Application of PacifiCorp for Approval of Its Proposed
Electric Rate Schedules and Electric Service Regulations,
Docket No. 99-035-10
February 1, 2000 Direct Testimony before the Public Service Commission of
Utah on behalf of the Large Customer Group in the Matter of
the Application of PacifiCorp for Approval of Its Proposed
Electric Rate Schedules and Electric Service Regulations,
Docket No. 99-035-10
Presentations
January 18, 2019 “The End of Big Iron” Portland State University
May 15, 2018 “The Tower of Bitcoin” CAPRE Portland Summit
Blockchain Panel.
April 11, 2018 “Breakdown and Post-Analysis of the Site C Review”
January 26, 2018 “Prudency, Recovery, and Rates”, Site C Summit
December 11, 2017 “Final Decision Review”, PVLA Press Conference
January 23-24, 2017 “Are Electric Markets Obsolete?”, Buying & Selling Electric
Power Conference, Seattle, Washington
December 3, 2015 “Ozymandias: Seventeen years of administered markets, high
costs, and poor eligibility”, Utility Markets Today, Rockville,
Maryland
May 6, 2014 “Economic Analysis of the Columbia Generating Station”,
Energy Northwest, Boise, Idaho
April 30, 2014 “Economic Analysis of the Columbia Generating Station”,
Portland State University, Portland, Oregon
April 22, 2014 “Economic Analysis of the Columbia Generating Station”,
Clark County, Vancouver, Washington
January 9, 2014 “Economic Analysis of the Columbia Generating Station”,
Northwest Power & Conservation Council, Portland, Oregon
January 1, 2014 “Economic Analysis of the Columbia Generating Station”,
Bonneville Power Administration, Portland, Oregon
December 2, 2013 “Economic Analysis of the Columbia Generating Station”,
Skamania, Carson, Washington
December 1, 2013 “Peak Peddling: Has Portland Bicycling Reached the Top of
the Logistic Curve?” Oregon Transportation Research and
Education Consortium, Portland, Oregon
July 12, 2013 “Economic Analysis of the Columbia Generating Station”,
Tacoma, Washington
June 21, 2013 “Economic Analysis of the Columbia Generating Station”,
Seattle City Light, Seattle, Washington
January 29, 2013 “J.D. Ross (Who)”, Portland Rotary Club, Portland, Oregon.
January 13, 2011 “Estimating the Consumer’s Burden from Administered
Markets”, American Public Power Association conference,
Washington, DC
October 15, 2009 “The Mysterious New York Market”, EPIS, Tucson, Arizona
October 14, 2009 “Do ISO Bidding Processes Result in Just and Reasonable
Rates?”, legal seminar, American Public Power Association,
Savannah, Georgia
June 22, 2009 “Pickens’ Peak Redux: Fundamentals, Speculation, or Market
Structure”, International Association for Energy Economics
June 5, 2009 “Transparency in ERCOT: A No-cost Strategy to Reduce
Electricity Prices in Texas”, Presentation at Texas Legislature
May 8, 2009 “Pickens’ Peak”, Economics Department, Portland State
University
April 7, 2009 “Pickens’ Peak: Speculators, Fundamentals, or Market
Structure”, 2009 EIA energy conference, Washington, DC
February 4, 2009 “Why We Need a Connecticut Power Authority”, presentation
to the Energy and Technology Committee, Connecticut
General Assembly
October 28, 2008 “The Impact of a Volatile Economy on Energy Markets”,
NAESCO annual meeting, Santa Monica, California
April 1, 2008 “Connecticut Energy Policy: Critical Times…Critical
Decisions”, House Energy and Technology Committee, the
Connecticut General Assembly
May 23, 2007 “Past Efforts and Future Prospects for Electricity Industry
Restructuring: Why Is Competition So Expensive?”, Portland
State University
February 26, 2007 “Trust, But Verify”, Take Back the Power Conference,
National Press Club, Washington, DC
May 18, 2006 “Developing a Power Purchase/Fuel Supply Portfolio”
February 12, 2005 “Northwest Job Impacts of BPA Market Rates”
January 5, 2005 “Why Has the Enron Crisis Taken So Long to Solve?”, Public
Power Council, Portland, Oregon
September 20, 2004 “Project Stanley and the Texas Market”, Gulf Coast Energy
Association, Austin, Texas
September 9, 2004 “Back to the New Market Basics”, EPIS, White Salmon,
Washington
June 8, 2004 “Caveat Emptor”, ELCON West Coast Meeting, Oakland,
California
June 9, 2004 “Enron Discovery in EL03-137/180”
March 31, 2004 “Governance and Performance”, Public Power Council,
Portland, Oregon
January 23, 2004 “Resource Choice”, Law Seminars International, Seattle,
Washington
January 17, 2003 “California Energy Price Spikes: The Factual Evidence”, Law
Seminars International Seattle, Washington
January 16, 2003 “The Purloined Agenda: Pursuing Competition in an Era of
Secrecy, Guile, and Incompetence”
September 17, 2002 “Three Crisis Days”, California Senate Select Committee,
Sacramento, California
June 10, 2002 “Enron Schemes”, California Senate Select Committee
Sacramento, California
May 2, 2002 “One Hundred Years of Solitude”
March 21, 2002 “Enron’s International Ventures”, Oregon Bar International
Law Committee, Portland, Oregon
March 19, 2002 “Coordinating West Coast Power Markets”, GasMart, Reno,
Nevada
March 19, 2002 “Sauron’s Ring”, GasMart, Reno, Nevada
January 25, 2002 “Deconstructing Enron’s Collapse: Buying and Selling
Electricity on The West Coast”, Seattle, Washington
January 18, 2002 “Deconstructing Enron’s Collapse”, Economics Seminar,
Portland State University
November 12, 2001 “Artifice or Reality”, EPIS Energy Forecast Symposium,
Skamania, Washington
October 24, 2001 “The Case of the Missing Crisis” Kennewick Rotary Club,
Kennewick, Washington
August 18, 2001 “Preparing for the Next Decade”
June 26, 2001 “Examining the Outlook on Deregulation”
June 25, 2001 Presentation, Energy Purchasing Institute for International
Research (IIR), Dallas, Texas
June 6, 2001 “New Horizons: Solutions for the 21st Century”, Federal
Energy Management-U.S. Department of Energy, Kansas City,
Kansas
May 24, 2001 “Five Years”
May 10, 2001 “A Year in Purgatory”, Utah Industrial Customers
Symposium-Utah Association of Energy Users, Salt Lake City,
Utah
May 1, 2001 “What to Expect in the Western Power Markets this Summer”,
Western Power Market Seminar, Denver, Colorado
April 23, 2001 “Emerging Markets for Natural Gas”, West Coast Gas
Conference, Portland, Oregon
April 18, 2001 “Demystifying the Influence of Regulatory Mandates on the
Energy Economy” Marcus Evans Seminar, Denver, Colorado
April 4, 2001 “Perfect Storm”, Regulatory Accounting Conference, Las
Vegas, Nevada
March 21, 2001 “After the Storm 2001”, Public Utility Seminar, Reno, Nevada
February 21, 2001 “Future Imperfect”, Pacific Northwest Steel Association,
Portland, Oregon
February 12, 2001 “Power Prices in 2000 through 2005”, Northwest Agricultural
Chillers, Bellingham, Washington
February 6, 2001 Presentation, Boise Cascade Management, Boise, Idaho
January 19, 2001 “Wholesale Pricing and Location of New Generation Buying
and Selling Power in the Pacific Northwest”, Seattle,
Washington
October 26, 2000 “Tsunami: Market Prices since May 22nd”, International
Association of Refrigerated Warehouses, Los Vegas, California
October 11, 2000 “Tsunami: Market Prices since May 22nd”, Price Spikes
Symposium, Portland, Oregon
August 14, 2000 “Anatomy of a Corrupted Market”, Oregon Public Utility
Commission and Oregon State Energy Office, Salem, Oregon
June 30, 2000 “Northwest Market Power”, Governor Locke of Washington,
Seattle, Washington
June 10, 2000 “Northwest Market Power”, Oregon Public Utility
Commission and Oregon State Energy Office, Salem, Oregon
June 5, 2000 “Northwest Market Power”, Georgia Pacific Management
May 10, 2000 “Magnesium Corporation Developments”, Utah Public
Utilities Commission
May 5, 2000 “Northwest Power Developments”, Georgia Pacific
Management
January 12, 2000 “Northwest Reliability Issues”, Oregon Public Utility
Commission
Volunteer Positions
2015-present Board member, Portland State University Master in Public
Policy Advisory Committee
2016-2017 Eastmoreland Neighborhood Association, Treasurer
2013-2016 Eastmoreland Neighborhood Association, President
2013-2017 Southeast Uplift Neighborhood Coalition, President
2013-Present City of Portland Office of Management and Finance Advisory
Committee
1990-Present Chairman, Portland State University Economics Department
Advisory Committee
Membership
American Economic Association
American Financial Association
Econometric Society
Western Economic Association
__________________________
ACKNOWLEDGEMENT
I am now and at all times herein mentioned a citizen of the United States,
over the age of 18 and competent to testify as a witness herein. I am the author
of the preceding report, "Needs and Costs of Energize Eastside".
I declare under the penalty of perjury under the laws of the State of
Washington that the preceding report is true and correct to the best of my
knowledge and belief.
DATED this 7th day of January, 2020.
Signature:
Printed Name: Robert McCullough
PTERRA, LLC
4 Automation Lane – Suite 150, Albany, NY 12205-1665
Tel: (518) 935-2579, Fax: (518)935-1066
www.pterra.com
Ric Austria
Executive Principal
Email: ricaustria@pterra.us
Mr. Austria is a founder of Pterra, LLC. He has over 35 years experience in electric
power transmission planning, operations, voltage simulation and analysis, design
and engineering, and brings this knowledge to help clients worldwide in the power
industry.
He is a renowned expert in the specialized fields of system reliability, transmission
planning, voltage stability and system analysis. He has provided expert testimony
in these areas in filings with the FERC, state and local public commissions. He has
led and conducted transmission studies in all US interconnections and over 25
national networks worldwide; each of which have determined major investment in
transmission, substations, underground and undersea cables, power conditioning
equipment and application of new analytical methodologies and technologies. Mr.
Austria has spoken at numerous conferences, authored articles and participated in
working groups on the subject of electric power transmission.
Mr. Austria was formerly Vice President of Consulting at Power Technologies, Inc.
(Schenectady, New York), Vice President of transmission studies at EPRI Solutions,
Inc. and Senior Specialist at the National Power Corporation. In these various roles,
he was responsible for developing new approaches to providing for reliability in
competitive power industry environments.
Mr. Austria is a senior member of the IEEE and its Power Engineering Society and
past chair of the Schenectady Section.
Areas of Focus
Transmission planning; voltage control and reactive power planning and design;
power system analysis; power system stability; power system reliability;
transmission reliability; operations planning; software development; technology
roadmapping; planning and operations training; energy markets.
Selected Project Experience
Maryland Public Service Commission, Case No. 9600, on Baltimore Gas and Electric’s application to construct the Key
Crossing project, a $200+ million double circuit 230 kV transmission line across the Patapsco River.
FERC Docket ER17-1138 on PJM Interconnection, L.L.C.’s (“PJM”) proposal to change its Tariff and Reliability
Assurance Agreement to implement more stringent requirements for External Capacity to be qualified to sell capacity
into the PJM market.
Resume of Ricardo Austria
Pterra, LLC
Page 2
September 2019
FERC Docket EL14-000 on complaint by Consolidated Edison Company of Ney York regarding the proposed cost
allocations by PJM Interconnection.
FERC Docket Nos. EL15-37-000 and ER16-120-000 New York Independent System Operator, Inc. (NYISO) to submit
tariff revisions governing the retention of and compensation to generating units needed for reliability, including
procedures for designating such resources, the rates, terms, and conditions for reliability must run (RMR) service,
provisions for the allocation of costs of RMR service, and a pro forma agreement for RMR service.
Designation of Competitive Renewable Energy Zones, PUC Texas. FPL Energy, AES Seawind and Invenergy. Expert
witness and testimony services in docket 33672.
FERC Docket ER06-880-003 on transmission projects included in PJM expansion plan. PSEG, PHI, PPL and FirstEnergy
companies in the PJM footprint. Expert witness and testimony services.
STATE OF NEW YORK PUBLIC SERVICE COMMISSION, Case No. 06-T-0650, Application of New York Regional
interconnect, Inc. for a Certificate of Environmental Compatibility and Public Need Pursuant to Article VII of the Public
Service Law, Expert witness and testimony services.
Confidential Client. Provided expert advice on method and conclusions derived by Southern Company regarding
Client’s voltage and closing angle stability impacts on the output of a proposed coal plant in southern Tennessee.
Identified aspects of analysis that required further review and alternative solutions to constraints on the proposed
plants.
Conjunction, LLC, Empire Transmission Line Project. Identified transmission feasibility of various configurations for
interconnecting Upstate NY with New York City through DC and AC lines. Developed models for simulating network
response with the project in service. Provided expert witness services during public and private meetings and hearings
with interested local and industry parties. Conducted System Reliability Impact Study, approved and accepted by
TPAS in 2004.
Old Dominion Electric Cooperative, Analysis of High Locational Prices in PJM. Performed electric transmission system
analyses to diagnose causes of high locational prices and evaluated remedies to reduce the prices in the area of
concern. Identified problem areas. Analyzed the existing transmission system and determined the causes of the
high locational prices and provided an estimate of the duration and magnitude of exposure to high prices. Specified
a solution to a voltage control problem which was influencing LMPs. (Implemented by ODEC). Identified solutions
for congestion costs in the Upper Peninsula.
Oklahoma Gas and Electric Company, Support of Arkansas Market Power Proceeding. Developed TTCs between
control areas and control area-to-control area TDFs in the vicinity of the OG&E. Studied the transmission topography
of the OG&E system to identify constraints that could impact a market power assessment. Identified realignment of
the OG&E area which reflects these constraints. Provided expert testimony to support market power filing in the
State of Arkansas.
Review of Transmission Plans Submitted to the Michigan Public Service on behalf of the PSC. Reviewed non-common
components of transmission plans submitted by Michigan utilities to the Commission in response to state
requirements. Conducted analytical verification of specific bases for the plans. Provided expert testimony to the
Commission on the assumptions, procedures and conclusions relating to the submitted plans.
New Jersey Board of Public Utilities. Audited reliability related practices and recent operations of New Jersey electric
utilities as part of a forensic investigation of events of July 3-8, 1999. Determined that near voltage collapse event
occurred on July 6, 1999 that New Jersey utilities and PJM were not adequately prepared for.
California ISO Trust and Trust Advisory Committee, Operating Reliability Requirements Study. Identified
requirements for reliable initial operation of the California ISO. This phase involved the aspect of location-dependent
or "must-run" generation and ancillary services, and was completed within a three-month study period. Clarified the
issue of "must-run" contracts for the Cal ISO's own task force on Transmission Reliability, as well as all other
participants in the nascent ISO and power exchange. Reviewed existing criteria and proposed criteria to maintain or
exceed existing transmission service reliability. Identified location-dependent conditions and dispatches, with
measures of effectiveness to help formulate alternative reliability-based dispatches.
BC Hydro, Canada, Methodology to Calculate Benefits From Generation-Related Transmission. Developed a
methodology to calculate benefits from transmission connecting hydro projects to a power grid. Provided support
for expert testimony.
Training Instructor Experience
Voltage Control and Reactive Power Planning Course - principles of voltage control
and reactive supply planning in transmission and distribution systems. Covers
Resume of Ricardo Austria
Pterra, LLC
Page 3
September 2019
equipment characteristics, load modeling, planning criteria, voltage stresses, bulk
system operations, reactive planning and analytical modeling.
Advanced Transmission Planning - principles of transmission planning. Covers
analytical methods and tools, planning methodologies, planning criteria, industry
structures, least cost techniques and a complete case study.
Reliability Assessment Methods - principles of reliability assessment for generation,
transmission and distribution systems. Covers outage modeling, reliability criteria,
regulatory and industry organizations, mathematical and analytical models,
performance measures and composite indices.
Control Center Technologies – hardware, software, processes and operator
requirements and roles in modern power system control centers.
Other courses: Optimal Power Flow, Improving Reliability of Large Interconnected
Systems, Competitive Markets, Dynamic Simulation for Power Systems, Locational
Marginal Pricing Basics.
Publications
1. "Automatic Load Shedding in the Luzon Grid," presented at the 5th IECEP Conference, Manila, Philippines,
November 1984, (co-author: F.C. Leynes).
2. "Reactive Power Planning Using an Optimal Power Flow," PTI Newsletter Power Technology, Issue No. 60, January
1990, (co-author: J.D. Mountford).
3. "Corrective Action: An Optimal Power Flow Application," PTI Newsletter Power Technology, Issue No. 62, July
1990, (co-author: N.D. Reppen).
4. "Applications of the Optimal Power Flow to Analysis of Voltage Collapse Limited Power Transfer," presented at the
1991 Voltage Phenomena Seminar, Deep Creek Lake, Maryland, August 1991, (co-authors: N.D. Reppen, J.A.
Uhrin, M.C. Patel, and A. Galatic).
5. "Performance of Methods for Ranking and Evaluation of Voltage Collapse Contingencies Applied to a Large-Scale
Network," 1993 IEEE/NTUA joint international power conference on Planning, Operation and Control in Today's
Electric Power Systems, Athens, Greece (co-authors: N.D. Reppen, J.A. Uhrin, M.C. Patel, and A. Galatic).
6. "Modern Analytical Tools are Changing the Way Transmission Planning is Done," PTI Newsletter Power
Technology, Issue No. 74, July 1993, (co-author: F.S. Prabhakara).
7. "An Integrated Approach to Transfer Limit Calculations," Computer Applications in Power, January 1995, pp. 48-
52, (co-authors: X.Y. Chao, N.D. Reppen and D.E. Welsh).
8. "Practical Determination of Operating Transfer Limits," PICA '95 conference paper, May 1995, (co-authors: X.Y.
Chao, N.D. Reppen and D.E. Welsh).
9. “A Closer Look at Transmission Planning in a Competitive Environment,” PTI Newsletter Power Technology, July
1995, (co-author: M. R. Pangilinan).
10. “Considerations in the Development and Evaluation of Alternatives for Long-Term Transmission,” presented at the
11th Conference of the Electric Power Supply Industry (11 CEPSI), October 21-15, 1996, Kuala Lumpur, Malaysia,
(co-authors: T.I. Leksan, P. Chonglertvanichkul, G. Behrens, and J. Slapp).
11. “Transmission Planning for Unbundled Generation Expansion,” presented at the 11th Conference of the Electric
Power Supply Industry (11 CEPSI), October 21-15, 1996, Kuala Lumpur, Malaysia, (co-authors: M.R. Pangilinan
and J. Batista Silva).
12. “A Composite Reliability Method for Resource Evaluation of an Island Grid or Local Load,” presented at the 11th
Conference of the Electric Power Supply Industry (11 CEPSI), October 21-15, 1996, Kuala Lumpur, Malaysia, (co-
authors: M. S. Basabe, N. D. Reppen and L.S. Sunico).
13. “Wheeling Tariffs for Transmission Services,” presented at the 11th Conference of the Electric Power Supply
Industry (11 CEPSI), October 21-15, 1996, Kuala Lumpur, Malaysia, (co-authors: R. Nadira, W. R. Puntel, P. S.
Hurley, R. C. Bacani, R. F. Nuqui, M. R. Pangilinan).
14. “Planificacion de Sistemas de Transmision de Energia Electrica en el Futuro: ¿Son Validas las Premisas
Tradicionales?,” presented at the Latin America Power ’97 Conference, April 29-May 1, 1997, Caracas, Venezuela,
(co-authors: R. Nadira, L. Cosenza, F. Lecaros, C. Fuentes, M. Avila, and J. Ramirez).
15. “Least-Cost Transmission Planning Considering Power Industry Restructuring,” presented at the IASTED
Conference, Orlando, FL., October 1997, (co-authors: R. Nadira, L. Cosenza, C. Fuentes, M. Avila, and J.
Ramirez).
16. “Managing Information on Transmission System Equipment Reliability,” PTI Newsletter Power Technology, Third
Quarter 1998, (co-author: N. D. Reppen).
Resume of Ricardo Austria
Pterra, LLC
Page 4
September 2019
17. “A Composite Reliability Assessment Method for a Deregulating Power System,” Proceedings of the 13th
Conference of the Electricity Power Supply Industry (CEPSI 2000), October 23 - 27, 2000, Manila, Philippines
(co-authors: Xiaokang Xu, Moises R. Gutierrez, Baldwin P. Lam, Humberto Burgos-Cruz and Héctor Villarroel-
Pedrazas)
18. “Voltage Stability Study of a Practical Power System,” Proceedings of the 13th Conference of the Electricity
Power Supply Industry (CEPSI 2000), October 23 - 27, 2000, Manila, Philippines (co-authors: Xiaokang Xu and
Michael Power)
19. “The State of Voltage Stability Assessment,” PTI Newsletter, Power Technology, Issue No. 97, Second Quarter
2001. (co-authors: Xiaokang Xu and Michael Power).
20. “A New Probabilistic Approach for Reliability Assessment of Urban Networks,” Accepted for presentation at the
IEEE Summer Meeting, Vancouver, British Columbia, Canada, July 15-19, 2001 (co-authors: Xiaokang Xu,
M.E.N. du Preez and Deon Very).
21. “Application of FACTS Technology for Increasing Power Transfers of Jiangsu Transmission System,” Accepted
for presentation at the CIGRE 2001 International Conference on Power Systems (CIGRE ICPS'2001),
September 3-5, 2001, Wuhan, Hubei, China (co-authors: Xiaokang Xu, Baldwin P. Lam, Wang Huaming, Fan
Haihong, Yang Lin & Wang Xu)
22. “Voltage Stability Assessment of the National Grid System Using Modern Analytical Tools,” Accepted for
presentation at the 2001 Transmission and Distribution Conference and Exposition, October 28 – November 2,
2001, Atlanta, George, USA (co-authors: Xiaokang Xu and Michael Power)
23. “Assessing the impact of substation-related outages on the network reliability,” Proceedings. International
Conference on Power System Technology, Year: 2002, Volume: 2, Pages: 844 – 848, (co-authors: X. Xu; B. P.
Lam; Z. Ma; Z. Zhu; R. Zhu; J. Hu)
24. “Transmission Planning in the Presence of Uncertainties”, presented at the PES 2003 General Meeting, July
13-17, 2003, Toronto Canada (co-authors: Ramon Nadira, Carlos A. Dortolina and Fernando Lecaros).
25. “Transmission Planning Today: A Challenging Undertaking”, Electricity Journal, May, 2004 (co-authors: Ramon
Nadira, Carlos A. Dortolina and Miguel Avila)
26. Reliability Assessment of an Island Grid System with Central and Distributed Generation Using Monte Carlo
Simulations”, accepted for presentation at CEPSI 2004 in Shanghai, China, September, 2004. (co-authors
Xiaokang Xu, Reiner Kuhr)
27. “Uprating Transmission Voltage – Planning Perspective,” Panel Session on Voltage Uprating, IEEE PES Summer
2005, San Francisco, CA, June 14, 2005
28. "Why not Voltage Uprating as a Planning Option?" Pterra Technical Articles published online at www.pterra.com,
June 2005
29. "Resource Planning for Island Networks" Pterra Technical Articles published online at www.pterra.com, July 2005.
30. "Overlaying DC Transmission On an AC System" Pterra Technical Articles published online at www.pterra.com,
August 2005. (co-authors R. Tapia, K. Dartawan, M. Elfayoumy, M. Gutierrez)
31. "Transmission Planning - Returning to Fundamentals," Pterra Technical Articles published online at
www.pterra.com, September 2005
32. "Open Source or Proprietary Data: the Model Dilemma," Pterra Technical Articles published online at
www.pterra.com, November 2005 (co-authors M. Gutierrez)
33. "The In-Between Voltage State," Pterra Technical Articles published online at www.pterra.com, December 2005
34. "Steel Mill in the Neighborhood," Pterra Technical Articles published online at www.pterra.com, January 2006
(co-authors K. Dartawan, M. Gutierrez, R. Tapia and C. St. Pierre)
35. "Two Views of Power System Reliability," Pterra Technical Articles published online at www.pterra.com, February,
2006
36. "Steel Mill in the Neighborhood: Part 2 (In Your Backyard)," Pterra Technical Articles published online at
www.pterra.com, April 2006 (co-author K. Dartawan)
37. "Subtransmission Planning," Pterra Technical Articles published online at www.pterra.com, June, 2006
38. "Developing Open Form User Models for Dynamic Simulation," Pterra Technical Articles published online at
www.pterra.com, February 2007 (co-author M. Gutierrez)
39. "The Voltage Ledge," Pterra Technical Articles published online at www.pterra.com, April 2007
40. “Converging the Power Flow 3: Mitigation” Pterra TechBlog published online at www.pterra.us, October 30, 2009
41. "On the Use of Aggregate Models of a Wind Farm," Pterra Technical Articles published online at www.pterra.com,
October 2009 (co-authors J. Chen, M. Gutierrez)
42. "Voltage Stability: The Voltage Ledge Seen Close-Up" Pterra Technical Articles published online at
www.pterra.com, October 2009
43. "Converging the Power Flow 3: Mitigation", Pterra Technical Articles published online at www.pterra.com,
October 2009
44. “Voltage Stability: The Voltage Ledge Seen Close-Up” Pterra TechBlog published online at www.pterra.us,
October 14, 2009
45. "HVDC Technology: DC Overlay on an AC System", Pterra Technical Articles published online at www.pterra.com,
November 2009 (co-authors K. Dartawan, M. Elfayoumy, M. Gutierrez, R. Tapia)
46. "Power Flow Solution Techniques", Pterra Technical Articles published online at www.pterra.com, November
2009. (co-authors M. Gutierrez, M. Elfayoumy, R. Tapia)
47. “Power Flow Solution Techniques” Pterra TechBlog published online at www.pterra.us, November 23, 2009 (co-
authors: M. Gutierrez, M. Elfayoumy, R. Tapia)
Resume of Ricardo Austria
Pterra, LLC
Page 5
September 2019
48. “Distributed Generation: Interconnection Steady State Impact” Pterra TechBlog published online at
www.pterra.us, November 9, 2010, (co-authors: Jingjia Chen, Ketut Dartawan)
49. “Distributed Generation: Things You Don’t Want to Miss!” Pterra TechBlog published online at www.pterra.us,
October 12, 2010 (co-author: K. Dartawan)
50. “Distributed Generation Impact: Sympathetic Tripping of Protection Devices” Pterra TechBlog published online
at www.pterra.us, September 15, 2010 (co-authors: E. Cano, K. Dartawan)
51. “Projecting Curtailment of Wind Farms Due to Transmission Congestion,” Paper presentation at WINDPOWER
2011 Conference & Exhibition, Anaheim, CA, May 22-25, 2011, (co-author: B. Adjemian)
52. "Harmonics Issues that Limit Solar Photovoltaic Generation on Distribution Circuits," World Renewable Energy
Forum (WREF 2012), May 13-17, 2012, at the Colorado Convention Center in Denver (co-authors: K. Dartawan,
L. Hui - Pterra, M. Suehiro - Maui Electric Co.)
53. “Lanai New Distributed Generation Impact Assessment,” Pterra website, October 2012, (co-authors: Ramon
Tapia, Jingjia Chen, Jamie Keller)
54. “Load Rejection Overvoltage Issue on Distributed Generation Projects,” POWER-GEN International, FL, USA,
Nov 12-14,2013, (co-authors: Ketut, Dartawan, Amin M Najafabadi, Le Hui)
55. “Power Quality Impacts and Mitigation of Distributed Solar Power,” presented to the IEEE San Francisco Chapter,
California Public Utilities Commission, San Francisco CA, Feb 17, 2016
56. “Approaches to Complying with NERC Standard PRC-019-2 on the “Coordination of Generating Unit or Plant
Capabilities, Voltage Regulating Controls, and Protection,”’ Pterra Tech Blog, January 2017, (co-authors: F.
Luces, T. C Garcia, C. Bautista, M. Gutierrez)
57. “Ground Fault Overvoltage and Distributed Generation: Factors for Occurrence,” Pterra Tech Blog, January 2017,
(co-authors: K. Dartawan, A. Najafabadi)
58. “Coordinating Generator Unit Capabilities, Excitation System, Voltage Control and Generator Protection,” ASME
2017 Power Conference, Charlotte, NC, June 2017
59. “Preparing Dynamic Databases for the Coming of Renewable Energy-based Generation,” Conference of Power
and Electricity Supply Industry 2018, Kuala Lumpur, Malaysia September 2018, (co-authors: F. Luces, M.
Gutierrez)
60. “Coordinating Generator Capabilities With Protection And Excitation System Controls – Case Study For A 230-
Mva Steam Turbine Generator Unit,” Conference of Power and Electricity Supply Industry 2018, Kuala Lumpur,
Malaysia September 2018, (co-authors: F. Luces, C. Bautista, T. Garcia)
Education
M.S. Electric Power Engineering, Rensselaer Polytechnic Institute, Troy, New York,
1988.
1
CENSE BACKGROUND REPORT / Jan Medley, Russell Borgmann, Daniel Elworth
How PSE Is “selling” the Energize Eastside Transmission Line Project to the public
Abstract
CENSE asserts that PSE is promoting an unneeded transmission line and substation project to create an
additional revenue stream to offset losses from decreased electrical consumption. PSE can earn a 9.8%
rate of return on infrastructure investments such as Energize Eastside.
CENSE also asserts that PSE did not reveal to the public that the Southern Segment of Energize Eastside
(from Talbot Hill to the proposed Richards Creek substation) could independently provide the additional
power PSE claims it needs and that the Northern Segment would merely provide redundancy.1 These facts
were known by PSE, but never disclosed to it’s Community Advisory Group (the CAG), nor in any public
education materials, or messaging used in PSE’s massive newspaper ad campaign.
In Washington state, regulated utilities have two options for obtaining permits to build electrical infrastructure:
• Submit an application to the Washington State Energy Facility Site Evaluation Council (EFSEC) that
provides a one-stop siting process for major energy facilities in the state2, or
• Apply to each city impacted by the project.
CENSE argues that because PSE does not have the data to substantiate the need for the project, it has
opted to apply for permits from four cities, none of which have transmission engineers on staff to evaluate
need, rather than submit one application to EFSEC whose staff are experienced in evaluating the need and
appropriateness of electrical infrastructure projects.
In December 2013, PSE launched a massive public relations campaign for Energize Eastside, the new
name for a project that, since 2007, had been known as the Sammamish-Lakeside-Talbot Hill transmission
line project.3 To manage the campaign, PSE retained Mark Williamson,4 Partner and Chairman of PRW
Communications, a Wisconsin-based public relations firm. Williamson is also a long-time professional
colleague of Daniel Doyle, PSE’s Senior Vice President and Chief Financial Officer.5
Following the approach outlined in Williamson’s mantra, “I elect transmission lines, power plants and
pipelines to public office,6” PSE adopted “political campaigning techniques7” to sell Energize Eastside.
PSE’s advertisements in the Bellevue Reporter and the Seattle Times, as well as talking points to city
decision makers claimed:
1 https://development.bellevuewa.gov/UserFiles/Servers/Server_4779004/File/pdf/Development%20Services/EnergizeEastside/Staff%20Report%20FINAL%201242019.pdf p.111 2 https://www.efsec.wa.gov/council.html 3 https://energizeeastside.com/documents (December 2013 Newsletter)4 http://prwcomm.com/now/?page_id=56 5 https://www.pse.com/about-us/leadership 6 http://prwcomm.com/now/?page_id=24 7 http://prwcomm.com/now/?page_id=15
2
• The “backbone” of the Eastside’s electric grid has not been upgraded in the last 50 years.
• Our population has grown eight-fold and soon demand from unprecedented growth will exceed the
grid’s capacity.
• We must upgrade now to avoid rolling blackouts in the near future.
• Conservation alone is not enough to keep up with our growing economy and population.
• Energize Eastside will update the grid with modern infrastructure.
CENSE’s position is these claims cannot be substantiated and PSE is using them to generate fear that
electricity on the Eastside is becoming less reliable and rolling blackouts are an imminent threat.
CENSE provides facts to disprove PSE’s claims and concludes that:
• Energize Eastside is not the backbone of the Eastside’s electrical grid.8
• Increased population growth is no longer correlated with an increase in electrical demand due to
significant improvements in energy conservation and other technologies.9
• Demand is currently flat and rolling black outs are not in our immediate future.10
• Conservation, with other non-transmission line solutions, could effectively keep demand flat.11
• Higher voltage transmission lines (HTVL) are an archaic technology and the antithesis to
modernizing the grid. Utilities world-wide are turning from HVTL in favor of technologies that provide
customers with more cost-effective and reliable electricity.12
8 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/final_electrical_reliability_study_phase_ii_ report_2012.pdf p. 509 https://www.vox.com/energy-and-environment/2018/2/27/17052488/electricity-demand-utilities 10 https://www.bpa.gov/news/pubs/FactSheets/fs200709-BPA%20to%20automate%20transmission%20 curtailment%20procedure%20for%20the%20Puget%20Sound%20Area.pdf 11 https://www.pse.com/pages/energy-supply/resource-planning 12 https://www.bpa.gov/Projects/Projects/I-5/Documents/letter_I-5_decision_final_web.pdf
3
Table of Contents
1. Permits from cities rather than Washington State Energy Facility Site Evaluation Council (EFSEC
2. Public relations campaign to promote Energize Eastside
3. Persistent advertising claims
4. Conclusion
5. Gallery of Energize Eastside ads in Bellevue Reporter
1. Permits from cities rather than Washington State Energy Facility Site Evaluation Council (EFSEC)
In Washington state, regulated utilities have two options for obtaining permits to build electrical infrastructure:
• Submit an application to the Washington State Energy Facility Site Evaluation Council (EFSEC) that
provides a one-stop siting process for major energy facilities in the state13, or
• Apply to each city impacted by the project.
EFSEC’s one-stop siting process includes coordinating all evaluation and licensing steps. If a project is
approved, EFSEC specifies the conditions of construction and operation; issues permits in lieu of any other
individual state or local agency authority; and manages an environmental and safety oversight program
of facility and site operations. An applicant can choose to receive certifcation under EFSEC for electrical
transmission facilities that are “at least 115 kilovolts and located more than one jurisdiction that has
promulgated land use plans and zoning ordinances.”14
CENSE argues that because PSE does not have the data to substantiate the need for the project, it has
opted to apply for permits from four cities, none of which have transmission engineers on staff to evaluate
need, rather than submit one application to EFSEC whose staff are experienced in evaluating the need and
appropriateness of electrical infrastructure projects. CENSE also argues that PSE predicted that a public
relations campaign would be more successful than an engineering justification in garnering the permits it
needed to build Energize Eastside.
13 https://www.efsec.wa.gov/council.html 14 https://www.efsec.wa.gov/cert.html#Energy%20Facility
4
2 Public relations campaign to promote Energize Eastside
To sell city decision makers and ratepayers on the need for Energize Eastside, PSE launched a massive
public relations campaign in December 2013.15 The campaign was managed by Mark Williamson,16 Partner
and Chairman of PRW Communications, a Wisconsin-based public relations firm. Williamson is also a long-
time professional colleague of Daniel Doyle, PSE’s Senior Vice President and Chief Financial Officer.17
Williamson, who is “nationally renowned for his record of success for getting controversial projects done,”
states to utility executives in PRW’s 2018 Statement of Qualifications:
“I know after spending 3 decades as a utility executive that one of the most frustrating
aspects of your job is getting critically-needed projects done.The public flatly does NOT
want new infrastructure near them. Period. Let PRW help you develop a strategy that
incorporates your own talented and experienced executives and un-stick the stuck vital
projects your communities need.18”
Using Williamson’s mantra, “I elect transmission lines, power plants and pipelines to public office,” PSE
adopted “political campaigning techniques19” to sell Energize Eastside. Advertisements in the Bellevue
Reporter and the Seattle Times, as well as talking points to city decision makers claim:
• The “backbone” of the Eastside’s electric grid has not been upgraded in the last 50 years.
• Our population has grown eight-fold and soon demand from unprecedented growth will exceed the
grid’s capacity.
• We must upgrade now to avoid rolling blackouts in the near future.
• Conservation alone is not enough to keep up with our growing economy and population.
• Energize Eastside will update the grid with modern infrastructure.
Advertising for Energize Eastside targets the public’s fears. Residents are being told, “There could be
rolling blackouts as soon as 2018.” Businesses are being told, “There won’t be enough power to grow your
business.” City governments are being told, “You won’t be able to support future business development and
support city growth.” However, these qualitative comments are NOT supported by quantitative facts. The
underlying quantitative data are being ignored, while PSE pushes an aggressive, persistent PR campaign.
15 https://energizeeastside.com/documents (December 2013 Newsletter)16 http://prwcomm.com/PRW-SOQ.pdf (page 16) 17 https://www.pse.com/about-us/leadership 18 http://prwcomm.com/PRW-SOQ.pdf (page 16)19 http://prwcomm.com/now/?page_id=15
5
Figure1
PRW’s process for managing controversial projects as a “political campaign, and not as an
engineering problem.20”
20 http://prwcomm.com/now/?page_id=15
PRW’S PROCESS
6
16
PRW TEAM — PARTNERS
MARK WILLIAMSON
Mark Williamson is partner/Chairman of PRW Communications. His areas of expertise
include all aspects of utility matters with special emphasis on infrastructure planning,
permitting and construction. His unique skills and talents include assembling and directing
teams that can repeat the process of getting projects done – on time and on budget –
two key components utility CEOs and executives strive for when tackling large projects.
Williamson has developed a strategic communications technique patterned on “election campaigning” –
polling, message development and communication – tools that he has consistently employed to get utility
projects approved, sited, built and on-line. He is a hands-on utility executive that gets the job done from day
one.
Williamson has been associated with American
Transmission Company (ATC) since its inception in
2001. He initially served on ATC’s board of directors
representing Madison Gas & Electric Company. Prior
to his work at ATC, Mark served as Executive Vice
President and Chief Strategy Officer with MG&E.
While at MG&E, he was central to the negotiations
that led to the formation of ATC, as well as Wisconsin’s
adoption of a utility infrastructure rebuilding period.
In June 2002, Williamson joined ATC as vice president of Major Projects. He oversaw external relations and
the public participation process that included local relations, environmental, real estate and state regulatory
functions. For ATC, he managed major transmission infrastructure projects including the 220-mile 345 kV
Arrowhead-Weston transmission line and the 100-mile 345 kV improvements in central Wisconsin. Today he
continues managing projects in Dane County, Wisconsin as a special consultant to ATC.
Williamson is a veteran utility executive. In his 16 years at MG&E, his responsibilities included general
management of environmental and safety, power supply and transmission, operations and engineering,
electric system planning, and gas rates and procurement. He has also been active in legislative initiatives
affecting the utility industry. He was instrumental in negotiations leading to legislation that permitted
guaranteed rate of return long-term leases for power plant construction, aiding construction of new coal fired
power plants in Wisconsin, as well as legislation easing right-of-way acquisition for transmission projects.
Earlier in his career, Williamson was a trial attorney for the Madison-based law firm of Geisler & Kay, SC, which
primarily focused on litigation relating to power plant and paper machine construction projects, product
liability cases and general corporate legal support for electrical and mechanical contractors. Williamson
earned a bachelor’s degree in Mathematics from the University of Wisconsin-Madison in 1976, and received
his law degree from the University of Wisconsin Law School in 1979.
Source: PRW Communications, 2018 Statement of Qualifications / http://prwcomm.com/PRW-SOQ.pdfFigure 2
Mark Williamson’s resume from PRW’s 2018 Statement of Qualifications.21
21 http://prwcomm.com/PRW-SOQ.pdf (page 16)
MARK WILLIAMSON’S RESUME
7
3. Persistent advertising claims
Claim #1: The “Backbone” has not been upgraded in the last 50 years.
Figure 3 OCTOBER 30 2015 Bellevue Reporter:
“The backbone of the Eastside electric grid has not been upgraded since man made that one giant leap
nearly 50 years ago. Soon, demand from record growth will exceed the grid’s capacity, risking longer and
more disruptive outages. Learn how PSE’s working with your community on safe, reliable solutions.”
In May 2016, Ms. Booga Gilbertson, Sr. Vice President, Operations at Puget Sound Energy stated, “The
backbone of the electric system serving Bellevue, and the Eastside, was last upgraded in the 1960s.”
Numerous PSE’s advertisements have also claimed that the Eastside electric system hasn’t been upgraded
in over 50 years. This statement is not true.
The Eastside’s High Voltage Transmission Line (HVTL) grid (115kV lines and above) is exactly that – a GRID,
a network with redundant paths. Our electricity grid is not a singular, centralized line subject to damage by
accidents, storms, natural disasters, or attack. A “backbone” can be severed, lead to paralysis of the region.
To operate reliably, it is essential that the grid act as a resilient multi-path network. There are many existing
redundant paths for power at this voltage to reach the Bellevue Lakeside Substation from both the Talbot
Hill (Renton) Substation and Sammamish (Kirkland) Substation.
8
Our transmission grid is a resilient network with redundant paths, and it has been upgraded on the
eastside several times in the 1990s and as recently as 2009. Public Records searches with the City of
Bellevue show that three of the five North-South High Voltage Transmission Lines through Bellevue were
built over time during the last 20 years. HVTL segments were added in 1996, 2000, 2001, 2004, 2006,
and 2009. PSE has built 3 additional North-South high voltage transmission lines, increasing the
Eastside’s capacity from 2 lines to 5 lines - a 250% increase in capacity - in the last 15 years, as
show in figure 4 below:
Figure 4
Where’s the backbone? Map of FIVE North-South Transmission lines in Bellevue. 22
22 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/final_electrical_reliability_study_ phase_ii_report_2012.pdf p. 50. The dates came from a Bellevue public records request, asking when the permits were granted to build each transmission line.
9
Each year, PSE is required to review our electricity infrastructure, identify risks, and update the system.
PSE would have been negligent in their regulated duty to provide reliable power to the region, if
they had not upgraded the Eastside transmission infrastructure in over 50 years.
PSE uses the word “backbone” without specifically defining the term. We are left to assume it means the
existing North-South 115kV lines that traverse Newcastle, Somerset, connect to Lakeside Substation and
continue north, roughly along 140th Ave NE through Bridle Trails. Mr. Jens Nedrud (former Senior Project
Manager, Puget Sound Energy – Energize Eastside Project) has publicly stated that this existing line
can be taken out of service for up to 9 MONTHS without grid ramifications. The multi-path network
nature of our grid allows for reliable flexibility. It is NOT an important “backbone” if it’s non-essential during
construction of Energize Eastside.
Claim #2: “Our population has grown eight-fold and soon demand from unprecedented
growth will exceed the grid’s capacity.”
The Energize Eastside advertising campaign implies that energy demand is driven mainly by population
and economic growth. At the same time, technology and energy efficiency are reducing demand. In
recent years, declining consumption is seen at the national level23 as well as in PSE’s service area, where
electricity sales have been shrinking since 2008 as shown in figure 5.
To be clear, total consumption is different than peak loads (or “demand” as PSE uses the term), but
consumption and demand are related, as PSE notes in their documents. PSE has not provided consumption
data specifically for the Eastside, so CENSE used revenue generated by electricity taxes in Bellevue
and Renton to produce estimates for consumption in those cities. Figure 5 below shows flat or declining
consumption for every year except 2011, when the Eastside had colder weather than normal. Contrary to
PSE’s inferences, increases in population and economic activity have not led to rising electricity use during
the last 5 years.
Figure 5
Electrical consumption for Bellevue and Renton, determined by revenue generated by electricity taxesˆ
23 https://www.vox.com/energy-and-environment/2018/2/27/17052488/electricity-demand-utilities
10
Claim #3: “We must upgrade now to avoid rolling blackouts in the near future.”
A 2007 BPA Factsheet states:
“It is unlikely anyone’s lights will go out when the automated curtailment system is used. BPA will
alert utilities in the affected area when the system looks as though a curtailment would be needed.
All affected utilities need to know in order to shift some generation and transmission patterns to avoid
the need for the curtailment. For another, once a curtailment is announced, the utilities have the same
options of shifting generation or transmission to assure that they have sufficient energy.
“In a perfect world, BPA and the regional utilities would determine if additional transmission lines
would alleviate the Puget Sound Area Northern Intertie (PSANI) congestion. Many people, however,
oppose having transmission lines in their neighborhoods, and BPA and the regional utilities
would have to sort out who is responsible for the new transmission lines and would have to make
arrangement for financing the upgrades. This may happen, but it will be a long time in the future.”24
Bonneville Power Administration also states that,“it is unlikely that anyone’s lights will go out” because
if necessary BPA’s transmission planning (Day-Ahead and Hour-Ahead planning) manages peak load
events via an automated system BPA implemented and has been using since 2007. More than 15 years of
data, contains not a single example of the U.S. exporting anywhere near 1,500MW of power to Canada,
especially during peak load events. BPA says that their automated system ensures there is sufficient
electricity to the Puget Sound25
Claim #4: “Conservation alone is not enough to keep up with our growing economy
and population.”
It is misleading to claim that conservation alone cannot meet future electrical demand. This implies that no
other non-wire solutions are available to use in conjunction with conservation to provide reliable electricity
for the Eastside. PSE submits an Integrated Resource Plan26 to the WUTC biennually that describes how
other non-wired solutions such as demand-response, distributed energy resources and storage used with
conservation can reduce the need for higher-voltage transmission lines.
Claim #5: “Energize Eastside will update the grid with modern infrastructure”
Higher-transmission lines are NOT modern infrastructure. They exemplify reliance on a 20th century,
centralized-grid to deliver electricity from a very distant source of generation. Modern infrastructure is
trending towards smaller grids with their own source of nearby generation, making them less vulnerable to
long-duration outages and potential cyber-hacking.27
24 https://www.bpa.gov/news/pubs/FactSheets/fs200709-BPA%20to%20automate%20transmission%20 curtailment%20procedure%20for%20the%20Puget%20Sound%20Area.pdf25 https://www.bpa.gov/news/pubs/FactSheets/fs200709-BPA%20to%20automate%20transmission%20 curtailment%20procedure%20for%20the%20Puget%20Sound%20Area.pdf26 https://www.pse.com/pages/energy-supply/resource-planning27 https://www.bpa.gov/Projects/Projects/I-5/Documents/letter_I-5_decision_final_web.pdf
11
4. Conclusion
CENSE asserts that PSE has not provided adequate data to document growing electrical demand on the
Eastside and that PSE is using unsubstantiated claims to influence decision makers to approve the project.
CENSE argues that in order for PSE to create an additional revenue stream to augment its declining
electrical- consumption revenue, PSE is proposing an infrastructure project that will promise a 9.8% rate of
return. If approved, CENSE believes PSE will roll all project costs, including advertising and the 9.8% return
on investment into its petition to the WUTC for increased rates. The result: An unneeded project that will
drastically alter the landscape of the Eastside, higher costs for ratepayers, and, over the 50-year life of the
project, a billion dollar return to PSE on a $300 million investment.28
28 King, Jeffrey. Lifetime cost analysis for Energize Eastside. What will Energize Eastside cost customers over its lifetime? February 17, 2016.
12
Figure 6
An ironic twist. A PSE ad for Energize Eastside flanks a letter to the editor of the Bellevue Reporter from
CENSE member, Russell Borgmann.
13
JUNE 12, 2015BELLEVUE REPORTER
It’s been 50 years since the last
major upgrade to the backbone
of the Eastside’s electric grid.
Since then, our population
has grown eight-fold and our
economy relies on technologies
the grid wasn’t built for. It’s time
to upgrade — learn how PSE is
working with your community on
a safe, reliable solution.
MARCH 20 2015BELLEVUE REPORTER
Eastside communities have
excelled at conservation. But
our growing economy and
population are out pacing even
our best conservation efforts.
We need to upgrade our electric
grid now. Learn how PSE is
working with your community on
a safe and reliable solution.
OCTOBER 3 2014BELLEVUE REPORTER
The Eastside is growing
faster than any other region in
Washington. Yet, demand for
reliable electricity will exceed
capacity in the near future.
We need a plan to meet this
challenge now. Conservation
alone won’t do it - we need
substantial infrastructure
upgrades. . . .
5. Gallery of Energize Eastside ads in Bellevue Reporter
14
AUGUST 7 2015BELLEVUE REPORTER
The backbone of the Eastside’s
electric grid has not been
upgraded in 50 years. Soon,
demand from new technologies
and our unprecedented growth
will exceed the grid’s capacity.
We must upgrade now. Learn
how PSE is working with your
community on a safe, reliable
solution.
SEPTEMBER 4 2015BELLEVUE REPORTER
It could happen as soon
as 2017. Since the 1960’s
Eastside population has grown
eight-fold, but the backbone
of our electric grid has not had
a major upgrade. We must
upgrade now to avoid longer
and more disruptive outages.
Learn how PSE is working with
your community on a safe,
reliable solution.
JULY 10 2015BELLEVUE REPORTER
In the event of an emergency,
first responders depend on
a reliable flow of electricity.
Yet, the Eastside’s electric
grid is feeling the strain from
unprecedented economic and
population growth. We must
upgrade the grid now. . . .
15
OCTOBER 2 2015BELLEVUE REPORTER
The backbone of the Eastside’s
electric grid has not been
up upgraded since the
1960s. Soon, demand from
unprecedented growth will
exceed the grid’s capacity,
risking longer and more
disruptive outages. Learn
how PSE is working with your
community on a safe, reliable
solution.
DECEMBER 25 2015BELLEVUE REPORTER
Eastside communities
excel at conservation. But
even our best conservation
efforts cannot keep pace
with our growing economy,
population and energy
needs. We need to upgrade
the backbone of the
Eastside’s electric grid now.
JANUARY 22 2016BELLEVUE REPORTER
The backbone of the Eastside’s
electric transmission grid had
its last capacity increase in the
1960s, when our population
was one-eighth the size it is
today. To keep your family warm
and secure, PSE is working
with your community on a safe,
reliable solution.
16
MARCH 25 2016BELLEVUE REPORTER
After listening to and working
with Eastside communities, we
have identified the preferred
route for the capacity upgrade
of the electric grid. It primarily
will follow the existing utility
corridor. This will help us meet
growing demand and minimize
the risk of disruptive outages.
AUGUST 12 2016BELLEVUE REPORTER
The backbone of the Eastside’s
electric grid was last upgraded
over half a century ago. Today,
the aging infrastructure is being
pushed beyond its capacity to
serve our growing 21st century
communities.
The Energize Eastside project
will upgrade the old grid with
modern infrastructure to keep
Eastside lights on.
OCTOBER 7 2016BELLEVUE REPORTER
So much has changed on the
Eastside since the 1960s. Our
population has grown eight-
fold. And new technologies
have driven an economic boom
across the region. But one thing
hasn’t changed - the backbone
of our electric transmission grid
is more than 50 years old.
17
DECEMBER 2 2016BELLEVUE REPORTER
The Eastside’s population
has grown eight-fold since the
1960s - faster than any other
region across our state.
But the backbone of the electric
transmission grid we rely on
is more than 50 years old.
Now this infrastructure is being
pushed beyond its capacity to
serve our communities . . .
DECEMBER 30 2016BELLEVUE REPORTER
It’s been 50 years since the last
major upgrade to the backbone
of the Eastside’s electric
transmission grid. . . Demand
for electricity is growing far
faster than even our most
aggressive energy conservation
efforts can’t match.
We need to act now to avoid
having to plan for rolling
blackouts in the very near future.
JUNE 2 2017 SEPTEMBER 20, 2018
OCTOBER 10, 2018
BELLEVUE REPORTER
Eastside population has grown
eight-fold since the 1960s.
But the backbone of our electric
transmission grid is more than
50 years old.
Energize Eastside will upgrade
the old grid to keep Bellevue’s
18
JUNE 30 2017BELLEVUE REPORTER
The Energize Eastside project
will upgrade the backbone
of the Eastside’s 50-year old
electric transmission grid.
For nearly four years, Puget
Sound Energy has shared
information about the project
with thousands of residents.
This includes an environmental
impact statement process . . .
AUGUST 4 2017BELLEVUE REPORTER
It’s been 50 years since the last
major upgrade of the Eastside’s
electric transmission gird.
Since then, our population has
grown eight-fold, and now the
grid is being pushed beyond its
capacity.
Conservation and new energy
technologies are essential,
but they alone cannot ensure
reliable electricity . . .
AUGUST 18 2017BELLEVUE REPORTER
PSE has selected the final route
for Energize Eastside - the first
major upgrade to the backbone
of the Eastside’s electric
transmission grid in more than
50 years.
19
OCTOBER 6 2017BELLEVUE REPORTER
“Eastside businesses have
thrived by adapting to the
challenges of our fast-growing
region and the global economy.
But our ability to remain
competitive is now at risk
because the backbone of the
local electric grid we all rely on
hasn’t seen a major upgrade
in over 50 years. . .” Kari Magill,
Rowley Properties
NOVEMBER 17 2017BELLEVUE REPORTER
“The Eastside’s economy is
powered by a highly talented
workforce and some of the most
innovative businesses in the
world.
“Our ability to continue
attracting the best depends
so much on the quality of our
region’s infrastructure. . .” Bart
Phillips, OneRedmond
MARCH 23 2018BELLEVUE REPORTER
With completion of a multi-year
environmental review process,
Puget Sound Energy’s Energize
Eastside project is another step
closer to construction.
Energize Eastside will upgrade
the backbone of the old grid to
serve the Eastside’s growing
population. The project will be
safely built and operated . . .
20
APRIL 20 2018BELLEVUE REPORTER
Energize Eastside will upgrade
the backbone of our electric
grid to serve the Eastside’s
growing population and
economy.
PSE evaluated several options
for the best route to locate the
new poles and wires.
We chose to follow the same
corridor as the existing lines. .
JUNE 8 2018BELLEVUE REPORTER
They say that healthy
infrastructure is the backbone of
a healthy economy.
That’s why Energize Eastside is
so vital to the Eastside’s future.
It will provide the first major
upgrade to the backbone of the
Eastside’s electric grid in over
50 years. . .
JULY 20 2018BELLEVUE REPORTER
As temperatures climb during
the summer, increased air
conditioning heats up demand
for electricity.
Energize Eastside will help
meet growing demand by
upgrading the Eastside’s
electric grid with more reliable
infrastructure. . .
21
AUGUST 23 2018BELLEVUE REPORTER
Eastside growth is pushing
demand for electricity beyond
the capacity of the existing
electric grid.
While Eastside communities
excel at conservation - and new
energy-saving technologies
are essential - these efforts
alone cannot ensure reliable
electricity.
We also must upgrade the
backbone of our electric
transmission grid. And that’s
exactly what Energize Eastside
will do - upgrade the grid’s
capacity and keep Eastside
lights on for years to come.
community advisory group
FINAL REPORT
January 2015
prepared by:
Community Advisory Group (CAG) Dissenting Report
Coalition of Eastside Neighborhoods for Sensible Energy CENSE
Excerpt from PSE’s Community Advisory Group (CAG) Minority Report Appendix B
1
Dissenting Report
We, the undersigned members of the “Community Advisory Group” (CAG) for PSE’s Energize Eastside
project, declare our dissent from the recommendations included in the Final Report of the CAG.
The CAG did not truly represent the wishes of the community for the following reasons:
1.CAG members were selected by PSE, not the community.
2.PSE misrepresented the full purpose of Energize Eastside.
3.PSE did not provide real data establishing the need for the project.
4.PSE did not provide a complete list of alternative solutions, and CAG members weren’t allowed
to discuss alternatives.
5.The CAG was not given real choices, because some of the route segments were never viable.
6.Few CAG members participated in critical evaluations.
7.The CAG facilitator was not impartial and frequently pressured members to support the group’s
conclusions.
8.CAG members were not asked to officially endorse the outcome of the CAG process.
The remainder of this report will provide additional detail regarding these eight objections.
1. CAG selection
Composition of the CAG was determined by PSE, not the community. PSE diluted the votes of
residential neighborhoods that had the most at stake. Only one quarter of the voting members
represented neighborhoods, and many affected neighborhoods had no representative. Some members
represented organizations which receive generous donations from the PSE Foundation.
2. The full purpose of Energize Eastside
Documents available from ColumbiaGrid, Seattle City Light, and the Bonneville Power Administration
make it clear that Energize Eastside solves three simultaneous problems: 1) load for PSE, 2) load for
Seattle City Light, and 3) regional grid reliability for Bonneville Power Administration (a federal agency).
According to a 2012 Memorandum of Agreement signed by PSE, SCL, and BPA, transmission lines in the
Puget Sound region can become congested when high local needs coincide with high flows of electricity
to British Columbia, especially when there are faults on BPA’s trunk lines. This is a concern because the
United States is obligated to provide electricity to Canada through the Columbia River Treaty. The large
scale of the Energize Eastside project addresses both local and international electricity needs. However,
Energize Eastside is not the only solution that can do this. It might not even be the most economical
solution, when the project’s impact on the community is considered. Reduced property values along the
entire 18-mile length of the line cause declines in economic activity and tax receipts, which must be
compensated by increasing tax rates on other residents, or decreasing support to people who need tax-
funded services.
PSE never disclosed the whole purpose of the project to CAG members. The company sought to
minimize regional questions by claiming only 3-8% of power flow serves Canada. While this might be
true on a normal day, Energize Eastside is designed to handle extraordinary power flows that occur in
rare emergency conditions. Without a full disclosure of the scope and purpose of the project, CAG
members were not able to accurately represent the views of their constituents regarding the project.
Appendix B: Minority Report
2
3. Eastside need
PSE illustrates the need for Energize Eastside using a graph titled “Eastside Customer Demand
Forecast.”1 This graph has been simplified so it can be easily grasped by the public. It shows demand
growing at an average rate of 1.9% per year, crossing the “System Capacity” line in 2017. According to
PSE, electricity outages will become more likely after that.
CAG members are well-informed individuals who had months to understand the issues. Therefore, we
expected PSE would provide CAG members with more detailed information regarding the need for the
project. There are many questions that members had. How has the Eastside’s electricity demand grown
over time? Why is demand supposedly growing at a much faster rate than population or economic
growth? Why is PSE’s projection of Eastside’s demand growth more than double that of Seattle’s or
Portland’s? Would programs such as Demand Response help mitigate our demand growth?
PSE did not answer these questions, saying that they were outside the scope of the CAG’s stated
mission. The CAG was formed only to provide recommendations on which route the overhead lines
should take through the five Eastside cities. PSE said that community input was not needed regarding
any other aspect of the project.
4. Alternative solutions
CAG members also raised questions about alternative solutions. They wondered why alternatives were
eliminated from consideration and further discussion of alternatives was not allowed.
We believe it is important to list reasonable and viable alternatives to Energize Eastside here, since
these ideas do not appear in the limited Final Report. The alternatives described below address only the
Eastside’s local need. BPA would have to build its own project to solve Canadian reliability issues, at a
lower cost to PSE’s customers.
The issue of cost is of critical importance to many CAG members, especially organizations representing
low-income residents like Hopelink and the YMCA. It is also of interest to businesses that are sensitive
to the cost of electricity. Adding 1-2% to electricity costs for the next 40 years may affect their
profitability. Many CAG members would have supported lower-cost alternatives if PSE had allowed
them to be explored by the CAG.
a.Demand-side Resources. Demand-side Resource (DSR) programs are used by utilities in almost
every state to reduce the stresses of peak load service and avoid construction of new
generation and transmission infrastructure. In the Northwest, Portland General Electric
devotes 14 pages of its latest Integrated Resource Plan to descriptions of various programs,
including a curtailment tariff, residential direct load control, critical peak pricing, and
conservation voltage reduction. Similar programs were studied in a detailed report created by
the Cadmus Group for PSE’s most recent IRP2. Which of these programs is PSE planning to
implement? The IRP says, “Demand response program costs are higher than supply-side
alternatives at this time, and PSE does not currently have a program in place.” Translation: it’s
cheaper to burn coal in a plant located in Colstrip, Montana (one of the dirtiest coal plants in
the nation) that provides nearly 1/3 of the Eastside’s electricity. The economics of cheap coal
1 http://energizeeastside.com/Media/Default/AbouttheProject/2013_1030_Single_Line_Load_Chart_v3.png
2 https://pse.com/aboutpse/EnergySupply/Documents/IRP_2013_AppN.pdf
3
and guaranteed returns for capital improvements like Energize Eastside provide little financial
incentive for PSE to pursue DSR programs.
b.Lake Tradition transformer. For several years before Energize Eastside was conceived, PSE
proposed to meet Eastside demand by adding a new 230/115 kV transformer located at Lake
Tradition (near Issaquah). Additional power would be delivered on existing 115 kV lines to the
Lakeside substation. PSE now claims that this solution causes other transformers to overload in
power flow simulations conducted by the company. However, these simulations include the
surge of electricity caused by faults in BPA’s trunk lines. If BPA were to solve those problems
with their own project, Lake Tradition might become a viable solution with much lower costs
and community impacts than Energize Eastside.
c.Upgrade 115 kV lines. It’s possible to use thicker wire and higher capacity transformers on
existing lines to increase capacity by approximately 29%. That is enough to delay further action
for at least a decade. During that time, it’s likely that technologies such as grid batteries,
distributed generation, and increasing efficiency will make other solutions possible. This will be
cheaper than Energize Eastside, and better for the environment. Upgrading the lines at their
current voltage will spare nearly 8000 mature trees that must be cut or removed along the Oak
or Willow routes to accommodate a 230 kV line (according to PSE’s counts). There is no record
that PSE studied this option. It was never mentioned during CAG meetings.
d.Gas powered plant. PSE studied the possibility of meeting Eastside needs using a gas-powered
generation plant. They dismissed this option in 3 sentences in their Solutions Study. Two of
the potential sites for the plant were judged to be too difficult to permit, although this
determination was made solely by the company without input from city officials. A third site
was dismissed because it would require construction of transmission lines. Neither the CAG
nor the cities were given further details about the costs of such a plant, where the transmission
lines would be located, how reliability of local generation compares to remote generation, how
it impacts the community, or how it might help reduce use of coal that creates much higher
emissions of atmospheric carbon, mercury, and sulfur.
e.Micro-grids and small turbines. A national expert says that the Puget Sound area is an ideal
place to use small gas turbines to inexpensively and incrementally serve peak loads. There is
no record that PSE studied this option.
f.Grid batteries. PSE says grid batteries are likely to play an important role in the future. The
company already has a pilot battery project in Bainbridge. But according to PSE, batteries are
too expensive and too risky to use at this time. The company says it can forecast future
demand, but it can’t forecast the viability of technology solutions that might address that
demand.
We believe that one or more of the above solutions would address Eastside’s demand and reliability
needs for many years at a lower cost than Energize Eastside, allowing us time to develop clean,
sustainable solutions rather than rushing a project that is out of scale for our needs as well as our
beautiful scenery.
4
For completeness, we will mention two other alternatives that CAG members were interested in.
Both of these would solve Canadian reliability issues as well as Eastside need, but for a considerably
higher price tag:
g.Underground lines. We list this alternative because it is the most frequently asked question by
the public: “In this day and age, why can’t we bury our transmission lines?” PSE has made this
option politically impossible, due to a tariff the company proposed to the Washington Utilities
and Transportation Commission (and which the UTC subsequently adopted). The tariff requires
each community who requests an underground line to bear the high cost of underground
infrastructure on their own. With the exorbitant costs estimated by PSE, this is not a realistic
option for any community. While this tariff seems reasonable for local distribution lines, we
hope its application to regional transmission lines will be revisited by the UTC.
h.Underwater lines. There are many examples in the U.S. of high-voltage transmission lines
being placed in lakes, rivers, and bays. This technology is maturing rapidly. PSE said they
would write a white paper on this alternative. The white paper was not released in time for
consideration by the CAG.
5. No real choices
It should be no surprise that the final routes selected by the CAG mostly follow the existing transmission
corridor. This is the result PSE expected from the beginning, and was confirmed by a senior PSE
engineer who said the process of route selection was needed to help the public feel like they were
involved in the project.
In particular, the choice between the L and M segments was a false choice. The L segment was never a
legally viable option due to well-known conflicts and impacts. PSE should have known this. It is also
highly questionable that the B segment was viable, due to the large amount of new right-of-way that
would need to be acquired to construct that segment.
We believe the CAG process was more about PR for PSE than real choices for the community.
6. CAG participation
In several cases, only a few CAG members participated in important evaluations. For example, at the
July 9th meeting, it was revealed that only 8 CAG members (less than a third of the CAG membership)
participated in an evaluation process to eliminate potential routes. These low participation rates didn’t
occur because CAG members were lazy or on vacation. Many of the residential representatives refused
to participate because they objected to the process.
7. CAG process
The facilitator for the CAG was a contractor hired by PSE, harming the appearance of impartiality. The
facilitator appeared to have two goals: 1) produce a route recommendation that isn’t too onerous to
PSE, and 2) achieve this result using “consensus building” techniques.
Unfortunately, these goals were achieved by pressuring or cajoling CAG members to abandon their
preferences and join the consensus view. For example, the facilitator would often say to a reluctant
member, “Could you live with the emerging consensus of the group?” Or, “Do you want your name to
be listed as the dissenting vote?” There were many times when a dissenting member would reluctantly
1
SECTION 6: INTRODUCTION
Alternatives
Recent electrical demand forecasts do not indicate a need for additional electrical infrastructure on the
Eastside. If demand does start to increase, incremental site-specific technologies would be far more cost
effective and less damaging to communities and the environment than Energize Eastside.
PSE’s evaluations of alternative technologies were outdated even at the time of analysis. In the past
six years, many utilities have invested in cost-effective technologies that PSE dismissed. PSE erred by
evaluating each technology (such as batteries, demand response, and electrical efficiency) as a stand-
alone solution rather than as an element of an integrated resource approach.
In 2019, the Washington legislature passed the Clean Energy Transformation Act (CETA). This landmark
law seeks to achieve a cleaner energy grid using renewable resources, smart technology, and conservation
policies that will also reduce Eastside peak demand. It makes no sense for customers to pay for a
transformed grid as well as a 20th-century transmission line that addresses the same needs.
An additional report examines the under-explored option of using the existing 230 kV transmission lines
owned by Seattle City Light that closely parallel PSE’s power lines through Renton and much of the
Eastside.
Table of Contents
6.1 Supreme Court Decision on “Demand Response” Written by Justice Kagan
Jan Medley, CENSE
6.2 Bonneville Power Administration Decison to Cancel I-5 Corridor Project
Karen Esayian, CENSE
6.3 ColumbiaGrid and Seattle City Light Connection
Karen Esayian, CENSE
CENSE REPORT / Jan Medley
Supreme Court rules “Demand Response” receive same rates for
conserving electricity as companies earn for generating electricity
Abstract
A 2016 Supreme court decision written by Justice Elena Kagan1 elegantly explains the economic value of
“demand response,” a strategy where large users of electricity are compensated for reducing power
consumption during periods of peak electrical demand. The Court’s arguments support the position that the
authority of the Federal Energy Regulatory Commission (FERC) should be upheld to pay large users of
electricity the same rate to reduce power consumption during periods of peak electrical demand as it would
cost companies to generate enough electricity to meet demand.
The regulatory approach, known as “demand response,” lowers costs for consumers and lessens the risk of
system failures that can cause blackouts. As Justice Elena Kagan wrote for the majority in the 6-to-2
decision:
“That practice (demand response) arose because wholesale market operators can sometimes
— say, on a muggy August day — offer electricity both more cheaply and more reliably by
paying users to dial down their consumption than by paying power plants to ramp up their
production.” 2
The Court’s decision rejected a claim by the Electric Power Supply Association (EPSA) that FERC’s
regulation of demand response interfered with retail rates and thus extended beyond FERC’s authority to
regulate only wholesale rates.
The Court also rejected EPSA’s second argument that even if the commission had the authority to issue
the regulation, it had acted arbitrarily in adopting it.
Clean energy advocates celebrate the decision, stating that it places demand response on a level playing
field with power plants and will spur investment and innovation leading to a cleaner power grid.
Table of Contents
1. What is Demand Response
2. State vs. Federal Authority
3. Conclusion
1 Fed. Energy Regulatory Comm'n v. Elec. Power Supply Ass'n, 136 S.Ct. 760, 193 L.Ed.2d 661 (2016)
2 https://www.supremecourt.gov/opinions/15pdf/14-840-%20new_o75q.pdf. p 2
1. What is Demand Response
Demand response pays large energy consumers (universities, manufacturers, large office buildings, etc.) to
reduce energy during times of peak demand. For electric grid operators and utilities, who must provide its
customers with cost-effective, consistent and reliable electricity, demand response is a much cheaper
alternative than paying power providers premium prices to provide the system with more electricity.
Because demand response is such a cost-efficient way to meet peak demand, the savings can be passed
along to all energy consumers.3
Since 1935, as part the Federal Power Act, the Federal Energy Regulatory Commission has had the
authority to regulate the demand response market.4 FERC manages the compensation related to demand
response for the wholesale electricity markets, in which electricity is competitively bought and sold.
In March 2011, FERC amended the Federal Power Act ruling that companies delivering demand response
services should receive the same rates for conserving electricity as companies earn for generating electricity. 5
2. State vs. Federal authority
In response, the Electric Power Supply Association (EPSA), representing electric power producers, took
FERC to court and challenged the order, arguing that FERC is authorized to regulate wholesale, but not
retail electricity transactions.6
In 2014, a D.C. Circuit court sided with the EPSA and found that states, not the federal government, have
exclusive jurisdiction over the demand response market.7
In 2016, Justice Kagan rejected that argument, stating that the regulation affected retail sales only
incidentally. She wrote:
“It is a fact of economic life that the wholesale and retail markets in electricity, as in every other
known product, are not hermetically sealed from each other. To the contrary, transactions that
occur on the wholesale market have natural consequences at the retail level. And so too, of
necessity, will FERC’s regulation of those wholesale matters.” 8
Justice Kagan rejected a second argument from the challengers: that even if the commission had the
authority to issue the regulation, it had acted arbitrarily in adopting it.
“The commission, not this or any other court, regulates electricity rates” The disputed question
here involves both technical understanding and policy judgment. The commission addressed
that issue seriously and carefully, providing reasons in support of its position and responding to
the principal alternative advanced. . .
3 https://www.energysmart.enernoc.com/why-does-supreme-court-care-about-demand-response
4 http://fortune.com/2016/01/25/supreme-court-demand-response-ruling/
5 https://www.ferc.gov/EventCalendar/Files/20110315105757-RM10-17-000.pdf
6 http://fortune.com/2016/01/25/supreme-court-demand-response-ruling/
7 Ibid
8 https://www.supremecourt.gov/opinions/15pdf/14-840-%20new_o75q.pdf p.18
“It is not our job to render that judgment, on which reasonable minds can differ. Our important
but limited role is to ensure that the Commission engaged in reasoned decision making — that
it weighed competing views, selected a compensation formula with adequate support in the
record, and intelligibly explained the reasons for making that choice.” 9
3. Conclusion
To clean energy advocates, this case epitomizes the confrontation between those who cling to the “fossil
fuel-centric 20th century centralized grid” and those who seek a more decentralized, resilient, nimble, and
diverse 21st century grid that includes a wide range of demand-side resources, including rooftop solar, wind
power, batteries, demand response, and energy efficiency.10
9 https://www.supremecourt.gov/opinions/15pdf/14-840-%20new_o75q.pdf p.33
10 https://www.energysmart.enernoc.com/why-does-supreme-court-care-about-demand-response
1
CENSE REPORT / Karen Esayian
Bonneville Power Administration Decision to
Cancel I-5 Corridor Project
Overview
The final environmental impact statement on BPA I-5 Corridor project was released in February of 2016. At
that time BPA's Elliot Mainzer promised that BPA would conduct additional analyses of financial forecasts,
planning assumptions and commercial practices.
On May 18, 2017 the BPA announced that it would not build the proposed 80-mile, 500kV transmission line
that would have stretched from Castle Rock, WA. to Troutdale, OR. The decision reflects BPA's
commitment to "taking a more flexible, scalable and economically and operationally efficient approach to
managing its transmission system."
BPA's decision embraces grid solutions that rely more on distributed resources and modern tools of
technology rather than infrastructure builds.
Attachment:
Elliot Mainzer letter of May 17, 2017
2
Department of Energy
Bonneville Power Administration
P.O. Box 3621
Portland, Oregon 97208-3621
EXECUTIVE OFFICE
May 17, 2017
In reply refer to: A-7
To parties interested in the I-5 Corridor Reinforcement Project:
The Bonneville Power Administration has completed an extensive analysis of the need for the I-5
Corridor Reinforcement Project and decided not to build the proposed transmission line. This
decision caps an intensive review that included one of the most comprehensive public engagement
processes BPA has ever undertaken. Much has changed since BPA proposed the transmission line,
and I have concluded that constructing the line would not fulfill our commitment to making the right
investment at the right time.
BPA proposed the I-5 Corridor Reinforcement project in 2009 as a solution to preserve reliability,
meet existing contract requirements, reduce curtailments, and serve demand on the transmission
system – which at the time was growing. More recently, BPA considered the size, local impacts and
increasing costs of the proposed project, which prompted us to take a hard look at all of our
transmission practices and analytics, including a fresh look at load (electrical demand ) forecasts,
generation changes and market dynamics.
As a result of this comprehensive review and the inherent difficulties associated with building this
line, we are taking a new approach to managing congestion on our transmission grid. My decision
today reflects a shift for BPA – from the traditional approach of primarily relying on new
construction to meet changing transmission needs, to embracing a more flexible, scalable, and
economically and operationally efficient approach to managing our transmission system. We will
also increase our reliance on advanced technology, robust regional planning, industry standard
commercial practices and coordinated system operations.
Going forward, we will leverage the tools of the modern energy economy to maximize the value of
federal assets for our customers and the broader region. Through the transformational efforts
described below, we will maximize grid availability, use and reliability to support economic growth
along this and other important transmission corridors.
To those who have been with us every step of the way, I would like to acknowledge and thank you
for the time you invested in reading our material, attending meetings and providing comments as we
took nearly nine years at significant cost to complete a comprehensive review of the project and its
potential impacts. This was a difficult decision, compounded by many technically complex and
moving parts, and I understand the uncertainty this created for the landowners and homeowners
along the route alternatives. Though the process was lengthy, I simply could not risk making a
decision of this magnitude without first acquiring the best possible information, and I can say with
confidence today that Bonneville is making the best decision for the region.
3
2
A summary of our in-depth review
In September 2016 we convened an independent review panel of industry experts to review study
assumptions, methodologies, results and assessments supporting the need for the I-5 Corridor
Reinforcement Project. The panel concluded that “the proposed 500-kV line could meet the
reliability needs…, but that line will add far more capacity than is required for reliability alone.” We
agreed.
We also observed changes to our regional power system and transmission reliability planning
standards. For example, the proposed transmission line would have helped manage the summer
congestion impacts of power that flows north to south across the South of Allston flowgate – the
portion of the transmission grid this project would have augmented. Contributing to this congestion is
power from the coal-fired generators in Centralia, Washington, that are required by state law to close
in 2020 and 2025. This should help relieve summer congestion, depending on where replacement
generation is sited. Additionally, new national reliability regulations took effect in January 2016.
These reliability standards changed the way line limits are calculated. This new standard will
increase the potential for other regional utilities to consider infrastructure upgrades or additions that
would provide additional transmission capacity and relieve congestion in this corridor.
Further, recent trends indicate that load growth has generally slowed relative to what was assumed in
prior studies. However, we are also seeing the potential rapid development of large loads associated
with the technology sector that could add hundreds of megawatts of baseload demand in a
concentrated geographic area. Meeting the needs of such sudden and unexpected loads is a
demanding task, whether through builds, technology or business changes. In this case, where we
have decided against building the proposed project, Bonneville and its regional utility partners will
need to maximize the use of modern approaches to grid design to meet load growth and economic
development objectives.
Moving forward
We will be transforming our approach to adding transmission capacity by making more scalable and
flexible investments in the federal transmission system. Focused effort will be given to integrated
coordination of operations, transmission planning and commercial processes to support our product
portfolio. Bonneville will need to establish a new level of risk tolerance to maximize the use of its
transmission assets while meeting customer needs.
We have already put in place or are considering the following transformational approaches:
Available transmission capacity calculations will be modified to take a more risk-informed
profile, potentially enabling greater sales on the existing transmission system.
In alignment with FERC pro forma tariff and industry standards, BPA will review and may
modify its commercial transmission products and services.
New state awareness tools and use of generation redispatch together with increased
operational connectivity with the California Independent System Operator will ensure more
effective real-time monitoring. The incorporation of real-time data and analysis into the
calculation of system limitations may release excess capacity while maintaining reliability.
Enhanced visibility and control of loads, resources and flows (including market flows) will
4
3
allow more accurate, effective and reliable management of the transmission system.
Non-wires measures to manage generation and loads to reduce peak congestion will launch
this summer. We also will look to use cutting-edge grid technologies such as battery storage
and flow control devices to proactively manage congestion and further extend operational
capacity of the existing system.
We will work closely with the region’s other utilities, regional planning organizations and
economic development organizations to convey the economic and operational implications of
siting loads and generation resources in different areas. We will incentivize new load cente rs
and resources to locate in areas that will make the best use of existing transmission capacity
and minimize costs to them and to the region’s electricity consumers.
The decision to not build the I-5 Corridor Reinforcement Project does not mean we and others will
not need to build new lines in the future to provide additional transmission capacity in the Northwest.
The region inevitably will need to build new lines, as well as rebuild existing, aging lines. But
through this decision today, Bonneville is committing to taking a forward-looking approach with its
investment decisions, and the region can be certain that BPA will seek first to use efficiencies and
build at the smallest scale possible to meet our customers’ needs, ensuring Bonneville remains a
reliable engine of economic prosperity and environmental sustainability in the Northwest.
Understanding the certainty of business dealings our customers require, I want to reinforce
Bonneville’s commitment to offering terms and conditions of transmission service that align with
FERC’s pro forma tariff as much as possible; and indeed, we will be moving closer to that paradigm.
Work is already underway to craft solutions and design our way forward. Within a month, we expect
to begin discussing these new approaches with our transmission customers and other stakeholders.
During these discussions, Transmission Services will explain how we will advance our strategy and
provide options for those seeking service across the South of Allston flowgate.
Thank you again for working with us as we take steps toward a more innovative transmission grid,
updated business practices and improved regional coordination. This work is indicative of our
commitment to working collaboratively with all of our stakeholders to deliver the best value for the
region.
Sincerely,
/s/ Elliot E. Mainzer, May 17, 2017
Elliot E. Mainzer
Administrator and Chief Executive Officer
1
CENSE REPORT / Karen Esayian
ColumbiaGrid Connection & Seattle City Light
Abstract
The formation of the ColumbiaGrid in 2006 was intended to facilitate multi-system transmission planning
between its members. The Memorandum of Agreement signed on January 31, 2012 between the
Department of Energy/Bonneville Power Administration, the City of Seattle/City Light Department and
Puget Sound Energy states "transmission congestion affecting the Puget Sound Area interconnection is a
shared problem."
A single transmission planning process was implemented beginning in 2015. In July of 2015 a report was
published laying out a 10 year plan. Included in this plan was the precursor of what is known today as
Energize Eastside. Somewhere along the line, this shared multi-system planning with ColumbiaGrid
members was forgotten.
Table of Contents
1. ColumbiaGrid Members and Working Agreements
2. Questions on the Use of Seattle City Light Power Poles for Energize Eastside
3. Regional Reliability Need or Local Reliability Need?
4. Conclusion
5. Appendix
1. ColumbiaGrid Members and Working Agreements
"ColumbiaGrid was formed with seven founding members in 2006 to improve the operational efficiency,
reliability, and planned expansion of the Northwest transmission grid. Eleven parties signed ColumbiaGrid’s
Planning and Expansion Functional Agreement (PEFA) to support and facilitate multi-system transmission
planning through an open and transparent process. In addition, starting in 2015, ColumbiaGrid has
implemented a single transmission planning process that satisfies the requirements under both PEFA and
2
Order 1000. This leads to a more comprehensive process which includes a wide range of studies with
different purposes."1 Currently listed as ColumbiaGrid members and participants are:
• Avista Corporation
• Bonneville Power Administration
• Chelan County PUD
• Grant County PUD
• Puget Sound Energy
• Seattle City Light
• Snohomish County PUD
• Tacoma Power
• Other Contributors are: Cowlitz County PUD, Douglas County PUD
2015 was the first year that ColumbiaGrid implemented its planning process under the PEFA/Order 1000
Functional Agreements. In the July 2015 System Assessment Report, it is explained that the process
involves a Ten-Year Plan and comprises a list of projects that planning participants are committed to build
in the coming years to address known transmission deficiencies.
In the 2015 list of proposed projects this "Eastside 230/115 kV Transformer and conversion of
Sammamish-Lakeside-Talbot Line to 230 kV which provides additional transformer capacity for the
Bellevue area and additional transmission capability through the Puget Sound area.2 was listed. This was
an immediate precursor to Energize Eastside as currently proposed by PSE. This point is made clear in an
April 30, 2015 letter from the Department of Energy, Bonneville Power Administration to Larry Johnson.3
PSE is only one of several members of the ColumbiaGrid who are committed to a multi-system
transmission plan in the Pacific Northwest. With regard to the Puget Sound area interconnection, the
Memorandum of Agreement signed on January 31, 2012 (attached to a FOIA letter from Dept. of Energy to
Mr. Larry Johnson dated April 30, 2015) between the Department of Energy/Bonneville Power
Administration, the City of Seattle/City Light Department and Puget Sound Energy, details the cooperation
expected of these parties in preserving the reliable operation of the Puget Sound Area interconnection.4
The document further states that "transmission congestion affecting the Puget Sound Area interconnection
is a shared problem,"5
1 https://www.columbiagrid.org/client/pdfs/2015SAfinal.pdf
2 https://www.columbiagrid.org/client/pdfs/2015SAfinal.pdf page 59
3 attachment: letter dated April 30, 2015 from Department of Energy to Larry Johnson
4 https://www.columbiagrid.org/client/PEFA-conformed-copy.pdf. page 3
5 https://www.columbiagrid.org/client/PEFA-conformed-copy.pdf. page 2
3
Another key member of the ColumbiaGrid is Seattle City Light. This is a municipal electric utility, owned by
the residents of Seattle and run by the City’s elected officials. The Utility serves a population of almost
700,000 people living in a 130 square-mile area, including the City of Seattle and several adjoining
jurisdictions. To serve these customers, City Light owns, maintains, and operates a multi-billion-dollar
physical plant. The physical plant includes:
• A distribution system with 14 major substations and more than 2,500 miles of overhead and
underground cable;
• A generation system comprising seven hydroelectric plants on the Skagit, Cedar, Tolt, and Pend
Oreille Rivers with a combined capacity of almost 2,000 megawatts;
• 650 miles of high-voltage transmission lines linking these plants to Seattle 6
6 http://www.seattle.gov/financedepartment/1116adoptedcip/documents/SEATTLE_CITY_LIGHT.pdf
4
2. Questions on the Use of the Seattle City Light Power Poles for
Energize Eastside
As the map below illustrates, several miles of the SCL transmission line are actually located on the
Eastside, running from the northern border of the proposed Energize Eastside project in Redmond through
Bellevue and Newcastle and into Renton, the southern border of the proposed PSE 230kV transmission
line.
Location of Seattle City Light Transmission Line on Eastside
Figure 1 SCL represented by dashed black line parallels the route of Energize Eastside
through much of Bellevue.
5
One of the alternatives not fully addressed by PSE for the proposed Energize Eastside project is the use of
Seattle City Light power poles for the 230kV transmission lines.
Uzma Siddiqi of Seattle City Light, in a letter to Nichols Matz of the City of Bellevue dated June 2, 2014,7
stated that SCL preferred not to use SCL's transmission lines for PSE's native load service needs.
In 2017 the question was again asked about using the existing SCL transmission towers to support the
purportedly needed 230kV PSE transmission lines. The letter to Mr. Larry Weis, Seattle City Light, from
Larry Johnson dated March 20, 2017 asked that question.8 The response was written by Sephir Hamilton,
Seattle City Light, on April 25, 2017. Mr. Hamilton replied that "PSE has never formally requested
transmission service on Seattle City Light's Eastside transmission lines." "Obviously, if PSE would make a
formal request for transmission service on Seattle City Light's Eastside lines, Seattle City Light would
respond appropriately."9
The letter also contends "Energize Eastside project is not subject to the Order No. 1000 because it is
located completely within Puget Sound's service territory." Further, "neither Puget Sound nor any eligible
party requested to have the project selected in the regional transmission plan for purposes of cost
allocation."10
It is apparent from these attached letters that the use of the Seattle City Light transmission line towers was
an alternative not fully researched nor pursued by PSE in their planning.
3. Regional Reliability Need or Local Reliability Need?
In original proposals for Energize Eastside by PSE, studies were included that described 1,500 MW flow to
Canada as a necessary component to this proposal.
This would indicate that Energize Eastside was developed as a regional plan.
In the Memorandum of Agreement signed on January 31, 2012, by representative parties from Seattle City
Light, Bonneville Power Administration and Puget Sound Energy, it specifies the memorandum as relating
to the Preferred Puget Sound Area Plan of Service Projects and Cost Allocation. There is emphasis on
sharing the problems in the Puget Sound Area, with projects and cost sharing arrangements provided as
appropriate. 11 Under the title: Preliminary Capital Cost Allocation, it is stated that "Parties agree to share in
the capital costs of Preferred Plan Projects." For Puget (Sound Energy) plan projects, it is stated that "BPA
7 attachment: letter dated June 2, 2014 from Uzma Siddiqi, Seattle City Light, to Mr. Nicholas Matz
8 attachment: letter dated May 20, 2017 from Larry Johnson to Larry Weis, General Mgr. Seattle City Light
9 attachment: letter dated April 25, 2017 from Sephir Hamilton to Mr. Larry Johnson
10 attachment: letter dated April 25, 2017 from Sephir Hamilton, Seattle City Light, to Mr. Larry Johnson
11 attachment: Memo of Agreement obtained through FOIA from Dept of Energy, Bonneville Power Admin. page 2
6
and Seattle City Light shall each pay to Puget an amount equal to one-third of the adjusted projected
capital cost of the Maple Valley to SnoKing Reconductor Project."12
All this leads to the conclusion that Energize Eastside, labeled as the Maple Valley to SnoKing
Reconductor Project, is a regional project.
There are questions that need to be answered: is Energize Eastside a regional project or is it for local
service needs? If it is for local service needs, why is the 1,500 MW flow to Canada part of the original
proposal? Given the Memorandum of Agreement stipulations, why is PSE not requesting the cost of the
project to be shared by BPA and SCL? The arrangement pursued by PSE only places the cost of the
project on the PSE rate base - the residents of the Eastside.
In the 2008 Acknowledgement Letter to PSE on the 2017 Integrated Resource Plan, the WUTC addresses
Energize Eastside with the comment that "it is still not clear if a joint utility analysis of all available
transmission and potential interconnections in the Puget Sound region might solve the Energize Eastside
reliability issues." A further criticism: "PSE's choice not to provide modeling data to stakeholders with
Critical Energy Infrastructure Information clearance from FERC13
4. Conclusion
A cooperative road plan was in place among ColumbiaGrid members for solving any transmission
deficiencies on the Eastside. It is clear that PSE did not fully research or pursue use of the Seattle City
Light transmission line towers for any purported reliability needs.
12 attachment: Memo of Agreement obtained through FOIA from Dept of Energy, Bonneville Power Admin. page 6
13
https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=5&ved=2ahUKEwiTirrhocPdAhUjGz
QIHdN2BmMQFjAEegQIBhAC&url=https%3A%2F%2Fwww.utc.wa.gov%2F_layouts%2F15%2FCasesPu
blicWebsite%2FGetDocument.ashx%3FdocID%3D1743%26year%3D2016%26docketNumber%3D16091
8&usg=AOvVaw3yNtZgvlPKizND-bXT6fcQ page 10
7
5. Appendix A
8
9
Full 98-page Report @ https://www.columbiagrid.org/client/PEFA-conformed-copy.pdf
1
CENSE REPORT / Karen Esayian
Impacts to Tree Canopy
Abstract
A lot has changed since PSE first proposed Energize Eastside five years ago. During that time, alternatives
to meet peak demand have been developed and implemented across the United States that would not
have the devastating impact to the environment as transmission lines. In 2019, Washington State enacted
the Clean Energy Transformation Act (CETA). This bears on Energize Eastside because it would require
PSE to invest in cleaner sources of electricity and smart technology to address demand peaks.
The proposed transmission line will require the removal of 3600 trees along an 18-mile corridor
predominately in residential areas1. In the Renton segment, the permit under consideration, 350 trees
would be removed: 58 percent of tree canopy. These trees must be removed to accommodate new poles
and transmission lines, but also to adhere to rules limiting vegetation encroachment onto electric
transmission line corridors. Removal of these trees not only creates an unacceptable environmental impact,
but violates plans and policies to protect tree canopy in Renton and other cities. Suggested mitigation of
planting small shrubs and trees, in place of mature, established trees would significantly reduce the amount
of carbon sequestration.
Recognizing these technological and legislative developments and denying PSE’s application to build
Energize Eastside would have a positive impact on the Eastside’s environment, including Renton.
Table of Contents
1. Tree Removal as Planned by PSE for its Transmission
2. Renton Policies Related to Tree Canopy
3. Replacement Plantings Insufficient to Mitigate Tree Loss
4. Conclusion
5. Appendix
1 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_4.4_plants_and_animals.pdf page 12
2
1. Tree Removal as Planned by PSE for its Transmission Lines
The proposed new transmission line will require the removal of trees for two reasons. First trees will be
removed to allow for the new towers for transmission lines. Second, and more substantially, the new
230 kV lines will require the removal of trees to provide a clear area to prevent interference by vegetation,
i.e. establishing so called “clear zones.” A number of these trees are considered significant. The
percentage of trees subject to removal ranges between 41% and 80% within the PSE proposed alignment.
This includes:
• Renton - 58% 2
• Richards Creek substation - 41%
• Redmond - 80%
• Bellevue north - 60%
• Bellevue central - 70%
• Bellevue south - 68%
• Newcastle - 64-68%
These numbers reflect tree removal projected for construction of the PSE 230kV transmission line. The
corridor as it currently exists has regular maintenance checks for vegetation with very few trees removed
because the predominate zone-use districts are residential, with well-maintained properties.
With the PSE proposal, in Renton 350 trees would be removed, of which 250 were determined to be
significant, 3 from critical areas and 38 from critical area buffers.3 The FEIS references “significant tree” as
defined by the trunk diameter (measured at 4 feet above existing ground.) In Bellevue, a significant tree has
at least, an 8-inch diameter; in Newcastle, at least, an 8-inch diameter for an evergreen or 12-inch diameter
for a deciduous tree; in Renton, at least a 6-inch diameter tree or, at least, an 8-inch diameter for alder or
cottonwood trees.
The current PSE Application has been bifurcated to include only the areas in Bellevue south, Newcastle
and Renton. Should PSE apply for applications covering Bellevue north and Redmond, an even greater
tree canopy would be impacted.
PSE asserts that the project is needed because of growth in Bellevue’s downtown and commercial areas.
But single-family residential land use predominates in the zones for the proposed 230kV transmission line
and towers. From the EIS: "Based on a linear-feet breakdown of the study area for PSE's proposed
alignment, the most common existing land uses include:"
2 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_4.4_plants_and_animals.pdf page 10-11
3 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_4.4_plants_and_animals.pdf pages 17-22.
3
• Residential (single-family and multi-family) (49%)
• Vacant land (17%)
• Industrial (9%)
• Institutional (9%)4 5
Substantially fewer trees would be removed if an alternative to the proposed 230kV transmission line were
implemented, such as energy storage and/or conservation. Alternatives should be located in commercial or
industrial areas as suggested my many residents commenting in the EIS, including CENSE.
It has also been documented that a mature tree canopy assists in carbon dioxide exchange, improves
water quality, reduces air pollution and reduces energy use (shade in summer months; wind reduction in
the winter). Trees constitute a useful weapon in the battle over greenhouse gases and climate change. 6 7
This tree removal not only impacts the character and appearance of residential areas, but these trees offer
habitat to many bird species and other small animals. The proposal for "clear zones" prescribed would
decimate residential landscapes - many with 40-50-year-old well maintained trees, water features, rock
gardens and specialty plantings, slow-growing alpine trees that in 40 years are just reaching 15-20 feet,
professional landscape plans and even vegetable gardens. The “Energize Eastside” Vegetation Analysis
notes that while some trees and other vegetation may be planned as mitigation, any newly planted trees
are limited to those that do not exceed certain heights.
2. Renton Policies Related to Tree Canopy
From Renton’s Staff Report to the Hearing Examiner on tree retention (page 6)
“The city’s adopted Tree Retention and Land Clearing Regulations (4-4-130) exempts maintenance
activities, including routine vegetation management and essential tree removal for public and
private utilities, road, right of way and easements in public parks.”
The Renton Staff Report recommends approval of the application on the basis of a final Landscape and
Tree Replacement Plan.
Of cities on the Eastside, Renton has the third lowest percentage of tree canopy, making it even more
important to preserve existing trees.
4http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_4.1_land_use_and_housing.pdf page 3
5 http://powerline-zoning.s3-website-us-west-2.amazonaws.com
6 http://www.naturewithin.info/urban.html
7 https://www.nature.com/news/tree-growth-never-slows-1.14536
4
Figure 1 Twenty nine percent of Renton’s land area is covered by tree canopy.
3. Replacement Plantings Insufficient to Mitigate Tree Loss
Mitigation measures are inadequate to offset the loss of trees as described above. Any substitute measures
are limited because no trees will be planted that would be of the size and breath of existing trees.
Moreover, some mitigation proposals call for new plantings some distance from the corridor, or simply the
payment of money, a pay in-lieu fee to the cities, providing no relief for adjacent property owners and
neighborhoods.8
It is also important to identify that the “Energize Eastside” project is proposed to deal with a limited time of
peak power shortages, in very short periods of very high or low temperatures. As discussed elsewhere in
this notebook, it is likely that within the next decade that other means of addressing possible peak power
shortfalls will be put into place. However, the tree loss will essentially be permanent. The Department of
Ecology EIS comment letter of June 19, 2015 (Fig. 6) expressed concern that this proposed project
would permanently result in the conversion in the plant community from a tree strata to a shrub strata. All
habitat functions would be permanently affected by the tree removal of between 41% and 80% along the
Eastside.
8 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/section_3.4_plants_and_animals.pdf page 33.
5
4. Conclusion
PSE’s proposal for Renton would result in a 58% loss of trees, along with ground vegetation, principally in
single family residential areas. Such losses are contrary to established city policy. The significant loss of
trees valued for their natural features, habitat, shading and cooling cannot be justified under the
circumstances. Mitigation for the loss of substantial tree canopy is not sufficient to off-set these losses. The
use of alternatives such as energy storage would not require the extensive tree canopy removal. The loss
of substantial numbers of significant trees, when combined with the overall environmental impact
supports denial of this proposal under SEPA guidelines.
6
PHASE 2 DRAFT EIS PAGE 3.4‐2
CHAPTER 3 LONG‐TERM (OPERATION) IMPACTS AND POTENTIAL MITIGATION MAY 2017
PLANTS AND ANIMALS
Source: King County, 2015; Ecology, 2014.
Figure 3.4-1. Study Area and Land Cover for Plants and Animals
5. Appendix
Study area and land cover for plants and animals 9
Figure 2 Path of transmission line would impact areas with 50-80% vegetation cover, eliminating biomass
important for CO2 sequestration.
9 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/section_3.4_plants_and_animals.pdf
1
CENSE REPORT / Karen Esayian, Deron Ferguson
Impact on Scenic and Aesthetic Views
Analysis Extended Beyond PSE Study Area
Abstract
Dean Apostol, scenic and environmental consultant, summarizes the principles of assessing visual impacts
and determining the level of significance in his publication, The Renewable Energy Landscape.1 The
normal criteria used is:
Visibility + Negative Visual Contrast + Sensitivity = level of impact
Visibility refers to how much a view is seen and by how many people. Negative visual contrast is measured
against the “desired visual character which can be natural or cultural or a combination of both.” Sensitivity
includes what is expected to be seen, how long it is viewed and the importance of the viewpoint to the
observer. The land on the Eastside, where PSE proposes to construct a 230kV transmission line, has
multiple locations that afford scenic views, including the Renton Highlands. The area is also dominated by
residential land use zones, so the concept of scenic visual impacts is an important consideration.
Table of Contents
1. Data on Population Affected by Proposed Energize Eastside
2. The Reality of Scenic Visual Impacts
3. View Duration and Distance
4. The Aesthetic Viewpoint
5. Conclusion
6. Appendix: Data Methodology and Photos
1
https://www.researchgate.net/publication/307633587_The_Renewable_Energy_Landscape_Preserving_Scenic_Views_in_our_S
ustainable_Future
2
1. Data on Population Affected by Proposed Energize Eastside
The study area for the visual analysis of the Energize Eastside project was limited to 0.25 miles from the
edge of the existing transmission corridor. Areas west of I-405 were excluded. The EIS stated: "while the
project would be visible at greater distances, significant visual impacts are not probable given the project's
scale relative to its largely mixed urban context.”2 This statement does not acknowledge the predominant
residential land use in the proposed transmission corridor. Given the numerous locations known for their
scenic views on the Eastside, for example the Renton Highlands - the basis of this analysis is shortsighted.
Consider this analysis from the map illustrating the population in block groups according to the distance
from the transmission corridor.
The number of residents (2010 census) whose scenic or aesthetic views would be impacted along the
originally proposed 16 miles of the Energize Eastside Project would be3:
• 122,818 residents at 0.5 miles, and
• 184,434 residents at 1 mile from the powerline and
• 325,562 residents that are within 2 miles of the transmission line.
2 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/section_3.2_scenic_views_and_the_aesthetic_environment.pdf
page 3
3 See Appendix: Visual Impact Energize Eastside – 16 mile
3
Figure 1 Number of residents, by blockgroups (represented by shades of blue) according to distance from
powerline,5 whose scenic and aesthetic views would be impacted. (Red dashes on the map represent
where powerline crosses public-street ROWs.) Map and data provided by Deron Ferguson
5 https://www.kingcounty.gov/services/gis/GISData.aspx
Block groups by distance band based on closest edge of block group to powerline
4
2. The Reality of Scenic Visual Impacts
Few of these Eastside residents would agree with the EIS statement that "significant scenic visual impacts
are not probable". Whether a homeowner lives up hill from the proposed 230kV transmission line or
downhill from the corridor - the towering poles will be visible against the skyline. And for residents who are
driving or walking even within 2-3 miles of the corridor, the transmission poles will be visible. Sensitivity
includes the expectations of what people view, how long they view it and the importance of the view.
Sensitivity is “the ability of viewers to see and care about a project’s impacts. The sensitivity to impact is
based on viewer sensitivity to changes in the visual character of visual resources. Viewers are either
sensitive or insensitive to impacts"6
The proposed "clear zone" cutting of trees and landscaping will further expose the industrial sized
transmission towers. Along the Eastside there are variations of scenic view possibilities: views of the lake,
the Seattle skyline and Olympic Mountains from Bellevue hillsides, views of greenbelts overlooking nature
preserves like Coal Creek, views from parks and lakes such as Lake Boren. All of these views would be
impacted by the construction of this proposed transmission line, most of which are well beyond the .25 mile
powerline-buffer defined as the study area.
Renton Staff Report to Hearing Examiner
“Staff has reviewed the proposal and has some concerns with regards to the visual
impacts of the proposed taller poles to the surrounding neighborhood unless mitigated.
Thus, to mitigate for the visual impacts of the proposed poles, a mitigation measure
was added to the EIS Consistency Analysis requiring that poles visible to the public be
treated with artwork. The proposed concept of adding artwork to the transmission line
poles was approved by the City of Renton Arts Commission on November 5, 2019. Staff
recommends as a condition of approval that individual art wraps for the transmission
line poles be submitted to the Current Planning Project Manager for review and
approval prior to the issuance of a Construction Permit. Artwork shall be installed prior
to the energizing of the transmission lines. With the implementation of artwork on the
proposed transmission line poles as well as the installation of landscaping as described
above, staff concurs that the proposed transmission line upgrade would be compatible
with the surrounding neighborhoods.7
6 United States Department of Transportation, Federal Highway Administration (FHWA). 2015. Guidelines for the Visual Impact
Assessment of Highway Projects. Washington, DC: USDOT FHA. P 6.1
7 https://edocs.rentonwa.gov/Documents/ElectronicFile.aspx?docid=8069815&dbid=1&repo=CityofRenton page 12
5
3. View Duration and Distance
View duration is discussed in the Vissering11 document referenced in the EIS.12 The document refers to
utility poles as being similar to wind turbines in height and scale. And it states that the longer a "project" is
visible to the viewer, the greater the sensitivity will be. The author maintains that "between 1/2 and 4 miles
away, landscapes are often an integral part of a scenic view. And depending on the sensitivity of the
viewing area, the orientation of views and the size of the project, adverse visual impacts can occur even at
distances up to 8 or 10 miles away” 13 This contradicts the EIS statement that the impact on views from a
distance is not significant. Judging the impact of views is subjective and not grounded in any objective
measurement.
4. The Aesthetic Viewpoint
The concept of scenic views is obvious (the view of Mt. Rainier or Lake Washington), but the concept of an
aesthetic viewpoint is more complicated.
Residents driving home day after day are very sensitive to what they observe in their community, their
neighborhood, or in their backyard. Viewer sensitivity to the aesthetic environment involves what the viewer
(resident) expects to see or prefers to see at that location14 For example, a 100-foot transmission pole in an
otherwise natural setting would not be preferred by most viewers. An industrial-sized power pole in a
landscaped residential garden would not be preferred. In the predominantly residential land-use zones that
comprise the transmission corridor, residents have landscaped and sited their homes to camouflage the
view of the existing 115kV power poles. With the proposed clear-zone construction, the landscaping would
be removed. Mitigation with 12-foot tall trees would not provide an adequate substitute for a 40-year-old
well-maintained, mature, tree canopy.
The contrast of the predominately low profile of the built environment (homes) with the height and size of
the proposed power poles would be severe.
Consideration should also be given to the aesthetic viewpoint at ground level. The damage from clearing
land and construction on residential properties in the corridor would be extremely significant. A power pole
that is 3 feet to 5 feet in diameter at the base when placed in a residential backyard will never be
aesthetically pleasing. This would be a long-term viewing impact to highly sensitive viewers. The
response to this concern in the FEIS was that: "the analysis did not focus on ground level views (which we
11 https://www.cesa.org/assets/2011-Files/States-Advancing-Wind-2/CESA-Visual-Impacts-Methodology-May2011.pdf page 25
12 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/section_3.2_scenic_views_and_the_aesthetic_environment.pdf
page 25
13 https://www.cesa.org/assets/2011-Files/States-Advancing-Wind-2/CESA-Visual-Impacts-Methodology-May2011.pdf page 21
14 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/section_3.2_scenic_views_and_the_aesthetic_environment.pdf
page 18
6
interpret to mean views looking down at the base of the poles)…15 The EIS further acknowledges that the
larger foundations would be noticeable when first installed and more likely the closer one is to the corridor,
but that this apparently did not warrant a separate discussion!
The residents have chosen to live in Eastside neighborhoods because of the aesthetic environment, and
often, because of the scenic views. If the presumed "need" for reliable electricity is in the commercial
district of downtown Bellevue, there is no zoning hierarchy justification for building Energize Eastside in
residential neighborhoods. This project should be located in the land-use district that requires additional
service.
5. Conclusion
To limit the study area for scenic and aesthetic views to 0.25 miles is shortsighted. The areas impacted
extend two to five miles from the transmission corridor. There would be a dramatic visual contrast between
power poles that are 100-130-foot tall and 1-2 story residences. The aesthetic impact of the proposed PSE
project would change the intended character of the residentially zoned districts in Renton.
6. Appendix: Data Methodology and Photos
Sources for data: (produced by Deron Ferguson)
Data Element Source File/Variable Source Organization
Population (2010 Census) sf1_2010_totpopp0010001 ftp://ftp.kingcounty.gov/gis-
web/GISData/admin_SHP.zip
Housing Units (2010 Census) sf1_2010_tothsgunitsh00010001 ftp://ftp.kingcounty.gov/gis-
web/GISData/admin_SHP.zip
Distance Band Calculated CENSE
Block Groups (map layer) Blkgroup10_shore.shp ftp://ftp.kingcounty.gov/gis-
web/GISData/admin_SHP.zip
Powerline (map layer) Manually digitized* CENSE
*Spatial data is not available from PSE for the proposed power line, so CENSE digitized its route based on
the existing route as determined by aerial imagery and proximity to parcel boundaries, as well as other
published non-spatial data from PSE (the Environmental Impact Statement, permit applications, etc.).
15 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/appendix_k_phase_2_comments_and_responses.pdf page
K-187
7
SECTION 9: INTRODUCTION
Zoning and Land Use Impacts
The documents in this section report the most obvious ways in which PSE’s proposed Talbot Hill/Lakeside
Transmission Line Project conflicts with the land use policies, land use codes and franchise agreements of
the cities involved. Analyses focus on type of land-use parcels directly adjacent to the transmission corridor
or within 100 or 500 feet of the corridor.
The first paper analyzes the parcel types adjacent or near the transmission corridor, the impact of the
proposed powerline on the intended character of residential neighborhoods, as well as the financial impacts
that would be borne by property owners.
The second paper identifies present land use of parcels (using parcel PRESENTUSE code from the King
County GIS Center). These tabulations show the predominant land use near the transmission corridor is
residential.
The final paper tallies the number of feet of public right-of-way crossed by the proposed transmission line
and discusses the appropriateness of the transmission line’s impact on public land.
Table of Contents
9.1 Regulations Related to Transmission Lines
Karen Esayian, Deron Ferguson, CENSE
9.2 Project Impacts on Residential Parcels
Karen Esayian, Deron Ferguson, CENSE
9.3 Project Impacts on Public Right of Ways
Karen Esayian, Deron Ferguson, CENSE
1
CENSE REPORT / Karen Esayian
ZONING AND LAND USE
Regulations Related to Transmission Lines
Abstract
The Renton portion of PSE’s Talbot Hill/Lakeside Transmission Line Project is located predominantly in land use
districts zoned residential. In fact, even considering variations in the criteria for determining land use designations,
the conclusion is that the predominant land use along the proposed transmission corridor is residential. The
proposed PSE project would have a significant impact on residential neighborhoods and homeowners, not only
aesthetically but financially. PSE's proposal conflicts with city land use codes which were enacted to protect the
intended character of residential neighborhoods.
Table of Contents
1. Description of the Corridor as Currently Zoned
2. Impact on Property Values
3. Conclusion
4. Appendix: Data Source and Methodology and Zoning Maps
1. Description of the Corridor as Currently Zoned
King County Assessor data, as reported in the FEIS, show the predominance of single-and-multi-family
residential land use in the zones proposed for PSE'S 230kV transmission line. Based on a linear-foot
breakdown of the study area for the project’s alignment from Redmond to Renton, the most common
existing land uses are:
• Residential (single-family and multi-family): 49 percent
• Vacant land (which includes portions of public parks): 17 percent
• Industrial: 9 percent
• Institutional: 9 percent1
1 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_4.1_land_use_and_housing.pdf page 3
2
Table 1 represents data from the King County parcel database which is tabulated from the Proposed
Powerline Feet by Present Land Use of Parcel report. The report documents the following parcels and their
use as designated for assessment.2
• Single-family residential: 256
• Condominium: 8
• Apartment: 5
• Single family (C/1 zone): 2
• TOTAL: 273
The 330 land use parcels counted in this tabulation are specifically for parcels that are crossed by the
transmission line. The parcel database field that was used to tabulate land use was called
“PRESENTUSE,” and is derived from King County assessor’s data.
Table 1
Present-Use Parcels Crossed by Proposed Transmission Line
Residential parcels represent the most common land use of properties located under the route of the
proposed transmission line.
2 https://www5.kingcounty.gov/sdc/FGDCDocs/KCA102_PRESENTUSE_PARCEL_faq.htm
3
2. Impact on Property Values
The proposed PSE project would have long term impacts on neighborhoods and immediate impacts on
homeowners. The current 115 kV line with H-frame structures has been incorporated into landscape plans
and shielded from view with mature trees. Construction that includes a "clear zone" on properties for
removal of the wooden poles and digging of holes for steel pole placement would have a significant impact
on homeowners’ property.
The steel poles proposed are 90-130 feet high and between 3-5 feet in diameter at the base. The height of
these poles would impact view shed, and aesthetically degrade and obstruct scenic views for residents
within 2 or more miles.
The removal of all mature landscaping would decrease property values, not only for the homeowner, but for
neighboring properties.
The results reported in Bottemiller & Wolverton “Price Effects of HVTL’s on Abutting Homes” from The
Appraisal Journal, state that this study included the Seattle higher-priced home market and showed that
“the effect of abutting a HVTL (high voltage transmission line) right-of-way was a much greater percentage
of price and the effect was more significant than for the data as a whole.”3 This correlates to property values
along the Eastside proposed transmission corridor
Another study, reviewed for the Journal of Real Estate Research, reports that vacant lots adjacent to high-
voltage transmission lines sell for 45 percent less than equivalent lots not located near transmission lines.
Even non-adjacent lots located within 1,000 feet of a transmission line sell at a discount of 18 percent.
Assuming that land represents 20 percent of a home's overall value, the 45 percent decrease translates to
a drop in total property value of about 9 percent.4
In the FEIS, a comparison of similar properties shows a variation in price per square foot between high-
and-low degrees of power line impacts range from a high of an 87 percent in land value in Renton to a low
of a 12 percent decrease in land values in Kirkland.5
The Economic Considerations Report acknowledges that property value is negatively impacted when large
transmission lines obstruct views and positively impacted when transmission lines are underground, and
views are improved.6
3 https://www.bpa.gov/Projects/Projects/I-5/2012documents/Article_PriceEffectsOfHighVoltageLines_March2013.pdf
page 56
4 https://www.wsj.com/articles/the-electrifying-factor-affecting-your-propertys-value-1534343506
5 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/pse_ee_economics_v5_final_160122.pdf
page 14-15.
6 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/fcs_group_economic_considerations_010417.pdf
page 3.
4
King County assessors would lower assessed values to account for negative influences such as obstruction
of a view (which primarily affect residential properties not commercial/industrial properties), residential land
being used for a public utility or an undesirable land use being "zoned" adjacent to a property.7
Not only would Eastside residents see their property values decrease, they would also see their utility bills
increase. In fact, all residents in the PSE service area would see an increase in their utility bills because of
the proposed project.1
The Cities of Renton and Bellevue would benefit from increased sales tax revenues based on the costs of
project construction, Ad Valorem tax, property tax revenues based on the construction of PSE assets, real
estate transfer tax revenues based on land transactions by PSE and Energize Eastside permit fees.8 This
is acknowledged in the FEIS.
Why should residentially-zoned land-use districts disproportionately shoulder the financial burden of
decreased property values and higher utility bills, when the expressed "need" for this project is "growth" in
the commercial zones of Bellevue? The land use codes stipulate that an electrical facility location be a
consequence of the needs of the customers located in that area.
The expressed “need” for Energize Eastside is not about need in the residential land use districts. Nor will
these residential areas profit from the taxes mentioned above. If there is a concern about electrical
reliability in the commercial land-use districts in the City of Bellevue, alternatives are available that could be
located near the need, rather than in residential districts.
3. Conclusion
Once the 230kV transmission poles are built there will be no going back. The damage will be done to
homeowner properties and to residential neighborhoods along the corridor. Nor should this financial burden
be placed on the homeowners. With the aesthetics of neighborhoods permanently altered, this proposal will
also change the dynamics of cities. The relevant land use codes and policies of the cities involved should
be respected and followed. Denying this proposal will preserve the intended character of residential land
use zones along the Eastside.
7 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/pse_ee_economics_v5_final_160122.pdf
page 7 and page 9
8 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/pse_ee_economics_v5_final_160122.pdf page 9.
5
4. Appendix
Data Source and Methodology and Maps
Source for Data
Data Element Source File/Variable Source Organization
Parcel PRESENTUSE code. PARCEL_ADDRESS ftp://ftp.kingcounty.gov/gis-
web/GISData/landuse_kc_consol_20_SHP.
zip
Powerline (map layer) Manually digitized* CENSE
A description for the parcel present use code is provided here at the following URL:
https://www5.kingcounty.gov/sdc/FGDCDocs/KCA102_PRESENTUSE_PARCEL_faq.htm
* Spatial data is not available from PSE for the proposed power line, so CENSE digitized its route based on
the existing route as determined by aerial imagery and proximity to parcel boundaries, as well as other
published non-spatial data from PSE (the Environmental Impact Statement, permit applications, etc.
Source for Maps
Data Element Source File/Variable Source Organization
Comprehensive Plan Land Use
Designations for King County - 20
Categories
LANDUSE_KC_CONSOL_20 ftp://ftp.kingcounty.gov/gis-
web/GISData/landuse_kc_consol_20_SHP.
zip
Powerline (map layer) Manually digitized* CENSE
6
Existing Transmission Corridor through Predominantly Residential Land Use Zones
Figure 1 The route of the existing 115kV transmission corridor, from Redmond to Renton, illustrating the
dominate land-use district as Single-Family Residential. (Map and data provided by Deron Ferguson)
7
Figure 2 Number of feet of power line per each land-use zone
Land-use zones traversed by PSE’S 230kV transmission line project
Number of feet of power line per each land-use zone
Land Use Powerline Feet # Powerlines
Single-Family Residential 59,802 1
Industrial/Manufacturing 7,807 1
Multi-Family Residential 6,229 1
Park/Golf Course/Trail/Open Space 2,997 1
General Mixed Use 2,495 1
General Commercial 2,238 1
Undesignated 1,738 1
Mixed Use Commercial/Office 629 1
Mixed Use Commercial/Residential 447 1
Office/Business Park 234 1
Agriculture-Related 0 0
Aviation and Transportation-Related 0 0
Central Business District 0 0
Forest 0 0
Historic District 0 0
Mineral Resource-Related 0 0
Mobile Home Park 0 0
Public Use/Institutional 0 0
Rural Area 0 0
Sensitive/Critical Area 0 0
1
CENSE REPORT / Karen Esayian
ZONING AND LAND USE
Project Impacts on Residential Parcels
Abstract
The proposed PSE 230kV Talbot Hill/Lakeside Transmission Line Project would be constructed from the
proposed Richards Creek Substation in the north to the Talbot Hill Substation in Renton in the south. Even
though PSE bifurcated the project and the current applications include only south Bellevue and the cities of
Newcastle and Renton, the data used in this report, describe the current land use with parcel count and
length for all segments of the proposed transmission line project.
Of the 14.9 miles of the entire transmission corridor, residential land use comprises 42,997 linear feet which
is over half of the total 78,794 linear feet. (53%)
The land-use parcels along this corridor are predominantly residential, whether directly adjacent to the
corridor or 100 feet or 500 feet away. The Land Use Codes of the impacted cities were developed to
maintain the integrity of the residential neighborhoods. The proposed power line would be within 500 feet of
2,711 residentially-zoned parcels, of which 2,085 are located in south Bellevue, Newcastle and Renton and
the remaining 626 are located in north Bellevue and Redmond.
Table of Contents
1. Present Land Use Zone Data
2. Conclusion
3. Appendix: Data Methodology and Charts
2
1. Present Land Use Zone Data
The 230kV transmission line proposed by PSE would be constructed in land use zones that are
predominantly residential.
The FEIS states 49 percent of the project includes land zoned for single-family and multi-family land use,
based on King County Assessor data1 The FEIS does not specify the exact methodology used in its
analysis, but maintains that this percentage "includes properties that are included in or abutting PSE's
proposed alignment or in close proximity to the right of way."2 It can be concluded from this analysis that
land use is predominantly residential the transmission corridor .
Table 1 summarizes a land-use analysis based on parcel PRESENTUSE3 code. The table delineates the
number of proposed powerline linear feet by present land use of parcel and shows the predominant land
use in the transmission corridor as residential. Specifically, for the cities included in the current PSE
applications, the following data is significant:
• South Bellevue residential use: 9,470 of 15,595 linear feet
• Newcastle residential use: 4,530 of 7,171 linear feet
• Renton residential use: 8,690 of 18,658 linear feet
Of the 14.9 miles of the entire transmission corridor in this analysis, residential land use comprises 42,997
linear feet which is over half of the total 78,794 linear feet. (53%)
1 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_4.1_land_use_and_housing.pdf page 3
2 http://www.energizeeastsideeis.org/uploads/4/7/3/1/47314045/chapter_4.1_land_use_and_housing.pdf page 1
3 https://www5.kingcounty.gov/sdc/FGDCDocs/KCA102_PRESENTUSE_PARCEL_faq.htm
3
Table 1
Number of Proposed Powerline Feet by Present Land Use Designation of Parcel
(Data and methodology provided by Deron Ferguson)
Note that three categories of use indicated vacant parcels (vacant single-family, vacant multi-family, and
vacant industrial) and were grouped with other categories for simplified presentation (single-family,
apartment, and industrial park, respectively.) 4
Of the 14.9 miles of the entire transmission corridor, residential land use comprises 42,997 linear which is
over half of the total 78,794 linear feet. (53%)
4 https://www5.kingcounty.gov/sdc/FGDCDocs/KCA102_PRESENTUSE_PARCEL_faq.htm
Present Use
Count
Parcels
EE
Length
North of
520
Between 520
and I90
South of
I90
Bellevue
North
Bellevue
South Bellevue Newcastle Renton Redmond
King
County
Single family (residential use / zone)256 36,773 11,236 5,150 20,387 14,223 8,679 22,902 4,300 6,110 2,163 1,298
School (Public)5 4,869 1,311 3,559 899 899 2,660 1,311
Utility, Public 7 4,575 3,062 626 888 1,332 1,332 181 3,062
Golf Course 1 3,922 3,922 3,922 3,922
Condominium (Residential)8 3,791 2,622 1,169 1,169 2,622
Park, Public (Zoo \ Abroretum)4 3,726 1,332 2,394 1,332 1,982 3,314 412
Open Space (Curr Use-RCW84.34)6 3,232 1,302 1,931 1,302 1,302 1,931
Unknown 8 3,191 1,322 272 1,597 272 272 1,517 80 1,322
Mortuary / Cemetary / Crematory 2 2,943 2,001 943 2,001 2,001 943
Right of Way / Utility, Road 3 2,153 2,153 2,153
Apartment 5 1,937 663 1,274 791 791 61 1,084
Industrial Park 4 1,778 322 1,456 322 322 1,456
Warehouse 2 1,551 1,551 628 924 1,551
Office building 4 1,264 931 333 931 333 1,264
Sport Facility 2 723 388 335 388 335 723
Single family (C/I Zone)2 496 496 169 327
Retail store 4 472 127 345 127 127 345
Auto Showroom and Lot 1 454 454 454 454
Shopping Center (Neighborhood)1 309 309 309
Church / Welfare / Religious Services 2 247 247 247
Open Space Timber Land / Greenbelt 1 241 241 241
Club 1 134 134 134
Easement 1 12 12 12 12
Total 330 78,794 20,867 17,738 40,190 25,590 15,595 41,186 7,171 18,658 10,481 1,298
Miles 14.9 4.0 3.4 7.6 4.8 3.0 7.8 1.4 3.5 2.0 0.2
4
The number of linear feet shown in the Tables 1,2 and 3 relate specifically to parcels that are crossed by
the line and do not include parcels that are adjacent or some distance away from the transmission line.
Included as residential: Single family, condominium, apartment and single family (C/1zone).
Table 2
In south Bellevue and Newcastle, the percent of proposed powerline linear feet passing through residential-
use designated parcels is greater than the 54.6 percent calculated for the entire transmission corridor.
Other land-use parcels are closely related to residential land use. These could be called "quasi-residential”
and would include parcels designated for schools, golf courses, parks and public spaces, open space and
open timber. As shown in Table 3, these parcel designations would add another 15,992 linear feet or 20.3
percent to the land that would be impacted by the proposed project.
Table 3
By adding the linear feet of powerline that would pass through “quasi-residential” land-use designations.
74.9 percent of the proposed powerline would cross over parcels with a neighborhood or park-like
character. (Table 4 in the Appendix for further details about the distribution of “quasi-residential” land use zones in each city.)
5
The previous data show that the number of linear feet directly under the proposed 230kV power line are
now zoned predominantly as residential.
Table 5 in the appendix shows the actual number of parcels by neighborhood plats that would be under or
within 100 or 500 feet of the proposed 230 kV powerline. The results are summarized below:
• Under the line - 363 residentially-zoned parcels
• 100 feet from the edge of the transmission corridor – 282 residentially-zoned parcels
• 500 feet from the edge of the transmission corridor – 2,066 residentially-zoned parcels
The proposed power line would impact a total of 2,711 parcels zoned as residential. Of these parcels,
2,085 are located in south Bellevue, Newcastle and Renton and the remaining 626 are located in north
Bellevue and Redmond.
6
2. Conclusion
It can be concluded from the data presented in the FEIS and the data used in this report from the King GIS
Center that the land use in the transmission corridor is predominantly residential. If parks, golf courses and
open spaces that residents enjoy are included as quasi-residential, then the percentage of linear feet with a
neighborhood character that would be crossed by the proposed 230kV transmission line increases from
54.6 percent to 74.9 percent.
All the data presented by CENSE and its expert witnesses corroborate that PSE’s transmission line
proposal would not follow the guidelines of cities’ land use codes. If PSE’s applications were approved, an
industrial-sized transmission line would be built through residential neighborhoods even when the
"presumed" need is in the commercial zones of Bellevue. Residential neighborhoods would bear most of
the aesthetic, environmental, and safety impacts of PSE’s. If increased electrical demand is created by
warehouses, office buildings or industrial parks, alternatives to a 230kV transmission line are available that
could be located within the land-use districts requiring additional service.
The Energize Eastside project would dramatically change the intended character of the predominantly
residential districts along the corridor. Maintaining the integrity of residential neighborhoods should be a
priority when considering this proposal, as that priority is codified in city land use codes.
Denying this proposal will preserve the intended character of the residential neighborhoods.
7
3. Appendix: data methodology and charts
Sources for Table 1,2,3
Number of Proposed Powerline Feet by Present Land Use of Parcel
Data Element Source File/Variable Source Organization
Parcel PRESENTUSE code. PARCEL_ADDRESS ftp://ftp.kingcounty.gov/gis-
web/GISData/landuse_kc_consol_20_S
HP.zip
Powerline (map layer) Manually digitized* CENSE
A description for the parcel present use code is provided here at the following URL:
https://www5.kingcounty.gov/sdc/FGDCDocs/KCA102_PRESENTUSE_PARCEL_faq.htm
* Spatial data is not available from PSE for the proposed power line, so CENSE digitized its route based on
the existing route as determined by aerial imagery and proximity to parcel boundaries, as well as other
published non-spatial data from PSE (the Environmental Impact Statement, permit applications, etc.
Table 4
Linear feet and percent of proposed power line that would cross over quasi-judicial parcels, by city.
8
Table 5 Number of Residential Parcels within 500 of Proposed Power Line
plat
avg residential
value approx area
total
parcels
residential
parcels
condo
units
min
distance
avg
distance
parcels on
line
parcels within
100 ft
parcels within
500 ft
names on
mailing list members
BURKE-FARRARS KIRKLAND DIV NO. 12 601,767 Redmond 73 73 0 50 717 0 4 23 8 0
GREENTREE ESTATES 480,436 Redmond 39 39 0 0 267 10 1 32 25 0
ROSEWOOD PARK NO. 02 532,571 Redmond 14 14 0 40 127 3 5 14 14 0
MERRYWOOD NO. 03 489,500 Redmond 18 18 0 44 188 2 4 18 5 0
STRATTONWOOD ADD 529,810 Redmond 58 58 0 9 626 7 0 14 14 0
TALLYHO NO. 04 555,259 Redmond 58 58 0 95 456 0 2 31 11 0
BIRCHWOOD 508,323 Redmond 31 31 0 95 668 0 3 11 5 0
SIXTY-01 AMENDED Redmond 8 0 465 0 1 6 0 8 429 0
CANTERWOOD 1,314,667 Bridle Trails 12 12 0 0 144 5 0 12 12 0
BRENTWOOD LANE 995,143 Bridle Trails 14 14 0 0 526 2 0 6 2 0
O FARRELLS BRIDLE TRAILS 1,138,913 23 23 0 87 591 0 4 9 0 0
TRAILS END ADD 1,000,905 Bridle Trails 42 42 0 0 284 13 1 32 12 5
BEAU CHEVAL ADD 1,162,800 Bridle Trails 10 10 0 0 454 2 0 6 9 1
CEDAR HIGHLANDS ADD 922,900 Bridle Trails 10 10 0 0 441 2 0 6 8 0
NEWCASTLE ESTATES 1,351,714 Bridle Trails 7 7 0 44 309 0 2 5 6 0
GLENWOOD ACRES 1,201,647 Bridle Trails 17 17 0 0 452 3 0 9 15 1
BELLEAIRE ESTATES 1,252,429 Bridle Trails 7 7 0 63 304 0 3 5 5 0
SHADOW WOOD LANE 1,103,692 Bridle Trails 13 13 0 0 529 2 1 6 12 1
CANTER GREEN 2,060,733 Bridle Trails 15 15 0 0 326 3 0 12 12 3
GLENGROVE LANE 1,113,545 Bridle Trails 11 11 0 65 270 0 4 8 9 1
KANTOR LANE HEIGHTS ADD 913,231 Bridle Trails 13 13 0 0 192 7 0 11 12 2
MEADOW WOOD 1,059,200 Bridle Trails 5 5 0 0 173 1 1 5 5 0
DARBY LANE 1,100,818 Bridle Trails 11 11 0 0 213 2 2 10 10 1
WESTMINSTER ESTATES 946,267 Bridle Trails 15 15 0 18 504 0 2 8 13 0
BELLEVUE GARDENS ADD 980,765 EBCC 34 34 0 0 565 7 0 11 5 0
CALIDAD HOUSE EBCC 1 0 23 84 84 0 1 1 23 0
TITONKA PARK NO. 03 876,115 EBCC 26 26 0 92 548 0 1 13 12 0
FERNDALE 704,833 EBCC 18 18 0 68 626 0 3 7 7 0
DORALEE ACRES ADD 919,541 Olympus 36 36 0 0 541 5 0 17 15 0
SKYRIDGE DIV NO. 05 667,636 EBCC 55 55 0 0 415 10 1 35 29 2
BELLEVUE WOODS 913,444 EBCC 9 9 0 0 88 4 1 9 8 0
SKYRIDGE DIV NO. 04 643,457 EBCC 35 35 0 0 155 12 1 35 22 1
WOODMOOR DIV NO. 01 640,588 EBCC 17 17 0 0 133 7 0 17 16 2
BANNERWOOD ADD 471,370 EBCC 46 46 0 17 356 0 8 32 24 0
EASTGATE ADD DIV K 478,046 Olympus 131 131 0 0 353 22 5 90 25 0
SOMERSET NORTH SLOPE 995,368 Somerset 57 57 0 0 463 7 2 33 20 5
SOMERSET NO. 16 855,429 Somerset 7 7 0 0 128 3 1 7 5 1
SOMERSET NO. 06 835,646 82 82 0 88 724 0 1 17 0 0
SOMERSET RIDGE 1,176,400 Somerset 20 20 0 0 538 2 2 10 6 0
SOMERSET ADD 1,044,290 Somerset 62 62 0 0 185 13 4 62 36 7
SOMERSET NO. 08 937,101 Somerset 178 178 0 0 407 31 2 115 47 12
SOMERSET NO. 15 1,204,146 Somerset 48 48 0 0 219 12 1 45 44 19
EDGEWOOD PARK 622,412 Somerset 51 51 0 0 471 4 3 30 9 1
FORESTHILL NO. 02 920,894 Somerset 66 66 0 30 403 2 7 43 11 2
9
The number of parcels described as “on the line” (363) is a little higher than the number of parcels
intersecting” the line shown in the table above. This is because, in this tabulation, we include parcels whose
property edge is within 10 feet of the line as being “on the line” (That is, we create a 10-foot buffer around
the line and then intersect that with the parcels). For example, we might have a case where the power line
runs along within 10 feet of a property’s edge; in that case, we also include the adjoining property, which is
within 10 feet, as “on the line.”
plat
avg residential
value approx area
total
parcels
residential
parcels
condo
units
min
distance
avg
distance
parcels on
line
parcels within
100 ft
parcels within
500 ft
names on
mailing list members
NEWPORT HILLS NO. 09 607,188 Newcastle 32 32 0 0 219 7 3 30 18 0
NEWPORT HILLS NO. 12 585,511 Newcastle 45 45 0 0 212 11 2 41 18 0
DEL MAR WOODS DIV NO. 01 588,188 Olympus 80 80 0 0 362 11 3 55 12 0
OAKS THE 584,639 Newcastle 36 36 0 97 345 0 3 33 3 0
DEL MAR WOODS DIV NO. 03 526,727 Newcastle 33 33 0 0 325 5 4 23 9 0
DEL MAR WOODS DIV NO. 05 506,222 Newcastle 9 9 0 0 80 3 2 9 5 0
NEWPORT WOODS ADD 471,609 Newcastle 87 87 0 40 626 2 5 33 7 0
DONEGAL 456,740 Olympus 119 119 0 0 462 5 19 73 24 0
LAKE BOREN SUBDIV 591,350 Olympus 19 19 0 0 360 1 1 13 2 0
OLYMPUS DIV NO. 02 587,872 Olympus 76 76 0 39 608 0 4 28 3 0
OLYMPUS 600,226 Olympus 137 137 0 0 160 33 23 136 100 19
EDEN'S GROVE 759,094 Newcastle 32 32 0 13 254 1 6 31 12 1
HILLMANS LAKE WASH GARDEN OF EDEN NO. 06426,750 Renton 32 32 0 0 651 1 2 10 4 0
BALCHS ALBERT SIERRA HEIGHTS NO. 04 286,292 Renton 48 48 0 32 241 0 12 43 10 0
HONEY CREEK RIDGE DIV NO. 03 575,098 Renton 41 41 0 0 211 6 11 36 16 0
BALCHS ALBERT SIERRA HEIGHTS NO. 05 407,167 Renton 6 6 0 0 131 1 2 6 4 0
SIR CEDRIC 1 0 0 0 0 1 0 1 0 0
GRACELAND TERRACE 297,725 Renton 43 40 0 0 135 13 5 43 18 0
SKYLAND HEIGHTS NO. 02 273,667 Renton 15 15 0 0 0 15 0 15 14 0
SKYLAND HEIGHTS NO. 01 287,714 21 21 0 87 135 0 11 21 0 0
LIBERTY RIDGE PHASE 02 355,175 Renton 40 40 0 38 362 0 5 28 6 0
LIBERTY RIDGE PHASE 1 370,458 Renton 120 120 0 39 341 0 21 95 21 0
LIBERTY RIDGE PH 06 382,556 Renton 117 117 0 72 775 0 2 25 7 0
LIBERTY RIDGE PH 04 400,879 Renton 33 33 0 88 419 0 7 19 7 0
LIBERTY RIDGE PH 03 374,237 Renton 38 38 0 76 208 0 13 38 14 0
SHADOW HAWK II PH 01 1 0 0 0 0 1 0 1 0 0
SHADOW HAWK I 1 0 0 47 47 0 1 1 0 0
***No Plat Name***913,733 856 827 0 0 739 35 32 249 160 5
3,621 363 282 2,066 1,511 92
Source: King County parcel database and CENSE mailing list address collection; the two datasets were joined on parcel address = CENSE mailing list address
Scope: All neighborhoods with at least one single- or multi-family residential parcel within a quarter mile of the proposed powerline (commercial and other use type parcels not included)
Count of residential parcels: 9,191; count of all mailing list records: 2,097 (matched to parcels: 1,932; unmatched: 165 )
Table is roughly ordered from north to south
min distance: the distance of the closest parcel in the plat to the power line
plat: plat name, if exists, from the parcel database avg distance: the average distance of all parcels within the plat
avg residential value: land + improved assessment value from parcel database parcels on line: the count of parcels with distance=0 OR trees > 0 OR poles > 0 (i.e, impacted parcels)
approx area: "area" tag added by CENSE during address collection (max value in plat)parcels within 100 ft: count of parcels not on line but within 100 feet of the power line
total parcels: count of unique parcel numbers within the plat parcels within 500 ft: count of all parcels within 500 feet of the power line
residential parcels: count of single family residential parcels within the plat names on mailing list: the count of unique CENSE addresses linked to parcels within the plat
condo units: count of unique addressses of condo units within the plat (if we have them)members: the count of unique CENSE address flagged as "member"
10