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POWER ENGINEERS SUPPORTING TRUTH
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March 19, 2004
Mr. Jimmy Glotfelty Director, Office of Electric Transmission & Distribution U.S. Department of Energy TD-1/Forrestal Building 1000 Independence Avenue, S.W. Washington, D.C. 20585
Re: National Transmission Requirements and the DOE
Dear Mr. Glotfelty:
The purpose of this letter is to comment on the discussion you and I had at the March 3, 2004, plenary session of the Consumer Energy Council of America (CECA). I believe that some of the matters we discussed are important, and I’d like to insure that I correctly understood your views and you understood ours. We recognize your desire to enhance the market but are deeply concerned this is being done at the expense of reliability. The core of our differences lies in our views on the knowledge and background needed to determine electric power policy and minimize the probability and extent of future blackouts. You obviously are concerned with providing facilities to implement the market, believing this will provide the required reliability. We have serious doubts that the market itself will insure reliable service. Your mind-set seems to be caused by filling all policy positions with lawyers and economists without having experienced engineers in similar positions to present and defend contrary views. This creates an environment where commercial interests can put themselves in positions to control policy and project funding. We do not believe this is in the public interest. A great deal of real world planning and operational experience is required to provide the needed judgment in developing policies and directing research programs in electric power. Review of our discussion at the meeting should help expand the reasons for our differences, specifically:
1. You mentioned that part of the problem is that the “old operators” are still trying to operate the system in accordance with past requirements, and we had to replace them with a “newer generation” of more progressive operators. It seems to us that you are ignoring the fact that those “past requirements” largely comprise the Laws of Physics as applied to electric power systems! The grid must be operated in accordance with these physical laws. Further, your comment seems to directly contradict your statement that we need to transfer past experience to present policies and operations. 2. You commented that I had questioned your ability to direct the Office of Transmission and Distribution. I noted that we were also concerned about the recent appointment of two more lawyers to the Federal Energy Regulatory Commission, since there already was a distinct lack of technical expertise on the Commission. Our PEST comments are not intended to be personal but rather are in line with our position relating to the lack of engineers in policy positions. (These PEST concerns are consistent with the views of many members of the engineering profession, as shown in the attached clipping from The Institute, an IEEE publication with a circulation of over 300,000.) 3. You responded that you thought you had excellent advice from the PSERC group of university professors. My concern is that, with a few exceptions, the individuals on this group had very little experience with the actual design of the USA transmission grid. I worry whether the views of many of these individuals are colored by their interests in obtaining research grants for their institutions and personal consulting assignments. These examples of individuals lacking experience causes, in large measure, the failure to apply lessons learned from past blackouts to the planning and operation of the present grid. As you correctly pointed out, this has been a major cause of our reliability problems today During the meeting discussions I pointed out that DOE activities, as evidenced in its various reports, have been focused on transmission reinforcements to relieve the economic transmission constraints experienced in the operation of our transmission system. I stressed for your benefit that the locations and causes of the most important reliability risks in operating the grid are not necessarily the same as the economic constraints. The August 14th blackout provides an example of this. Later, I commented privately to you that there are engineering techniques for identifying the locations of greatest reliability risk, and that their application is necessary to determine overall transmission policy and minimize the probability of blackouts, which do not appear to have been considered. In your presentation you reviewed the work that DOE has been doing in developing future transmission policies, mentioning that a group of “experts” had reviewed required grid development for the next 30 years. We understand that this report was based on a two-day meeting at which a majority of the participants had commercial interests in the resulting “vision”, and most lacked experience in the overall requirements and problems of our transmission grid. This certainly was not an in-depth analysis of all issues involved. At no time has the merits of a National Power Survey, as has been conducted in the past, been discussed. In these Power Surveys a broad based group of senior planning and operational personnel met and hammered out a long-range technical roadmap to meet future needs. These past surveys took many months and involved the best technical expertise available. (See “Power and the Public Interest -- the Memoirs of J.C. Swidler” recently published by the University of Tennessee). In regard to the forthcoming report on the August 2003 Blackout, you stated that, while NERC’s recommendations are a good first step, the DOE’s final report will involve significant additional requirements to strengthen our systems. You indicated that the new standards must be put in place quickly to accommodate new market procedures, yet you never referred to the technical requirements. While we appreciate your desire to improve reliability, we question the ability of the leadership and staff of the Federal Government, with its lack of technical experience, to make wise decisions and take the necessary steps regarding technical issues. In summary, you appear to be dedicated to a policy of facilitating and enhancing the operation of the bulk power market, while paying insufficient attention to the Laws of Physics and their application to electric power systems. We are concerned that your activities do not include an evaluation of the overall impact of your policies on the reliability of supply and overall cost to the general public. While you state that you want to ensure the transfer of past experience and knowledge to future power system operations and procedures, you contradict this objective by relying heavily on advisors who have no real world expertise, or who have commercial interests. I believe this letter provides a fair and correct record of our respective positions. If you believe any of the statements or positions attributed to you in this letter are incorrect or unfair, I would very much like to hear from you. Several of us would be more than willing to meet with you to discuss these matters further, either in private or in public. Out intent is to release the final version of this letter to the general public in the second week of April in the hopes that a more public discussion of the issues covered can be held. . Sincerely yours,
Jack Casazza Power Engineers Supporting Truth
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