Virginia State Corporation Commission (SCC) staff on June 30 said that the SCC should demand more information from Virginia Electric and Power (Dominion Energy Virginia) before granting the company’s request to extend the in-service date of a 230-kV transmission project.
As noted by staff, the company in March 2014 filed an application and supporting documents for a certificate of public convenience and necessity for the Remington CT-Warrenton 230-kV double-circuit transmission line, Vint Hill-Wheeler and Wheeler-Loudoun 230-kV transmission lines, 230-kV Vint Hill switching station, and 230-kV Wheeler switching station (collectively, the “projects”).
In November 2014, after staff’s suggestion to consider a variation of the company’s preferred Option C – the company’s preferred alternative route – for the projects, the company filed supplemental direct testimony and a supplemental appendix that redefined the former Vint Hill-Wheeler and Wheeler-Loudoun 230-kV lines to be the Vint Hill-Wheeler and Wheeler-Gainesville 230-kV lines.
Staff said that it also discovered during the course of the proceeding that Option A for the projects could be a viable alternative to the company’s proposed Option C for the projects. Since the company did not believe Option A was viable, no route for Option A had yet been published, staff said, adding that it filed in March 2015 its second motion requesting that a hearing examiner direct the company to publish routes for Option A. Noting that the hearing examiner granted its motion, staff said that three alternatives for the projects were considered in the proceeding: Option A 2/3 Staff (Option A), Option B, and Option C.
The hearing examiner in November 2015 issued a report, finding that both Option A and Option C meet the identified need in the proceeding, and recommending that the SCC approve Option C.
Staff also noted that the SCC in February 2016 issued its final order in the case, requiring the company to build and place the projects in service by July 1, 2017, but granting the company leave to apply for an extension for good cause shown.
Less than a month before the required in-service date of July 1, the company filed the motion for extension, staff noted, adding that, according to the company, “[d]ue to unforeseen changes in zoning and local approval requirements and outage constraints, combined with the necessary construction and energizing sequencing, the company will not be able to complete the project by the deadline of July 1, 2017.”
According to the company’s June 12 motion, due to changes in Prince William County, Va., zoning laws, the company was required to obtain Special Use Permits (SUPs) for the new Vint Hill and Wheeler switching stations. As of the date of its filing, the company has obtained the SUPs, but is still in the process of obtaining site plan approvals for both substations from the county. Construction cannot begin until the site plans are approved, the company added, noting that it anticipates that construction on the Vint Hill switching station will be completed by March 2018, while the Wheeler switching station and the line from Vint Hill to Wheeler will be completed by May 1, 2018.
The company further noted that during the project’s design phase, it determined that the wreck and rebuild of the two-mile section of the Northern Virginia Electric Cooperative (NOVEC) line between Wheeler and Dam Junction could be scheduled only during an outage from October 2017 to April 2018, due to load issues.
In addition, the company determined that the conversion of the remainder of that line between Dam Junction and Gainesville had to be built in sections, working from Wheeler to Gainesville, in order to keep NOVEC’s Linton Hall and Atlantic Delivery Points energized from the existing 115-kV source until an outage can be taken to convert and cutover each substation to the 230-kV source from the opposite direction.
The company added that it requests that the current July 1 deadline provided in the final order be extended to Dec. 31, 2018, claiming that “such extension will not prejudice any person or party.”
In its June 30 response, staff said that given the hearing examiner’s and commission’s reliance on Option C’s construction schedule in selecting the company’s preferred project alternative for construction, and given the ongoing heightened risk of prolonged outages for customers in the area, staff maintains that more information is needed from the company before the SCC can consider the requested extension and determine that, in fact, no person or party is prejudiced by the requested extension and that good cause exists for the requested extension.
Any delay to these projects is troublesome given the area’s ongoing NERC reliability violations that could result in a fine to the company of up to $1m per day per violation, which could potentially be passed through to customers, staff claimed.
The company has presumably already gone through all of the necessary steps to obtain the SUPs for each switching station, without any indication to the SCC that construction of the projects was facing delay, staff claimed.
The company “should have notified the commission as soon as the company became aware that it would not meet the in-service date of the projects,” staff said.
The company gives no indication of where it stands in the process of obtaining “site plan approvals” for the two switching stations in its motion, or even whether those approvals are likely, staff claimed, adding, “Rather, [the company] asks the commission to rely on the company’s anticipation that the required approvals will come such that construction of this portion of the projects would be complete less than a year from now, in March and May 2018, with no data to substantiate these claims.”
Of the delayed wreck and rebuild of NOVEC’s line between Wheeler and Dam Junction, staff said that the company gives no further information regarding the “load issues” or what, if anything, has changed since the SCC’s consideration of the application.
“The motion’s meager reference to ‘load issues’ is insufficient for the commission to evaluate whether [the company]’s extension request, in fact, will prejudice no person or party and whether, in fact, good cause exists,” staff claimed.
By the end of 2018, the evidence in the case establishes that customers would pay $16.4m more for Option C than Option A due to additional projects required in 2018, staff claimed.
Among other things, staff said that in light of the pending extension request, the company should update the SCC on the current estimated cost of the projects.