CENSE REJECTS U.S.E. S REPORT ON ENERGIZE EASTSIDE

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1 CENSE REJECTS U.S.E. S REPORT ON ENERGIZE EASTSIDE CENSE.org May 4, 2015 SUMMARY Members of the Coalition of Eastside Neighborhoods for Sensible Energy (CENSE) want to see an energy solution for the Eastside that benefits everyone, and harms no one. To better understand the challenges and opportunities, we have eagerly awaited the report of Bellevue s Independent Technical Analyst, which we asked the City of Bellevue to hire last June. Now that we have read the report authored by Utility System Efficiencies, we find that it answers some of our questions. But it leaves key questions unanswered. These omissions make it difficult for us to agree with U.S.E. s conclusion that Energize Eastside is reasonable and necessary. Our response to U.S.E. s report has been co-authored by CENSE and Richard Lauckhart, who served as VP of Power Planning for Puget Sound Power & Light, the company that became PSE. Mr. Lauckhart has over 40 years of industry experience, including over 20 years at Puget Power. We include Mr. Lauckhart s bio in Appendix A. CENSE finds significant flaws and omissions in the U.S.E. report that cast doubts regarding its conclusions: 1. Independent forecast missing. U.S.E. did not perform an independent load forecast, the most critical question residents had about the need for Energize Eastside. 2. Updated demand map missing. U.S.E. admitted that PSE s map of electricity demand didn t make much sense, but did not update the map as CENSE requested. 3. Cost-effective savings ignored. U.S.E. ignored savings identified by E3 totaling 56 MW. 4. Local generation turned off. U.S.E. rubber-stamped questionable assumptions made by PSE, such as turning off all local generation west of the Cascades in power flow simulations. 5. Growth trends unexplained. U.S.E. did not explain how population and employment trends lead to PSE s projections of demand growth. 6. Mostly downtown growth. U.S.E. did not show a need for this project outside of the downtown Bellevue and the Bel-Red corridor. 7. Substation loads missing. U.S.E. did not show peak load on Eastside substations, a key requirement for transmission studies. 8. Canadian flow unexplained. U.S.E. did not provide sufficient information about Canadian flow to settle this concern. We include in Appendix B a copy of the questions we posed to U.S.E. in January, with annotations to indicate whether U.S.E. s report actually answers these questions. 1

2 1. INDEPENDENT FORECAST MISSING CENSE asked for an independent forecast to validate the need for Energize Eastside, and to be sure that PSE isn t pursuing Energize Eastside to satisfy its own corporate goals. PSE has a strong incentive to build projects like this one. In fact, due to outdated energy regulations in our state, infrastructure projects are the only way the company makes money. We felt a truly independent forecast was necessary to settle these questions. Our concerns are reinforced by PSE s claim that the Eastside is experiencing demand growth at twice the rate forecast for Seattle. Seattle is also experiencing rapid growth in population and employment. According to PSE, vigorous growth on the Eastside nullifies conservation and efficiency trends that are well-documented at the national and regional level. For more than a year, PSE provided no historical data to support their forecast. Bellevue Mayor Claudia Balducci underscored the importance of an independent forecast with this statement at the December 8 meeting authorizing the contract with U.S.E.: I think that a kind of a truism about working with consultants is they tend to want to give you what it is they believe you want to receive We expect them to provide independent judgment. Instead of providing an independent judgment, U.S.E. essentially rubber-stamped PSE s forecast, declaring it reasonable. Their report contains little new analysis or careful examination of PSE s forecast assumptions. 2. UPDATED DEMAND MAP MISSING PSE created a map of electricity demand, shown at left, which supposedly demonstrates why the entire Eastside needs the new transmission line. According to this map, every city and neighborhood that the transmission line passes through is demanding the highest level of electricity. To create this map, PSE used peak demand data from the coldest and hottest days in 2009, both of which were extreme. The map represents usage levels which would only occur if customers ran their furnaces and air conditioners simultaneously. Even with that explanation, it s hard to believe that downtown Bellevue and Mercer Island are using the same level of electricity. We criticized this map during our meeting with U.S.E. in January, and they said it didn t make sense to us either. U.S.E. told us they would create a more accurate map. On page 37 of the report, U.S.E. admits they didn t have enough information to create a better map. As a result, we don t know who this project benefits, or where opportunities might exist for targeted conservation and efficiency programs. We are very disappointed with this outcome. 2

3 3. COST-EFFECTIVE SAVINGS IGNORED During their own investigation of the need for Energize Eastside, PSE employed a consultant named E3 to study alternatives to new poles and wires. E3 found 56 MW of cost-effective savings through increased Electrical Efficiency, Distributed Generation, and Demand Side Resources. This amounts to 8% of the emergency system capacity PSE uses for planning purposes, so it s a significant amount. E3 s savings would save customers money and benefit the environment. Despite repeated questions from CENSE, PSE has refused to acknowledge E3 s findings. We asked U.S.E. to explain how these savings might mitigate the need or timing of Energize Eastside. Unfortunately, we find no mention of the E3 study in U.S.E. s report. 4. LOCAL GENERATION TURNED OFF To determine when and how their system might be stressed, PSE uses power flow simulations with the following assumptions: 1. An extremely rare emergency condition: 2 of the 4 transformers that serve the Eastside are offline. 2. Peak winter load: a 23-degree day and peak usage in the morning or evening. 3. All local generation turned off. The third assumption adds stress to the system, but is not a realistic scenario. PSE could require these local generators to be online when peak load is anticipated. U.S.E. rubber-stamped PSE s assumption without comment on page 51: The ITA also confirmed the Northern Intertie (Path 3) transfers matched PSE s modeling plan (Table 8.2), and that PSE s winter generation dispatch scenario of no PSE and SCL generation west of the Cascades was modeled in the winter cases CENSE members explicitly asked about this assumption during our meeting with U.S.E. in January. U.S.E. s lead engineer, Gordon Gomegys, offered an explanation that involved renewable resources located east of the Cascades. This explanation made little sense to us, but we expected to see more detail in the final report. Again, we are sorely disappointed in this omission. 3

4 5. GROWTH TRENDS UNEXPLAINED U.S.E. includes this chart of Eastside population and employment projections on page 20: This graph shows population growing at slightly less than 1% per year, and employment growing at 1.7% per year. We hoped U.S.E. would explain at a conceptual level how these growth trends lead to growth in electricity demand of 2.4% per year. U.S.E. offers no explanation that might help the average person understand how these trends relate to electricity demand. 6. MOSTLY DOWNTOWN GROWTH U.S.E. lists 39 projects that are expected to be built in downtown Bellevue and the Bel-Red district during coming years. The report implies that these developments will use more electricity than the buildings they replace. However, U.S.E. did not list any projects in other Eastside cities. Should we conclude that the majority of the new demand will come from downtown Bellevue? We know that power poles as high as 13-story buildings will have a severe impact on dozens of neighborhoods, schools, and parks along the 18-mile route of the transmission line. Are these neighborhoods being asked to sacrifice their quality of life in order to subsidize development downtown? Would downtown developers demand better solutions if the transmission line were coming through their property? Our intent in asking these questions is not to start an argument between residents and businesses, but to work cooperatively towards an energy solution that benefits everyone and harms no one. The Eastside is capable of finding such a solution. 7. SUBSTATION LOADS MISSING The U.S.E. report does not provide data on peak loads for individual substations. Expert transmission planners (such as Mr. Lauckhart) view this data as key to transmission studies. This information would enable us to determine if smaller, more targeted alternatives are feasible. 4

5 Lacking independent analysis of substation data, we must trust that PSE has fairly evaluated all alternatives and reasonably concluded that a 230 kv transmission line is the only viable option. This is not the result we expected from a truly independent analyst. 8. CANADIAN FLOW UNEXPLAINED CENSE has repeatedly asked PSE and U.S.E. to provide the amount of Canadian electricity flow, in megawatts, that is being simulated in their power flow studies. Neither has responded with a specific number. PSE says the number is 5-8% of system capacity, but we don t know if they mean their normal system capacity (1600 MW) or the N-1-1 capacity modeled in power flow studies (706 MW). We don t know if this 5-8% value represents normal everyday flow, or if it is a winter peak level. We believe it serves PSE s strategic interests to keep this number vague. U.S.E. says they modeled a scenario with 0 MW of Canadian flow. On page 65, U.S.E. reveals that the number of overloads is reduced from 5 to just one. This reinforces our suspicion that Canadian flow is having a significant effect on overall system stress. If Canadian flow were diverted from PSE s lines, could the one final overload then be alleviated by other means? Could a third transformer at Talbot Hill help to prevent overload? Could E3 s savings combined with lower Canadian flow accomplish the same thing? These questions are not academic, even though U.S.E. claims that it is not possible to reduce Canadian flow due to U.S. treaty obligations. They fail to mention that this flow does not have to happen on PSE s lines. The utility consortium ColumbiaGrid previously endorsed a relatively inexpensive project to upgrade wires on Seattle City Light s 230 kv line through the Eastside. If that project were pursued, the amount of Canadian electricity on PSE s line would be significantly reduced. CONCLUSION U.S.E. declined to do the power flow simulation we are most interested in. It would include the following features: 1. Reconductor the Seattle City Light line to serve Canadian flow. 2. Reduce peak demand using E3 s recommendations. 3. Install a third transformer at Talbot Hill to eliminate an overload at that location. 4. Anticipate the impact of rapid developments in grid and residential battery storage such as those announced by Tesla on April 30. We suspect that such a study would not only delay the need for a new transmission line by many years (possibly forever), it would save customers money, preserve neighborhoods and the environment, and enhance the Eastside s reputation as a forward-thinking, technologically-advanced, and environmentally supportive community. We welcome the opportunity to work with policymakers and PSE to achieve this better outcome for the Eastside. 5

6 APPENDIX A: BIO OF RICHARD LAUCKHART J. Richard Lauckhart has 40 years of experience in power supply planning, electricity price forecasting and asset valuation. He began his career as a distribution engineer with Pacific Gas & Electric Co., and held various positions at Puget Sound Power & Light Co. (now Puget Sound Energy) in power supply planning, culminating as vice president of power planning. For the last 12 years Mr. Lauckhart has performed consulting assignments related to power market analyses, price forecasting services, asset market valuation, integrated resource planning, transmission line congestion analysis, and management of strategic consulting engagements for clients in North America, including investor-owned and municipal utilities, independent power producers, and lenders. Mr. Lauckhart received a bachelor of science degree in electrical engineering from Washington State University in 1971 and a masters degree in business administration from the University of Washington in 1975 Representative Project Experience Black & Veatch September 2008 to October 2011 MANAGING DIRECTOR Mr. Lauckhart oversees wholesale electricity price forecasting, project revenue analysis, consults regarding wind integration matters electric interconnection and transmission arrangements for new power projects, and other related matters in the electric power industry. In addition, he heads Black & Veatch s WECC regional power markets analysis team. WECC Power Market Analysis and Transmission Analysis, Henwood/Global Energy Decisions/Ventyx SENIOR EXECUTIVE Mr. Lauckhart oversaw wholesale electricity price forecasting, project revenue analysis, consulted regarding electric interconnection and transmission arrangements for new power projects, and other related matters in the electric power industry. In addition, he headed Global Energy s WECC regional power markets analysis team. Lauckhart Consulting, Inc President Primary client - Puget Sound Energy (formerly Puget Sound Power & Light Company): Involved in power contract restructuring, market power analysis, FERC 888 transmission tariffs, and other matters. Testified at FERC regarding Puget s 888 tariff. Testified for Puget in June, 1999 arbitration with BPA regarding transmission capability on the Northern Intertie. 6

7 Northwest IPP Under retainer with IPP from July 1996 through December 31, Involved primarily in merchant power plant development activities including permitting activity, owner s engineer identification, environmental consultant identification, water supply arrangement, transmission interconnection and wheeling arrangements, gas pipeline arrangements, economic analysis, forward price forecasting, marketing, and related issues. Levitan & Associates (Boston) Participated in teams involved in electric system acquisition activities. Performed preliminary analysis for a major retail corporation regarding possible participation as an aggregator in the California deregulated electric market. Involved in the evolving discussions about deregulation in the state of Washington including participant in HB 2831 report and ESSB 6560 report. Member of advisory task force for Northwest Power Planning Council study of generation reliability in the Pacific Northwest. Participating writer in a newsletter advocating electric deregulation in the state of Washington. Puget Sound Power & Light Company VICE PRESIDENT, POWER PLANNING Involved in all aspects of a $700 million per year power supply for a hydro/thermal utility with a 4,600 MW peak and 2,200 amw energy retail electric load. Included responsibility for a 22 person department involved in power scheduling (for both retail and wholesale power activity), power and transmission contract negotiation and administration, regulatory and NERC compliance, forward price forecasting, power cost accounting, and retail rate activity related to power costs. Activity included matters related to 650 MW of existing gas-fired, simple cycle combustion turbines. In addition, 660 MW of combined cycle cogeneration qualifying facilities were developed by others for Puget during this time frame. Detailed understandings of the projects were developed both for initial contractual needs and later for economic restructuring negotiations. Mr. Lauckhart was the primary person involved in developing Puget s Open Access transmission tariff in accordance with FERC Order 888. Puget Sound Power & Light Company MANAGER, POWER PLANNING The company s key person in developing (1) a WUTC approved competitive bidding process for administering PURPA obligations, and (2) a WUTC approved regulatory mechanism for recovery of power costs called the Periodic Rate Adjustment Mechanism (PRAM). 7

8 Puget Sound Power & Light Company DIRECTOR, POWER PLANNING The company s key person in developing a power cost forecasting model that was customized to take into account the unique nature of the hydro generation system that exists in the Pacific Northwest. Puget Sound Power & Light Company MANAGER, CORPORATE PLANNING Responsible for administering the corporate goals and objectives program. Puget Sound Power & Light Company FINANCIAL PLANNING Improved and ran a computerized corporate financial forecasting model for the company that was used by the CFO. Puget Sound Power & Light Company TRANSMISSION PLANNER Performed transmission engineering to assure a reliable transmission system. Pacific Gas & Electric Company DISTRIBUTION ENGINEER Performed distribution engineering to assure a reliable distribution system. Other Relevant Experience Expert testimony for Montana Independent Renewable Generators related to avoided cost regulations and pricing filed February 2009 at the Montana PSC Expert Testimony for LS Power in the SDG&E Sunrise Proceeding regarding economics of in-area generation vs. the cost of transmission and imported power Spring 2007 Expert Testimony for BC Hydro in the Long Term Resource Plan, February 2009 dealing with natural gas price forecasts and REC price forecasting Expert Testimony for John Deere Wind in a proceeding in Texas in November 2008 related to avoided costs and wind effective load carrying capability. 8

9 Expert Testimony for Two Dot Wind before the Montana commission regarding wind integration costs Spring 2008 Expert Testimony in the BC Hydro Integrated Electricity Plan proceeding regarding WECC Power Markets. November Expert Testimony for Colstrip Energy Limited Partnership before Montana PUC regarding administration of QF contract prices. July Expert Testimony for Pacific Gas & Electric regarding current PURPA implementation in each of the 50 states. January Expert Testimony in CPUC proceeding regarding modeling procedures and methodologies to justify new transmission based on reduction of congestion costs (Transmission Economic Analysis Methodology TEAM). Summer Expert Testimony for BC Hydro regarding the expected operation of the proposed Duke Point Power Project on Vancouver Island, January 2005 Expert Testimony for PG&E regarding the cost alternative generation to the proposed replacement of steam generators for Diablo Canyon, Summer of Expert Testimony in an arbitration over a dispute about failure to deliver power under a Power Purchase Agreement, Fall Integrated Resource Plan Development. For a large investor-owned utility in the Pacific Northwest, Global Energy provided advanced analytics support for the development of a risk-adjusted integrated resource plan using RISKSYM to provide a stochastic analysis of the real cost of alternative portfolios. Expert Testimony for SDG&E, Southern California Edison, and PG&E regarding IRPs, WECC markets and LOLP matters before the California PUC, Miguel-Mission Transmission Market Analysis-San Diego Gas & Electric. San Diego Gas & Electric retained Global Energy to oversee an analysis of the economic benefits associated with building the Mission-Miguel transmission line and the Imperial Valley transformer. Global Energy performed an analysis of the economic benefits of the Mission-Miguel line, prepared a report, sponsored testimony at the CPUC, and testified at the CPUC regarding the report. Valley-Rainbow Transmission Market Analysis-San Diego Gas & Electric. San Diego Gas & Electric also engaged Global Energy to analyze the economic benefits associated with building the Valley-Rainbow transmission line and to respond to the CPUC scoping memo that SDG&E should describe its assessment of how a 500 kv interconnect, like Valley-Rainbow, will impact electricity markets locally, regionally, and statewide. Global Energy analyzed the economic benefits of the Valley-Rainbow line, prepared a report, sponsored testimony at the CPUC, and testified at the CPUC regarding the report. Damages Assessment Litigation Support. Global Energy was engaged by Stoel Rives to provide damages analysis, expert testimony and litigation support in for its client in a power contract damages lawsuit. Global Energy quantified the range of potential damages, assessed power market conditions at the time, and provided expert testimony to enable Stoel Rives client to prevail in a jury trial. Expert Testimony, Concerning the Economic Benefits Associated with Transmission Line Expansion. Testimony prepared on behalf of San Diego Gas & Electric Company, September

10 Expert Testimony, Concerning market price forecast in support of Pacific Gas and Electric hydro divesture case, December Expert Testimony, Prepared on behalf of AES Pacific regarding value of sale for Mohave Coal project to AES Pacific for Southern California Edison, December Expert Testimony, Prepared on behalf of a coalition of 12 entities regarding the impact of Direct Access of utility costs in California. June Mr. Lauckhart was Puget s primary witness on power supply matters in eight different proceedings before the Washington Utilities and Transportation Commission. Mr. Lauckhart was Puget s chief witness at FERC in hearings involving Puget s Open Access Transmission Tariff and testified for Puget in BPA rate case and court proceedings. 10

11 APPENDIX B: CENSE QUESTIONS FOR U.S.E. Below are the questions that CENSE submitted to U.S.E. during our initial meeting in January. We added annotations in red to indicate whether the U.S.E. report answers our questions. Q1: UNDERSTANDING THE REAL NEED To better understand the need for Energize Eastside, we would like to see a graph similar to this one from Seattle City Light 1 (orange annotations by CENSE): -0.1% / year We note that peak load (the same as demand in PSE s graph) has been gradually declining in Seattle for the past 27 years, despite significant economic and population growth during that period. Also, Seattle s forecast rate of growth is less than half of PSE s. Similar trends are occurring in Portland. We ask the consultant to produce an analogous graph for the Eastside that shows the following data, with values independently determined by the consultant using unfiltered, raw data from PSE or other sources: 1. Time period from 2000 to 2030 (15 years of historical data, and a forecast for the next 15 years). 2. Values for One-Hour Peak Load (MW) with grid outage (N-1-1 state in Q3 below). 3. Values for One-Hour Peak Load (MW) with no grid outage (N-0 state). 4. Values for Annual Average Load (amw) with grid outage (N-1-1 state in Q3 below). 5. Values for Annual Average Load (amw) with no grid outage (N-0 state). 6. A line showing existing System Capacity (which PSE shows as approximately 710 MW on its Forecast) including any allowable increase for temporary loads. We would like the consultant to independently verify PSE s value. 7. A line showing the future System Capacity of Energize Eastside, including any allowable increase for temporary loads, which we would like the consultant to independently verify. 8. A line showing the Total Transfer Capacity of Energize Eastside. 1 p

12 The graph should be accompanied by an explanation of the methodologies used and assumptions made to produce each value on the graph so we can understand how they were determined and to what extent they are independent of PSE s values. (None of the details requested above are included in U.S.E. s report.) Q2: DISTRIBUTION OF PEAK USE PSE shows the following map that purports to demonstrate high electricity demand throughout the Eastside: 2 Unfortunately, the methodology used to create this map is unsound. We have been told by PSE that it combines peak use data from both summer and winter peaks which occurred over 5 years ago. The inclusion of summer peak data is not relevant to the winter peak problem Energize Eastside seeks to address and makes the problem look much worse. Furthermore, the data was scaled and smeared to protect consumers privacy. The result of these manipulations suggests that Mercer Island is using electricity at the same intensity as downtown Bellevue, which is hard to believe

13 We ask the consultant to create a more accurate map showing winter peak loads for the same area shown in PSE s map. The updated map should show data from a representative winter peak which occurred no more than 2 years ago. To provide adequate detail, data should come from measurements of peak loads at the level of individual distribution substations. An accurate map is important, because localized peaks might be addressed by localized solutions. Some may represent prime opportunities for conservation. (On page 37 of their report, U.S.E. states that their map was not clear enough to warrant inclusion.) Q3: EASTSIDE VS. REGIONAL NEEDS The VP of Transmission Planning for the Bonneville Power Administration (BPA) tells us that Energize Eastside is part of a regional transmission plan developed jointly by PSE, BPA, and Seattle City Light (SCL) to address three issues: 1. Load for the Eastside 2. Load for Seattle 3. Reliability of the Northwest Washington Electric Grid This is confirmed in planning documents from the Columbia Grid consortium and agreements signed by PSE, SCL, and BPA. 3 The role of Columbia Grid and BPA is illustrated in this diagram, which shows how Energize Eastside (upgrades to the lines between Talbot and Sammamish) helps to address two outages on BPA lines indicated by arrows near the Monroe station: p. 5 13

14 We believe this diagram is relevant to PSE s Eastside Customer Demand Forecast, because PSE s Needs Assessment predicts no overload condition for Eastside infrastructure under extreme peak loads (13 degree winter weather) by 2022, even with very low conservation: N-0 Thermal and Voltage Violation Summary For all cases, there are no thermal or voltage violations for the all lines in (N-0) state Case 2-Winter Peak, Normal Weather: For all elements in service (N-0), there were no thermal or voltage violations for winter peak, normal weather, with all levels of conservation modeled (i.e. 100%, 75%, 50%, or 25%) conservation Case 3-Winter Peak, Extreme Weather: For all elements in service (N-0), there were no thermal or voltage violations for winter peak, extreme weather, with all levels of conservation modeled (i.e. 100%, 75%, 50%, or 25%) conservation Case 2-Winter Peak, Normal Weather: For all elements in service (N-0), there were no thermal or voltage violations for winter peak, normal weather, with all levels of conservation modeled (i.e. 100%, 75%, 50%, or 25%) conservation. 5 p

15 Case 3-Winter Peak, Extreme Weather: For all elements in service (N-0), there were no thermal or voltage violations for winter peak, extreme weather, with all levels of conservation modeled (i.e. 100%, 75%, 50%, or 25%) conservation. In order to better understand this issue, we ask the consultant to produce a series of simple one-line diagrams that illustrate the following: 1. Existing Eastside infrastructure and the direction and amounts of electricity flow during a normal winter peak load event with no nearby grid outages (N-0 in industry parlance). 2. Using the diagram and peak scenario created in 1. above, show the effects on and amounts of electricity flow during an N-1-1 outage of BPA s transmission lines as indicated in the Revised Plan diagram above. 3. Diagram Eastside infrastructure if Energize Eastside is built as proposed, with the direction and magnitude of electricity flow during a normal winter peak load event under N-0 conditions. 4. Using the diagram created in 3. above, show the effects on and amounts of electricity flow during the same N-1-1 outage specified in 2. above. If it s not clear from these diagrams, we are especially interested to know what percentage of the electricity flowing on Eastside transmission lines is flowing to Canada or points north in the normal and N-1-1 scenarios. We would like the consultant to verify that the values used in PSE s Eastside Customer Demand Forecast assume a scenario in which a winter peak demand event occurs on the Eastside at the same time a major transmission outage (an N-1-1 event) occurs nearby on the grid. We would also like the consultant to explain how likely it would be for these events to occur simultaneously. How many hours per year is this worst-case scenario likely to happen in 2015, 2020, 2025 and 2030, assuming Energize Eastside were not built? How would these forecasts change if BPA constructed the Echo Lake-Monroe 500 KV Transmission Project currently listed as ON HOLD in BPA s 2014 Annual Progress Report to the Western Electricity Coordinating Council? 6 (We find no answers to these questions in U.S.E. s report.) Q4: RELIABILITY We are unsure that spending $200 million on Energize Eastside is the best way to improve the reliability of our power. To better understand this, we ask the consultant to characterize all power outages for the years by their causes. We are especially interested to know how the incidence of outages caused by system overload on the equipment which Energize Eastside would replace compares to downstream outages caused by extreme weather, tree strikes, accidents, downstream equipment failure, etc. We ask the consultant to forecast how many outages in the next five years ( ) would be avoided by implementation of Energize Eastside. (These questions remain mostly unanswered in U.S.E. s report. On page 47, U.S.E. estimates Energize Eastside will avoid one outage every 3-30 years.) 6 p. 8 15