East Avenue and Queen City Substation Improvement Project

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1 East Avenue & Queen City Substation Improvement Project VIA FIRST CLASS MAIL August 29, 2017 Judith C. Whitney, Clerk Vermont Public Utility Commission 112 State Street, 4 th Floor Montpelier, VT Re: East Avenue and Queen City Substation Improvement Project Certificate of Public Good Section 248J Permit Process 45-Day Notice of Project Filing Dear Judy: This letter and enclosed information describe the Vermont Electric Power Company Inc. and Vermont Transco LLC (collectively VELCO ) proposed East Avenue and Queen City Substation Improvement Project (the Project ), which includes upgrades to VELCO s existing facilities in the cities of Burlington and South Burlington, and consists of upgrading VELCO s East Avenue Substation located at 74 University Road in Burlington and VELCO s Queen City Substation located at 10 Central Avenue in South Burlington. We anticipate filing our formal petition with the Vermont Public Utility Commission (PUC) on October 16, 2017, requesting a Certificate of Public Good to construct the Project. The state permitting process requires VELCO to provide notice to the cities of Burlington and South Burlington and other stakeholders at least 45 days prior to a formal filing with the PUC 1. For your information, attached to this letter, is a Project overview and substation site layouts. Before the Project is filed with the PUC, VELCO will conduct informal discussions to address concerns you may have about the impact of the Project. VELCO will hold a public meeting on September 19, to share information, collect feedback and address concerns from affected communities. You will also receive a notification of our petition when it is filed with the PUC. Please note the Planning Commissions may make recommendations within 40 days of the submission of this 45-day notice, which date is October 9, So that VELCO has sufficient time to incorporate your feedback prior to the October 16, 2017 anticipated filing date, VELCO is requesting that comments be submitted by October 3, Planning commissions also have the right to make revised recommendations within 45 days after the date the Petition is filed with the PUC, if the Petition contains new or more detailed information that was not previously included in these plans. 1 The process is governed by Public Utility Commission Rule 5.400, which can be viewed on the PUC's website at 2 Public meeting will begin at 6 p.m. September 19 at Burlington Electric Department s Spark Room at 585 Pine Street in Burlington, VT P a g e

East Avenue & Queen City Substation Improvement Project For additional information regarding the PUC processes, including your right to participate in the proceeding, please refer to the "Citizen s

2 East Avenue & Queen City Substation Improvement Project For additional information regarding the PUC processes, including your right to participate in the proceeding, please refer to the "Citizen s Guide to the Vermont Public Service Board's Section 248 Process. 3 The Citizens Guide can be found at For information on public participation through public comment or intervention please go to As the Project is still in the design phase, we will continue discussions and expect to receive feedback on this Project from various stakeholders. Please note that we expect to make the formal filing with the PUC on October 16, If you are interested in a presentation on this Project, have comments or want further information, please contact Scott Mallory, Project Manager, at or smallory@velco.com. So that we may better address any questions or concerns you may have, please contact us before October 3, The documents that accompany this letter have been electronically filed using epuc. Sincerely, Scott Mallory, Project Manager Enclosures: Attachment A Project Overview Attachment B East Avenue Substation Overall Ortho Plan Attachment C Queen City Substation Overall Ortho Plan 3 As of July 1, 2017, the Vermont Public Service Board s new name is the Vermont Public Utility Commission. The Citizen s Guide has not yet been updated to reflect the name change P a g e

3 East Avenue and Queen City Substation Improvement Project Overview Introduction Vermont Electric Power Company Inc. (VELCO) was formed in 1956 when local distribution utilities joined together to create the nation's first statewide "transmission only" company in order to provide access to clean hydro power and build and maintain the state s high-voltage electric transmission grid. VELCO constructs, owns and operates most of Vermont s in-state, high-voltage transmission grid (essentially 115 kv and above), that connects Vermont to the regional and national electric power supply system. VELCO s network also provides the electric supply to Burlington Electric Department (BED) and Vermont s 15 other local distribution utilities. The proposed East Avenue and Queen City Substation Improvement Project (the Project) addresses system deficiencies that compromise electric reliability under certain circumstances. The Project is located at VELCO s existing East Avenue Substation in Burlington and Queen City Substation in South Burlington. As is explained in this overview, VELCO expects to file a request with the Vermont Public Utility Commission (PUC) on October 16, 2017, for permission to undertake this Project and, assuming PUC and other approvals are granted, currently plans for the work to be completed and in service by December, This proposed Project overview describes the following: System deficiencies Alternatives evaluated for this Project The Project s description The Project s impact The anticipated Project filing date with the PUC Local and regional planning commissions rights to comment on the Project plans Glossary of italicized terms Description of the system deficiencies Electric energy remains a cornerstone of our local and state economies, our quality of life, and our communities. Households, businesses and public services like schools and hospitals all rely on electricity for communication, lighting, heating, ventilation, and the operation of appliances and equipment. If transmission facilities fail, large geographic areas can lose their electric service. Transmission utilities such as VELCO are required to design, operate and maintain a transmission network according to national and regional reliability standards. VELCO continuously assesses the adequacy of its system to ensure Vermont s transmission network meets national and regional reliability criteria. 1 P a g e

4 VELCO s electric transmission network is connected to its East Avenue Substation, located at 74 University Road in Burlington, and its Queen City Substation, located at 10 Central Avenue in South Burlington. East Avenue Substation is connected to Burlington Electric Department s (BED s) distribution system and Queen City Substation is connected to both BED s and Green Mountain Power s (GMP s) distribution systems, which in turn, provide service to their respective customers. The power grid is a complicated network of transmission and distribution components that work together to deliver safe and reliable power. Recent improvements to the grid have increased the quality and reliability of the power that VELCO is able to deliver. However, as the power grid expanded and grew, and as the topology of the system changed, so did the fault current levels on the system. The fault current is the maximum current available should there be a short circuit, such as a ground fault on the system. These faults can occur for a number of reasons, such as wildlife (squirrels, birds, snakes, etc.), vegetation (tree limbs), weather (wind-blown conductors, lightning, etc.), and structural failure (car driving into a pole). When the fault current reaches or exceeds the capability of the existing infrastructure its electrical ratings system reliability, worker safety and, in some cases, public safety is at risk. Fault current on the system has now reached a level that must be reduced in order to ensure that the ratings on some electrical components of the distribution system are not exceeded. Alternatives evaluated There are several possible methods to mitigate this issue: (1) VELCO can replace the specific electrical components that do not meet the required level of available fault current with components that do; (2) VELCO can install equipment that interrupts the fault current when it does exceed the ratings of the components; or (3) VELCO can install, equipment that reduces the level of fault current. The company evaluated each of these methods to determine the most appropriate solution and concluded that equipment with higher fault current ratings was not available for all the components in question and therefore VELCO did not consider this a viable option. VELCO also determined that the installation of equipment that interrupts the fault current when it does exceed the rating of the components would also result in the interruption of electric service to customers fed from those components. VELCO also deemed this option unacceptable due to the customer impacts it would cause. VELCO evaluated the option of installing equipment that reduces fault current level, namely installing more impedance on the system. This can be done by replacing the three existing 115/13.8 kv transformers at the East Avenue and Queen City Substations with transformers that have a higher impedance, or by installing air core reactors adjacent to these existing transformers. It was determined to be more economical to install the air core reactors rather than replace the transformers. VELCO is proposing to decrease the available short circuit current on the system by installing air core reactors within the existing East Avenue and Queen City Substations. This solution will limit the available fault current on the system to within the electrical ratings of the existing system equipment without reducing the reliability of the power that we deliver. VELCO screened the Project for its potential to be resolved through non-transmission alternatives (e.g., energy efficiency or new generation) using the tool developed by the Vermont System Planning Committee (VSPC). The screening determined that the Project was not a candidate for a non-transmission solution 2 P a g e

5 because the proposed upgrades are being driven by the need to address a short-circuit issue. Thus, nontransmission alternatives could not resolve the present problems at the VELCO East Avenue and Queen City Substations. The screening conclusion was reviewed by the VSPC. Project Description The Project consists of two primary components. Component One Reactor Installation at East Avenue Substation Install two (2), 115 kv, three-phase air core reactor assemblies, each consisting of three (3), single-phase reactors, in a stacked configuration. Each single-phase reactor measures approximately 4 feet tall by 7 feet in diameter. Install two (2) reactor stands (one for each reactor assembly). Install two (2) bus support stands (one for each reactor assembly). Install concrete foundations to support the reactor and bus support stands Modify existing bus work as required, to integrate the new reactors into the electrical circuit. Component Two Reactor Installation at Queen City Substation Install one (1) 115 kv, three-phase reactor assembly, consisting of three (3), single-phase reactors, in a stacked configuration. Each single-phase reactor measures approximately 4 feet tall by 7 feet in diameter. Install one (1) reactor stand. Install two (2) conductor support stands. Install concrete foundations to support the reactor and conductor support stands. Movement of conductors outside of the fence to inside the fence to connect to the reactor assembly. Assuming regulatory approval, construction is expected to start in the spring of 2018 with a targeted completion date of December Although the engineering for this Project is not yet complete, the attachments depict preliminary design layouts for each of the substations. During construction of the proposed solution at Queen City Substation, VELCO will also take the opportunity to improve the physical security of that substation by extending the existing fence approximately 10 feet outside the existing control building in the southwest corner of the substation, as shown in the attached drawing. VELCO s new standard for security is to install a physical security perimeter around all substation infrastructure. The new perimeter will consists of an eight-foot chain link fence, with motion detection sensors that are able to detect when someone touches the fence, topped with one foot of barbed wire. Currently, the control building at Queen City Substation serves as the physical security perimeter without a fence. An extension of the fence around the control building will help us maintain a high level of safety and guard against any potential vandalism or terrorism. 3 P a g e

6 Project s impacts Aesthetics Both the Vermont Natural Resources Board and the PUC utilize the so-called Quechee Lakes standard [set forth in the decision Quechee Lakes Corporation, #3EW0411-EB and #3O439- EB (1986)] to guide their aesthetics analysis. According to the Quechee Lakes standard, regulators must first determine whether a project will have an adverse impact on aesthetics and scenic and natural beauty. A project has an adverse impact if it is out of character with its surroundings. Specific factors that regulators use to make this evaluation include the nature of the project surroundings, the compatibility of the project design with those surroundings, the suitability of the project colors and materials with the immediate environment, the visibility of the project, and the impact of the project on open space. If regulators conclude that a project will have an adverse effect, the next step in the two-part test is to determine whether the adverse effect of the project is undue. The adverse effect is considered undue when regulators find that any one of the following questions is answered yes: (1) Does the project violate a clear, written community standard intended to preserve the aesthetics or scenic beauty of the area? (2) Have the applicants failed to take generally available mitigating steps which a reasonable person would take to improve the harmony of the project with its surroundings? (3) Does the project offend the sensibilities of the average person? Is it offensive or shocking because it is out of character with its surroundings or significantly diminishes the scenic qualities of the area? For transmission upgrades, the PUC s aesthetic analysis, however, does not end with the results of the Quechee test. In addition, the PUC s aesthetic assessment is significantly informed by overall societal benefits of the project. PUC Docket No. 6860, Order of 1/28/05 (footnotes omitted). VELCO s aesthetic consultant, T. J. Boyle Associates, LLC (TJB), a landscape architecture and planning firm, has reviewed the preliminary design plans and performed a visual analysis of the areas of the proposed Project upgrades. The findings of this analysis led them to conclude that the proposed Project will not have an adverse effect on the scenic or natural beauty or aesthetics of the area. This is due to the fact that, while visibility in areas nearby to the East Avenue substation will be possible, the Project will generally not be visible from other publicly accessible locations. The Project at the Queen City substation is not expected to be visible from the roadside due to existing vegetative screening. Where it is visible, the proposed reactor equipment is compatible with the existing substations, and would not constitute a major change to the existing character. Due to the lack of significant Project visibility, and its compatibility with the existing permitted substations, the second part of the Quechee Analysis was not administered. In conclusion, TJB believes this Project meets the Quechee Test insofar as its impact on aesthetics will not be unduly adverse. Noise VELCO s noise consultant, Resource Systems Group, Inc. (RSG) has measured sound levels at the both the existing East Avenue Substation and the existing Queen City Substation and has assessed the potential noise impacts associated with the Project. A complete engineering noise analysis will be provided as part of the Project s filing with the PUC. Preliminary findings from RSG indicate that under normal operating 4 P a g e

7 conditions there will be a negligible change in sound levels at the nearest residence and under high-load conditions there will be no more than a 2 dba increase in sound levels at the nearest residence at either of the substations and below standard noise limits imposed by the PUC. Transportation The Project poses no long-term traffic impacts in Burlington or South Burlington. VELCO anticipates only minor, short duration traffic impacts, if any, due to deliveries of equipment and material to the substations during the construction period (expected to be from spring 2018 to December 2018). Such deliveries will use existing roads with vehicles that are commonly used on public roads. During delivery of any large equipment, VELCO will employ the services of traffic control personnel to manage traffic flow. Right of the local and regional planning commissions to comment on the Project plans Section 248(f) of Title 30 of the Vermont Statutes Annotated provides that municipal and regional planning commissions are entitled to receive this notice and make recommendations to the PUC and to the Applicant within 40 days of the submission of this 45-day notice to the planning commissions, which date is October 9, So that VELCO has sufficient time to incorporate your feedback prior to the October 16, 2017 anticipated filing date, VELCO is requesting that comments be submitted by October 3, Planning commissions also have the right to make revised recommendations within 45 days after the date the Petition is filed with the PUC, if the Petition contains new or more detailed information that was not previously included in these plans. Recommendations made to the PUC under Section 248(b)(1), or the lack of such recommendations, do not preclude municipal and regional planning commissions from presenting evidence during technical hearings if they exercise their right to appear as a party under Section 248(a)(1)(G) & (H). For additional information regarding the PUC processes, including your right to participate in the proceeding, please refer to the "Citizen s Guide to the Vermont Public Service Board s Section 248 Process. * The Citizens Guide can be found on the PUC s website here: The PUC s website ( also includes a public participation section that contains information on the PUC process. As the Project is still in the design phase, VELCO will continue discussions and expect to receive feedback on this Project from various stakeholders. Please note that the PUC Petition and filing anticipated for October 16, 2017, as well as other pertinent Project updates, will be posted on VELCO s website at: To request a presentation on this Project, make comments or request further information, please contact Scott Mallory, Project Manager, at or smallory@velco.com. * As of July 1, 2017, the Vermont Public Service Board s new name is the Vermont Public Utility Commission. The Citizen s Guide has not yet been updated to reflect the name change. 5 P a g e

8 Glossary of terms Air core reactors are a type of electrical equipment that consists of a coil of wire. They contain no oil and are covered in epoxy. They are used to reduce the short circuit current to levels within the rating of components of the power system. Bus refers to the arrangement of overhead bus bar and associated switching equipment in a substation. Distribution is the final stage in the delivery of electric power. It carries electricity from the transmission system to individual consumers. Vermont has 17 local distribution companies that include municipal utilities like Burlington Electric Department, cooperatives like Vermont Electric Coop, and one large investor-owned utility, Green Mountain Power. Impedance is the effective resistance of an electric circuit or component to alternating current. Party status means the PUC has determined that a person or entity has an interest in the outcome of a case before the commission and can participate fully in hearings, filings and other aspects of the legal proceeding. Formal parties may provide testimony and participate in evidentiary hearings. Hearings. All formal parties must follow the Commission's procedural rules, and are subject to the orders of the Commission. Petition is the formal legal filing. In this case, it is the formal application and supporting materials filed with the PUC to request approval in the form of a Certificate of Public Good to construct the proposed substation upgrades. Transmission refers to the part of the electric system that operates at high voltage and carries large amounts of electricity from generation plants to the lower-voltage distribution system, which supplies electricity to local areas. Vermont Public Utility Commission (PUC) was formerly called the Vermont Public Service Board. The name was changed by the Vermont legislature effective July 1, P a g e

Ascutney Substation Upgrade

Ascutney Substation Upgrade VIA MAIL February 18, 2011 Chair Town of Weathersfield Planning Commission P.O. Box 550 Ascutney, VT 05030 Re: Ascutney Substation Upgrade Certificate of Public Good Section