Sea turtles, sturgeon, wetlands and shipping accidents — transmission developers seeking the contract to fix the Artificial Island stability problem invoked all of them and more last week in arguments against their competitors.

All five of the development teams identified as finalists filed comments with PJM, the last chance for contestants to make their case before PJM planners announce their selection next Monday.

State regulators also weighed in, as did PSEG Nuclear LLC, the operator of the Salem and Hope Creek nuclear plants at Artificial Island.

North or South

Each of the finalists has proposed a 500-kV line paralleling an existing 500-kV line to Red Lion, Del., including Delmarva Power’s Delaware River crossing north of Artificial Island.

Supporters say using an existing path could result in less public opposition than a new southern overhead crossing envisioned in 230-kV proposals by LS Power and Dominion. The two companies and Transource Energy, a joint venture of American Electric Power and Great Plains Energy, have also proposed southern routes with submarine crossings.

Environmental Concerns

But the New Jersey Board of Public Utilities said the developers of the 500-kV proposals might have difficulty winning regulatory approvals because the path would cross the Supawna Meadows National Wildlife Refuge, the Alloway Creek Watershed Wetland Restoration Site and the Abbotts Meadow and Mad Horse Creek Wildlife Management Areas.

The BPU noted that the Susquehanna to Roseland 500-kV transmission line was delayed for three years because of problems obtaining approvals to cross federal lands even though it had been designated for “rapid response” by the Interior Department. The project “resulted in protests, delays and costs well above initial estimates for mitigation,” BPU said.

“PJM’s analysis of the five projects in the Red Lion 500-kV option group recognizes negative impacts for all as to wetlands and land permitting but only `some impacts’ as to public opposition,” the BPU continued. “In our experience, that is an optimistic view of the likely public response to these projects.”

LS Power agreed, citing an opinion from its outside counsel concluding that permitting of the northern route “is likely not obtainable,” due in part to the existence of the southern crossing options.

Transource argued that its submarine crossing proposal was preferable to an overhead line, noting the potential for shipping accidents, such as a 1987 crash that resulted in a nine-month outage to the Delmarva Power crossing. Transource also said an overhead crossing would require towers about 100 feet tall, which could increase the likelihood of public opposition.

PSE&G, which proposed a northern route, countered that the submarine crossing proposed for the southern route could impact a submerged dike “normally considered historic in nature,” an artificial reef created from sunken World War I ships (Sunken Ship Cove) or habitats for protected species, “including the shortnose sturgeon, the Atlantic sturgeon, the hawksbill sea turtle, the loggerhead sea turtle, Kemp’s ridley sea turtle and the leatherback sea turtle.”

Order 1000 Implications

Even before making a selection decision that is certain to disappoint all but one of the finalists, PJM is already receiving criticism for how it has managed the competition — the first in PJM under the Federal Energy Regulatory Commission’s Order 1000.

The Delaware Public Service Commission complained that the proposed cost allocation for the 230-kV solutions “displayed neither logic nor fairness” in assigning all of the cost to the Delmarva Power zone. In contrast, the cost of the 500-kV proposals would be spread among two dozen transmission zones and merchants. (See Delaware Unhappy with Artificial Island Cost Allocation.)

The commission requested PJM planners provide details on the distribution factor (DFAX) analyses for the 230-kV and 500-kV solutions and “explain how a transmission project to alleviate an operational issue in one transmission zone could be solely the cost responsibility of a different transmission zone.”

The Exelon-Pepco team criticized PJM planners’ modifications to developers’ plans, which included the addition of static VAR compensators (SVCs) to all projects and the removal from the Dominion and PSEG proposals of a second Hope Creek-to-Salem tie line. (See Dominion, PSE&G Proposals Gain in Artificial Island Race.) “The tweaking of proposals eliminates the competitive nature intended by the FERC Order 1000 process,” said Exelon-Pepco.

Transource said PJM should make its decision based on the merits of the projects as proposed rather than comparing them after PJM’s modifications.

“This will send a strong signal to developers that the relative quality of their work will be rewarded in the PJM process and that the burden is on the developers, not PJM, to get the details right,” Transource said. “It would set a concerning precedent if PJM decided that none of the proponents `sponsored the selected project,’ based on the modifications made by PJM, and designated the project to the incumbent transmission owner(s).”

Nuclear Operator’s Concerns

PSEG Nuclear also criticized PJM planners’ decision to use SVCs, saying they have never been used to correct “transient angular stability” and would pose “unknown and potentially challenging regulatory risks.”

The company noted that Artificial Island is the “second-largest nuclear installation in the country with well-known stability challenges.”

“The worst case consequences that will result from a contingency-induced stability event coincident with an SVC failure include loss of all offsite power to the three co-located nuclear units at AI as well as potential collateral impacts to the offsite sources at neighboring regional nuclear plants,” the company said. “These consequences will influence the [Nuclear Regulatory Commission] to require an in-depth review.”