Craig Taborsky Testimony

Q.        MR. TABORSKY, PLEASE STATE YOUR NAME, OCCUPATION AND CURRENT POSITION.

A.        My name is S. Craig Taborsky.  I am currently the Transmission/Generation Engineer for the Maryland Public Service Commission (PSC), located at William Donald Schaefer Tower, 6 St. Paul Street, Baltimore, Maryland 21202-6806.  A statement of my educational background and professional qualifications is provided as Attachment 1.

Q.        WHAT IS THE PURPOSE OF THIS TESTIMONY?

A.        The purpose of this testimony is to discuss the reliability and stability of the electric system with the addition of the project proposed by Catoctin Power, LLC (“Catoctin” or “Applicant”) a division of Sempra Energy, Inc.   Reliability and stability are two factors the Commission is required to consider prior to issuing a certificate of public convenience and necessity (“CPCN”) pursuant to Section 7-207 of the Public Utility Companies Article of the Annotated Code of Maryland.

Q.        HAVE THE EFFECTS OF THIS PROJECT ON THE RELIABILITY AND STABILITY OF THE ELECTRIC SYSTEM IN MARYLAND BEEN DETERMINED?

A.        Not at this time.  PJM determines the project’s effects on reliability and stability by including the project in its modeling of the electric system.  Prior to putting the project in service, the Applicant must comply with PJM’s direct connection requirements and network upgrades identified in any Interconnection Agreement between Catoctin and PJM or a transmission owner.    If Catoctin complies with all of PJM’s requirements, the project should not impact the reliability and stability of the electric system in Maryland.

Q.        DO YOU HAVE A RECOMMENDATION ?

A.        Yes.  If the application for a CPCN is granted, I recommend the following conditions:

1)     Prior to putting any portion of the project in service, the applicant shall file with the Commission  a listing of the transmission system improvements required by PJM and certification that the improvements have been completed;  and

2)     Prior to putting any portion of the project in service, the applicant shall file with the Commission a listing of the interconnection requirements of the interconnecting transmission line owner and certification that the interconnection requirements have been met.

Catoctin should be required to make such filings at least thirty (30) days prior to putting any portion of the project in service.

Q.        WHAT IS THE APPLICANT PROPOSING?

A.        The proposed project consists of two 161 MW combustion turbine (CT) generators and one 318 MW steam turbine (ST), for a maximum total generating capability of 640 MW.  The units will generate at 18.0 kV using natural gas for fuel.  Catoctin will construct the Project on the Eastalco Works industrial complex (“Eastalco Complex”) in Frederick County.  Catoctin intends to connect the Project to existing dual 230 kV transmission lines at the Eastalco site via an existing on-site substation.    The existing dual 230 kV transmission lines are connected through the Doubs substation to the transmission system of Allegheny Power (“Allegheny”), which is part of the PJM Interconnection or grid.  Construction of the project is scheduled to begin in the spring of 2005 and conclude in the summer of 2007.   According to PJM’s report from the Transmission Expansion Advisory Committee (TEAC) dated June 21, 2004, the project will be online during the second quarter of 2007.

Q.        PLEASE DESCRIBE THE PROCESS BY WHICH GENERATORS INTERCONNECT TO THE GRID. 

A.        A potential interconnection customer, such as Catoctin, must comply with the PJM Open Access Transmission Tariff (“OATT”), as approved by the Federal Energy Regulatory Commission (“FERC”).  PJM organizes generation interconnection requests into clusters, or queues, for the purpose of identifying required transmission system improvements.   Upon the receipt of an interconnection request, PJM conducts sequential studies, provided the potential customer meets certain requirements to retain its queue position.  The studies are dependent on other projects within the geographical area.  The studies performed by PJM are the Feasibility Study, the Impact Study and the Facilities Study.  The studies are intended to determine what system enhancements are necessary to accommodate the interconnecting generator and maintain the reliability and stability of the transmission system. 

Q.        PLEASE DESCRIBE THE FEASIBILITY STUDY.

A.         Computer modeling of the electric system is used by PJM to evaluate the feasibility of new generation with respect to compliance with the East Central Area Council (“ECAR”) of the North American Electric Reliability Council (“NERC”) reliability and stability criteria.  Short circuit calculations are performed to ensure that circuit breaker capacities are not exceeded.  This report identifies direct connection requirements and network impacts.  Once the Feasibility Study is completed, a Feasibility Report is issued.  In order to maintain its queue position, the applicant must then execute an Impact Study Agreement.

 Q.        PLEASE DESCRIBE THE IMPACT STUDY.

A.         The Impact Study is a continuation of the Feasibility Study with the inclusion of a more detailed analysis.  Capacity Resources are evaluated for load deliverability and generation deliverability.  Load deliverability is a measure of the ability to transfer power to the load in a particular sub-area.  Generator deliverability is a measure of the ability to export generation from a sub-area.  Stability is evaluated for critical contingencies.    Short circuit calculations are performed, taking into consideration all elements of the regional plan, to ensure that circuit breaker capacities are not exceeded.  In order to maintain its queue position, the applicant then must execute a Facilities Study Agreement.  By executing the facilities study the potential interconnection customer retains the assigned priority in the PJM queues.

Q.        PLEASE DESCRIBE THE FACILITIES STUDY.

A.        The Facilities Study further defines the construction details and responsibilities for the direct connection requirements and network upgrades and their cost. 

Q.        CAN YOU EXPLAIN WHAT IS MEANT BY A CAPACITY RESOURCE?

A.        A capacity resource provides generation sold in bilateral contracts or through the PJM Capacity market to Load Serving Entities (“LSEs”) to fulfill the LSE’s obligation to serve load under The Reliability Assurance Agreement.  According to PJM’s OATT, an accredited Capacity Resource has Capacity Interconnection Rights commensurate with its size in megawatts.  Capacity Interconnection Rights entitle the holder to deliver the output of a Capacity Resource at the bus where the Capacity Resource interconnects to the transmission facilities.

Q.        IS THE APPLICANT REQUIRED TO SIGN AN INTERCONNECTION AGREEMENT WITH PJM PRIOR TO INTERCONNECTION?

A.        Yes.  An Interconnection Agreement must be executed and filed with FERC.  For a Capacity Resource, the Interconnection Agreement identifies the interconnection and the rights of the Interconnection Customer to participate in the PJM markets as well as the obligations, on the part of the Interconnection Customer, to pay for system enhancements required for the interconnection.

Q.        IS THE APPLICANT REQUIRED TO SIGN AN INTERCONNECTION AGREEMENT WITH THE LOCAL TRANSMISSION OWNER PRIOR TO INTERCONNECTION?

A.        Yes.  The Applicant is required to sign an Interconnection Agreement with the local transmission owner.  This document specifies the system enhancements necessary for the physical and electrical interconnection of the generator to the transmission owner’s system.  The document may also specify requirements related to the operation and maintenance of the system enhancements.  The specifications are dependent upon the standards of the local transmission owner.  However, most of the system enhancements have already been identified during the course of the PJM studies, since the local transmission owner participates in the PJM studies.  This ensures safety and reliability for the local area. If this application for a CPCN is approved, Catoctin would be required to sign an Interconnection Agreement with Allegheny Power

Q.        IN WHICH PJM QUEUE IS THE CATOCTIN PROJECT LISTED?

A.        The project is listed in the following queue:

                        Queue             Name                          MWs               Queue date   

                        G51_W62      Eastalco 230 kV       640                 July 31, 2001

 Q.       WHAT IS THE STATUS OF THE QUEUED PROJECT?

A.        Feasibility and Impact Studies have been completed for queue G51_W62.  The Facilities Study Agreement has been executed.   The Facilities Study is expected to be completed by the end of this year (2004).

Q.        WHAT ARE THE DIRECT CONNECTION REQUIREMENTS FOR THE PROJECT?

A.        The generation project will be interconnected to the transmission system at Eastalco Substation via a single-circuit 230 kV line between the Project site and the Substation.  The Interconnection customer is responsible for construction of all facilities located at the generator site, including line terminal with circuit breaker for the 230 kV line required for Direct Connection to the Eastalco Substation.  Two 230 kV metering packages on the lines between Doubs and Eastalco will also be required.  There may also be changes required in the design of relay coordination with Doubs.

Q.        WHAT ARE THE NETWORK IMPACTS IDENTIFIED IN THE PJM IMPACT STUDY?

A.        The project was studied as a 640 MW capacity resource. Short circuit analysis indicates the need to replace about seven breakers at the Doubs 230kV substation.  The Impact Study also requires upgrades or replacements for about 26 breakers at Dickerson.  The total cost for the Interconnection of the Eastalco G51_W62 project, including the direct connection facilities and all network upgrades, is $11.08 million according to the Impact Study issued May 2003.  This figure is likely to vary depending on additions or deletions of projects in the queues and any changes in the baseline reliability model that may have occurred during the last 18 months.  The Facilities Study is expected to provide an update for these costs.

PJM’s Regional Transmission Expansion Planning Process (“RTEPP”) has identified the need to upgrade the 500/230 kV transformers at the Doubs substation for the year 2007 baseline planning period.   If put into service before 2007, the inclusion of Catoctin’s project in the 2007 baseline reliability study would postpone or eliminate the need to upgrade the transformers at Doubs.  Catoctin may receive a credit for offsetting this cost. 

Q.        DID THE IMPACT STUDY ADDRESS THE ISSUE OF STABILITY OF THE GRID?

A.         Yes.  According to the Impact Study, stability analysis was performed at 2007 light load conditions and for maximum summer generator output.  The range of contingencies evaluated was limited to that necessary to assess expected compliance with ECAR criteria.  As a result of this analysis and to satisfy the transient stability criteria, a special protection scheme is required.  Whenever one of the two 230 kV lines to Doubs goes out of service, it is important that the generator is tripped should the other line go out of service.  As more unit-specific dynamic and transient data become available for a variety of expected operating conditions, future studies may indicate the need for further precautions.

Q.         WHAT BENEFITS WILL THE PROJECT PROVIDE FOR THE ELECTRIC SYSTEM IN MARYLAND?

The project will contribute to future generation adequacy in Maryland and throughout the PJM control area.  Furthermore, the project can be dispatched by the PJM control center for reactive and voltage support at Doubs.  Electrically, EastAlco is a good site for this project due to its proximity to Doubs.   The project may help to alleviate the frequent excessive loading of the 500 kV BlackOak- Bedington Transmission Line which feeds Doubs. 

Economically, the applicant has identified this site as viable in view of the PJM Locational Marginal Prices (“LMP”).  The project fosters the transition to a workable competitive energy market. Depending upon the cost of its generation, the EastAlco project could also help to alleviate congestion costs associated with power flows from West to East through Doubs.

Q.        HAVE THE FEASIBILITY AND IMPACT STUDIES IDENTIFIED THE NEED FOR ADDITIONAL TRANSMISSION LINES?

A.        No.  The application states that the project will be developed without the need to construct off-site transmission lines.  Catoctin intends to connect the project to existing transmission lines on-site via an existing on-site substation which, in turn, is interconnected by dual 230 kV ties to the transmission system of Allegheny Power through Doubs.

Q.        ARE TRANSMISSION ENHANCEMENTS REQUIRED BY AN IMPACT STUDY GUARANTEED TO BE REQUIRED IN THE FUTURE?

A.        No.  PJM’s Impact Study for this project dated May 2003 states that the baseline reinforcements are under review.  PJM is continually re-evaluating the reliability of the grid through its TEAC and RTEPP procedures.  Any changes to the baseline may modify the Impact Study results, which will be reflected in the Facilities Study.  Changes in the status of other projects in the queues may also affect the results. The results of the Impact Study are likely to change, especially since it was issued approximately 18 months ago.  The applicant must continue to execute agreements required by PJM to maintain the queue position for the project; otherwise, the studies will no longer be valid.

Q.        DOES THIS CONCLUDE YOUR TESTIMONY?

A.        Yes.