whomai2u and Schoen ...
Putting the transmission analysis into perspective, it is too complicated technically for a layperson and unlikely others but us will take PREPA to task. Good smokescreen on their part and to eliminate us in Stage 1. However, the price advantage which represents $75 million over Ciro plus added economic benefits with high DC/AC ratio and battery storage, is a different story and should not be in dispute. Our price change was clearly of record and acknowledged by PREPA, yet never used. Xzerta, however, was able to change their price. Also putting that into perspective, why wouldn't PREPA or FOMB want to take into account any project willing to lower their price. My belief is that they should have given notice to all projects of the opportunity to revise their price going into the final round of ranking and even FOMB could have set a price target for approval of any project based on the Fiscal Plan. All a smokescreen.
So the issue at hand is that Montalva should not have been eliminated in Stage 1 and such disqualification was prejudicial to Montalva and ratepayers.
Noteworthy is that the 73 MW limit referenced for elimination comes from the Sargent & Lundy study report of June 2020, where they identify a limit of 73 MW under what is known as an N-1-1 contingency as being the maximum power with no violations before some curtailment of Montalva output would be required assuming the simultaneous outage of two transmission lines and in this case both ends of line 37100 that Montalva is connecting to. The issue is whether using an extreme N-1-1 contingency that might curtail Montalva for up to 7 MW when generating at full power and that at all other times can operate at full power for all N-1 and N-2 contingency cases, is sufficient reason to eliminate Montalva in Stage 1 and not to perform an economic evaluation in Stage 2. Also, the 80 MW came from PREPA as an acceptable project size and not from PBJL. PREPA reduced the size of Montalva from 100 MW to 80 MW in order to meet all of its transmission system criteria. 73 MW was never mentioned and unknown until PBJL located a copy of the S&L report in a filing with PREB. The study report had never been provided to PBJL. The disqualification was subjective and lubricious and based on the combination of extreme events (N-1-1 contingency) that even if they did occur would be of short duration. Further there is no penalty to PREPA unless the total of curtailment exceeds 40 full power hours each year. That would allow for over 457 hours of 7 MW of curtailment at no cost to PREPA, which also assumes Montalva was operating at full power during the time of the curtailment. Given the remote likelihood of an N-1-1 occurrence and the possible costs to PREPA, the elimination of Montalva in Stage 1 is even more ludicrous.
Referencing the Sargent & Lundy report of June 2020,
1. On page 29, 6.1.2.1, regarding Montalva "...a project size of 73 MW does not introduce any new thermal violations or make worse any existing violations. This is true for N-1, N-2, and N-1-1 contingency cases."
2. "A project size of 80 MW also does not introduce any new thermal violations with normal operations of the transmission system. The project also does not introduce any new thermal violations or make worse any existing violations for N-1 or N-2 contingency cases; however, S&L identified overloads for the N-1-1 contingency case...This equates to losing both ends of line 37100, requiring all existing generation on line 37100 to flow down through the San German 115/38-kV transformer, overloading the 38--kV branches in the area...The output of the project would need to be curtailed in this event."
Losing 7 MW of power under the extreme and remote circumstances cited is dwarfed by the price advantage and that any occurrence would be of low probability and of short duration in the first place. However, even under the circumstances of an N-1-1 outage, the amount of curtailment represents only 7 MW and is significant only if Montalva has solar conditions to be generating at full power. If it happened early in the day, late in the day or at night, or at any other time Montalva would not have the solar conditions to be operating at full power, it would have no bearing whatsoever. One normally does a statistical analysis to know the probability of occurrence, how many hours per year and at what power level to equate the economic cost of such occurrences. One could likely find some set of contingencies and combination of failures to compromise every project. That is why every contingency is evaluated statistically with N-1 being the most likely to consider. Then it becomes a consideration of cost/benefit. Do you spend funds to overcome the contingency or pay for the power not delivered during the outages. When at Southern California Edison on our Western Wind projects we had to do this exact analysis to support our applications to the Public Utilities Commission and I had a group of four full time transmission engineers doing the studies and another group of MBA's doing the cost/benefit financial analyses. No such studies were done by PREPA and I would need to review if the consultant did any as well.
Specifically, the issue is that these contracts are what are known as take-or-pay contracts and so long as the project is available to deliver energy to the grid, then PREPA must pay for that power if the transmission system is compromised and they curtail Montalva. Even under those circumstances, PREPA gets 40 hours of full power credits annually against those occurrences and more if it is a force majeure.
In summary, the evaluation and ranking of Montalva's was not done correctly even when taking into account possible costs for transmission contingencies that might require curtailment of some of the generation of Montalva. For the record, the contingencies we are discussing are extreme and remote to occur in the first place and not evenly applied to all projects. As noted on page V of the Sargent & Lundy report, S&L also performed an N-1-1 contingency evaluation for a project where "... the N-1-0 outages for these contingencies are power lines that, based on input from the PREPA Operations Division, are frequently out-of-service." What that means is an evaluation of Montalva generation with two transmission lines out-of-service. Even in the most extreme case that S&L could evaluate with two selected transmission lines out-of-service, the system could still handle 73 MW of Montalva generation and only needs to curtail 7 MW for the duration of the dual outage.
New Energy Partners makes several statements that indicate they are not transmission engineers and do not totally understand the dynamics of what is going on. They do recognize the issue with the take-or-pay contracts, but they make no attempt to evaluate the statistical relevance with Montalva and an N-1-1 occurrence. They seem to accept this as a frequent event that easily exceeds the 40 hours of curtailment credit and that it is not acceptable without repair of the lines. Obviously this is what they are being told. They do not understand that the 40 hours are full power hours. 7 MW of curtailment would give PREPA over 457 hours without penalty and assumes Montalva was capable of generating full power during all hours of curtailment. Also NEP seems to make the point that this would be a "total" trip of Montalva and require spinning reserve to handle the occurrence. What would happen in practice is a reduction in power and not a total trip which is a major assumption on their part. They do make the comment that if the lines were repaired, then all would be fine. Therein lies the nexus as to who is making the statements that these lines trip frequently and must be repaired before anyone can use them. FYI, PREPA had no problem with this until the ranking came up. Also, PREPA had determined that 80 MW would meet all criteria. NEP does pick up on this as to how PREPA submitted the project for approval and now says they have a problem with outages. Convenient.
The key statement by NEP that I believe is not accurate is that "Under Montalva PPOA Appendix B, Montalva is required to implement a protection scheme that will automatically curtail the total generation of the facility, if necessary, when an N-1-1 contingency in transmission line 37100 (occurs)." The distinction is that there would be an automatic reduction in generation to 73 MW and not necessarily a total curtailment of the facility. Depends on the speed of the trip and recovery to 73 MW. Of more importance is the assumption that the lines in both directions trips frequently and at the same time. There are also no details as to what repairs are needed. Transmission lines by themselves do not trip. Tripping means there is an overload or short (fault). A short or fault of a line is very rare and generally is caused by high winds blowing the lines together. What generally happens is a problem at the substation in the relays which is not a high cost repair. If the lines were in as bad a shape as being conveyed, the frequent loss of power to customers would not be acceptable. A section maybe, but not multiple lines as a common occurrence.
We will pose questions as to the repairs needed, the frequency of trips and a statistical analysis of possible costs to PREPA for curtailments. Properly analyzed, is this grounds for disqualifying Montalva for having 7 MW of excess power under an N-1-1. No. Also, in the worst case, you would reduce Montalva's capacity from 80 MW to 73 MW and it would be ranked #1. Given their assumptions, why was Montalva not evaluated at 73 MW and allowed to go larger if the lines were repaired? Also, if Montalva ranks higher than Ciro, it should be allowed to go to 90 MW or back to its original 100 assuming repairs were made. Lastly, if properly evaluated and seeing the savings of Montalva, why did PREPA not consult with LUMA before eliminating Montalva?
What is also missing is our proposal to build a tie-line into the Guanica substation which has a robust line to Costa Sur. .
Lastly, the RFP shows 113.3 MW of interconnection potential at San German TC not 73 MW.
BTW We will have big news shortly on Alberta and more on Paul Morris Forward Living - Keller Williams both as a stand alone deal and with Sage. Do not underestimate Alberta (we purposely chose projects where public filings are not needed to protect our competitive advantage) and Paul Morris Forward Living Keller Williams looking to roll it into GRB as mentioned in the previous news release. Paul has $7.8 Billion in sales and $160 Million in commission income to roll into GRB. Once approved that will be big for GRB.
JEFF CIACHURSKI
Chief Executive Officer
Greenbriar Capital Corp
Greenbriar Capital Holdco Inc
Greenbriar Capital (U.S.) LLC
Captiva Verde Land Corp
9 Landport
Newport Beach
California USA
92660
Direct: 949-903-5906
email: westernwind@shaw.ca
www.greenbriarcapitalcorp.ca
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