Maryland state regulators should grant a certificate of public convenience and necessity (CPCN) for Baltimore Gas and Electric’s (BGE) Northeast Transmission System Improvement Project, if appropriate conditions are adopted, according to the Maryland Department of Natural Resources’ Power Plant Research Program (PPRP).
In Oct. 7 direct testimony on behalf of the PPRP, Sandra Shaw Patty, manager of transmission projects for the PPRP, told the state Public Service Commission (PSC) that those conditions include that construction of the project and operation of the resulting overhead transmission line is to be undertaken in compliance with all applicable local, state and federal laws and regulations, including those involving non-tidal wetlands, erosion and sediment control and forest conservation.
The project in Harford and Baltimore counties in Maryland consists of three segments of line: A – Conastone substation to Graceton substation; B – Graceton substation to Bagley substation; and C – Bagley substation to Raphael Road substation.
The entire project, Patty added, is intended to add a new 230-kV overhead transmission line circuit around the northeastern section of BGE’s Maryland electric distribution service territory. The segments A, B and C are about eight, 14 and 6 miles long, respectively.
In Segment A, BGE proposes to add a second 230-kV circuit on the vacant north side of an existing double-circuit overhead tower line – along 7.25 miles of the approximately 8.5-mile-long route. On the remaining approximately 1.25-mile-long portion of the right of way (ROW), a steel pole, overhead, single-circuit 115-kV line will be installed from the Graceton substation to the Five Forks switching station.
In segments B and C, Patty added, BGE proposes to remove the existing 230-kV, single-circuit, lattice tower structures – currently along the centerline of the ROW – and install new steel-pole, double-circuit 230-kV transmission structures that will be located on the eastern half of the ROW, offset about 33 feet east of the centerline. The existing transmission circuit and the new transmission circuit will be installed on those new poles.
Patty also noted that in segments B and C, a new transmission line, with two circuits and greater capacity, is being built.
Other conditions call for the project to begin within two years of a final, non-appealable PSC order that provides BGE with a CPCN for the project; the project must be placed in service Jan. 1, 2018; and if conditions warrant a change in either the construction start date or the in-service date, then BGE is to notify the PSC and the PPRP.
Additionally, BGE is to provide the PPRP and the PSC engineering staff with these as-built details: engineering and construction plans of the linear facilities, including ROW width, length and total acreage of the ROW; transmission line structure and foundation types, dimensions and locations; transmission line conductor configuration; and nominal length of span between transmission line structures.
Furthermore, any impact to wetlands, including vernal pools within or abutting the project site, is to be mitigated if required by Maryland non-tidal wetlands laws and regulations. BGE is to also locate all structure foundations and access roads outside of streams, 100-year floodplains and wetlands, and at least 25 feet beyond the delineated boundaries of wetlands, unless otherwise approved by Harford and Baltimore counties, among other entities, as applicable.
The conditions also call for BGE to avoid, to the greatest extent possible, construction and disturbances at all stream, wetland and forest crossings identified by the department’s Wildlife and Heritage Service as being the known location of, in the vicinity of, or potential habitat for, rare, threatened or endangered species.
In addition, herbicide applications, subject to applicable law and landowner requirements, are to be performed in accordance with industry best practices and are to only use EPA-registered herbicides in accordance with label recommendations.
Among other things, the conditions noted that in the event that relics of unforeseen archaeological sites are identified during construction, BGE, in consultation with and as approved by the Maryland Historical Trust, is to develop and implement a plan for avoidance and protection, data recovery or destruction without recovery of such relics or sites.
In her testimony, Patty noted that according to BGE and PJM Interconnection, the project is expected to provide multiple reliability benefits and reduce congestion costs once placed into service, which is currently anticipated to be Jan. 1, 2018, if not before.
Specifically, the proposed second 230-kV Graceton to Bagley circuit will resolve a reliability criteria violation expected to occur as early as 2020. That violation, she added, occurs for a tower line outage on BGE’s double circuit Conastone to Northwest 230-kV transmission line under average, or 50/50 peak load conditions. The addition of a second Graceton to Bagley 230-kV circuit also increases power flows on the adjacent single circuit Conastone to Graceton and Bagley to Raphael Road 230-kV lines.
BGE and PJM, Patty added, anticipate additional reliability benefits can be achieved with the project, including enhanced system stability and greater service reliability that can be expected from any transmission system enhancement, and improved operations and maintenance flexibility with a second circuit being added to an existing transmission line corridor.
In particular, she added, the project increases BGE’s ability to import power into its system from the north, and this added import capacity eliminates BGE’s current dependence upon the generation output from the Wagner and Crane fossil fuel generating stations to maintain reliability during significant contingency operations, including the Conastone to Northwest tower line outage.
Also, BGE and PJM have said the project will alleviate congestion in the transmission corridor that has been a significant and ongoing concern for years. Patty added that during 2012 alone, market congestion costs in the corridor were about $35m, and PJM projects that those costs will fall to zero with the project in service.
“To put the value of that congestion cost reduction into perspective, the estimated capital cost to construct the project is $73.5[m], or just over two years’ congestion costs,” she said.
Patty also noted that PPRP has identified potential effects of the project on streams, wetlands and the Deer Creek Scenic River; wildlife and sensitive species; forest resources; historical and archaeological resources; and land use, including state lands such as Gunpowder Falls State Park and Rocks State Park in the subject portion of Harford and Baltimore counties.
She said an initial recommended licensing condition, for instance, requires BGE to submit plans for all new access roads and modifications to existing roads, as well as limits of disturbance for access road construction and quantitative assessments of impacts to wetlands, wetland buffers and forests.
Among other things, she noted that PPRP expects construction or operation of the project to affect wildlife or any threatened or endangered species.
Of particular concern, Patty added, are several significant forest-interior-dwelling species (FIDS) habitat areas that are adjacent to or split by the ROW.
Patty said that vegetation clearing during construction and subsequent vegetation management activities in the ROW will influence the long-term stability and viability of those areas of FIDS habitat, and impacts should be minimized, including avoiding clearing, mowing and disturbance during the April-August breeding season.