Chloe, WV July 13, 2012

Similar documents
107 FERC 61,053 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

VIA ELECTRONIC FILING

STATE OF NORTH CAROLINA UTILITIES COMMISSION RALEIGH DOCKET NO. E-2, SUB 1089 BEFORE THE NORTH CAROLINA UTILITIES COMMISSION

Hallinan Law Offices, PLLC

Duquesne Light Our Energy...Your Power

The Commission met on Wednesday, February 20, 2013, with Chair Jones Heydinger, and Commissioners Boyd, Reha, O Brien, and Wergin present.

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) ) )

Duquesne Light Our Energy... Your Power

NERC SPCTF Supplemental Assessment Addressing FERC Order 693 Relative to:

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

130 FERC 61,211 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

UNITED CHURCH OF CHRIST LOCAL CHURCH DISASTER PREPAREDNESS AND RESPONSE PLANNING GUIDELINES

FUNDAMENTALS OF ELECTRICITY TRANSMISSION COURSE

Duquesne Light Our Energy... Your Power

November 13, Ms. Kimberly Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C

BC Hydro writes to provide the BCUC with its second errata to the Addendum to Assessment Report No. 6 (Addendum) filed on September 30, 2013.

Currant Lake Telecommunication Tower

Energy. Request For Proposals for Renewable Power Supply Resources

SOUTH CAROLINA ELECTRIC & GAS COMPANY REQUEST FOR PROPOSALS FOR SOLAR PHOTOVOLTAIC DISTRIBUTED ENERGY RESOURCES AT TWO DESIGNATED SITES

May 16, 2013 EX PARTE. Ms. Marlene H. Dortch Secretary Federal Communications Commission th Street, SW Washington, DC 20554

Standard Development Timeline

The Narragansett Electric Company d/b/a National Grid

Day-Ahead Market and Forward Reliability Commitment Timing to Meet FERC Order on Compliance for Gas Electric Scheduling Requirements

Incident Planning Guide Tornado Page 1

NERC SPCTF Supplemental Assessment Addressing FERC Order 693 Relative to PRC System Protection Coordination

Request for Proposal (RFP)

DEC 1 b FEDERAL ENERGY REGULATORY COMMISSION Office of Energy Projects Division of Dam Safety and Inspections 805 SW Broadway, Suite 550

2018 RENEWABLE ENERGY GROWTH PROGRAM

PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON

Request for Qualifications (RFQ) Environmental and Permitting Services

December 17, 2003 Homeland Security Presidential Directive/Hspd-8

New York s 1115 Waiver Programs Downstate Public Comment and PAOP Working Session. Comments of Christy Parque, MSW.

NEW HAMPSHIRE S REEMPLOYMENT PROTECTIONS FOR MEMBERS OF THE NATIONAL GUARD. By Captain Samuel F. Wright, JAGC, USN (Ret.) 1 And Nathan M.

411 Seventh Avenue. Pittsburgh, PA 15219

National Grid System Reliability Procurement DemandLink Pilot Update

BEFORE THE GUAM PUBLIC UTILITIES COMMISSION ) ) ) ) ) ) ) ) INTRODUCTION

Brooke County Access I, L.L.C., Brooke County Access Project Monthly Pre-filing Status Report #5 Docket No. PF

Testimony of T.J. Glauthier President & CEO, Electricity Innovation Institute Affiliate of EPRI (Electric Power Research Institute)

STATE OF NORTH CAROLINA UTILITIES COMMISSION RALEIGH DOCKET NO. E-2, SUB 1089 ) ) ) ) ) )

REQUEST FOR LETTERS OF INTEREST

Before the Federal Communications Commission Washington, D.C COMMENTS OF NTCA THE RURAL BROADBAND ASSOCIATION

FirstEnergy Human Services

APPENDIX I AGENCY CONSULTATIONS

Appendix 5A. Organization Registration and Certification Manual

OLD FISHERS FORD TRUSS MORGAN COUNTY, WEST VIRGINIA STATE PROJECT S FR#: MN

Generator Replacement at the Garden River Power Plant

DEPARTMENT OF THE NAVY FISCAL YEAR (FY) 2017 REQUEST FOR ADDITIONAL APPROPRIATIONS

APPENDIX N. GENERIC DOCUMENT TEMPLATE, DISTRIBUTION STATEMENTS AND DOCUMENT DATA SHEET and THE IMPORTANCE OF MARKING DOCUMENTS

TRANSMISSION TRANSMISSION SYSTEM OPERATIONS DIVISION

To ensure system protection is coordinated among operating entities.

PacifiCorp 2017S SOLAR Request for Proposals. Bidder s Conference Portland November 21, 2017

Pursuant to the Public Utility Holding Company Act of 2005 ("PUHCA 2005"), 1 and

Generator Interconnection System Impact Study Report Carteret County, NC MW Queue #297 Original Submittal Revision 1

Approved Project Sponsor s Participating TO Application Process Clean-Up. Proposal and Tariff

Sustainable Maryland Certified MML Panel Discussion

Dear Chairman Sanchez and Members of the House Ways and Means Committee,

411 Seventh Avenue. th Floor. Pittsburgh, PA December

REQUEST FOR PROPOSAL (RFP) Posey County Long Range Transportation Plan

New England Telehealth Consortium

USACE 2012: The Objective Organization Draft Report

TRANSMISSION EXPANSION IN THE MIDWEST

PER-005 System Personnel Training

WHEREAS, Mn/DOT has been asked to participate in consultation for and to be an invited signatory to this Programmatic Agreement (PA); and

Small and Large Generator Interconnection Procedures

Southern California Edison Original Cal. PUC Sheet No E Rosemead, California (U 338-E) Cancelling Cal. PUC Sheet No.

Frequently Asked Questions

Allegheny Energy. Edward G. Kennedy Senior Attorney. Dear Ms, Squire:

Emergency Support Function 14. Community Recovery and Mitigation

Case 1:15-cv EGS Document 50 Filed 12/22/15 Page 1 of 21 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

PENNSYLVANIA PUBLIC UTILITY COMMISSION Harrisburg, PA 17105

Overview of the EHR Incentive Program Stage 2 Final Rule published August, 2012

Nursing Facility Policy Changes in 2009 Legislation

DEPARTMENT OF HOMELAND SECURITY BOARD FOR CORRECTION OF MILITARY RECORDS FINAL DECISION

The State of Interconnection in NYS:

WASTE NICHOLAS COUNTY SOLID AUTHORITY I.. RE: March 1,2013

Town Center Distributed Energy Resource Microgrid Feasibility Study Incentive Program

April 13, 2015 VIA ELECTRONIC FILING. Veronique Dubois Régie de l'énergie Tour de la Bourse 800, Place Victoria Bureau 255 Montréal, Québec H4Z 1A2

DEPARTMENT OF HOMELAND SECURITY BOARD FOR CORRECTION OF MILITARY RECORDS FINAL DECISION

Request for Proposal

SREC Securitization Straw Proposal June 13, 2008

July 1, 2006 Revision 2

Public Service Commission

AUSTIN ENERGY REQUEST FOR PROPOSALS (RFP) FOR THE PURCHASE OF RENEWABLE CAPACITY & ENERGY FROM RENEWABLE ENERGY RESOURCES

KEARNEYSVILLE, WEST VIRGINIA

The favor of a reply is requested.

NPCC Tasks Related to NERC Blackout Recommendations Timeline

May 7, Via Electronic Mail

City and County of San Francisco LIFELINES COUNCIL. MEETING NOTES Meeting #9 Developing the Lifelines Council Work Program

SAINT ALBANS, WEST VIRGINIA

WECC Standard VAR-STD-2a-1 Automatic Voltage Regulators

Southwest Garden Neighborhood Association 4950 Southwest Avenue St. Louis, MO (314)

1 LAWS of MINNESOTA 2014 Ch 250, s 3. CHAPTER 250--H.F.No BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF MINNESOTA:

PHILADELPHIA ENERGY AUTHORITY

High Prairie Substation Telecommunication Tower

SOMERSET COUNTY, MARYLAND

NPCC Tasks Related to NERC Blackout Recommendations Timeline

Request for Proposals Emergency Response Plan, Training and Vulnerability Assessment

The favor of your reply is requested.

REVISOR RSI/BR RSI-ENERGY

REQUEST FOR PROPOSAL FOR Network Penetration and Vulnerability Testing

Transcription:

D & PO Box 3 Chloe, WV 25235 July 13, 2012 Sandra Squire Director, Executive Secretary Division WV Public Service Commission 201 Brooks St. PO Box 812 Charleston, WV 25323 re: WV PSC case 07-0508-E-CN Dear Ih. Squire: I have enclosed comments in the above-styled case. I have also enclosed 12 copies of our filing according to PSC rules. As these are comments by a non-party protestant in the case, I do not believe this filing did not requires service on any other parties. Please notify me if service is required. Very truly yours, Biff Howley Steering Committee Chairman Coalition for Reliable Power enclosures

~~ ~~~ ~~~~~ t CASE NO. 07-0508-E-CN PUBLIC SERVICE COMMISSION OF WEST VIRGINIA TRANS-ALLEGHENY INTERSTATE LINE COMPANY Application for a Certificate of Convenience and Necessity authorizing the construction and operation of the West Virginia segments of a 500 kv electric transmission line and related facilities in Monongalia, Preston, Tucker, Grant, Hardy, and Hampshire Counties, and for related relief...-- 9 - c, c..- e u-* COMMENTS CONCERNING REPORT FILED BY FIRSTENERG%: WEST VIRGINIA SUBSIDIARY UTILTIES AS ORDERED BY THE COMMISSION AUGUST 1,2008 Protestant Coalition for Reliable Power, offers the following comment on the report filed May 17,2012 concerning the reconductoring and upgrading of transmission lines in West Virginia as ordered in the August 1,2008 Commission order in this case. I i BACKGROUND On August 1,2008, the Commission filed a final order in this case. In that order, in its review of the evidence, the Commissioners stated: II.B.5. The Commission Will Require Allegheny to Submit a Plan To Address Line Upgrades. Although we have concluded that reconductoring is not a feasible substitute for TrAIL, (see Part II.B.2, above), there are benefits to be derived from reconductoring or otherwise upgrading existing transmission lines. Looking to the future the Commission desires to maximize the capability of existing transmission lines, if possible. One means to achieve that goal is to reconductor or otherwise upgrade existing lines. It is reasonable to assume that once constructed, TrAIL will facilitate this kind of proj ect. The Commission will require Allegheny to file, within one year of the date TrAIL is completed and in service, a plan for reconductoring or otherwise upgrading its transmission facilities. (August 1,2008 TrAIL Order, p. 48) Allegheny Energy and TrAILCo to file a report, as follows: Page 1 of 8

IT IS FURTHER ORDERED that within one year of the date TrAIL is completed and in service TrAILCo and its corporate affiliates shall submit a plan for reconductoring or ~~ otherwise upgrading their respective transmission facilities. Note that the Commission did not order a report on the physical condition of Allegheny s transmission facilities. The Commission specifically ordered a plan for reconductoring or otherwise upgrading these transmission facilities. The Commission s order was forward looking and was not concerned with routine maintenance and inspection issues. In its review of the evidence, the Commission stated it was specifically interested a plan to maximize the capability of existing transmission lines not a report on their physical condition. On May 17,2012, TrAILCo and its corporate affiliates, namely Monongahela Power Company and The Potomac Edison Company, all subsidiaries of FirstEnergy, filed what these parties described as an EHV Condition Assessment ) which the parties cover letter also described as the transmission facility condition assessment required in the Commission s August 1,2008 Order in this docket. Although TrAILCo and its corporate affiliates claim that this May 17,2012 report is responsive to the Commission s August 1,2008 order, the only reference in the report concerning a plan for reconductoring or otherwise upgrading their respective transmission facilities) was the following statement: Based on the most recent condition, reliability and capacity assessments of the EHV Facilities in West Virginia, there are no immediate or short term plans (within the next five years) for upgrading the structures, conductor or hardware on the EHV Facilities in West Virginia. The Companies will continue to implement their inspection and maintenance programs and to participate actively in the RTEP process. Page 2 of 8

~~ Mr. + COMMENTS TrAILCo and its corporate affiliates produced five short pages of text primarily ~ describing the physical condition of their equipment and about 170 pages of appendixes including publications from PJM Interconnection. The FirstEnergy companies did not provide a plan for reconductoring and upgrading, as directed by the Commission. Most of their five pages of text were devoted to their claim that they have no plan. It appears from the report that TrAILCo and its parent company FirstEnergy have ceded all control of the companies high voltage transmission system in West Virginia to PJM Interconnection. Because PJM Interconnection is not a utility licensed to operate under the authority of the West Virginia Public Service Commission, this conveyance of authority has clearly circumvented West Virginia statute. With this report, FirstEnergy is essentially denying the authority of the West Virginia Public Service Commission over high voltage transmission owned and operated by FirstEnergy subsidiaries Mon Power and Potomac Edison in West Virginia. On June 30,201 1, Commission Staff Attorney John Auville filed a petition to require American Electric Power s (AEP s) West Virginia subsidiaries and FirstEnergy s West Virginia subsidiaries to file reports as ordered by the Commission in the TrAIL case before the deadline established in the Commission s August 1,2008 order. With the current West Virginia blackout (Many state power customers, including the signatory below, remain without power as of this date, the twelfth day following the June 29,2012 storm.), Mr. Auville s petition appears prescient, although the Commission s denial of the petition does not. Auville s replymower - comfy objections to his petition was ~~~ filed with the ~~~ Commission on July 27,20 1 1. His reply noted specifically that West Virginia utilities owning Page 3 of 8

~ ---the-typxrfin o ~ ~~ ~~ c c and operating high voltage transmission facilities in our state could not duck their planning ~ responsibilities by hiding behind the skirts of PJM Interconnection. We quote Mr. Auville s reply at length, because all of his points bear directly on the inadequacy of the May 17,2012 report filed by FirstEnergy. We have added emphasis to particular points that we believe provide clear summaries of the issues surrounding the current May 17,2012 report: While Staff recognizes both Allegheny/First Energy and American Electric Power have agreed to provide this information to the Commission, Staff has some concerns about the information the Companies plan to put in the report coupled with some general concerns about the transmission planning, or the lack thereof, that is being done by both Companies. The first issue is both Companies appear to intimate that they, and by inference this Commission, have abdicated responsibility for all high voltage transmission planning and maintenance to PJM. Staff realizes PJM is the regional transmission planning authority; however, this fact does not absolve the utilities from their duty to plan and maintain the operation of their own equipment. Staff expects the utilities to study their own transmission equipment and undertake projects which improve the condition and performance of the equipment outside of the PJM process. Otherwise, the system ends up in the condition presented in the TrAIL proceeding: a system in crisis with very limited options or solutions which all but eliminates the possibility for a complete review of less costly options. The Companies reliance on the PJM process is not transmission planning. It is transmission reacting and is not in the best interest of West Virginia customers. Staff expounds that a perfect example of the type of behavior Staff expects from the utilities in this State was recently displayed by VEPCO, who approached PJM on its own to rebuild the Mt. Storm-Doubs line. VEPCO chose not to await any directive from PJM on how to upgrade the line as VEPCO saw a window of opportunity and seized it. VEPCO s rebuild will not only eliminate the possibility of a disastrous tower failure, but will also dramatically increase the carrying capacity on the line. That tells Staff that not only were the towers outdated, severely deteriorated and in need of replacement, but the conductors and wire were old, outdated and in need of replacement as well. At some point an asset becomes so inefficient that it needs to be replaced in order to keep up with technological advances. A utility should not wait until the asset fails or until PJM has given them a directive to do something with the asset to repair/replace it. The VEPCO example is the kind of proactive planning Staff expects the utilities in this State to engage in along with rm atioxrs t a ff-exp ectsto-~e-conta~~ed-in-any-rep or t-submitt ed-to-t he Commission. Staff asserts at a minimum, any report should contain the name of the line, the age of the line, the length and location of the line, the current condition of the line in Page 4 of 8

terms of physical condition and its operating efficiency and any planned upgrades to the line and facilities. Consideringthetone-ofthe-responses3rom both-aep-and-allegheny/first-energyin conjunction with the average at best maintenance of rights-of-way, performance, etc. the Commission discovered in the recent Storm Outage GI, Staff is concerned the electric utilities have forgotten their main objective: to provide safe and reliable electric service to the citizens of this State. The main objective of any report filed with the Commission is for the Companies to give the Commission a clear picture of the condition of the transmission assets in this State and what if any type of planning and maintenance the Companies are engaging in relation to those assets beyond we are waiting for PJM to tell us what to do next. This is an opportunity for the Companies to inform the Commission how they are fulfilling their duty to the citizens of this State and prove they are concerned about the maintenance of their facilities and are proactive in the planning and maintenance of their transmission facilities. PJM Interconnection and the Federal Energy Regulatory Commission (FERC) have done actual harm to state transmission planning by providing profit incentives and cost recovery for system upgrades and new transmission projects that serve their own purposes. As a result, AEP and FirstEnergy have no interest in assessing or planning the future capabilities of their high voltage transmission system, unless they can receive special rate subsidies from FERC or PJM Interconnection. As Mr. Auville noted in his reply quoted above, AEP s and FirstEnergy s West Virginia utilities have obligations under West Virginia statute, regardless of the rate payer funded financial incentives available to them from other sources. FirstEnergy s May 17,20 12 report demonstrates clearly that its subsidiaries are not interested in meeting those obligations. In its May 17,2012 report, FirstEnergy concentrated on an account of its inspection and maintenance efforts, although the company provided little specific information, other than to claim that its steel lattice towers were in far better condition than the towers that Dominion -- Energy s VEPCO decided to replace on the Mt. Storm to Doubs 500 kv line. Page 5 of 8

~ ~ ~~~~ vulnerabilitl ~~ ~~~~ ~~ ~~~~~~~ ~ ~~~ i In fact, the current FirstEnergy blackout demonstrated that FirstEnergy has failed to adequately assess the durability of its steel lattice towers, particularly on its 500 kv transmission system in West Virginia. FirstEnergy s report included no reference to any assessment of its West Virginia towers concerning a clearly demonstrated vulnerability of those towers to thunderstorm downburst s and microbur sts. Structural engineers have modeled and described the particular vulnerability of loading on steel lattice tower arms in the strong down drafts in storm microbursts. We have appended two photographs, in Appendix A, provided by FirstEnergy of one of their steel lattice towers destroyed by the June 29,2012 storm on a 500 kv transmission line near Ellenboro, WV, and from Great River Energy s Web site (http://blog.greatriverenergy.com/2011/08/26/storm- damages-vital-transmission-line/) of a similar structure that was destroyed in a Minnesota storm on August 1, 20 1 1. Both towers failed in exactly the same place on the structure, and in almost exactly the same way, In their paper titled Modelling [sic] of tornado and microburst-induced wind loading and failure of a lattice transmission tower, published in the journal Engineering Structures (Engineering Structures 23 (2001) pp. 365-375 also at http://www.eng.uwo.ca/people/esavory/engstruct.pdf) authors Eric Savory and others described exactly this kind of damage in their models, eleven years ago. Despite the fact that these kinds I of storms and downburst incidents are clearly possible in West Virginia and the steel lattice towers in FirstEnergy s high voltage transmission system are clearly vulnerable, there is no mention of either the vulnerability or any plan to protect or upgrade these towers from this In its May 17,2012 report FirstEnergy attempted to divert the Commission s attention Page 6 of 8

~ ~~ ~ ~~~ ~~ ~~ ~ ~~~~ ~ Y from their failure to comply with the Commission s August 1,2012 Order by focusing only on the physical condition of its transmission facilities, and the company s claim to have met its responsibilities to inspect and maintain those facilities. In fact, as described above, FirstEnergy failed even in its diversionary tactic. There is no mention in the company s May 17,2012 report of the well documented vulnerability of its own steel lattice transmission towers. And six weeks later, that vulnerability was clearly demonstrated by the collapse of its own towers. This is exactly the kind of planning failure and reactive behavior that Mr. Auville decried in his June 27,2011 reply quoted above. The Coalition for Reliable Power respectfully requests that the Commission require Mon Power, TrAILCo and Potomac Edison to produce a report that is responsive to the Commission s August 1,2008 order, which the current report is not. Respectfully submitted this 1 1 th day of July, 20 12, 0., Bill Howley Steering Committee Chairman Coalition for Reliable Power Page 7 of 8

Appendix A Source: ht~s://wmiw.~rstener~corp. com/newsroon~/summer_stornz_image_ gallery. html *a1 Mi.nnesc ita Source: http://blog. greatriverenergy. com/2011/08/26/storm-damages -vital.-transmission-line/ Page 8 of 8