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