Legalectric

It’s all been happening over at NoCapX 2020 — there’s exciting news to publish here on other things, but no time until after tomorrow at 4:30!!

It was one of those weeks.   First CapX 2020 provides official notice that the Brookings-Hampton transmission line is delayed.  [Motion to Suspend Proceedings!]

Hot in the heels of CapX 2020’s notice of “delay” of the Brookings-Hampton transmission line, PSEG provides official notice that it is withdrawing their NJ DEP permit for the Susquehanna-Roseland transmission line:

Please take notice in accordance with N.J.A.C. 7:A12.6(f). Public Service Electric and Gas Company (PSE&G) is hereby amending the above-referenced permit applications submitted to the New Jersey Department of Environmental Protection (NJDEP). PSE&G is withdrawing the applications for the section of the Project located to the west of the proposed Hopatcong Switching Station. The municipalities west of the Hopatcong Switching Station include Sparta Township, Byram Township, Andover Township, the Town of Newton, Fredon Township, Stillwater Township and Hardwick Township The company may resubmit a new application or applications to NJDEP for the western section of the Project at a later date.

It’s all here in their Notice to affected towns:

PSEG’s Notice of Withdrawal – NJ DEP

And here’s the real deal:

PSEG Amended NJ DEP Permit filed 5/14/10

The funniest part is this — AS IF!!!

We know that they’ve got a problem at the Delaware Water Gap… we know they’ve got a problem at the NJ DEP… Now I wonder… how much of the Pennsylvania part is withdrawn???

Just like the CapX 2020 transmission project, the Susquehanna-Roseland transmission project was approved as a whole, the studies used to justify it were on the project as a whole, the BPU decision approving the project was on the project as a whole… so what, now they can say they just don’t need that part???  I don’t think so…

The MAPP line, PEPCO’s Mid-Atlantic Power Pathway transmission line project through Maryland and Delaware, is in the news again. But why???  Where the line is not needed, and it’s withdrawn by PJM and PEPCO, why is this being accepted?  Why is this regarded as a “win?”

Remember that they pulled the project?

PEPCO letter 1.8.09 to suspend MAPP, includes 1.8.09 letter from PJM’s Herling

And before that, the part from Indian River to Salem was eliminated?

MAPP – PEPCO-PJM Press Release May 19, 2009

The May, 2009, Press Release says:

According to Gausman, PJM has also reviewed the need for the section of the line that would run from Delmarva Power’s Indian River substation near Millsboro, Del., to Salem, N.J., and has decided to move this portion of the line into its “continuing study” category. This means that the reconfigured MAPP line will now extend approximately 150 miles from northern Virginia, across southern Maryland and the Chesapeake Bay, and terminate at Indian River. The change would likely reduce the total project cost from $1.4 billion to $1.2 billion.

And then there’s the report that shows there’s no need, that demand is downdowndown, that “congestion” is downdowndown, that price of electricity is downdowndown, that demonstrates that the market concept that they’re all drooling over will have them aspirating their aspirations:

Marketing Analytics – PJM State of the Market Report 2009

So then why did they send out a press release last week:

PEPCO May 5, 2010 Press Release – MAPP Transmission Line

…which every Peninsula news outlet gave pretty much verbatim coverage?

And then there’s the PJM RTEP 2009, released February 26, 2010.

So here’s how their press release looks after the papers get it:

Delaware utilities: Plan takes power line under Choptank

Proposed route would lead to little disruption in Del.

By AARON NATHANS • The News Journal • May 8, 2010

Delmarva Power’s planned high-voltage power line would be submerged below the Choptank River through Dorchester County, Md., the utility announced this week.

The Mid-Atlantic Power Pathway would run from Virginia to Maryland, across the Chesapeake Bay and end at the Indian River Power Plant in Millsboro.

It is being planned by Pepco Holdings Inc., parent company of Delmarva.

The company reports it has been successful in acquiring 90 percent or more of the rights of way needed to build the line through Dorchester County.

This portion of the line would run below the Choptank River, making landfall east of Cambridge, Md. It would continue underground briefly before moving above ground northeast of U.S. 50. It would cross the Nanticoke River near Vienna, Md.

In Delaware, the power line would be built on existing rights of way, approaching from Mardela Springs, Md., moving toward Delmar, and finishing in Millsboro.

Delmarva would not need to widen existing rights of way or clear any vegetation in Delaware, spokesman Matt Likovich said. The existing poles along this route would be replaced to support the more powerful lines, he said.

The portion of the line that runs through Maryland requires approval from federal and state agencies, including the Maryland Public Service Commission. Delaware’s PSC has no such oversight authority.

“We’ve spent a great deal of time listening to the citizens of Dorchester County,” said Bob Jubic, project manager. “With input from landowners, residents, environmental groups and government officials, we believe that the Choptank Route is the best choice as it minimizes the impact on the environment, agriculture and culturally significant areas in the county.”

Pepco Holdings has already announced the route for the MAPP project on the other side of Chesapeake Bay. About 20 of the 72 miles there would need to have new structures installed, and would also need new structures to cross the Potomac and Patuxent rivers.

PSC approval is unlikely to come until PJM Interconnection, the regional power grid manager, decides next month whether new power lines will be needed to ensure electric reliability in the region. Delmarva officials say they are not waiting for that green light to plan for the line, which they hope to have in service in June 2014.

Delaware PSC Chairwoman Arnetta McRae wrote a letter to PJM last month expressing the commission’s opinion that the project should go ahead on schedule to relieve reliability and cost concerns, and to provide a future pathway for offshore wind power to flow through the area.

Maps of the route through Dorchester County will be on public display at the Holiday Inn Express in Cambridge, Md., on Wednesday from 4 to 8 p.m. during an information session with the company. For more information, call the MAPP office at (410) 221-6207 or visit www.powerpathway.com.

Now read the other “articles” and tell me if there’s an echo in the room:

Underwater power line route suggested
Proposal under Chesapeake avoids refuge

By Calum McKinney • Staff Writer • May 6, 2010

But the day before it was better, with some original quotes:

Delmarva Power proposes Choptank route for MAPP project

(with NO byline)

Imagine 190 foot transmission towers through the Delaware Water Gap, between Pennsylvania and New Jersey.

That’s what’s proposed by PSE&G for its Susquehanna-Roseland transmission line.  This quad/tri bundled 500kV line is HUGE, ugly beyond belief, and it’s just so big that I can hardly comprehend, there’s nothing that large that I’ve found.  Others like it are being cancelled by PJM due to lack of demand, and this one should be too…

From the Pocono Record:

Park Service report on power line plan released

Anyway, the National Park Service is doing an Environmental Impact Statement, and leading up to that is “scoping,” which, as Grant Stevenson noted yesterday at the Task Force meeting, is THE most misunderstood term.  I agree.  It just zooms over people’s heads, and comments end up being of the “I hate this project because___” and nothing that relates to what the scope of the environmental review should be.  Utter waste of time, and something to be mindful of with the CapX 2020 transmission scoping meetings coming up.

SCOPE: Range, area of coverage, breadth

So “scoping” in this sense is the range, area of coverage, and breadth of environmental review.

We had comments on the scope a few months ago, and there were something like 6,500 comments.  Yes, that’s right, SIX THOUSAND FIVE HUNDRED!  At the meetings I went to, it was standing room only and the comments were notably on point, they were profound examples of those rare uplifting meetings.  Facilitation of the meetings was so good it felt like they really were interested in what we had to say.  It was all taken down by a court reporter.  THAT level of attention and appreciation is SO rare… and dig this … afterwards I RECEIVED A THANK YOU NOTE FOR PARTICIPATING.  That is a first, I’ve never gotten a thank you note from an agency for showing up and speaking out.  I’m thinking of framing it (after sending it to MN’s Dept. of Commerce).

NATIONAL PARK SERVICE – SUSQUEHANNA-ROSELAND 500kV TRANSMISSION LINE PAGE

Here’s their report:

Public Scoping Report – Susquehanna-Roseland transmission

The next step?

The NPS is currently developing preliminary alternatives for the project. Our plan is to host public meetings to present and receive feedback on these preliminary alternatives this summer. Announcements and news releases will be prepared to inform and invite the public to these meetings.

We’ll keep you posted.

Xcel Energy”s Hiawatha Transmission Project is sticking in my craw again.  I’m having one of those “Xcel is evil” kind of days.  Xcel is hiding reliability information under a claim of “Security.”  How absurd can they get?  Don’t they get that if I was going to blow up substations, a) I don’t need their stupid info to do it, and b) I would have done it a long time ago?  Earth to Mars, that’s not my M.O.  But noooooooooo…

I’ve been looking at Xcel’s SAIDI, SAIFI and CAIDI distribution reliability reports, one of the things I’m happiest about in the 2001 legislative session.  Minn. Stat. 216B.029. Why?  Because Xcel’s Scott Zima testified at the public hearing for the Hiawatha Transmission Line Project that the claimed “reliability” problems did not show up in their SAIDI, SAIFI and CAIDI reports.  WAS ANYONE LISTENING?

What is SAIDI, SAIFI and CAIDI?  They’re distribution reliability indices.  Here are definitions stolen from Rochester Public Utilities 2009 Electric System Engineering & Operations Report:

• SYSTEM AVERAGE INTERRUPTION DURATION INDEX – SAIDI

SAIDI is defined as the average duration of interruptions for customers served during a specified time period.  Although similar to CAIDI, the average number of customers served is used instead of number of customers affected.

The unit of SAIDI is minutes.  A common usage of SAIDI is: “If all the customers on the distribution system were without power the same amount of time, they would have been out for _________ minutes”.

• SYSTEM AVERAGE INTERRUPTION FREQUENCY INDEX – SAIFI

SAIFI described the average number of times that a customer’s power is interrupted during a specified time period.  “SAIFI-short” is calculated using the number of customers affected by momentary interruptions (such as brief breaker or recloser operations).  “SAIFI-long” is calculated using the number of customers affected by sustained interruptions.

The units for SAIFI are “interruptions per customer”.  A common usage of SAIFI is: “On the average, customers on the distribution system experienced _______ interruptions”.

• CUSTOMER AVERAGE INTERRUPTION DURATION INDEX – CAIDI

CAIDI is the weighted average length of an interruption for customers affected during a specified time period.

The unit of CAIDI is minutes.  A common usage of CAIDI is:  “The average customer that experiences an outage on the distribution system is out for ___________ minutes.”

Here’s some background info about SAIDI, SAIFI and CAIDI reports from Edison Institute:

State of Distribution Reliability – 2005

Here’s the Minnesota rule about reporting SAIDI, SAIFI and CAIDI:

7826.0500 RELIABILITY REPORTING REQUIREMENTS.

Subpart 1. Annual reporting requirements.

On or before April 1 of each year, each utility shall file a report on its reliability performance during the last calendar year. This report shall include at least the following information:

A. the utility’s SAIDI for the calendar year, by work center and for its assigned service area as a whole;
B. the utility’s SAIFI for the calendar year, by work center and for its assigned service area as a whole;
C. the utility’s CAIDI for the calendar year, by work center and for its assigned service area as a whole;
D. an explanation of how the utility normalizes its reliability data to account for major storms;
E. an action plan for remedying any failure to comply with the reliability standards set forth in part 7826.0600 or an explanation as to why noncompliance was unavoidable under the circumstances;
F. to the extent feasible, a report on each interruption of a bulk power supply facility during the calendar year, including the reasons for interruption, duration of interruption, and any remedial steps that have been taken or will be taken to prevent future interruption;
G. a copy of each report filed under part 7826.0700;
H. to the extent technically feasible, circuit interruption data, including identifying the worst performing circuit in each work center, stating the criteria the utility used to identify the worst performing circuit, stating the circuit’s SAIDI, SAIFI, and CAIDI, explaining the reasons that the circuit’s performance is in last place, and describing any operational changes the utility has made, is considering, or intends to make to improve its performance;
I. data on all known instances in which nominal electric service voltages on the utility’s side of the meter did not meet the standards of the American National Standards Institute for nominal system voltages greater or less than voltage range B;
J. data on staffing levels at each work center, including the number of full-time equivalent positions held by field employees responsible for responding to trouble and for the operation and maintenance of distribution lines; and
K. any other information the utility considers relevant in evaluating its reliability performance over the calendar year.

Subp. 2. Initial reporting requirements.

By March 30, 2003, each utility shall file its SAIDI, SAIFI, and CAIDI for each of the past five calendar years, by work center and for its assigned service area as a whole. If this information is not available, the utility shall file an explanation of how it has been tracking reliability for the past five years, together with reliability data for that period of time. If the utility has implemented a new reliability tracking system that makes comparisons between historical data and current data unreliable, the utility shall explain this situation in its filing.

Statutory Authority: MS s 216B.81

Xcel has to file these reports annually.  And since Xcel’s Mr. Zima’s testimony that the reliability problems they claim as the basis for need for the Hiawatha Project are NOT reflected in the SAIDI, SAIFI and CAIDI reports (WAS ANYONE LISTENING?), I spent some time looking at the annual reports filed this year:

Xcel’s Initial Filing – Docket 10-310

Xcel’s Initial Filing – Docket 10-310 – Attachment D – Part 1

Xcel’s Initial Filing – Docket 10-310 – Attachment D – Part 2

And there’s another older docket where similar information was recently filed:

Xcel’s Annual Filing – 02-2034 – Part 1

Xcel’s Annual Filing – 02-2034 – Part 2

Xcel’s Annual Filing – 02-2034 – Part 3

To search these dockets,go to www.puc.state.mn.us and click on “Search eDockets” and then plug in the docket numbers.

And here’s an example of what’s wrong with this picture – look at the crudely whited-out Feeder Line column:

Who cares?  Well, I do… why?  Because when they say that the distribution system is such a problem that they need a big honkin’ shiny new transmission line, and then one of their engineers testifies that this distribution “reliability problem” they’re whining about and inflicting an oversized transmission “solution” on a community about ISN’T showing up in the SAIDI, SAIFI and CAIDI distribution reliability reports, that’s a problem.  IS ANYONE TRACKING THIS?  It’s not rocket science, it’s basic vetting of their claims!

Looking at their letter in the filing in Docket 02-2034, there’s this amazing statement:

Security Data

The raw reliability data provided with this filing includes “security data” as
defined by Minn. Stat. § 13.37, subd. 1(a). Xcel Energy believes that some of the
raw data on the disks and/or that has been eFiled could be manipulated to reveal
the location and size of certain facilities that have been summarized in the
Monthly Report. The public disclosure or use of this information creates an
unacceptable risk that those who want to disrupt the electrical grid for political
or other reasons may learn which facilities to target to create the greatest
disruption. For this reason, pursuant to Minn. Stat. § 13.37, subd. 2, we have
excised this data from the public version of our filing.

p. 5,  Xcel’s Annual Filing – 02-2034 – Part I (emphasis added).

Excuuuuuse me?

The public disclosure or use of this information creates an unacceptable risk that those who want to disrupt the electrical grid for political or other reasons may learn which facilities to target to create the greatest disruption.

What a load o’ crap. It is so illogical — those they’re having problems with aren’t necessarily, and probably just AREN’T, the ones to target to create the greatest disruption!

So I calls up Xcel, I do… and leave a message with Bria Shea because Jody Londo who signed the cover letter with the “Security” note was not in, explaining what info in what dockets I’m looking for and that I’m wanting to sign a confidentiality agreement to get it.

But noooooooooooo, guess again.  I get a call back from someone in “Legal” (I didn’t know they had an Illegal department) and here they are making a bogus argument about PUBLIC disclosure, and I’m asking for disclosure with a confidentiality agreement.  She wants to know if I’m a party, which I’m not, there are no parties in these dockets.  And even if a party, even with a confidentiality agreement, no, because it’s a SECURITY issue.  Oh, yeah… right… I’m a terrorist, wanting their “feeder line” information to take out electricity to some select target…  Guess she’s been talking to Mike Krikava, thinking only a terrorist would want to enter a 2005-MAPP map into a transmission proceeding.  That’s as wacky as a judge thinking it’s appropriate to do a transmission proceeding without a map entered in as evidence!

So now I get to “evaluate my options.”  It’s possible to do some triangulation with the reports and with the Attachments to Xcel’s Hiawatha Project Application, but… sigh… we all know what their concern is — that someone might read it and make some sense of it, and understand what it means.