Case No. 10-T-0139
BEFORE THE STATE OF NEW YORK PUBLIC SERVICE COMMISSION ______In the Matter of Application of Champlain Hudson Power Express, Inc. for a Certificate of Environmental Compatibility and Public Need Pursuant to Article VII of the PSL for the Construction, Operation and Maintenance of a High Voltage Direct Current Circuit from the Canadian Border to New York City
Case 10-T-0139 June 7, 2012 ______Prepared Testimony of: M. Antony Lopez-Lopez Senior Consultant Bryndan Associates, Inc. P.O. Box 2176 Princeton, NJ 08543
On behalf of:
New York Power Authority
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1 Q. Please state your name, affiliation, and title.
2 A. My name is M. Anthony López-López. My business address is Bryndan Associates Inc., P.O.
3 Box 2176, Princeton, NJ 08543. I am a Senior Consultant with Bryndan Associates, Inc. and
4 have been retained by the New York Power Authority (“NYPA”) to assist in addressing the
5 potential for technical and construction issues impacting NYPA’s facilities as a result of the
6 proposed Champlain Hudson Power Express project (“CHPE”).
7 Q. Please describe your educational background, work experience, and qualifications.
8 A. I graduated from New York University with a Bachelor of Science in Electrical Engineering
9 in 1974 (Honors); New Jersey Institute of Technology with a Master of Science in Electrical
10 Engineering in 1977; and New Mexico Highlands University with a Masters in Arts in Business
11 Administration in 1980 (Honors).
12 I am a licensed Professional Engineer with active licenses in New York and New Jersey, and an
13 inactive license in New Mexico.
14 I am Senior Member of the Institute of Electrical and Electronic Engineers.
15 Between 1974 and the present I have been employed by: American Electric Power (Generation
16 & Transmission Planning) 1974 – 1977; Public Service Co. of New Mexico (“PNM”)
17 (Generation & Transmission Planning, and Strategic & Financial Planning) 1977 - 1988; Ebasco
18 Services (Planning, Consulting, Project Management and Construction Management) 1988 –
19 1993; Raytheon Engineers & Constructors (Planning, Consulting, Project Management and
20 Construction Management) 1993 – 1995; PSEG (Power & Energy Trading) 1995 - 1997; LG&E
21 Energy (Power Marketing & Trading) 1997 –1998; SmartEnergy (Founder) (Chief of Energy
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1 Operations) 1998-2001; and Bryndan Associates (Founder) (Consulting) 1998 – Present. My
2 employment has continuously been in functions associated with electric power generation,
3 transmission, and distribution; specifically including planning, engineering, construction,
4 marketing, finance, regulation and management.
5 I have participated in the planning and engineering of several AC and DC high voltage
6 transmission projects in the NY area; some of these projects include the 345 kV submarine cable
7 crossing of the Arthur Kill from Linden, NJ to Con Ed’s Goethals Substation in Staten Island,
8 NY; the HVDC NYRI Transmission Project including overhead, underground and submarine
9 construction; the HVAC Cross Hudson Project including underground, submarine and
10 horizontal-directional-drilling construction, NRG studies and planning for their Astoria and
11 Staten Island facilities, the Sunset Energy Park Project (barge mounted interconnection in
12 Gowanus, Brooklyn). Additionally, I am currently providing engineering, regulatory and overall
13 consulting services for a multi-billion dollar expansion of the Texas (ERCOT) 345 kV
14 transmission system (CREZ), a confidential HVDC submarine cable crossing in California, the
15 expansion of PJM’s EHV system, and solar projects in New Jersey.
16 I have testified or prepared testimony in regulatory and civil proceedings as follows: Queensland
17 Commission (Australia) – Prepared testimony on Power Production Cost; Public Service
18 Commission of Chile – Prepared testimony on Cost of Service; New Mexico Public Service
19 Commission – Prepared and presented testimony on Cash Flow and Financing; Indiana Public
20 Service Commission – Prepared testimony on Steam/Electric Cost Allocations; Federal Energy
21 Regulatory Commission - Prepared and presented testimony on behalf of PNM in rulemaking
22 proceedings, including Docket Nos. RM88-4-000 and RM88-5-000, covering topics such as
23 Regulations Governing Independent Power Producers; Bidding Programs; Administrative
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1 Determination of Full Avoided Costs; Sales of Power to Qualifying Facilities and
2 Interconnection Facilities; Dade County, Florida - Prepared and submitted expert testimony on
3 Independent Power Producer’s reliability of service; Federal Energy Regulatory Commission -
4 Prepared and presented testimony on behalf of NRG Energy Center Dover, LLC for providing
5 cost-based Reactive Supply and Voltage Control to the PJM Interconnection, LLC in Docket
6 No. ER06-1459; Federal Energy Regulatory Commission - Prepared and presented testimony on
7 behalf of RPL Holdings, Inc. for providing cost-based Reactive Supply and Voltage Control to
8 the PJM Interconnection, LLC.
9 Recent prepared testimony relevant to this proceeding are (1) for the Article VII filing for the
10 “New York Regional Interconnection” (NYRI), a 190 miles 400 kV HVDC project from upstate
11 to downstate NY, and (2) the “In-City” 345 kV interconnection from New Jersey Bergen Station
12 area to Con Edison’s West 49th Street Substation crossing the Hudson river (the latter was
13 subsequently renamed “Cross Hudson Project” after a change in ownership). These 2 projects
14 include HVDC, HVAC, overhead, underground, submarine and horizontal-directional-drilling
15 cable installation construction, as well as mass impregnated and XLPE cable technologies.
16 Q. Are you a member of any professional organization?
17 A. I am a senior member of the Institute of Electrical and Electronic Engineers.
18 Q. Have you ever given or prepared expert testimony in other proceedings involving the
19 licensing of transmission projects and, if so, please explain the nature of these proceedings?
20 A. As indicated previously in this document, recent relevant testimony prepared are (1) for the
21 Article VII filing for the “New York Regional Interconnection” (NYRI), a 190 miles 400 kV
22 HVDC project from upstate to downstate NY, and (2) for the “In-City” 345 kV interconnection
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1 from New Jersey Bergen Station area to Con Edison’s West 49th Street Substation, crossing the
2 Hudson river (the latter was subsequently renamed “Cross Hudson Project” after a change in
3 ownership). These 2 projects include HVDC, HVAC, overhead, underground, submarine and
4 horizontal-directional-drilling cable installation construction, as well as mass impregnated and
5 XLPE cable technologies.
6 Q. Please describe your responsibilities with regard to the present Champlain Hudson
7 Power A.Express Article VII application.
8 A. I have been retained by NYPA to provide an assessment of the technical, engineering and
9 construction issues that may impact NYPA’s facilities along the CHPE project.
10 Q. Are you familiar with high voltage direct current (“HVDC”) transmission projects and,
11 if so, please describe your experience.
12 A. Yes, I am very familiar with the HVDC technology, with the most recent experience being
13 in the NYRI and California projects (described previously). My experience with HVDC goes
14 back to the early 80’s with several planning and engineering efforts in the Western Electric
15 Coordination Council for interconnection between the US western and eastern transmission
16 grids. The HVDC and Phase Angle Regulator technologies were also evaluated for the Cross
17 Hudson Project. In general, HVDC is an alternative technology that is consider in most long
18 transmission lines or for the interconnection of large systems such as PJM with NYISO, and the
19 WECC with the eastern grid.
20 Q. Are you familiar with underground transmission cables and, if so, please describe your
21 experience.
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1 A. Yes, I am very familiar with underground cable installation, including the different cable
2 technologies such as pipe-type, self-contained, mass impregnated, and XLPE. The most recent
3 experience with underground installations being the NYRI, the Cross Hudson (In-City) projects,
4 and the Linden-Goethals 345 kV project.
5 Q. What is the Power Authority of the State of New York (“Power Authority”)?
6 A. NYPA is a corporate municipal instrumentality and political subdivision of the State of New
7 York, created and operating pursuant to Public Authorities Law §§ 1000-1017, and has its
8 principal office at 30 South Pearl Street, Albany, New York 12207.
9 Q. Are you familiar with the transmission line project called the Champlain Hudson
10 Power Express?
11 A. Yes, from my review of various documents on file in these proceedings and my participation
12 in conferences with the applicant/developer, Champlain Hudson Power Express, Inc. (“CHPEI”)
13 and the Power Authority, I am familiar with the proposed Champlain Hudson Power Express
14 (“CHPE”) primary route.
15 Q. Do you know whether the proposed primary route of the Champlain Hudson Power
16 Express crosses any Power Authority facility?
17 A. The proposed primary route of the CHPE transmission line crosses Power Authority facilities
18 in several locations: the Marcy South (Roseton to East Fishkill segment) transmission line
19 (“Marcy South Line”); the Plattsburgh to Vermont transmission line (“PV20 Line”); and the
20 Astoria to Rainey Cable crosses the Power Authority’s Q35 L&M lines.
21 A portion of the Roseton to East Fishkill segment of the Marcy South Line includes submarine
22 cables that are buried in the sediment below the Hudson River. The proposed primary route of
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1 the CHPE Line crosses the Power Authority’s submarine cables in the sediment below the
2 Hudson River.
3 Part of the PV20 Line is buried in the sediment below Lake Champlain in a west to east direction
4 from Cumberland Head, New York to Vermont, and the CHPE Line proposes to cross the PV20
5 Line under water (New York side) in the sediment below the Lake.
6 The proposed primary route connects to the Power Authority’s 345 kV substation located on
7 Con Edison property.
8 Q. What is your understanding of the CHPEI’s interconnection arrangement at the
9 Astoria site?
10 A. The CHPEI is proposing to interconnect their AC output from the CHPE project at NYPA’s
11 Astoria Annex, and to construct a new 345 kV cable to the Rainey Substation . CHPEI has
12 indicated that this arrangement will meet the deliverability objectives of the Project without the
13 need of mitigating control mechanisms such as Special Protection Systems (“SPS”).
14 Q. Are you aware of a proposal in which CHPEI sought to use a Special Protection
15 System (“SPS”) to achieve deliverability of 1,550 MW from the proposed converter station
16 to the greater New York City area and the grid?
17 A. Yes, I am familiar with CHPEI’s proposal to use a SPS at the Astoria Point of
18 Interconnection (“POI”) as a proposed control mechanism to achieve deliverability of the
19 capacity of the CHPE line. In a July 15, 2011 Notice of Request for System Impact Study for
20 Champlain Hudson Power Express-Astoria Special Protection System (“SIS SPS Notice”),
21 CHPEI requested that the New York Independent System Operator (“NYISO”) conduct a System
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1 Impact Study (“SIS”) of a Special Protection System (“SPS”). The Power Authority
2 commented on the Developer’s draft scope and the NYISO drafted a “Scope of the System
3 Impact Study for the Transmission Developers Inc. Champlain Hudson Power Express-Astoria
4 Special Protection System
5 Q. Why is the proposed SPS at Astoria a technical issue of concern to NYPA?
6 A. Our concern is broadly based on the application of an SPS in any circuit arrangement that
7 may impact our facilities and affect negatively the reliability of our system. In this instance,
8 NYPA’s concern with the potential for the use of an SPS derives from the impact on the two 345
9 kV pipe-type cables that are directly connected to the proposed POI of the CHPE project.
10 Specifically, the two cables are the Q35 L & M transmission cables
11 If an SPS was to be considered by the CHPEI at any time for this project, NYPA will require
12 strict conformance with all applicable rules, guidelines and requirements of the NYISO, NPCC
13 and NYSRC as these specifically apply to the use of an SPS. The report (Exhibit 123 of the Joint
14 Proposal) on record claims a deliverability solution would exist using a SPS in conjunction with
15 a reinforcement feeder to the Rainey Substation. However, the report postulates a contingency
16 resulting in the loss of a single element. NYPA objects to the application of a SPS pursuant to
17 this contingency, which NYPA views as contrary to NYSRC Rules, Part B Transmission
18 Capability - Planning.
19 Moreover, in the cases studied, non-design contingencies would give rise to SPS function,
20 requiring emergency operation of the Q35 feeders with a frequency not intended by the NYSRC
21 Rules, Part B Transmission Capability - Planning.
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1 Therefore, NYPA objects to the use of a SPS to protect the Q35 feeders, as proposed in Exhibit
2 123.
3 These concerns are implicit in the NYSRC rules, where on page 17 of the Rules for Planning and
4 Operating the New York State Power System it states:
5 “For contingencies "b", "c", "e", "f", and "g" in Table A that are not confined to the loss of a
6 single element, transmission owners may request the NYISO for an exception to allow the post-
7 contingency flow on a facility up to its STE rating. This is permissible provided operating
8 measures are available to reduce the flow below the LTE rating within fifteen (15) minutes and
9 not cause any other facility to be loaded beyond its LTE rating. Operating exceptions shall be
10 well documented, including NYISO comments, and must be approved by the NYSRC.”
11 And;
12 A Special Protection System (SPS) may be employed to provide protection for infrequent
13 contingencies or for temporary conditions that may exist such as project delays, unusual
14 combinations of system demand and equipment outages or unavailability, or specific equipment
15 maintenance outages. An SPS may be applied to preserve system integrity in the event of severe
16 facility outages and extreme contingences. The decision to employ an SPS should take into
17 account the complexity of the scheme and the consequence of correct or incorrect operation as
18 well as benefits. An SPS should be used judiciously and when employed, should be installed
19 consistent with good system design and operation policy.
20 Q. What are the Q35 L & M transmission lines?
21 A. The Q35 L & M lines, two 345 kV transmission underground/submarine cables in service
22 since 1974 which the Power Authority owns and which Con Edison maintains and repairs, were
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1 formerly generator leads that originated from the high side bus of the 24 kV/345 kV generator
2 step up transformer at the NYPA Poletti Site. The lines cross the East River and continue
3 underground under First Avenue terminating at Con Edison’s East 13th Street 345 kV substation.
4 When NYPA built its Astoria Annex 345 kV substation (“Astoria Annex”) the Q35 lines were
5 connected into the Astoria Annex.
6 The Q35 feeders are part of the New York State Bulk Electric System (BES) and their
7 unavailability would, by definition, present general reliability concerns. In addition, the location
8 of the Q35 cables under the streets of Queens and Manhattan, and buried in the sediment of the
9 East River present unique maintenance and repair issues.
10 Q. What is an SPS?
11 A. A SPS is an automatic protection system designed to detect abnormal or predetermined
12 system conditions, and take corrective or mitigative actions to maintain system reliability. Such
13 action may include changes in demand, generation (MW and Mvar), or system configuration to
14 maintain system stability, acceptable voltage, or power flows.
15 Q. Are there other instance in which the Power Authority has allowed an SPS on its
16 facilities?
17 A. Yes. In cases in which, the application of the SPS met the rules, guidelines, requirements
18 and reliability standards in place at the time, the Power Authority has allowed an SPS on its
19 facilities.
20 Q. Has the New York Independent System Operator (“ NYISO”) studied the impact of the
21 Developer’s proposed SPS on the bulk transmission system?
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1 A. The NYISO has not conducted a System Impact Study (“SIS”) of the Developer’s SPS. The
2 Developer withdrew its SIS request to the NYISO and the impact of the Developer’s SPS on the
3 New York State bulk transmission system has not been studied.
4 Q. Has the Power Authority analyzed the CHPEI’s proposal to build a new 345 kV
5 transmission line from the Power Authority’s Astoria Annex to Consolidated Edison’s
6 Rainey substation?
7 A. No. CHPEI has not supplied sufficient information to properly analyze whether a new
8 Astoria-Rainey line will allow deliverability of 1,550 MW.
9 Q. Does that conclude your testimony?
10 A. Yes, it does.
11