dps staff comments on nyseg's assessment of alternatives

8/12/2019 DPS Staff Comments on NYSEG's Assessment of Alternatives

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RE: Case No. 12-T-0248:Application of New York State Electric & Gas Corporation for a

Certificate of Environmental Compatibility and Public Need for the Construction of the

"Columbia County Transmission Project," Approximately 1.1 Miles of 115 Kilovolt

Transmission Lines and related facilities in the Towns of Chatham, Ghent, and

Stockport, in Columbia County.

DPS Staff Comments on NYSEGs February 26, 2014, Assessment of Alternatives

The Staff of the Department of Public Service (DPS) designated to represent the publicinterest in this proceeding (Staff) has the following comments on the Assessment of Alternativesfiled by New York State Electric & Gas Corporation (NYSEG).

Regarding Attachment B

Based upon the Chatham Area being 49.1% of the Mechanicville Division load (as per IRCCTP-12-093 (DPS-48)), the megaWatt (MW) figure shown as part of the base case(normal) power-flow (in Attachment B, page 1) total flow into the Chatham Area (the sum of115 kV inputs into Wyantskill, Stephentown, Falls Park and Craryville) is equivalent to aMechanicville load above the forecasted load of 252 MW. We do not concur with thishigher level, and NYSEG has not provided an explanation for why this higher load levelwas used, which makes the results more conservative thereby potentially necessitatingcompletion of some of the Staffs 34.5 kiloVolt (kV) phased work that may otherwise not beneeded.

Regarding Attachment C

The identification of the location of the 34.5 kV feeders exiting the proposed Falls ParkSubstation site and County Route 22, as depicted at Attachment C mapping, does notreflect the locations identified by DPS Staff in mapping submitted in October 2013.(Compare locations at Pages 2, 6, 12 and 16 of 24 in NYSEG Attachment C with DPS mapentitled "34.5 kV System Alternative" filed October 30, 2013, which accompanies this filing.)Staff would like to review the specific locations of proposed feeders 1 through 4 withNYSEG to identify specific constraints and opportunities for location of new feederlocations. Staff notes that NYSEG proposes to rebuild the existing distribution circuit in thisarea as part of the Feeder #3, which is acceptable as an alternative to Staffs earlierproposal.

Regarding Attachment D

1. NYSEG has provided no explanation for why land acquisition and right-of-way (ROW) costs(on Attachment D) for the DPS Staff 34.5 kV plan (distribution circuits to be built on alreadyexisting ROW or on existing roads requiring rights-of-way of approximately 20 foot widths)are expected to cost $210,000 or 34% more than the NYSEG 115 kV proposal (atransmission circuit that will require 75 to 100 foot wide new off-road ROW).

2. NYSEG has provided no explanation for why access roads and matting costs (onAttachment D) for the DPS Staff 34.5 kV plan (distribution circuit to be built or rebuilt on


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Case No. 12-T-0248

DPS Staffs Comments

existing roads) are expected to cost $231,000 or 15% more than the NYSEG 115 kVproposal (transmission that will be built off-road).

3. NYSEG has provided no explanation for why environmental control and restoration costs(on Attachment D) for the DPS Staff 34.5 kV plan (distribution to be built or rebuilt onexisting roads) is expected to cost $1.8 million or 80% more than the NYSEG 115 kV

proposal (transmission that will be built off-road).

4. NYSEG has provided no explanation on whether the administrative overhead adder is apercentage allocation of fixed and sunk corporate costs, or if it is truly an incremental costunique to a specific project. Admittedly, regardless of whether these costs are sunk orincremental, they should be added to the total capitalized cost of a completed project.However, for the purposes of comparing prospective projects, we believe sunk fixed costsare irrelevant and should be ignored; and that only true incremental costs should beincluded in a comparison.

5. NYSEG indicated that Allowance for Funds Used During Construction (AFUDC) costs (onAttachment D) for the DPS Staff 34.5 kV plan is $2.9 million or 78% higher than the NYSEG115 kV proposal. With respect to AFUDC, presumably most of the distribution line work inthe DPS Staff 34.5 kV plan can be built and completed in small sections each in a matter ofmonths and capitalized or booked in a relatively short amount of time thereby incurringlower AFUDC costs. Transmission line projects, on the other hand, have much longerconstruction times, and cannot be capitalized on a piecemeal basis since they are not usedand useful until fully completed. NYSEG has assumed the same 13.5% AFUDC adder forboth the 34.5 kV distribution work and the 115 kV transmission project, which we believeunduly penalizes the 34.5 kV line work.

6. The second 115/34.5 kV transformer at the Falls Park Substation, along with a fourth 115kV breaker and two 34.5 kV breakers (downside of the 115/34.5 kV transformer and the

split bus tie breaker) should be cost estimated as a separate line item since presumablythese may be needed in the future, but not in the short term.

7. With respect to its cost estimate for the DPS Staff 34.5 kV plan distribution line work,NYSEG has provided no detail on type of construction, number of poles to be replaced,underground costs, and whether estimates were a bottoms-up consolidation of projectspecific estimates or a tops-down per unit cost estimate.

8. With respect to its cost estimate for the DPS Staff 34.5 kV plan substation work, NYSEGhas not provided cost detail on individual substation projects (e.g., capacitor bank andassociated breaker work and which substation projects are included in Phase 1 versusPhase 2), and whether estimates were a bottoms-up consolidation of project specific

estimates or a tops-down per unit cost estimate.

Regarding Attachment E

1. In Attachment E, NYSEG raises a number of concerns and suggests additional work that itbelieves will be needed (some of which is not part of the DPS Staff 34.5 kV proposal); butdid not indicate which, if any, of this work is included in the cost estimates on Table 9-2 of

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Case No. 12-T-0248

DPS Staffs Comments

Attachment D, and which are not. Based upon this and several of the more specificconcerns raised herein, we are unable to verify whether the cost estimate comports withthe intent of the DPS Staff 34.5 kV plan.

2. NYSEG suggests the need for an addition of 5 sets of 34.5 kV reclosers for the DPS Staff34.5 kV plan to improve reliability without an explanation of why they will be needed.

Taking into account that load presently served by four 34.5 kV feeders would be served byeight feeders under the DPS Staff plan, thereby reducing the exposure of existing feeders -while apparently no 34.5 kV reclosers are recommended by NYSEG for its 115 kVproposal, which maintains four 34.5 kV feeders serving the area - we do not concur with theneed for 34.5 kV reclosers as NYSEG has recommended for the DPS Staff 34.5 kV plan.

3. NYSEG has provided no definitive explanation of why 34.5 kV breakers need to be addedto both ends of the #615 line when none exist now.

4. DPS Staffs intent for Falls Park Feeder #3 is to both serve local load and growth along theway and provide an emergency backup tie (normally open) in the event the Greenbush-Stephentown 115 kV line or the Stephentown 115/34.5 kV line are out of service for anextended period. NYSEG has proposed two different express 34.5 kV normally closedcircuits for Feeder #3, presumably to serve only as an emergency backup (and alsopresumably requiring another circuit along Route 22, et al., to serve local load). We do notconcur with this approach.

5. NYSEG has indicated that a number of substation 34.5 kV capacitor banks will need SF634.5 kV breakers (at Chatham-Hilltop, NYSEG is recommending an underground dip andrise due to space limitations in adding the breaker). As an alternative to these substationbreakers, we would instead recommend use of pole mounted capacitor banks (perhaps inindividual sizes of 600 to 1,200 kVAr) with vacuum switches (and/or some which may befixed unswitched capacitor bank installations) as a more economical approach.

6. NYSEG indicates that it intends to install SF6 34.5 kV circuit breakers without anexplanation of why it has chosen to use SF6 circuit breakers over more environmentallyfriendly and likely less expensive (for a medium voltage application such as 34.5 kV)vacuum circuit breakers.

Regarding Attachment F

1. The assumption stated at page 1-2 is that "all 115 kV routes proposed by the parties wereoverhead transmission lines." As stated at the November Technical Conference, DPS Staffassumed in mapping the ValKin-Klinekill alternate (as generally proposed by ProtectGhent) that this alternative would include an underground segment between ValKin station

and the intersection of the route with the National Grid ROW at or near the abandonedrailroad grade east of State Farm Road. Staff further stated that its consideration ofalternative locations of the NYSEG proposed route does not include identification oflocations that could be later proposed for underground installation, based on furtheranalysis.

2. Staff recommends that the analysis of the Protect Ghent Churchtown-Craryville Proposalinclude a variation that would add a new 115 kV circuit from Craryville to Klinekill in additionto the Churchtown-Craryville circuit. While this would be a significantly longer length of

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Case No. 12-T-0248

DPS Staffs Comments

transmission line, it would have the advantage of maximizing the use of existing NYSEGROW and be electrically similar to the NYSEG proposed facility (and the DPS Staff and

Ag&Mkts 115 kV variations), as well as the ValKin-Klinekill alternative.

3. The bullets conveying the "Advantages" and "Disadvantages" of the various alternatives interms such as "fewer than average" or "longer than average" may benefit from a

comparative table of actual numbers of features or factors under consideration, rather thanthe relative descriptions provided.

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dps staff comments on nyseg's assessment of alternatives

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