VERMONT SYSTEM PLANNING COMMITTEE
September xx, 2012
Mrs. Susan Hudson, Clerk
Vermont Public Service Board
112 State Street
Montpelier, VT 05620-2701
RE:
Docket 7081: Investigation into Least-Cost Integrated
Resource Planning for VELCO’s Transmission System—
Follow-up on Board’s order of 1/30/2012
Dear Mrs. Hudson:
The purpose of this letter is to submit to the Public Service Board the revised Non-Transmission
Alternatives (NTA) Screening Form utilized by the Vermont System Planning Committee and the
Vermont utilities to identify reliability deficiencies that require full NTA analysis. This filing also
includes the definitions of the terms “impracticable” and “uneconomic” as used in the context of the
NTA Screening Tool.
History
On 1/30/2012, the Board issued an order approving some VSPC-proposed amendments to the
Docket 7081 Memorandum of Understanding (MOU), modifying some amendments, and placing
additional conditions on the parties. Among these conditions was a requirement that:
2. Within six months of the date of this Order, the non-transmission alternatives
(“NTA”) screening tool shall be updated and filed with the Board, in accordance with the
process set forth in paragraph 21 of the MOU. If, despite good-faith efforts, the VSPC has not
completed the revisions to the NTA screening tool within six months, the Parties must file a
status report on the actions and efforts to date on completing revisions to the NTA
screening tool with an estimate as to when the revisions will be completed and final.
3. The parties, through the VSPC process outlined in Paragraph 21 of the MOU, shall
further define the terms “impracticable” and “uneconomic” in the context of revising the
NTA screening tool. These definitions shall be filed with the Board by July 31, 2012, for the
Board’s approval. Parties shall have two weeks from the date that the definitions are filed to
submit comments on the definitions. (PSB Docket 7081 order approving MOU amendments,
1/30/2012, p. 12)
On July 30, 2012, the VSPC filed a status report with the Board describing the process underway at
the time to revise the screening form and define the terms “impracticable” and “uneconomic.” The
status report requested additional time for the VSPC to make the required filings by October 1,
2012.
At its quarterly meeting September 12, 2012, the VSPC made final changes to the screening form
and definitions, and approved the submission of this filing. The definitions are incorporated into
this letter below. The revised NTA Screening Tool is attached.
366 PINNACLE RIDGE ROAD RUTLAND, VT
PHONE 802.773.9161 FAX 802.770.6440
Mrs. Susan Hudson
September xx, 2012
Page 2.
Definition of “uneconomic” in the context of the revised NTA Screening Form
In the context of the revised NTA Screening Form, “uneconomic” is defined by step 4. Specifically,
and for screening purposes only, alternatives to a transmission upgrade are considered to be
uneconomic when:
The likely reduction in costs from the potential elimination or deferral of all or part of the
upgrade is less than $2.5 million.
This definition of uneconomic is informed by the following considerations:
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The NTA Screening Form is being revised as part of the PSB-approved VSPC process reform.
Among the primary goals of process reform is to shift VSPC efforts away from excess
process and towards the successful implementation of non-transmission alternatives. The
change of the relevant thresholds from the present NTA Screening Form ($2 million cost /
$1 million reduction) to the proposed threshold of $2.5 million savings is intended to help
focus VSPC efforts and NTA analyses on those projects that have the potential to provide the
greatest benefit to Vermont. The VSPC notes that a comprehensive NTA analysis is very
resource intensive and can cost in the hundreds of thousands of dollars.
Not all NTA analyses result in the identification of viable alternatives to transmission
upgrades. Given this risk, it is appropriate to focus resources and dollars on those projects
that have the potential to provide the greatest benefits.
The $2.5 million threshold for the reduction in upgrade costs in step 4 of the NTA Screening
Form does not account for the costs of the NTAs themselves, captures only the expected
savings to the cost of the transmission project, and as such is a conservative screen.
Definition of “impracticable” in the context of the revised NTA Screening Form
The definition of the term “impracticable” is incorporated as Question 1 of the NTA Screening Form.
The form defines a proposed project as “impracticable” if it meets any one of the following criteria:
a. Project is needed for a redundant supply to a radial load; or
b. Project is maintenance-related, addressing asset condition, operations, or safety; or
c. Project addresses transmission performance, e.g., addition of high-speed protection or a
switch to sectionalize a line; or
d. Project is needed to address stability or short circuit problems.1
1 “Stability”
refers to the ability of a power system to recover from any disturbance or interruption. Instability
can occur when there is a loss of synchronism at one or more generators (rotor angle stability), a significant
loss of load or generation within the system (frequency stability), or a reactive power deficiency (voltage
stability). Stability problems are influenced by system parameters such as transmission line lengths and
configuration, protection component type and speed, reactive power sources and loads, and generator type
and configuration. Due to the nature of instability, non-transmission alternatives involving addition of
generation or reduction of load will not solve these problems.
Mrs. Susan Hudson
September xx, 2012
Page 3.
In addition to the above criteria, the screening form provides an opportunity for a utility to
identify other technical reasons why NTAs are impracticable. In the event that the “other”
category is employed, the responsible utility must provide a detailed, written justification
for the classification, which must be reviewed by the VSPC.
The revised screening tool was developed through extensive collaboration within the VSPC
during the past eight months. We welcome any questions the Board may have about the
resulting product.
Respectfully submitted,
Deena L. Frankel, Secretary
Vermont System Planning Committee
Attachment: NTA Screening Form
cc.
VSPC
Docket 7081 service list