The New York State Public Service Commission, in a Sept. 17 order, granted certain waivers in relation to the New York Power Authority’s (NYPA) proposed rebuild of the existing Moses-Adirondack 1&2 230-kV Transmission Lines.
As noted in the order, NYPA on April 5 filed with the commission an application for a certificate of environmental compatibility and public need for authority to:
- Rebuild its existing 230-kV Moses-Adirondack 1 and 2 transmission lines, which extend about 86 miles from the St. Lawrence Power Project’s Robert Moses Power Dam switchyard in the Town of Massena, St. Lawrence County, to the Adirondack substation in the Town of Croghan, Lewis County
- Build certain upgrades to the Moses switchyard and the Adirondack substation
The commission added in its order that NYPA proposes to divide the project into two phases, with Phase One, for instance, consisting of replacing 78 miles of the two lines currently configured as single circuits on separate wooden H-frame structures with two new single-circuit lines on steel monopoles.
While NYPA intends to design and build the transmission lines with the capacity to operate at 345 kV, the initial operating voltage would be 230 kV.
Phase Two, the commission added, would involve replacing the remaining length of the transmission lines with two single circuits on steel monopoles, as well as upgrading the Moses switchyard and the Adirondack substation to operate at 345 kV. Before beginning Phase Two, NYPA intends to submit an environmental management and construction plan, as well as petition to amend the certificate to permit the project to operate at 345 kV, the commission said.
Except for an approximately one-mile reroute at the State University of New York (SUNY) at Canton campus, NYPA proposes to build the project entirely within an existing right of way (ROW) that it maintains, the commission said.
With its application, NYPA submitted a motion requesting waivers of certain of the commission’s regulations governing the content of an application for a certificate, the commission said, adding that NYPA amended its motions in August and submitted an additional set of maps in support.
Among other things, NYPA requests a waiver of the requirement that it submit New York State Department of Transportation (NYSDOT) maps at 1:24,000 scale showing “the proposed right of way (with control points indicated), covering an area of at least five miles on either side of the proposed facility location”; “where the construction or reconstruction of the proposed facility would necessitate permanent clearing or other changes to the topography, vegetation or man-made structures”; and “any known archaeological, geologic, historical or scenic area, park, or untouched wilderness on or within three miles of the” ROW, the commission said.
Originally, in lieu of the 1:24,000 scale NYSDOT maps specified in the regulation, NYPA provided maps at a 1:96,000 scale based on United States Geological Survey (USGS) 7.5-minute topographic maps. The commission added that NYPA argues that the smaller scale maps provide a better context of the region surrounding the project than the larger scale maps.
As part of its amended application, NYPA also submitted maps based on USGS maps at 1:24,000 scale, asserting that the USGS maps contain the information required by regulation and provide for better clarity of existing features than the required NYSDOT maps.
The commission noted that the combination of the proposed maps will show all the information required by regulation, and that the additional 1:96,000 scale maps may also facilitate a better understanding of the greater regional context of the proposed project. Accordingly, the requested waiver, as amended, is granted, the commission said.
Noting that Article VII applications must include NYSDOT maps showing the location of any alternative route considered, the commission said that NYPA said that it did not evaluate any alternative routes for the entire project because they were determined not to be practicable. NYPA did consider two small alternative route segments for the portion of the proposed ROW that would be located within the SUNY Canton camps, which is about one mile of the entire 86-mile proposed ROW.
To the extent the commission determines that the mapping requirements apply to those alternative route segments, NYPA requests that it be allowed to provide a depiction of the alternative route segments using an overlay on aerial photography, as contained in the application. The commission added that NYPA’s requested waiver is unopposed and the proposed depictions contain the necessary information for the alternative route segments in the SUNY Canton campus; the commission granted the requested waiver.
The commission also said that Article VII applications must include a System Reliability Impact Study (SRIS) “forwarded by the Transmission Planning Advisory Subcommittee [TPAS] for approval by the operating committee of the New York Independent System Operator [NYISO], which shows effects on stability of the interconnected system.”
NYPA asserts that the commission has routinely accepted a System Impact Study (SIS) instead of the SRIS specified in the regulation because the SIS is substantially identical to the SRIS and is the only study that NYISO performs to assess the impacts on the stability of the state’s bulk electric system of upgrades to the AC transmission system of the type proposed by NYPA, the commission said.
NYPA said that it meets the regulatory requirements by providing an SIS for Phase One of the project, and that before undertaking Phase Two, it will request an amendment to its certificate to permit the project to operate at 345 kV, which will require it to submit a second SIS at that time.
Under those circumstances, the commission added, NYPA requests clarification that it is not required to submit an SIS for Phase Two of the project in order for its application to be deemed complete for Phase One of the project. In the alternative, NYPA requests that any requirement to provide an SIS for Phase Two of the project with its current application be waived, the commission said. NYPA states that the requested clarification or waiver would facilitate proper planning for future transmission expansion, the commission said.
NYPA’s request for the waiver is reasonable and therefore granted, the commission said, adding that in the future, when NYPA undertakes Phase Two of the project to allow it to operate the project at 345 kV, NYPA must provide with its request to amend any certificate issued in the proceeding an SIS addressing system impacts of the project operating at 345 kV.