POWER ENGINEERS SUPPORTING TRUTH

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Office of Electric Transmission and Distribution                           Sept. 18, 2004

Department of Energy

 

Re:      Designation of National Interest Electric Transmission Bottlenecks (NIETB)

 

            As requested in the Federal Register, Volume 69, Number 140 of July 22, 2004, we are hereby submitting our comments on the Notice of Inquiry and Opportunity to Comment.

 

•  The Notice of Inquiry contains a number of incorrect statements, particularly:

  1.  The electric system was not built over a number of years primarily to serve local customers, as incorrectly stated in the Inquiry.  It was built from the 1960s on to integrate the regions of the country and make possible significant power exchanges between them.  There is a large amount of technical literature available which has indicated these interregional purposes.  They are described and additional references given in “The Development of Electric Power Transmission”, one of the IEEE Case Histories of Achievement in Science and Technology[1].  This can be obtained electronically from www.lulu.com. 
  2. The statement that, until recent years, trade among electric utilities was modest is not true.  The trade was quite extensive in a great many areas: e.g., Southern-TVA, Niagara/St. Lawrence to NY City, PJM minemouth to East Coast, Pacific Northwest to California, Four Corners, the Intermountain project, Quebec to New York, Quebec to New England, etc.  Nor were these done without extensive planning and ongoing coordination: witness the intra- and interregional efforts of the “tight” power pools (PJM, NYPP, and NEPOOL), the Regional Reliability Councils, interregional groups such as MEN, VEM, and VAST, and project-oriented efforts like the Hydro Quebec-New England Phase 2 studies. All of these were the product of a culture of cooperation and coordination – a culture now replaced by competition and confrontation.
  3. The statement that the increase in regional electricity trade saves consumers billions of dollars is not correct.  The studies to determine these savings have been based on zero interregional trade as the alternate, not on the actual interregional trade as it existed before restructuring.
  4. The statement that over the past 25 years, investment into new transmission facilities has significantly declined is misleading.  Major transmission investments were made in the 1960s, 1970s, and 1980s to provide for the long-range needs of our power systems and nation.  This included the addition of 345 kV, 500 kV, and 765 kV systems.  These systems provided far more capacity than needed at the time of their installation, but were selected in order to minimize total long-range costs.  Customers and Market Participants have to a large extent been reaping the benefits of these wise, long-term investments, eliminating the need for additional transmission right up to the present. 

 

•  There are two kinds of transmission problems in our power systems.  One is economic, whereby energy transfers that would produce savings cannot be made.  The other is reliability, where risks are taken such that normal contingencies would have severe adverse consequences.  The risks identified in your proposed procedure are predominantly economic.  Those with profits at stake will most certainly stress the need to eliminate such “bottlenecks.”  However, the most important risks are those which threaten reliability of service.  Particularly important at this time is the new requirement to consider national security as a dominant factor in analyzing reliability risks. 

 

•  Any analysis of “bottlenecks” must be done against a backdrop defining our national objectives with regard to development of the electric power grid. These objectives must consider both economic and reliability goals as well as national security. Fixing a specific transmission bottleneck with a “local fix” could prove to be extremely short sighted without a standard to measure success. To define these objectives, to review and reduce these risks and to minimize the probability, extent and duration of major power outages we propose that a National Power Survey be made.  It should be modeled after the National Power Survey of 1964 which, by the late 1980s, resulted in annual economic benefits of $28 billion from interregional power exchanges and coordination. This survey should address tradeoffs between an increasing scale of interregional transfers of electricity, the transmission costs involved, and the resulting increased exposure to widespread blackouts caused by acts of sabotage.  The DOE has purported to have made studies to achieve some of the objectives of such a national power survey, particularly its work on the National Energy Policy (May 2001), the Department’s National Transmission Grid Study (May 2002), and the Transmission Grid Solutions Report (September 2002) issued by the Electricity Advisory Board.  However, these studies do not address many of the key questions that need to be resolved concerning the future of our transmission systems: 

1.     What possible changes in grid design would reduce the probability, extent, and duration of major power interruptions such as blackouts? 

2.     What are the potential effects of dividing our three existing large synchronous networks into eight or ten smaller networks, interconnected by DC? 

3.     What are the potential effects of new generation developments, such as major additions to nuclear and coal-fired units, or major additions to distributed generation? 

4.     New technologies have been proposed for measuring and analyzing system security.  What are their costs, and how would they affect the design and operation of the power system?

5.     Wide area measurement procedures to facilitate better control of the grid are being pursued, and claims are being made for such developments as a “self-healing grid.”  What are the possibilities, risks and costs of these procedures?

6.     What changes in our national electric market policy are feasible to achieve low cost and reliable service for the American consumer, considering the importance of national security?

7.     Should design and operating standards, or criteria, for the transmission system be strengthened; i.e. to consider conditions beyond the present “n-1” criteria?

 

•  All of these questions could be investigated in a National Power Survey.  The survey should not be conducted by the Government, but by experienced engineers from industry – preferably those currently involved in regional planning for the various existing organizations such as ISOs, RTOs, power pools and industry coordination groups. The study should be under the direction of an outside independent board of industry experts.  It should not be organized based on stakeholder interests, for unfortunately stakeholder interests are predominantly commercial.  The objective of the study should be to develop a sound long-term basis for future expansion of our transmission systems – recognizing reliability, economics, new technology, revised commercial policies and national security. 

 

The Notice of Inquiry also solicits answers to three important questions, which we would like to provide:

1.     Question:  Are the Electricity Advisory Board’s recommended criteria for designation of NIETBs sufficient?  Answer:  No.  They do not address the key issues discussed above.

2.     Question:  What should be the role of transmission grid operators, utilities, and other market participants in addressing NIETBs?  Answer:  The basic alternatives for developing our future transmission systems should be determined in the National Power Survey discussed above. The role of the various participants in the regions should be to provide engineering support for the Survey and then to develop the solutions under the guidelines that have been developed in the National Power Survey. 

3.     Question:  How might DOE identify bottlenecks in regions where pertinent data are not available?  Answer:  This should be done in the National Power Survey and by the existing regional organizations.  The DOE’s role should be solely to keep abreast of the information developed in these other studies.

4.     Questions:  What actions should DOE undertake to monitor progress towards mitigation of designated NIETBs?  Answer:  The DOE should have an observer at the steering group level of the National Power Survey. Upon completion of the study, each RTO/ISO should be required to report to DOE/FERC by date certain on how it will address the findings of the National Power Survey. DOE/FERC should then monitor progress on the RTO/ISO follow up activities.

 

We appreciate the opportunity to comment on the issues that have been raised.  Our concerns are:

1) that the role of government not be extended into areas for which the government lacks the necessary competence;

2) that commercial and profit interests not dominate decisions which will affect the welfare of all the American public; and

3) that a mechanism be established allowing true experts with extensive experience in the electric power industry to develop a basic scenario for future transmission development in the United States.

                                    Sincerely,

 

 

                                    Power Engineers Supporting Truth

                                    J.A. Casazza

                                    G.C. Loehr

                                    Frank Delea

                                   


 

[1] Authored by J.A. Casazza.

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