2013 10 29 CCTP Alternate Solutions by Benjamin Swett.pdf

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BENJAMIN SWETT1185 County Route 22

Ghent, NY 12075518-828-6394

[email protected]

www.benjaminswett.com

October 29, 2013

Hon. Eleanor SteinAdministrative Law JudgeNew York State Public Service CommissionThree Empire State Plaza

Albany New York 12223-1350

Case 12 - T - 0248 - Application of New York State Electric & GasCorporation for a Certificate of Environmental Compatibility and PublicNeed for Construction of the Columbia County Transmission Project,Approximately 11.1 Miles of 115 Kilovolt Transmission Lines and relatedfacilities in the Towns of Chatham, Ghent and Stockport, in ColumbiaCounty.

Dear Judge Stein,

Thank you for the opportunity to present ideas for alternative solutions to theproposed 115 kV electric transmission corridor through Ghent. The testimony of NYSEGplanner Jeff Mckinney on September 17, 2013 suggested that NYSEG has applied toconstruct the proposed new 115 kV line to solve two problems:

1) A flaw in the current configuration of the Churchville-Craryville line rendersthat line vulnerable to outages that, in recent years, have affected as many as4,507 NYSEG customers for as many as eight days and twenty-two hours andcould affect as many as 9,900 customers for an untold number of days. AsNYSEG writes in its application, an equipment failure that resulted in theloss of the existing Churchtown-Craryville 115-kV line would result in

imminent voltage collapse. Under these conditions, 9,900 customers(corresponding to 26 MVA during winter and 31 MVA during summer) are atrisk of having their service dropped. During his testimony on September 17,Mr. Mckinney called this weakness in the Churchtown-Craryville line acritical contingency for our local system. A new 115 kV line bringingadditional power to the area from a separate source and along a different routewould serve as a backup to prevent outages along the Churchtown-Craryvilleline from affecting customers.


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2) In recent years, power usage in the area has been increasing at a rate of 3.1

percent a year, making it, as Mr. Mckinney said in his testimony, one of thestrongest growing areas in the NYSEG footprint. An additional 115 kv linecoming in from a separate source would increase the capacity of the system

and provide the potential for enough additional electricity to accommodategrowth at the current rate of 3.1 percent for the next 17 years, until 2030.

Although Mr. Mckinney combined these two problems in his testimony, if theproblems are considered separately they suggest a two-step solution that could solveNYSEGs contingency problem in potentially less intrusive, less expensive, and morelong-lasting ways than immediately building a new 11.1-mile overhead 115 Kv powerline through Ghent. It would require NYSEG to fix a known existing problem beforeseeking to spend money building new structures or opening new rights of way. The two-step solution would involve: 1) correcting the flaw in the current configuration of theChurchtown-Craryville line, and 2) increasing the capacity of the system feeding the

Craryville area.

Step 1: Correcting the FlawThe flaw consists of a 920-foot section of underground cable under the Taconic

State Parkway that twice in the last five years has experienced failure, leading, in onecase, to nearly nine days without power for 4,507 people. The delay in restoring powerwas caused by the combined difficulties of locating the source of the failure in theunderground line, applying to the NYS DOT for a permit to run temporary cables overthe parkway, running those temporary cables over the parkway, removing the damagedsection of cable from under the parkway, and bringing in and installing new undergroundreplacement cable. In fact, according to testimony by NYSEG engineer Michal Bartczakon September 24, it took more than a month to replace the failed cable and the power tothe Craryville area would have been compromised for that long if it had not been for theerection of the temporary cables over the parkway. By comparison, when an overheadcable on the same line experienced failure from a broken pole in 2013, the line was outfor only three hours. As Mr. Mckinney said in his testimony on September 17, the flaw inthe Churchtown to Craryville line is the most significant problem in the Mechanicvilledivision and has been a concern since the 1990s: a loss in Churchtown to Craryville alsotakes out the line to Kline Kill. So it's one line . . . . Churchtown, Craryville to Kline Killis the most limiting contingency.

The flaw can be corrected in two ways: A) replace the 920-foot undergroundportion of the line with overhead cable or B) rebuild the 920-foot underground section sothat it could contain additional underground cable to serve as backup and so that it couldbe more easily accessed in the case of an emergency and repaired as quickly as anoverhead line.

A)Replace the underground cable with overhead cable over the Taconic Parkway.Replacing the underground section with overhead cable would be the cheapest

and simplest solution, but it would require special approval from the New York State


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Department of Transportation and the NYS Office of Parks, Recreation and HistoricPreservation for an easement to put the lines overhead. In its April 27, 2011 FrequentlyAsked Questions document, NYSEG writes, New York State Department ofTransportation and State Historic Preservation Organization regulations do not permitoverhead lines to cross the Taconic parkway. But in CCTP-12-090, NYSEGs response

to my information request BCS-2 (attached), NYSEG engineer Michal Bartczak cites thefour statutes that give the New York State Department of Transportation and theDepartment of Parks, Recreation and Historic Preservation general authority over the

construction of utility facilities within the parkway system, including the power to require

undergrounding of electric transmission lines. Significantly, none of these four regulations

specifically forbids overhead lines over the parkway; rather, they give these agencies the

authority to require that lines be put underground. To cite the most directly pertinent, Section

14.09 of the NYS Parks, Recreation and Historic Preservation Law provides that the State

Historic Preservation Office must review any construction project that may have an adverse

impact on the quality of any historic, architectural, archeological or cultural property that is

listed on the national register of historic places or property listed on the state register or is

determined to be eligible for listing. Such review would be necessary in this case because

the Taconic State Parkway is on the National Register of Historic Places.

When I asked in my information request BCS-2 if NYSEG has held discussions withthe New York State Department of Transportation and/or the State Historic PreservationOrganization on the possibility of a permanent variance to replace the undergroundportion of the Churchtown-Craryville 115 Kv transmission line with overhead lines,NYSEGs response (attached) was, no. When I asked if NYSEG has ever formallyapplied to these two agencies for such a variance, the answer was, again, no. When Iasked for copies of any correspondence among the entities on this subject, NYSEGresponded that none could be found. Why, though able to acquire a permit to put linestemporarily over the Parkway, NYSEG was unwilling to pursue an easement to put the

lines permanently over the parkway and did not even discuss the matter with theappropriate agencies strikes me as curious, especially when compared to the much greaterimpact and cost of the alternative solution now being proposed at least partially to solvethis problem, a new 11.1-mile transmission line including 8.4 miles of new right of waythrough Ghent. If the Public Service Commission were to require NYSEG to attempt torepair the existing flaw in its system before building a new transmission line, wouldntthe affected agencies at least have to give an overhead Taconic Parkway proposal seriousconsideration?

Currently, two sets of overhead lines owned by NYSEG already cross the TaconicParkway in Columbia County: the 115 kV Klinekill-Craryville Section of Line 984, and

the 34.5 kV Craryville-Mellenville Line 611. Judge Stein, if you were to drive along theTaconic Parkway between the Claverack and Philmont exits, you would cross under thesetwo sets of overhead lines and you would see how little impact they have on the views ofthe surrounding countryside from the Taconic Parkway. When compared to the visualimpact of the proposed 11.1-mile CCTP on all the roads and homes along it, the effectseems especially trivial. They cross an already-existing major human imposition on thelandscapea parkwayof the kind across which one is accustomed to see transmissionlines run. The quick view of them as one drives underneath at 55 mph gives little time to


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register their existence. In contradiction of the statements by Christian Lynn in histestimony on October 24 that a project has less impact when seen from a greater distance,in fact, from a moving car on the Taconic State Parkway, the more distant prospects andthe more general views are what one notices and is able to notice. From a moving car, thegreater the distance to an object the more it appears to be standing still and the longer one

sees it.

Adding a new set of transmission lines across the Taconic Parkway a few milessouth of the two already-existing sets would have little additional impact and would be afar less expensive solution than the proposed CCTP. The State Historic PreservationOffice is already reviewing the CCTP in light of its significant impacts on more than 100houses and an historic district on or eligible for listing on the State or National Registerof Historic Places. Surely it would be only fair to give this office a chance to weigh therelative impact of a solution involving the construction of only 925 feet of overheadtransmission line over a parkway as opposed to 8.4 miles of transmission lines along anew right-of-way through historic agricultural properties in Ghent. It certainly seems

unlikely that such a solution would raise the kind of community opposition that theproposed CCTP has in Ghent.

B)Rebuild the underground section under the Taconic Parkway.The more complex but ultimately, perhaps, more useful solution to the flaw in the

Churchtown-Craryville line would be to rebuild the 925-foot underground section toallow easier access to the cables and to allow for additional backup cables to be placedunder the road. Such rebuilding would also require approval of the New York StateDepartment of Transportation and the NYS Office of Parks, Recreation and HistoricPreservation, but presumably such approval would be easier to acquire because it wouldbe for a project that would have no visual impact on drivers on the parkway. When I

asked during my cross-examination on September 24 if it was possible to construct anunderground transmission line . . . under a road, that would provide easy access to thecables, either through widening and deepening the tunnel to allow technicians to walkalongside the cables and repair them or through pre-constructed access-ways from abovesuch as are commonly called manholes, NYSEG engineer Michal Bartczak agreed that itwas possible.

During that same cross-examination Mr. Bartczak talked about problems withunderground construction and with the 925-foot underground section under the TaconicParkway. When we have a break or a failure of an overhead circuit, said Mr. Bartczak,it is clearly visible, we can locate it very, very fast. When we have a problem or . . . an

outage of an underground circuit, by the nature of it being buried underground, it is veryhard or can be hard to locate it. So that is one of the main issues. Also, you know, oncewe locate it, it takes a while -- a much, much longer time to replace the undergroundsection of the cable than it does an overhead line. By rebuilding and expanding theunderground section under the Taconic to allow a technician to walk through the tunnelalongside the cables, NYSEG could reduce the time required to locate and replace thedamaged cable by making the underground cables as accessible as the overhead ones.This would significantly reduce the impact on customers in the event of a cable failure in


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a far less expensive way than the proposed CCTP. Although a more complex constructionjob than putting the cables overhead, it must still be far cheaper than the $28 million costof the proposed CCTP. Perhaps the cost would be about equivalent to that of building theproposed new Ghent switching stationabout $6 million.

A significant advantage of rebuilding the underground portion of the Churchtown-Craryville line would be that it could be made large enough to contain enough cables tosupport a second 115 kV transmission line between the Churchtown and Craryvillesubstations. This would allow NYSEG to expand the capacity and increase the poweravailable to the system as a whole (see below) without having to apply again to the NYSDOT and the State Historic Preservation Office for an additional tunnel or to putadditional overhead cables over the parkway. And it would allow NYSEG to add anotherline to the area while using an existing right of way. As a general management policy,isnt it better to fix a 925-foot fault in an existing transmission line before setting out tobuild an entirely new 11.1-mile transmission line?

Step 2: Increasing CapacityCorrecting the flaw in the Churchville-Craryville line, either by acquiringpermission to run the cables over the parkway or by rebuilding the underground sectionto allow easier access to the cables and the installation of backup cables, would eliminatethe critical contingency referred to by Mr. Mckinney but would not directly solve theproblem of load growth in the Mechanicville division. However, by removing thepotential for lengthy delays due to problems with repairing the underground cables, itwould give NYSEG time to explore more creative, less expensive, and lessenvironmentally, economically, and visually impactful ways to increase the powerflowing into the Craryville area. These include:

A. Construct a new 8.5-mile 115 Kv line between National Grids Valkin and NYSEGsKlinekill substations.By acquiring approximately 5 miles of right-of-way along the existing CSX

railroad track that parallels the direct route between the two substations and thenundergrounding the approximately 3.5 miles that would connect the two substations tothe railroad track right-of-way, NYSEG could provide an identical level of additionalpower to the Klinekill substation in a less obtrusive and less expensive way than theproposed CCTP. Although in his testimony Mr. Mckinney said that National Grid hadrejected such a plan because of congestion at the Valkin Substation, in fact Mr. Hurstshowed in his cross-examination that it was NYSEG that had rejected the plan and thecongestion at the Valkin substation could be relieved through an expansion project. Of

several plans considered in system planning studies in prior yearsincluding anexpansion of the Churchtown-Craryville line (see below)the Valkin-Klinekill proposalwas considered the least expensive. NYSEG has provided no studies to allow us tocompare the costs of a Valkin-Klinekill line to the proposed CCTP, but I suspect thatbecause it would be shorter and because it would not require the construction of theGhent switching station, it would be less expensive for the NYSEG customers who wouldultimately bear the cost of this project.


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In general, the advantages of a Valkin to Klinekill approach would be 1) the linewould be less expensive to build because it would be 8.5 miles rather than 11.1 mileslong and would not require the construction of the new Ghent switching station; 2) theline would have a less detrimental impact on the working agricultural fields of ColumbiaCounty because, of the 8.5 miles of the line, approximately 5 would follow a pre-existing

industrial-type right of way, leaving just 3.5 miles of new right of way on which to buildthe line; 3) the line would have a less detrimental environmental and visual impact, againbecause, of the 8.5 miles of the line, approximately 5 would follow a pre-existing right ofway, leaving just 3.5 miles of new right of way on which to build the line; 4) installingthe line underground on all or portions of these 3.5 miles would also reduce its visualimpact and would make it less vulnerable to storms; 5) such a configuration wouldcontribute less to the fragmentation of the New York landscape because more of the linewould follow an existing right-of-way; 6) the line would not require the construction ofthe new Ghent switching station, leading to cost savings that could support the additionalcosts of underground construction or expansion of the Valkin substation.

B. Expand the Churchtown-Craryville corridor to include an additional 115 kV line.With an expanded tunnel under the Taconic State Parkway or permission to crossthe Taconic with overhead cables, NYSEG would have no obstacle to adding anadditional line beside the already-existing Churchtown-Craryville line. During histestimony, Mr. Mckinney said that including an additional 115 kV line along theChurchtown-Craryville right of way would not be the equivalent of the proposed CCTP,but his testimony referred to a situation in which the new line would share the existingflaw at the underground stretch under the Taconic. Were this flaw to be removed,presumably an additional line could have the same improving effect on system capacityas the proposed CCTP. In a NYSEG System Planning Study Report referred to by Mr.Hurst during his cross-examination of Mr. Mckinney on September 17 (Exhibit #30 in

this case), a new Churchtown-Craryville 115 kV line was rejected in favor of a Valkin-Klinekill line because the Churchtown-Craryville would be more expensive and becauseit would share or almost share the same right of way as the existing 115 kV lineChurchtown-Craryville and will not substantially improve the system reliability overthe existing transmission line configuration. Presumably the unreliability of theexisting transmission line configuration is caused by the underground portion of theline under the parkway. Were this portion to be made more reliable a Churchtown-Craryville option would become viable. As for the greater expense over the Valkin-Klinekill option, without concrete figures it is impossible to judge the relative costs ofthis option, the Valkin-Klinekill option, and the proposed CCTP. If NYSEG were toreceive permission to run the line over the Taconic parkway rather than having to rebuild

its tunnel under the parkway, the expense would presumably be more reasonable. Onewould hope that the PSC could require NYSEG to estimate the various costs so actualcomparisons could be made.

The advantages of this approach over that of building a new 115 Kv line throughGhent are 1) it would have fewer environmental, visual, and agricultural impacts becauseit would use an existing right-of-way for the entire 8 miles of the additional line ratherthan opening a new one through 8.4 miles of mainly unspoiled farmland; 2) since it


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Given NYSEGs self-described inexperience with underground construction,unless an underground version of the proposed CCTP is actually put out to bid--and to acompany experienced in longer underground transmission projectsNYSEGs in-houseprojections of underground as opposed to aboveground construction costs would seem aninadequate basis on which to reject an underground solution to the proposed CCTP. In

response to Information Request C of the June 22, 2012 Appendix A InformationRequests, NYSEG estimated that the cost of an underground routing of the proposedCircuit 726 would cost three times as much as the proposed aboveground routing of thesame circuit. These cost estimates were based, as Mr. Bartczak said in his September 24testimony, not on a competitive bidding process but on the historic cost of labor forunderground construction on certain small sections of underground circuits in oursystem. Based on the historic costs of these small sections of underground circuitsbuilt more than ten years ago, the estimates do not account for the cost-savings that couldbe achieved through construction of a longer line through different geographiccircumstances in the present day.

The advantages of an underground as opposed to an aboveground routing fromthe proposed CCTP cannot be ignored: 1) the visual impact would be minor ornonexistent both where the line crosses by public spaces and where it passes throughprivate, where it can be seen from historic homes and districts eligible for registry on thestate or national registers of historic places or where it can be seen from other homeswhere the view would be just as bad though the house had no government protection; 2)by installing a separate line underground NYSEG would be providing an entirely newpower source for the Mechanicville Division whose vulnerabilities to storms or terrorismwould be different from those possessed by all of the other power sources coming in tothe Mechanicville Division; 3) while installing this line underground NYSEG couldinstall sufficient cable in advance either to increase capacity in the future or to cover for

any difficult-to-repair failures in the underground line; 4) the line would contribute less tothe fragmentation of the New York State landscape because, although there, it would bemostly invisible; 4) while the line would be more expensive to install initially, if properlyinstalled it could achieve much lower maintenance costs over the long term in itsprotected position under the earth than those of an aboveground line which is constantlyexposed to wind, weather, and wildlife.

ConclusionArticle 7 of Public Service Law does not specifically require a proposed

transmission facility to conform to a long-range plan for the preservation of the landscapeof New York State, nor does it require a proposed transmission facility to conform to a

long-range policy for the reduction of carbon emissions into the atmosphere. As a result,utilities in New York State have few encouragements to design facilities in a mannerconsistent with the need to address climate change and prevent the further fragmentationof the landscape of Upstate New York. My suggested alternatives seek to address theseconcerns while reducing costs and environmental and social impacts by: 1) solving theexisting flaw in the system before seeking to expand the system; 2) looking for routesthat follow existing rights of way for as long as possible rather than opening new rights ofway; 3) looking for the shortest practical routes; 4) undergrounding when not following


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existing rights of way; 5) avoiding the construction of the proposed Ghent switchingstation.

Thank you again for the opportunity to suggest these alternatives. I would behappy to answer any questions about them or do further research into any of the ideas if

you or any of the other parties would like.

Sincerely,

Benjamin Swett

Documents

2013 10 29 CCTP Alternate Solutions by Benjamin Swett.pdf