The Maryland Department of Natural Resources, Power Plant Research Program (PPRP), in its initial brief filed with Maryland regulators concerning a proposed 138-kV overhead transmission line by Exelon’s (NYSE:EXC) Delmarva Power, recommended that the regulators open a proceeding to establish a more orderly transmission planning process.
That process should require transparency to allow stakeholders to protect state interests, including the environment, and should be one where each public utility is held accountable to its customers for the costs they must absorb as a result of its planning decisions, the PPRP said.
The PPRP also recommended that the state Public Service Commission (PSC) require the least impactful alternative to the crossing of the Pocomoke River as part of a PPRP recommended condition, and that the PSC adopt the remainder of the PPRP’s recommended conditions as they pertain to Delmarva Power’s project.
As noted in the July 13 initial brief filed by PSC staff, Delmarva Power last August filed an application for a certificate of public convenience and necessity (CPCN) to build the new overhead line from the Piney Grove substation in Wicomico County, Md., to the Maryland/Virginia state line. The new line would terminate about six miles south of the state line at the Wattsville substation in Accomack County, Va. Staff added that the Maryland portion is 24.75 miles long, and would be built on existing right of way (ROW) currently used for a Delmarva Power 69-kV overhead transmission line. The new overhead line would use single steel pole structures that would also carry the 69-kV line, which has been identified as needing to be rebuilt due to its age, in a side-by-side vertical configuration with the 138-kV line, staff added.
The ROW crosses the Pocomoke Scenic River in an eight-mile-long segment just north of Snow Hill, the PPRP said in its filing, adding that that section of the river is considered as having the characteristics of a wild river and falls within the state’s “critical areas.” The proposed overhead line crossing of the Pocomoke River would increase the size of the structures to accommodate two transmission lines – a rebuilt 69-kV line and the new 138-kV line.
The PPRP also said that it does not oppose Delmarva Power’s application, despite having reservations about the adequacy of the company’s submission, and the overarching issue of whether the new transmission line was planned in a manner that appropriately considered important interests of the state and its citizens.
Delmarva Power has agreed to accept, and comply with, the PPRP’s initial recommended licensing conditions, which will provide for compliance with state laws and regulations. However, the PPRP added, in view of evidence developed in the record and during an evidentiary hearing, much has come to light in the review of the proposed project that could seriously impact the effectiveness of Maryland’s CPCN process to guard state interests if not adequately addressed.
The PPRP said that Delmarva Power’s application did not identify sensitive natural resources, including the Pocomoke Scenic River and certain “critical areas,” and did not provide analysis on feasible alternative routing to its proposed route, nor did it provide a comparison of the environmental impacts.
The PPRP further noted that it requested that information last November and December, and that Delmarva Power provided a portion of the requested information in a supplemental environmental review document, filed on Feb. 5.
As a result of the project, Delmarva Power’s customers would finance transmission capacity to accommodate merchant generation and sensitive resources of the state may be at risk, the PPRP claimed. Late in the CPCN process, and at the request of the PPRP, Delmarva Power provided other options for the river crossing for consideration during public hearings, the PPRP said. PPRP requested that the PSC require the least impactful of those alternatives and urged the PSC to duly consider an underground alternative for the scenic river crossing as the appropriate option.
The PPRP also said that the case illustrates how state interests can be overlooked or discounted under the current transmission planning process in the Delmarva Peninsula. The PPRP noted that PJM Interconnection in August 2012 cancelled the Mid-Atlantic Power Pathway (MAPP) project, performed updated interconnection and reliability studies of Delmarva Power’s transmission system, found multiple overloads that previously were not identified overloads, announced a baseline upgrade for the “X1-096” project and, thereafter, presented its standard announcement of a need for a baseline upgrade to solve a Regional Transmission Expansion Plan (RTEP) reliability violation.
“No one questioned the reasonableness of giving a 150 MW wind farm the right to connect to Delmarva Power’s transmission system at the Kings Creek substation, or of giving 120 MW of solar projects the right to connect to the transmission system in the Virginia portion of the Delmarva Peninsula at any point in time after those respective projects entered the queue,” the PPRP said. “Such questioning would have been appropriate given the transmission constraints in this area (i.e., only two 138 kV lines into and out of Virginia).”
Those circumstances could have been avoided if modeling of Delmarva Power’s transmission system with and without the MAPP project and associated transmission upgrades had been done during that timeframe to understand whether capacity in the transmission system being given away to developers was, effectively, contingent capacity based upon the MAPP project being placed in service, the PPRP said.
“This case is a warning sign that it is time to consider how this transmission planning process should be improved to protect state interests,” the PPRP said.
PJM performs power flow studies looking for overloaded transmission system elements, and those studies reflect inputs that PJM has developed on load forecasts and system topology, including generators and transmission lines, as part of the RTEP process, the PPRP noted. Transmission owners, like Delmarva Power, are responsible for proposing solutions to, or expansions of, those transmission systems to reduce the probability that transmission system elements could become overloaded or fail, thereby negatively affecting transmission system customers.
The responsibilities for performing the first step in the transmission planning process – that is, monitoring the capability of the Maryland utilities’ transmission systems to meet the current and future needs of transmission system customers – are not well defined, the PPRP claimed.
The PSC could direct Delmarva Power to request that PJM communicate to Delmarva Power when loadings on transmission lines are approaching what may be determined by the commission to be an unacceptable level, and the PSC could also direct electric utilities to monitor their transmission system, without relying on PJM. Transmission utilities carried that function out before restructuring of the electric utility industry in Maryland and the existence of PJM as an RTO, the PPRP added, noting, “This case underscores that the return of such a function is ripe for serious consideration.”
PSC staff’s brief
In its July 13 brief, PSC staff recommended that the PSC grant a CPCN for the project, subject to the conditions recommended by the state agencies. Staff said that the main issue regarding aesthetics relates to the crossing of the Pokomoke River.
Delmarva Power has proposed four configuration for the river crossing along with an underground alternative, staff said, adding that it does not consider the underground alternative – which has an estimated cost of $86.95m – to be a viable option as Delmarva Power would not be able to meet the in-service date set by PJM if it were chosen.
The project cost for each of the overhead or aerial alternative crossings range from $44.7m to $48.2m, staff said, adding that it believes that each of the four aerial alternatives is viable and could be selected.
Among other things, staff said that it cannot support the PPRP’s recommendation to open a new proceeding to investigate transmission expansion planning as currently formulated.
Although the PPRP has recommended, along with staff, that the application to build the 138-kV line be granted, the formulation for the proposed proceeding suggests that the proposed 138-kV Delmarva Power transmission is actually not required – and perhaps thus imprudent – and that construction of the line would result in excessive transmission line development that harms the environment, staff said.
“Staff would, however, support a proceeding that investigates how the transmission expansion planning process can be improved to alert stakeholders and the state when transmission lines which are approaching thermal or other overload limits due to planned new generation facilities,” staff said.
Delmarva Power’s brief
In its July 13 initial brief, Delmarva Power requested that the PSC grant its application for a CPCN, saying that the evidentiary record demonstrates that the Piney Grove to Wattsville Project is the best and most efficient long-term solution to resolve the post-contingency thermal violation identified by PJM that could, if left unaddressed, result in service interruptions for customers in Accomack and Northhampton counties in Virginia, and Worcester County, Md., as early as June 2018.
The contingencies include the fault of a 138-kV circuit breaker at either Delmarva Power’s Kings Creek substation in Somerset County, Md., or at Delmarva Power’s Oak Hall substation in Accomack County, the company said.
The project would provide an additional 138-kV transmission line into the existing transmission network that would support exporting generation from the Virginia portion of the Delmarva Peninsula to load throughout the peninsula, the company said.
The new line would mitigate the PJM baseline reliability violation by reducing the flow on the existing transmission facilities, including the 138-kV transmission line between the Piney Grove and New Church substations, the company said.
The project would resolve the PJM-identified post-contingency violation, and leverage the need for Delmarva Power to rebuild the existing 69-kV overhead lien between the Piney Grove and Kenney substations, as well as the existing 69-kV overhead line between the Kenney and Wattsville substations.
Among other things, the company further noted that the project negates the need to schedule outages for multiple transmission facilities because it requires Circuits 6712 and 6729 to be de-energized for construction, which are the same two 69-kV transmission lines identified to be rebuilt.