Comments on the Nevada Hydro Presentation to Joint Committee Workshop on In-state and Interstate Transmission and Potential In-State Corridors on May 14, 2007 byJacki Ayer (presentation by Nevada Hydro, pdf; transcript of presentation, pdf)
Why LEAPS is not economically viable
What credible persons and agencies say
Lies, Inaccuracies, and Misleading Statements
Comments on Nevada Hydro Presentation to Joint Committee Workshop on In-state and Interstate Transmission and Potential In-State Corridors
California Energy Commission June 13, 2007
Dockets Office, MS-4
Re: Docket No. 06-IEP-1F
1516 Ninth Street
Sacramento, CA 95814-5512Subject: Lake Elsinore Advanced Pumped Storage (LEAPS) & CEC Corridor Planning Efforts
Reference: Docket No. 06-IEP-1F
2007 IEPR -Transmission
Dear Ms. White;
On May 14, 2007, The Nevada Hydro Company (TNHC) presented the LEAPS project at the Joint Committee Workshop on In-state and Interstate Transmission and Potential In-State Corridors. I just reviewed the TNHC presentation and the transcript from the Workshop, and I have substantial concerns regarding the accuracy and veracity of some of the LEAPS project information that was provided by TNHC. In the paragraphs below, I specifically address these inaccuracies and deficiencies in the same order as the TNHC presentation. My comments also address inaccuracies in the testimony given by Mr. Wait during the LEAPS presentation. I trust that the CEC will find this information useful in determining whether or not to include LEAPS in any draft Corridor plan that is developed.FROM PAGE 2 OF THE TNHC PRESENTATION:
“ TE/VS Interconnect functions as stand-alone reliability solution to San Diego”
FALSE. The CAISO specifically found that the TE/VS component of LEAPS is “not needed to solve any reliability problem” [May 1, 2007 CAISO comments in response to FERC’s order on Rate Request]. In fact, CAISO has also stated that “In general there are no reliability concerns with the [LEAPS-TE/VS] project mainly thanks to the mitigating effect of the Sun Path Project…” [from the August 31, 2006 CAISO Staff Memo to CAISO Board of Governors]. In other words, LEAPS-TE/VS potentially causes reliability problems that can be avoided by implementation of Sun Path. This position is also echoed in the Final Environmental Impact Statement (EIS) document prepared by FERC for the LEAPS Project. The truth is that CAISO has only evaluated the TE/VS component of the LEAPS project in conjunction with the Sunrise Powerlink and the IID Green Path project (together known to as Sun Path) and the Tehachapi project, and has not conducted a detailed, stand-alone assessment of the LEAPS-TE/VS project.“500 MW of renewable storage…”
INCORRECT, INACCURATE, AND MISLEADING. For LEAPS to provide storage of renewable energy, prior arrangements must be made to directly connect LEAPS with renewable power sources. For example, LADWP is making arrangements to exclusively transport Tehachapi wind power to operate their Castaic pumped storage power plant, so it is legitimately claimed that the Castaic Power Plant provides renewable energy storage (see testimony re the LA Tehachapi Transmission Project and the May 14, 2007 CEC Corridor Workshop). No such arrangements have ever been made for LEAPS, as evidenced by the Project EIS (January, 2007) and all other reports prepared pursuant to CARTS, CSRTP, STEP, TCSG, etc.
“ 500 kV link to SCE’s 500 kV system”
NO NEED ESTABLISHED It was made clear in the LEAPS Final EIS prepared by FERC that SCE does not need LEAPS power, therefore a 500 kV connection to SCE service territory is unnecessary for the project. If LEAPS power were to be used by SDG&E, it should be via a 230 kV line, since SDG&E neither wants nor needs 500 kV power at the TE/VS point of junction.“2007 Construction Start”
UNLIKELY TNHC has not yet prepared the draft Environmental Impact Report (EIR) which is likely to have substantial and substantive comments. This prognosis is based on the fact that nearly every state and federal agency that commented on the EIS documents found the final EIS to be deficient, as evidenced by agency comments submitted under Docket P-11858. Following the public comment period, the Final EIR must then be prepared, and the State Water Board must use this document to ascertain whether a Water Quality Certification should be granted. Only after this process is completed can FERC consider whether or not to grant the license, and this action will be followed by certain legal challenge. Because we are now nearly half way through 2007, it is highly unlikely that this project will begin construction in 2007.“Critical asset facilitating Statewide management of renewables”
FALSE There is an active and comprehensive plan in place to develop projects that will enable load centers throughout Southern California to access the renewable power sources in California and other states. NONE of the studies that I have evaluated pursuant to these plans and developed by programs such as CARTS, CSRTP, TCSG, STEP, etc. have relied on LEAPS-TE/VS to ensure that SCE, SDG&E, PG&E, or LADWP are able to connect to renewables.“Promotes attainment of RPS and GHG goals”
FALSE As indicated above, it appears that no electrical transmission company or entity is relying on LEAPS to meet their RPS goals. In addition, LEAPS does not provide electricity that can be used to meet their RPS goals, since LEAPS does not qualify as a renewable asset according to the CEC Renewables Portfolio Standard Eligibility Guidebook. Moreover, LEAPS contributes substantially to the formation of Greenhouse Gases, because it requires 20% more electricity during the pumping stage than it releases during the generation stage, and no provisions have been made to operate the pumps using energy from non-combustion sources. If, on the other hand, it were proposed to operate LEAPS with a renewable energy source (such as proposed by LADWP for their Castaic power plant), then it could be legitimately claimed that LEAPS promotes attainment of GHG goals. However, no such arrangements have been made.“Complementary to SDG&E’s Sunpath to create backbone”
MISLEADING AND INACCURATE CAISO clarifies that Sunrise will address SDG&E congestion/reliability problems, and Green Path will enable SDG&E to meet RPS goals. Taken together as Sun Path, these projects address SDG&E needs within CAISO’s planning horizon. LEAPS will not create a backbone for SDG&E because SDG&E does not want or need 500 kV power on the Talega-Escondido line. Most importantly, CAISO and the STEP have ascertained that LEAPS will not have project benefits which offset it’s costs [page 1-5 of the Final EIS]. So why would CEC consider a project in their corridor planning effort if it is too expensive and provides no added benefits beyond those anticipated by other CAISO-approved projects?
FROM PAGE 3 OF THE TNHC PRESENTATION:
“ TE/VS has a 1,600-MW design capacity”
MISLEADING From this statement, it appears that either FERC is improperly permitting this project with a 1,000 MW capacity [page 1-6 of the Final EIS] or TNHC intends to construct a larger and more substantial system than what is anticipated by FERC.“TE/VS Public Lands Route”
MISLEADING Portions of the LEAPS project are on developed private lands, and a substantial portion of the transmission line (approximately 30%) are on or immediately adjacent to private property. I urge the CEC to not be mislead on this point.“TE/VS Only 500 kV link from San Diego to California Grid”
INACCURATE AND MISLEADING The Sunrise Powerlink provides a new 500 kV line into San Diego that will be connected to the California grid via the Green Path project at full build out. This combined “Sun Path” project will provide an interconnection between the Serrano-Valley-Devers line to the Imperial Valley station, which is linked to the Sunrise Powerlink. As reported at the most recent STEP meeting (March, 2007), LADWP is working on an interconnection with SCE for the northernmost portion the Green Path Project. In other words, the Sun Path project will also provide a 500 kV line into San Diego that is connected to the California Grid. Of course, the Sun Path project will provide SDG&E with 500 kV power when and where it is needed, unlike the LEAPS project, which dumps 500 kV power at an SDG&E location that requires 230 kV power. In fact, the inconvenience of the LEAPS project will force SDG&E to spend nearly $2 Billion to accommodate the LEAPS connection at 500 kV [Chapter VII, page 26 of Supplemental Testimony from SDG&E to the CPUC on January 26, 2007].“TE/VS Links available renewable resources (e.g. Tehachapi) for use in San Diego”
INACCURATE AND MISLEADING The second report of the Tehachapi Collaborative Study Group (TCSG) places most of the burden on SCE (shared somewhat by CAISO) to determine transmission infrastructure necessary to bring Tehachapi power to SCE and SDG&E territories [Volume 2 of Second TCSG Report, April 18, 2006]. SCE presented the Tehachapi Transmission Project to the CPUC in December, 2006, and CAISO approved the project on January 18, 2007. In these actions, neither SCE nor CAISO identify LEAPS as a component in the Tehachapi Transmission project, nor do they rely on LEAPS in any capacity to transmit Tehachapi power. Moreover, the Sun Path project is expected to provide opportunities to SDG&E to meet their RPS goals. Justification for this statement by TNHC is lacking, since it is not at all clear how TE/VS will play any role in transmitting renewable resources to San Diego.“TE/VS Interconnect System Impact Studies Complete”
FALSE Recent studies of the TE/VS component of the LEAPS project conducted by CAISO considered the system impacts of TE/VS only in the presence of both Tehachapi and Sun Path. These results clearly indicate that TE/VS does not provide additional reliability benefits [see the May 1, 2007 CAISO response to FERC’s Order on Rate Request]. CAISO has not performed a detailed impact study of the TE/VS component and, judging from CAISO’s response to FERC, it is unlikely that one will be conducted in the near future. Perhaps TNHC believes that the study conducted by John Kyei [May 17, 2004 STEP meeting] constitutes an adequate impact analysis of TE/VS, but a close inspection of this study reveals that it did not consider the additional benefits of the fully built Green Path project when linked with the Sunrise project (i.e. Sun Path) in the comparison between TE/VS and Sunrise. Aside from the fact that the Kyei study reveals TE/VS and Sunrise to have roughly equivalent system impacts, the Kyei study is not particularly relevant and should not be relied upon by CEC in determining the appropriateness of including LEAPS-TE/VS in any In-State Transmission Corridor Plan.Note: According to the May 2007 CAISO Generator Interconnection Queue, it appears that the System Impact and Facilities Studies of the pumped storage component of the LEAPS project are complete, but system impact studies of the TE/VS component have not even begun. As transmission infrastructure, TE/VS will undergo an entirely different procedure than the LGIP that has been pursued for the pumped storage component. TNHC has applied to CAISO for consideration as a Participating Transmission Owner [see February 2007 submittal] but this application has not been approved and no substantive action by CAISO has been taken pursuant thereto. In fact, CAISO is not likely to proceed on the TNHC PTO application until other matters with FERC are resolved [per conversation with CAISO staff June 11, 2007]
“TE/VS Grid connection graded by CAISO”
FALSE The extent of CAISO’s analysis of the TE/VS grid interconnection is summarized in CAISO’s May 1, 2007 comments to FERC that the LEAPS transmission line is not needed to solve any reliability problem. While TNHC’s intent in making this statement is not clear, it is certainly clear that substantial work must still be completed before the TE/VS component of LEAPS is considered “graded” by CAISO (whatever that means).FROM PAGE 6 OF THE TNHC PRESENTATION:
“ TE/VS interconnect construction can commence in 2007”
NOT LIKELY See above comments.“FERC has independently evaluated need for the TE/VS interconnect”
FALSE A review of the “Purpose” and “Need” statements found in the Final EIS reveals that FERC only relies on Kyei’s and other STEP studies in their attempt to justify a need for the TE/VS line [see Section 1.2 of the Final EIS]. Indeed, the Final EIS provides no indication of any independent assessment conducted by FERC, even though the Final EIS is precisely the document where such studies would be included. Therefore, TNHC’s assertion that FERC had independently established the need for at TE/VS interconnect does not appear to be supported by any FERC published documents.“TE/VS interconnect has the support of affected federal agencies”
INACCURATE AND MISLEADING Numerous federal agencies (including the EPA and the U.S. Department of Fish & Wildlife) have gone on record that the analyses completed pursuant to this project are incomplete, and indeed it appears that the Final EIS is deficient. In fact, until a Clean Water Certification is obtained (and it is not guaranteed that one will be granted by the State Water Board) FERC cannot even approve the project because a hydro license cannot be issued without this certification. Therefore it is not necessarily true that this project has the “support of affected federal agencies”.
“ TE/VS interconnect allows for storage of renewable resources”
FALSE This statement is false and shall remain false until such time as TNHC makes arrangements to power the LEAPS water pumps with renewable energy (as LADWP is doing with their Castaic power plant).“TE/VS interconnect improves System Reliability”
FALSE The TE/VS component of LEAPS is not even “needed to solve any reliability problem” [CAISO’s May 1, 2007 response to FERC]. So how then can TNHC assert that it will improve system reliability?FROM PAGE 7 OF THE TNHC PRESENTATION:
“ TE/VS interconnect provides access to renewable energy such as Tehachapi”
MISLEADING See above comments“TE/VS interconnect provides congestion mitigation”
FALSE This statement is not supported by the data, particularly in light of the status of the Sunrise Powerlink project.“TE/VS interconnect has minimal environmental costs”
FALSE The environmental costs and impacts of the LEAPS project have NOT YET BEEN ESTABLISHED as evidenced by all the deferred impact and mitigation analyses contained in the Final EIS. The CEQA process has not even begun, and the State Water Board has not received the data necessary to ascertain the impact on state water resources. In fact, the State Water Board and the EPA have commented repeatedly on the inadequacies and incompleteness of the environmental assessment included in the EIS [see FERC filings under Docket P-11858]. Finally, and perhaps most disturbing of all, this project will create a new corridor in the pristine and virtually untouched portions of the Cleveland National Forest. For the record, the Cleveland National Forest is surrounded by Riverside, Orange, San Diego, Los Angeles and San Bernardino Counties, and is the only undeveloped area of substantial size in this region (which is confirmed by a quick glance at any area satellite photo). The inclusion of the LEAPS project in a state or federal Energy Corridor Plan will also increase the environmental impacts exponentially, since it will provide a vehicle for other transmission projects to be located in the same area. The statement that this project has “minimal environmental costs” is absurd on its face, and it is certainly not supported by the facts.FROM PAGE 9 OF THE TNHC PRESENTATION:
“ SDG&E/SCE/CAISO System impact studies and interconnection studies completed”
INACCURATE AND MISLEADING As indicated in the May 1, 2007 response to FERC, CAISO has only conducted an interim study that includes a preliminary reliability analysis of the TE/VS portion of the LEAPS project. In addition, CAISO has not processed the PTO application submitted by TNHC in February, nor has CAISO approved the TE/VS project for grid connection. It is true that CAISO has completed the system impact study of connecting the pumped storage project to the grid, however this factor is not particularly relevant to the CEC in determining whether or not to include the TE/VS component in a draft corridor plan.“CAISO interconnect approval granted in March 2007”
INACCURATE AND MISLEADING CAISO has only considered interconnection of the pumped storage component of the LEAPS project. CAISO has not processed the TNHC PTO application, and has not approved the TE/VS interconnection project. Since the TE/VS component will be the subject of any CEC corridor debate, it is rather disingenuous to give CEC a false impression that CAISO has approved the interconnection of TE/VS as a grid asset.FROM PAGE 12 OF THE TNHC PRESENTATION
“ CAISO found 150+ million in annual benefits provided by LEAPS”
FALSE CAISO published a preliminary benefits analysis of LEAPS [CSRTP Interim Memorandum submitted to the Board of Governors in August of 2006] which quantifies some economic benefits (albeit much less than $150 million) but these results are skewed because they are derived from the assumption that LEAPS sponsors would receive payment through the TAC. Of course, this economic analysis is probably no longer relevant, because CAISO has now elected to treat LEAPS as a generation asset rather than a transmission asset. Moreover, the California Electricity Oversight Board believes that LEAPS project will not provide ratepayers with any economic benefit [CEOB Comments to FERC on May 1, 2007 -Docket ER06-278].“LEAPS benefits RPS and greenhouse gas emission reduction goals”
FALSE As clarified above, LEAPS has not been configured to operate with renewable energy, therefore it will not provide RPS benefits. With respect to greenhouse gas emission reduction goals, the project is only 83.3% efficient, which means LEAPS will create 20% more greenhouse gases per MW than combustion-based generators.PAGES 13-18 DOES LEAPS MEETING CEC CORRIDOR ELIGIBILITY CRITERIA?
“ LEAPS is needed by 2017 to ensure reliability of power imported to San Diego”
FALSE CAISO has found that LEAPS is not needed to solve any reliability problem. In fact, the reliability problems that are caused by LEAPS will be mitigated by the Sun Path Project [August 31, 2006 interim report to the CAISO Board of Governors]. TNHC claims that FERC has independently identified reliability benefits, but FERC failed to mention these benefits in the Final EIS that was just released in January.“LEAPS is needed by 2017 to relieve congestion and connect San Diego to the Grid”
FALSE The only documents and studies asserting that LEAPS relieves congestion are those which compare LEAPS to the Sunrise Project, and all these documents clarify that only one of these projects is necessary to address San Diego’s congestion problems. Because the Sunrise project is much further along in the entitlement process than LEAPS, it is unlikely that LEAPS will provide any congestion relief to the California grid. Moreover, the CAISO approved Sunrise and Green Path projects at full build out will connect San Diego to the grid without LEAPS.“LEAPS is needed by 2017 to ensure access to renewables from the north”
FALSE Sunrise and the expanded Green Path will provide SDG&E with access to renewables from the north and east without relying on LEAPS. It is unlikely that LEAPS will play a role in distributing Tehachapi power to SDG&E since SCE, LADWP and PG&E are expanding their transmission infrastructure to address the issue of accessing renewables without LEAPS.
“ LEAPS is near a load center and is threatened by continued development”
INNACURATE AND MISLEADING TNHC indicates that LEAPS will employs a “public lands route” so why is the project threatened by continued development? In fact the Final EIS trivializes the economic and environmental impacts of LEAPS to privately held lands because the project is primarily on federal lands. It is rather duplicitous to now claim that this particular CEC Corridor criterion applies to the LEAPS project.“LEAPS allows storage for renewables, facilitates attainment of RPS goals and reduces GHG”
FALSE These claims are effectively eliminated in the comments provided above.“Identified by DOE as draft National Interest Electric Transmission Corridor”
FALSE TNHC appears to claim that LEAPS has been identified by the DOE in their draft National Interest Electric Transmission Corridor, which is not true. The DOE just released the latest draft of the Southwest Area National Corridor, which designates a broad area that encompasses a large number of electricity sources and sinks. It does not in any way endorse a particular project and it certainly does not identify LEAPS in the maps that have been prepared. This fact was confirmed in a conversation last week with DOE staff in Washington DC who are working on the Section 1221 National Interest Energy Transmission Corridor Project.“Identified by USFS under Section 368”
FALSE As with the National Interest Electric Transmission Corridor comment, it appears that TNHC claims that LEAPS is included in the draft Section 368 Energy Corridor Map, which is, of course, untrue. Per a June 12, 2007 conversation with Mr. Virgil Mink of the Trabuco Ranger District (with jurisdiction over the Cleveland National Forest), LEAPS is not (nor has it ever been) included in any 368 corridor maps prepared submitted to the DOE by the USFS, including the most recent submittal. Section 368 corridors are up to a mile wide, limited to federal lands, and established for many purposes including transportation of oil and natural gas. I understand that CAISO and LEAPS proponents have requested that the LEAPS project be designated as a Section 368 corridor, but these requests do not appear to have been granted.
In this submittal, I have included specific citations and supplemental information to substantiate the assertions made and to factually clarify the actual status and circumstance of the LEAPS project. Should you require additional information, please contact me at AirSpecial@aol.com. Thank you for this opportunity to provide comment, and I appreciate your time and attention to this matter.Sincerely,
Jacqueline Ayer