Evaluation of PG&E Responses to Data Requests
The California Public Utilities Commission (CPUC) is reviewing Pacific Gas and Electric Company’s (PG&E’s) proposed Santa Cruz 115 kV Reinforcement Project (Project) in accordance with California Environmental Quality Act (CEQA).
As part of this process the CPUC has submitted, to date, ten (10) requests for additional data to PG&E, to which PG&E has filed responses. The full list of requests and responses can be seen on the CPUC official page for this project.
NOPOC has been reviewing all documents pertaining to the project, and has identified three (3) unsubstantiated, three (3) incomplete, five (5) unanswered and one (1) inaccurate responses by PG&E to the questions posed by the CPUC in the data request.
NOPOC, as a party to this proceeding, has requested that this list be entered into the record, and that the CPUC deem PG&E’s responses to the following questions as unsubstantiated, incomplete, unanswered, and/or inaccurate, and require PG&E to respond completely, accurately, clearly and with substantiating data. This will afford everyone the ability to understand the impact of this project on the environment and community values of the affected areas.
Additionally in its response to Data Request #10 Question #5 PG&E introduces three new and as of yet unexplored alternatives to this project which the CPUC should ask for PG&E to provide full details as viable alternatives called Alternative 5A, 5B, and 5C to be considered along with the other alternatives enumerated in Data Request #8.
As part of this process the CPUC has submitted, to date, ten (10) requests for additional data to PG&E, to which PG&E has filed responses. The full list of requests and responses can be seen on the CPUC official page for this project.
NOPOC has been reviewing all documents pertaining to the project, and has identified three (3) unsubstantiated, three (3) incomplete, five (5) unanswered and one (1) inaccurate responses by PG&E to the questions posed by the CPUC in the data request.
NOPOC, as a party to this proceeding, has requested that this list be entered into the record, and that the CPUC deem PG&E’s responses to the following questions as unsubstantiated, incomplete, unanswered, and/or inaccurate, and require PG&E to respond completely, accurately, clearly and with substantiating data. This will afford everyone the ability to understand the impact of this project on the environment and community values of the affected areas.
Additionally in its response to Data Request #10 Question #5 PG&E introduces three new and as of yet unexplored alternatives to this project which the CPUC should ask for PG&E to provide full details as viable alternatives called Alternative 5A, 5B, and 5C to be considered along with the other alternatives enumerated in Data Request #8.
Question #1 – Alternative 1
Please provide data or documentation illustrating/supporting the claim that the alternative would not meet loading and voltage needs (i.e., what is the current load, how much load/voltage would this alternative provide and how was that determined).
PG&E Response
…...Anticipated future load growth would only exacerbate these potential load-shedding scenarios. PG&E’s distribution planners are projecting that the summer peak load in the Santa Cruz area could reach 158 MW within 10 years.…..
NOPOC Comment
Unsubstantiated response – PG&E has provided no data to support this and yet they repeatedly use growth as part of the justification. They MUST substantiate the growth predictions or not be allowed to use growth as a justification for this project.
Please provide data or documentation illustrating/supporting the claim that the alternative would not meet loading and voltage needs (i.e., what is the current load, how much load/voltage would this alternative provide and how was that determined).
PG&E Response
…...Anticipated future load growth would only exacerbate these potential load-shedding scenarios. PG&E’s distribution planners are projecting that the summer peak load in the Santa Cruz area could reach 158 MW within 10 years.…..
NOPOC Comment
Unsubstantiated response – PG&E has provided no data to support this and yet they repeatedly use growth as part of the justification. They MUST substantiate the growth predictions or not be allowed to use growth as a justification for this project.
Question #3 – Alternative 3
Please define the components of “rebuilding” (e.g., pole replacement? Substation work involved? Can be generally described) and associated cost implications (again, in general terms). Please provide a map indicating conceptually where new facilities would be located (or existing facilities expanded) so that we can assess the “substantial environmental impacts” conclusion.
PG&E Response
…..PG&E is currently evaluating the overall costs of design, procurement of equipment and materials, and construction for this alternative and will provide this information in a subsequent submittal….
NOPOC Comment
Incomplete response – PG&E provided a supplemental response to Data Request #8 describing the undergrounding of the Cox-Freedom Boulevard segment, however no mention of further evaluation of Alternative 3 is present. The CPUC should follow up, and require PG&E to submit this material as indicated in this response.
Please define the components of “rebuilding” (e.g., pole replacement? Substation work involved? Can be generally described) and associated cost implications (again, in general terms). Please provide a map indicating conceptually where new facilities would be located (or existing facilities expanded) so that we can assess the “substantial environmental impacts” conclusion.
PG&E Response
…..PG&E is currently evaluating the overall costs of design, procurement of equipment and materials, and construction for this alternative and will provide this information in a subsequent submittal….
NOPOC Comment
Incomplete response – PG&E provided a supplemental response to Data Request #8 describing the undergrounding of the Cox-Freedom Boulevard segment, however no mention of further evaluation of Alternative 3 is present. The CPUC should follow up, and require PG&E to submit this material as indicated in this response.
Question #7 – Alternative 4D
Assuming this alternative is technically feasible, please provide a revised project description for the underground segment describing the work to be completed including: a) the procedure and process for trench installation of the power line; b) temporary work areas (work and access corridors, staging areas); c) any additional vegetation, tree removals, or grading; d) materials and quantities for trenching and fill including cubic yards reused onsite versus disposed of offsite; e) equipment tables; f) construction crew composition and size; and g) maintenance associated with underground power lines (activity type and frequency).
PG&E Response
All portions of the question are addressed, with one exception, which is the request for visual simulations of the underground alignment of the Cox-Freedom Segment. These simulations are currently being prepared and PG&E anticipates submitting them to the California Public Utilities Commission (Commission) in early July.
PG&E has prepared a Project Description for the underground segment, which is provided in Attachment A: Project Description and describes the work that would be required to construct the segment based on a 30-percent design level.
NOPOC Comment
Incomplete response – It is now late August, where are the visual simulations for the underground work. We should see visual simulations of the completed vaults with vegetation removed, of both riser poles along with retaining walls, fences etc.
Unsubstantiated response – In all documentation by both PG&E and CPUC to this point, the new 1.7 mile section of transmission line starting at 1975 Cox Rd and ending at the Rob-Roy substation on Freedom Boulevard has been referred to as the “Cox-Freedom Segment”. This segment is the one which Data Request #8 Question #7 refers to for study for possible underground. However, PG&E decided to only explore undergrounding Cox Road, Day Valley Road and part of McDonald Road, approximately .8 miles, or slightly less than half the 1.7 mile segment. No explanation or rationale has been given for this choice and no study was presented for undergrounding the whole segment as requested.
Assuming this alternative is technically feasible, please provide a revised project description for the underground segment describing the work to be completed including: a) the procedure and process for trench installation of the power line; b) temporary work areas (work and access corridors, staging areas); c) any additional vegetation, tree removals, or grading; d) materials and quantities for trenching and fill including cubic yards reused onsite versus disposed of offsite; e) equipment tables; f) construction crew composition and size; and g) maintenance associated with underground power lines (activity type and frequency).
PG&E Response
All portions of the question are addressed, with one exception, which is the request for visual simulations of the underground alignment of the Cox-Freedom Segment. These simulations are currently being prepared and PG&E anticipates submitting them to the California Public Utilities Commission (Commission) in early July.
PG&E has prepared a Project Description for the underground segment, which is provided in Attachment A: Project Description and describes the work that would be required to construct the segment based on a 30-percent design level.
NOPOC Comment
Incomplete response – It is now late August, where are the visual simulations for the underground work. We should see visual simulations of the completed vaults with vegetation removed, of both riser poles along with retaining walls, fences etc.
Unsubstantiated response – In all documentation by both PG&E and CPUC to this point, the new 1.7 mile section of transmission line starting at 1975 Cox Rd and ending at the Rob-Roy substation on Freedom Boulevard has been referred to as the “Cox-Freedom Segment”. This segment is the one which Data Request #8 Question #7 refers to for study for possible underground. However, PG&E decided to only explore undergrounding Cox Road, Day Valley Road and part of McDonald Road, approximately .8 miles, or slightly less than half the 1.7 mile segment. No explanation or rationale has been given for this choice and no study was presented for undergrounding the whole segment as requested.
Question #3
Please provide data that supports the approach of adding a second circuit to decrease outages and increase reliability. For example, describe how adding a second circuit will reduce outages in the area if outages are caused by falling trees, which could affect both circuits, and lighting strikes.
PG&E Response
This question suggests that the probability of an event causing sustained outages on both circuits on the new tubular steel pole (TSP) line is the same as the probability of an event compromising the existing wood-pole circuit. While severe events could simultaneously affect transmission circuits that share common structures or are located in the same corridor (e.g., wildfires, severe storms, earthquakes), such severe events are much less frequent than single-circuit outages and do not usually result in sustained outages to the affected circuits.
PG&E’s transmission system has experienced double-circuit transmission line outages; however, these types of events are not a common occurrence and are much less frequent than single-circuit outage events. Most of these double-circuit events occur on very long transmission lines that are located in either mountainous/wooded areas or in predominantly agricultural areas. In 2013, there were approximately 800 unplanned outages on PG&E’s transmission paths. Of these, only 94 involved the simultaneous outage of multiple circuits, and in over 50 of these events, most or all of the affected lines experienced only a momentary outage.
The proposed Project will rebuild a 7-mile, wood-pole section of the Green Valley-Camp Evers line into a double-circuit TSP line. Figure 1: Existing and Proposed Poles shows the wood-pole structures used on the existing single-circuit line and the TSPs planned for the new double-circuit line. The design will help protect the system from double-circuit outages. First, the two circuits will be mounted on taller TSPs, with the two circuits separated by more than 16 feet. This makes the likelihood of, for example, a falling tree knocking out both circuits, very low. In addition, the use of TSPs and the line route make the probability of a car-pole accident knocking out both circuits also very low. A double-circuit outage caused by a severe event such as a wildfire could still occur, but such events should be very infrequent.
NOPOC Comment
Unanswered question – This response does not answer the question. First, the question is for data and the response provides an argument completely devoid of data. Second, the data requested is to support the approach PG&E is taking and the response only addresses the example given.
Please provide data that supports the approach of adding a second circuit to decrease outages and increase reliability. For example, describe how adding a second circuit will reduce outages in the area if outages are caused by falling trees, which could affect both circuits, and lighting strikes.
PG&E Response
This question suggests that the probability of an event causing sustained outages on both circuits on the new tubular steel pole (TSP) line is the same as the probability of an event compromising the existing wood-pole circuit. While severe events could simultaneously affect transmission circuits that share common structures or are located in the same corridor (e.g., wildfires, severe storms, earthquakes), such severe events are much less frequent than single-circuit outages and do not usually result in sustained outages to the affected circuits.
PG&E’s transmission system has experienced double-circuit transmission line outages; however, these types of events are not a common occurrence and are much less frequent than single-circuit outage events. Most of these double-circuit events occur on very long transmission lines that are located in either mountainous/wooded areas or in predominantly agricultural areas. In 2013, there were approximately 800 unplanned outages on PG&E’s transmission paths. Of these, only 94 involved the simultaneous outage of multiple circuits, and in over 50 of these events, most or all of the affected lines experienced only a momentary outage.
The proposed Project will rebuild a 7-mile, wood-pole section of the Green Valley-Camp Evers line into a double-circuit TSP line. Figure 1: Existing and Proposed Poles shows the wood-pole structures used on the existing single-circuit line and the TSPs planned for the new double-circuit line. The design will help protect the system from double-circuit outages. First, the two circuits will be mounted on taller TSPs, with the two circuits separated by more than 16 feet. This makes the likelihood of, for example, a falling tree knocking out both circuits, very low. In addition, the use of TSPs and the line route make the probability of a car-pole accident knocking out both circuits also very low. A double-circuit outage caused by a severe event such as a wildfire could still occur, but such events should be very infrequent.
NOPOC Comment
Unanswered question – This response does not answer the question. First, the question is for data and the response provides an argument completely devoid of data. Second, the data requested is to support the approach PG&E is taking and the response only addresses the example given.
Question #4
Please provide photographs of power poles that are like those proposed to be used on the project and located in other areas of Santa Cruz County. Alternatively, indicate that there are no similar structures in the County.
PG&E’s Response
Photographs of existing power poles and towers in Santa Cruz County similar to those proposed for the Project are provided in Attachment B: Representative Photographs of Structures and Poles in the Project Vicinity. As shown in the photographs, structures similar to the TSPs proposed for the Project can be found on the Camp Evers-Paul Sweet 115 kV line. Note, however, that these structures have dipped crossarms, as opposed to the gull crossarms proposed under the current design for the Project. In addition, the wood pole portions of the Green Valley- Watsonville and Metcalf-Green Valley 115 kV lines have different framing than that of the current Project design (wishbone and two-pole structures). A single-circuit TSP with distribution underbuild is also found on the Green Valley-Watsonville 60 kV line. In addition, several lattice structures similar to the height of the proposed Project can be found on the Moss Landing- Metcalf 500 kV line, Metcalf-Moss Landing #1 230 kV line, Moss Landing-Green Valley #1 115 kV line, and Green Valley-Paul Sweet 115 kV line. These existing structures can exceed heights of 140 feet.
NOPOC Comment
Unanswered question – The request is to provide pictures and locations of poles that are like the proposed poles, implied is both the 102’ TSP as well as the 80’ wood poles. The photographs provided are of the following:
Please provide photographs of power poles that are like those proposed to be used on the project and located in other areas of Santa Cruz County. Alternatively, indicate that there are no similar structures in the County.
PG&E’s Response
Photographs of existing power poles and towers in Santa Cruz County similar to those proposed for the Project are provided in Attachment B: Representative Photographs of Structures and Poles in the Project Vicinity. As shown in the photographs, structures similar to the TSPs proposed for the Project can be found on the Camp Evers-Paul Sweet 115 kV line. Note, however, that these structures have dipped crossarms, as opposed to the gull crossarms proposed under the current design for the Project. In addition, the wood pole portions of the Green Valley- Watsonville and Metcalf-Green Valley 115 kV lines have different framing than that of the current Project design (wishbone and two-pole structures). A single-circuit TSP with distribution underbuild is also found on the Green Valley-Watsonville 60 kV line. In addition, several lattice structures similar to the height of the proposed Project can be found on the Moss Landing- Metcalf 500 kV line, Metcalf-Moss Landing #1 230 kV line, Moss Landing-Green Valley #1 115 kV line, and Green Valley-Paul Sweet 115 kV line. These existing structures can exceed heights of 140 feet.
NOPOC Comment
Unanswered question – The request is to provide pictures and locations of poles that are like the proposed poles, implied is both the 102’ TSP as well as the 80’ wood poles. The photographs provided are of the following:
- 147’ lattice steel tower in Moss Landing
- 57’ wood pole in the City of Watsonville
- a second 57’ wood pole in the City of Watsonville
- 102’ lattice steel tower in the City of Watsonville
- 59’ wood pole in the City of Watsonville
- 65’ wood pole in the City of Watsonville
- 68’ TSP in the City of Watsonville
- 102’ lattice steel tower in the City of Santa Cruz
- 85’ lattice steel tower in the City of Santa Cruz
- 93’ lattice steel tower in the City of Santa Cruz
- 80’ TSP in the City of Scotts Valley
- 75’ TSP in the City of Scotts Valley
- 75’ TSP in the City of Scotts Valley
Question #5
Please revise visual simulations previously provided to account for tree removal and tree and vegetation trimming if the visual simulations do not already account for tree removal and vegetation trimming. Explain how tree removal and vegetation trimming are depicted in the visual simulations if the visual simulations already account for tree removal and vegetation trimming.
PG&E’s Response
Three simulation views were revised to account for tree removal and vegetation trimming in response to the CPUC’s request. These views include the following:
The revised simulations are provided in Attachment A: Revised Visual Simulations Depicting Tree Removal and Vegetation Trimming. After reviewing the previously prepared visual simulations, it was determined that only these three views required revisions to account for tree removal and vegetation trimming. In preparing these simulations, PG&E assumed that an approximately 60-foot-wide tree removal and vegetation trimming corridor will be required along the line in these locations, with small trees and shrubs remaining in place.
NOPOC Comment
Inaccurate answer – The Cox Road simulation is incomplete; First, the pole has no ‘top’ or resistors or wires and its is the incorrect height. Second, given the angle of this photograph it is impossible to see all the trees removed on Day Valley. Generally, they should provide simulations which show how the areas which are currently forested will look like after the project.
Please revise visual simulations previously provided to account for tree removal and tree and vegetation trimming if the visual simulations do not already account for tree removal and vegetation trimming. Explain how tree removal and vegetation trimming are depicted in the visual simulations if the visual simulations already account for tree removal and vegetation trimming.
PG&E’s Response
Three simulation views were revised to account for tree removal and vegetation trimming in response to the CPUC’s request. These views include the following:
- the view from Pinto Lake Park looking east;
- the view from Cox Road near Day Valley Road looking southeast; and
- the view from Freedom Boulevard near Shadowmere Way looking southeast.
The revised simulations are provided in Attachment A: Revised Visual Simulations Depicting Tree Removal and Vegetation Trimming. After reviewing the previously prepared visual simulations, it was determined that only these three views required revisions to account for tree removal and vegetation trimming. In preparing these simulations, PG&E assumed that an approximately 60-foot-wide tree removal and vegetation trimming corridor will be required along the line in these locations, with small trees and shrubs remaining in place.
NOPOC Comment
Inaccurate answer – The Cox Road simulation is incomplete; First, the pole has no ‘top’ or resistors or wires and its is the incorrect height. Second, given the angle of this photograph it is impossible to see all the trees removed on Day Valley. Generally, they should provide simulations which show how the areas which are currently forested will look like after the project.
Question #8
Please provide a record of service outages that justifies the purpose and need of the project, as presented in the Proponent’s Environmental Assessment.
PG&E’s Response
PG&E proposed this Project to the California Independent System Operator to address system loading and voltage issues that could result in violations of system reliability requirements approved by the North American Electric Reliability Corporation (NERC). NERC Transmission Planning Standard TPL-002-0b requires that the transmission system be stable and operating within applicable thermal and voltage limits for either a single-element outage (Category B) or a two-element outage (Category C). In addition, customer load should not be shed for a Category B outage. While load shedding is permitted for Category C outages, the load shedding must be planned and controlled. If any utility is found to be operating its transmission system in violation of these reliability standards, NERC could level penalties and fines.1
With future load growth in the Santa Cruz area, a single outage of either the Green Valley-Camp Evers line or the Green Valley-Rob Roy line on a hot summer day could result in an overload of the remaining line. This would be a violation of the NERC reliability standard.
Table 1: Outage History of the 115 kV Lines Supplying the Santa Cruz Area (1992 – 2014) provides a summary of the outage histories for the two 115 kV lines supplying the Santa Cruz area. These two lines have experienced a number of outages in the last 22 years, with each line experiencing a sustained outage about once every 2.5 years. Only three of the sustained outages were less than 2 hours in duration; the remaining 14 sustained outages had durations of 4 to 26 hours.
Please provide a record of service outages that justifies the purpose and need of the project, as presented in the Proponent’s Environmental Assessment.
PG&E’s Response
PG&E proposed this Project to the California Independent System Operator to address system loading and voltage issues that could result in violations of system reliability requirements approved by the North American Electric Reliability Corporation (NERC). NERC Transmission Planning Standard TPL-002-0b requires that the transmission system be stable and operating within applicable thermal and voltage limits for either a single-element outage (Category B) or a two-element outage (Category C). In addition, customer load should not be shed for a Category B outage. While load shedding is permitted for Category C outages, the load shedding must be planned and controlled. If any utility is found to be operating its transmission system in violation of these reliability standards, NERC could level penalties and fines.1
With future load growth in the Santa Cruz area, a single outage of either the Green Valley-Camp Evers line or the Green Valley-Rob Roy line on a hot summer day could result in an overload of the remaining line. This would be a violation of the NERC reliability standard.
Table 1: Outage History of the 115 kV Lines Supplying the Santa Cruz Area (1992 – 2014) provides a summary of the outage histories for the two 115 kV lines supplying the Santa Cruz area. These two lines have experienced a number of outages in the last 22 years, with each line experiencing a sustained outage about once every 2.5 years. Only three of the sustained outages were less than 2 hours in duration; the remaining 14 sustained outages had durations of 4 to 26 hours.
Table 1: Outage History of the 115 kV Lines Supplying the Santa Cruz Area (1992 – 2014)
| Transmission Line | Number of Momentary Outages | Number of Sustained Outages | Total Accumulated Duration (minutes) |
| Green Valley - Camp Evers | 9 | 8 | 9432 |
| Green Valley - Rob Roy - Paul Sweet | 11 | 9 | 3984 |
NOPOC Comment
Unanswered question – This is a summary of outage data, not a record or the detailed data, it omits the dates, length of outage and reason for outage. The question was to provide a record of outages that justifies the need for this project and the summary of outages does not answer that. Furthermore, it is suspicious that data was gives for a 22 year period without explaining the reason for starting on 1992. If they had provided the record, as requested, one could see when these outages where and if they are becoming more frequent or less. Finally, in this answer they make an unsubstantiated statement which they have made before “future load growth in the Santa Cruz area”. PG&E has provided no data to indicate this growth exists which MUST be provided if it is part of the justification of this project.
Unanswered question – This is a summary of outage data, not a record or the detailed data, it omits the dates, length of outage and reason for outage. The question was to provide a record of outages that justifies the need for this project and the summary of outages does not answer that. Furthermore, it is suspicious that data was gives for a 22 year period without explaining the reason for starting on 1992. If they had provided the record, as requested, one could see when these outages where and if they are becoming more frequent or less. Finally, in this answer they make an unsubstantiated statement which they have made before “future load growth in the Santa Cruz area”. PG&E has provided no data to indicate this growth exists which MUST be provided if it is part of the justification of this project.
Question #2
Please provide any meeting notes between PG&E and the Central Water District concerning potential impacts on CWD water lines. Please provide notes on meetings with Santa Cruz County Public Works Department, and any other agencies for consultations that have occurred since the Draft IS/MND circulation.
PG&E’s Response
PG&E staff met with Ralph Bracamonte of the Central Water District (CWD) on February 24, 2014. PG&E and the CWD discussed the location of existing water lines along the Cox-Freedom Segment and the status of the California Environmental Quality Act process for the project. PG&E and the CWD agreed to further discussions on how to protect and/or repair existing water lines during construction of the project. No meeting notes were prepared. In addition, PG&E met with the Santa Cruz County (County) Public Works Department on April 22, 2014. Meeting notes from the Public Works Department meeting are provided in Attachment C: Santa Cruz County Public Works Department Meeting Notes.
NOPOC Comment
Incomplete response – “No meeting notes were prepared.” First, they completely forget to notify CWD, then when they finally meet with them (February 2014 a full 2 years after they were supposed to) they have a meeting and take no notes? Without notes having been taken how do they know what was covered at that meeting, what action items each side took, and what was agreed to?
Please provide any meeting notes between PG&E and the Central Water District concerning potential impacts on CWD water lines. Please provide notes on meetings with Santa Cruz County Public Works Department, and any other agencies for consultations that have occurred since the Draft IS/MND circulation.
PG&E’s Response
PG&E staff met with Ralph Bracamonte of the Central Water District (CWD) on February 24, 2014. PG&E and the CWD discussed the location of existing water lines along the Cox-Freedom Segment and the status of the California Environmental Quality Act process for the project. PG&E and the CWD agreed to further discussions on how to protect and/or repair existing water lines during construction of the project. No meeting notes were prepared. In addition, PG&E met with the Santa Cruz County (County) Public Works Department on April 22, 2014. Meeting notes from the Public Works Department meeting are provided in Attachment C: Santa Cruz County Public Works Department Meeting Notes.
NOPOC Comment
Incomplete response – “No meeting notes were prepared.” First, they completely forget to notify CWD, then when they finally meet with them (February 2014 a full 2 years after they were supposed to) they have a meeting and take no notes? Without notes having been taken how do they know what was covered at that meeting, what action items each side took, and what was agreed to?
Question #5
Under the No Project Alternative, the project would not be implemented. In this case, would PG&E implement some type of system alternative as a temporary fix as demand increases? Please provide a description of what this system alternative would be, if applicable. If PG&E could/would not make any other changes, please explain why and the consequences of not making any changes to reliability, growth, etc.
PG&E Response
…..Third, PG&E might have to disable the automatic restoration features at Rob Roy Substation if the STATCOM is out of service during a summer peak demand period. This action would be necessary to protect against potential overload problems, should there be overlapping outages of the STATCOM and the Green Valley-Rob Roy Power Line section. Consequently, an outage of the line between Green Valley and Paul Sweet substations would result in an extended outage to Rob Roy Substation. Service restoration for some of the Rob Roy Substation load would be conducted manually by system operators, depending on system conditions. However, if the Green Valley-Rob Roy Power Line section is out during a summer peak demand period, PG&E system operators might need to immediately drop Rob Roy Substation if the STATCOM also goes out.
Note as well that as area loads continue to grow, PG&E would need to reinforce its transmission system. At a summer peak demand level of 155 megawatts (MW)—which is a less than 7- percent increase over the current peak demand level of 147 MW—a single outage of the Green Valley-Rob Roy Power Line section would result in the Green Valley-Camp Evers 115 kV Power Line loading up to 100 percent of its summer emergency rating. A single outage of the Green Valley-Camp Evers 115 kV Power Line would result in the Green Valley-Rob Roy Power Line section loading up to 98 percent of its summer emergency rating. If either of these scenarios were to occur, PG&E would be in violation of North American Energy Reliability Corporation transmission system reliability criteria, which does not allow equipment overloads for an outage of a single element in the transmission system.
At that point, PG&E would have the following three options to help reinforce its transmission system:
reconductor the existing two 115 kV transmission lines (note this would not provide equivalent system benefits as the proposed Project);
install generation in the area, which would be available during evening peak demand periods; or
install large utility-scale energy storage facilities in the area, requiring the substantial expansion of an existing substation or the construction of a new substation along the alignment.
Implementation of either option 2 or 3 would still necessitate future replacement of the existing conductors on the 115 kV lines.
Also note that there are several potential complications with reconductoring the approximately 25.9 circuit miles comprising the two existing 115 kV lines. The first complication is that the Green Valley-Rob Roy Power Line section is located close to a gas transmission pipeline for more than 4 miles of its length. A major upgrade in the electric transmission line conductor could require replacement of the existing wood pole structures of the line with tubular steel poles (TSPs). Per PG&E’s engineering guidelines, that would necessitate moving the electric transmission line more than 10 feet away from the gas pipeline. This would significantly increase the reconductoring cost and the number of trees that would need to be removed to accommodate the relocated line.
The second complication is that there are several sensitive habitat locations for the Santa Cruz long-toed salamander along the Green Valley-Rob Roy Power Line section, which would be disturbed by the activities associated with construction in this area.
NOPOC Comment
Unsubstantiated response – It is noted that the question states “as demand increases” and it has not been accepted as a given that demand will increase. No evidence has been submitted to substantiate this growth and there is significant data available indicating that energy use in the San Francisco Bay Area and Santa Cruz county is stable to decreasing therefore it is requested that PG&E provide definitive data supporting any claims of growing demand.
Inconsistent response – As part of the third sub-optimal action which starts “Third, PG&E might have to disable the automatic restoration features at Rob Roy Substation if the STATCOM is out of service during a summer peak demand period.” PG&E states they ‘might’ have to disable… if , without indicating what conditions would necessitate this action. Saying they ‘might’ is implying they maybe they do disable automatic restoration and maybe they do not if STATCOM is out of service. This answer in incomplete without specifying these conditions.
Furthermore, this section refers consistently to a concurrent or simultaneous failure in two separate systems. However, in PG&E own response to Data Request #9 Question #3 they state a “ double-circuit outage caused by a severe event such as a wildfire could still occur, but such events should be very infrequent.” One has to accept that a double circuit outage has the same likelihood as a simultaneous failure of a circuit and some other separate system such as STATCOM. Making it “very infrequent” and therefore not an issue.
Unsubstantiated response – Again, PG&E makes reference to “area loads continue to grow, PG&E would need to reinforce its transmission system” without any evidence to back up this claim. It can be equally claimed that as area loads decrease the need for this project is eliminated.
Unexplored alternative – None the less, presuming that PG&E becomes in violation of “North American Energy Reliability Corporation transmission system reliability criteria” they state they would have three options:
The first “potential complication” is that a “major upgrade in the electric transmission line conductor could require replacement of the existing wood pole structures of the line with tubular steel poles (TSPs).” As this ‘could’ be needed PG&E should include explanation and documentation as to what conditions would require this and what might be done to mitigate these conditions to allow the potential new conductor to be placed on the existing wood poles.
The second “potential complication” is that “there are several sensitive habitat locations for the Santa Cruz long-toed salamander along the Green Valley-Rob Roy Power Line section, which would be disturbed by the activities associated with construction in this area.” However, this is exactly true if they perform the proposed project and yet PG&E does not see any issues with sensitive habitat locations in that case.
Under the No Project Alternative, the project would not be implemented. In this case, would PG&E implement some type of system alternative as a temporary fix as demand increases? Please provide a description of what this system alternative would be, if applicable. If PG&E could/would not make any other changes, please explain why and the consequences of not making any changes to reliability, growth, etc.
PG&E Response
…..Third, PG&E might have to disable the automatic restoration features at Rob Roy Substation if the STATCOM is out of service during a summer peak demand period. This action would be necessary to protect against potential overload problems, should there be overlapping outages of the STATCOM and the Green Valley-Rob Roy Power Line section. Consequently, an outage of the line between Green Valley and Paul Sweet substations would result in an extended outage to Rob Roy Substation. Service restoration for some of the Rob Roy Substation load would be conducted manually by system operators, depending on system conditions. However, if the Green Valley-Rob Roy Power Line section is out during a summer peak demand period, PG&E system operators might need to immediately drop Rob Roy Substation if the STATCOM also goes out.
Note as well that as area loads continue to grow, PG&E would need to reinforce its transmission system. At a summer peak demand level of 155 megawatts (MW)—which is a less than 7- percent increase over the current peak demand level of 147 MW—a single outage of the Green Valley-Rob Roy Power Line section would result in the Green Valley-Camp Evers 115 kV Power Line loading up to 100 percent of its summer emergency rating. A single outage of the Green Valley-Camp Evers 115 kV Power Line would result in the Green Valley-Rob Roy Power Line section loading up to 98 percent of its summer emergency rating. If either of these scenarios were to occur, PG&E would be in violation of North American Energy Reliability Corporation transmission system reliability criteria, which does not allow equipment overloads for an outage of a single element in the transmission system.
At that point, PG&E would have the following three options to help reinforce its transmission system:
reconductor the existing two 115 kV transmission lines (note this would not provide equivalent system benefits as the proposed Project);
install generation in the area, which would be available during evening peak demand periods; or
install large utility-scale energy storage facilities in the area, requiring the substantial expansion of an existing substation or the construction of a new substation along the alignment.
Implementation of either option 2 or 3 would still necessitate future replacement of the existing conductors on the 115 kV lines.
Also note that there are several potential complications with reconductoring the approximately 25.9 circuit miles comprising the two existing 115 kV lines. The first complication is that the Green Valley-Rob Roy Power Line section is located close to a gas transmission pipeline for more than 4 miles of its length. A major upgrade in the electric transmission line conductor could require replacement of the existing wood pole structures of the line with tubular steel poles (TSPs). Per PG&E’s engineering guidelines, that would necessitate moving the electric transmission line more than 10 feet away from the gas pipeline. This would significantly increase the reconductoring cost and the number of trees that would need to be removed to accommodate the relocated line.
The second complication is that there are several sensitive habitat locations for the Santa Cruz long-toed salamander along the Green Valley-Rob Roy Power Line section, which would be disturbed by the activities associated with construction in this area.
NOPOC Comment
Unsubstantiated response – It is noted that the question states “as demand increases” and it has not been accepted as a given that demand will increase. No evidence has been submitted to substantiate this growth and there is significant data available indicating that energy use in the San Francisco Bay Area and Santa Cruz county is stable to decreasing therefore it is requested that PG&E provide definitive data supporting any claims of growing demand.
Inconsistent response – As part of the third sub-optimal action which starts “Third, PG&E might have to disable the automatic restoration features at Rob Roy Substation if the STATCOM is out of service during a summer peak demand period.” PG&E states they ‘might’ have to disable… if , without indicating what conditions would necessitate this action. Saying they ‘might’ is implying they maybe they do disable automatic restoration and maybe they do not if STATCOM is out of service. This answer in incomplete without specifying these conditions.
Furthermore, this section refers consistently to a concurrent or simultaneous failure in two separate systems. However, in PG&E own response to Data Request #9 Question #3 they state a “ double-circuit outage caused by a severe event such as a wildfire could still occur, but such events should be very infrequent.” One has to accept that a double circuit outage has the same likelihood as a simultaneous failure of a circuit and some other separate system such as STATCOM. Making it “very infrequent” and therefore not an issue.
Unsubstantiated response – Again, PG&E makes reference to “area loads continue to grow, PG&E would need to reinforce its transmission system” without any evidence to back up this claim. It can be equally claimed that as area loads decrease the need for this project is eliminated.
Unexplored alternative – None the less, presuming that PG&E becomes in violation of “North American Energy Reliability Corporation transmission system reliability criteria” they state they would have three options:
- reconductor the existing two 115 kV transmission lines
- install generation in the area
- install large utility-scale energy storage facilities in the area
The first “potential complication” is that a “major upgrade in the electric transmission line conductor could require replacement of the existing wood pole structures of the line with tubular steel poles (TSPs).” As this ‘could’ be needed PG&E should include explanation and documentation as to what conditions would require this and what might be done to mitigate these conditions to allow the potential new conductor to be placed on the existing wood poles.
The second “potential complication” is that “there are several sensitive habitat locations for the Santa Cruz long-toed salamander along the Green Valley-Rob Roy Power Line section, which would be disturbed by the activities associated with construction in this area.” However, this is exactly true if they perform the proposed project and yet PG&E does not see any issues with sensitive habitat locations in that case.
Question #8b
For Alternative 4D (Undergrounding Cox Road, Day Valley Road, and McDonald Road Segments), please provide the following information:
b. Provide a rationale for the location of the underground vaults – can the vaults be moved to a location where fewer trees would be impacted?
PG&E Response
…..At each riser structure, it is recommended that a vault be installed within 100 feet of the riser structure. This allows a cable splice near the riser structure in the event of a termination failure. The vaults would not have splices within them during construction, nor would they be used to pull cable. However, they are designed to facilitate pulling and splicing at a later date, if needed.…..
NOPOC Comment
Unsubstantiated response – According to this, the plan is for 4 vaults taking land from 4 different properties and yet they only plan on using 2 vaults or 50% of them. While planning for potential failures is admirable, in this case they are overbuilding by 100%, twice what they need which seems excessive given the circumstances. Furthermore, it implies that PG&E might already have plans for upgrading this system once it is completed.
For Alternative 4D (Undergrounding Cox Road, Day Valley Road, and McDonald Road Segments), please provide the following information:
b. Provide a rationale for the location of the underground vaults – can the vaults be moved to a location where fewer trees would be impacted?
PG&E Response
…..At each riser structure, it is recommended that a vault be installed within 100 feet of the riser structure. This allows a cable splice near the riser structure in the event of a termination failure. The vaults would not have splices within them during construction, nor would they be used to pull cable. However, they are designed to facilitate pulling and splicing at a later date, if needed.…..
NOPOC Comment
Unsubstantiated response – According to this, the plan is for 4 vaults taking land from 4 different properties and yet they only plan on using 2 vaults or 50% of them. While planning for potential failures is admirable, in this case they are overbuilding by 100%, twice what they need which seems excessive given the circumstances. Furthermore, it implies that PG&E might already have plans for upgrading this system once it is completed.