From: Luis Contreras ~mailto:doccontr~ras~~mail.com] Sent: Tuesday, November 12,2013 3:12 PM To: Connie Griffin

2013 NOV ! 2 P 4: I 4 Cc: Dallas Heltz Subject: < Public Comment docket 13-0414 One more 345 kV line will NOT improve&@ @lwlp[3

Your Honor,

Attached i s an important comment fo r your review.

We need to improve G r i d Reliability. Attached are proven ways to improve our G r i d without one more 345 kV transmission line.

Downtime cost is estimated as $150 Billion per year

Dallas: please print in Color and post

Respectfully,

D r . Luis Contreras

November 12, 2013

Arkansas Public Service Commission

Attn: Secretary of Service Commission

P.O. BOX 400

L i t t l e Rock, AR 72203-0400

Re: D o c k e t No. 13-041-U SWEPCO's Application

< One more 345 kV line w i l l not improve G r i d Reliability >

Dear Secretary:

f -13 d9-t iio W d l the IS- I Q U . ~ ~ . SPP claims w e

need this line to improve Grid reliability. The SPP claim is

false: AEP wants the facilities to increase their f i n a n c i a l

a s s e t s to back 30 year Bonds and keep shareholders happy. This

is a serious objection, j u s t i f i e d by t h e following arguments:

1. What is Grid reliability?

2 . How do you measure G r i d reliability?

3. What improves Grid rel iabi l i ty?

4 . Which country has the highest G r i d reliability?

5 . Why w o u l d SPP make a false claim?

6. To protect the long term benefit of the people of Arkansas,

APSC should deny the AEP application in full.

1

I. What is G r i d reliability?

Grid downtime in t h e United S t a t e s costs the US economy around

150 billion d o l l a r s a year . T h i s is serious money. We need to

reduce downtime to compete in world markets.

What is grid r e l i a b i l i t y ? You won't f i n d a definition on the S P P

website. They say something about keeping t h e lights on.

Utilities use several terms with no consistent definition:

availability, unavailability, blackouts, brownouts, rotational

brownouts, and other names.

SWEPCQ, in their o b j e c t i o n t o the Neighbors Motion to Dismiss

defines reliability as follows:

A reliable g r i d is one that has been designed, B u i l t and

operated to insure reliability agains t eman &he mdtt

t u z U k l p Z y of coatizq#enchs. That requires studies that look

w e l l i n to the future, ant ic ipates all contingencies, and

directs the construction of the necessary transmission

facifities in a timely manner.

SWEPCO says nothing about squirrels. I guess that is not one of

t h e unlikely contingencies their engineers thought about. Will

they have to re-design and dismantle t h e Grid, j u s t to make it

Squi r re l proof? We can't have squirrels taking the lights o u t !

2. How do you measure G r i d reliability?

This is not an easy question. The European Union (EU) uses a

simple metric based on end custcaner experience. That is the Lean

way, what the customer sees and what the customer cares about.

In 2006, t h e N e t w o r k Agency began calculating the System Average

Interruption Duration Index (SAIDI) . SAIDI does not include

2

planned interruptions or downtime due to n a t u r a l d i s a s t e r s .

SAIDI only includes unplanned interruptions lasting more than

three m i n u t e s .

Germany's Network Agency announced that t he German g r i d on ly had

a downtime, S A I D I , of 15 minutes per year in 2011.

i

Las t spr ikg, when the German government resolved to shut down

e i g h t of the country's 17 nuclear p l a n t s w i t h i n a week, there

was concern about whether the country's g r i d would remain

reliable. Not only did the coun t ry avoid a major b lackou t during

the w i n t e r , but its availability actually increased over the

average g o i n g back to 2006, when reporting began.

The G e r m a n grid has proven to be the most re l iab le among

European Union (EW) member states year after year. Germany's performance can only be properly appreciated in the context of other countries. Germany has consistently been the leader among

3

EU member states. The number of minutes of g r i d interruptions in o t h e r countries such as France, which had 62 minutes of SAIDI

downtime in 2007, is several times t h e German l e v e l .

The United States had a SAIDI of 240 minutes in 2 0 0 7 which would

pu t the US at t he bottom of the chart.

3. What -roves Grid reliability?

Not what you think; smart g r i d s are an idea t o sha re data on a n

old unreliable system. They a r e very expensive, something

utilities like (it goes in the assets column of their f i n a n c i a l

reports) and they pass the f u l l cost to ra tepayers . We have seen

recent ly t h a t software does not make a messy healthcare problem go away; same with electrical power.

G r i d reliability does n o t improve adding a n o t h e r 345 kV

transmission l i n e and a station at Kings River, like SPP w a n t s

to do: "if all you have is a hanmer, everything looks like a

nail." Adding components increases cost and complexity; it does

n o t improve reliability. E l e c t r i c a l Engineers l i k e to talk about

redundancy and they would argue with you more redundant p a r a l l e l

pa ths are t h e best way to improve reliability; they have books

and courses that show this works in theory. A l l it does is dr ive

electrons nuts; they don't know where to go as they move ve ry

f a s t , c lose to the speed of light. This does not w o r k . A s k any

Squirrel, they know how to t a k e down a grid, any t i m e t h e y g e t

co ld .

The c e n t r a l b u l k generation model that d a t e s back t o N i k o l a

Tesla in 1800 's has a major drawback: a large f a i l u r e i n one

p a r t of the grid can cause cur ren t to r e - rou te itself to flow

from the remaining g e n e r a t o r s t o consumers over transmission

4

l i n e s of insufficient capaci ty , causing f u r t h e r f a i l u r e s . One

downside to a w i d e l y connected grid is thus the possibility of

cascading failure and widespread power outage.

How then, do you improve reliability? T h e Lean way to improve

reliability is to change the current G r i d , as Germany and many

countries in Europe have done, without spending tons of money,

us ing a l l available resources (renewables come t o mind), one

household at a time. No t a k i n g p r i v a t e l a n d or s h u t t i n g down a S a f a r i Park , no

use of eminent domain , no permanent environmental

d e v a s t a t i o n . Engineers and regular folks get involved t o

make t h i s happen, is not about lawyers or lobbyists.

Gxid-tie distributed r e n e w a b l e energy solutions f Total G r i d

Maintenance for the existing grid are the lean w a y to *rove

reliability

Total Grid Maintenance, what Toyota calls T o t a l Productive

Maintenance, requires a n overall improvement s t r a t e g y driven top

down with participation of a l l employees. This is a difficult

task, with no immediate financial results. For a while, i t looks to accountants as a huge expense t h a t must be avoided. Customers

benefit, b u t tha t is n o t what drives top management decisions in

utilities, concerned with quarterly financial results.

Several factors explain t h e f r a g i l e state of the US Grid:

Aging power equipaaent - older equipment have higher f a i l u r e

r a t e s , leading to customer interruption rates affecting the

economy and soc ie ty ; also, o lde r assets and f a c i l i t i e s lead to

higher inspection maintenance cos ts and f u r t h e r repair and

r e s t o r a t i o n c o s t s .

5

0

Obsolete system layout - o lde r areas require serious

additional substation s i t e s and rights-of-way t h a t cannot be

obtained i n c u r r e n t area and are forced to use existing,

insufficient f a c i l i t i e s .

Outdated engineering - traditional t o o l s for power delivery

planning and engineering are ineffective in addressing c u r r e n t

problems of aged equipment, obsolete system layouts, and

modern deregulated loading levels

O l d thinking - planning, engineering, operating of s y s t e m

using concepts and procedures that worked i n v e r t i c a l l y

integrated industry exacerbate the problem under a deregulated

industry. Dis t r ibu ted generation and consumption, f o r example

is not considered as an option by SPP / AEP and APSC.

4. Which country has the highest G r i d reliability?

If you guess US, you get an F. I f your guess i s Germany you get

an A+ as they have led the world for many years.

5 . Why would SPP make a false claim?

Why not? They are the "experts" and they can say whatever they

want, with data protected by federal pr ivacy laws. SWEPCO, f o r

example, requests confidential protection f o r most of their

applications as soon as someone s ta r t s a sk ing questions, and

APSC approves their request in a couple of days. If nothing

e l s e , t h i s i s a way to make intervenors pay through the nose as

all data requests have t o be f i l e d by an expe r t lawyer, and APSC

takes days to process these requests. 1

Besides, SPP has to be consistent, t hey have used t he "we need

more 345 kV lines before," and they c a n ' t change t h e i r story

j u s t fo r u s . I f you don't b e l i e v e me ( i n case someone actually

6

reads this) look at the APSC docket 10-174-U filed in 2010 and

approved in April 2013 f o r a 14 mile long 345 kV transmission

line. Why would SPP want a 1 4 mile l o n g EHV l i n e when they could

have used a 6 9 kV or even a 161 kV line to move electrons 14 miles would be a mystery. B u t of course in the O z a r k s we know

the rest of the story.

I a m s u r e t h e r e a r e good people at SPP; I don’t know any of

them. If you w o r k for SPP or have friends there, please don‘t

t a k e t h i s personally. This disclaimer i s needed since there a r e

people we know who may be secret members of SPP.

6 . To protect the long term benefit of the people of ATkansas,

APSC should deny the AEP application in full.

My assumption is APSC works for the peop le of Arkansas.

SPP makes a good argument: we need to improve G r i d reliability.

They j u s t don‘t know how to do it. T h e cost to t h e US Economy of

having blackouts, brownouts or outages of any c o l o r is huge.

As I write t h i s objection, there is a brownout in the US grid: with the unavailability of the 400-megawatt IMW) power supply

from Leyte because of damuged transmission lines, the Leyte-

Panay-Cebu grid has a 160-MW power shortage leading t o brownouts

s t a r t i n g yesterday. “ D u r a t i o n of the r o t a k i o n a l brownouts w i l l

depend on t h e time and a v a i l a b l e supply they have a t the t i m e .

The 10 a.m. brownout yesterday lasted f o r t w o hours .”

Just a f e w days ago, November 7 , 2013, a single squirrel took

the SWEPCO grid down a f f e c t i n g Arvest Bank customers in Arkansas, Missouri, Kansas and Oklahoma.

7

People t e l l me SPP is controlled by AEP, and the relationship

between S P P and APSC has been questioned in the press:

AEP

SPP APSC As we wait f o r Judge Connie G r i f f i n , aga ins t all odds, we pray

APSC will protect the economy, environment, health and future of

the Ozarks . Please Judge G r i f f i n , deny the SWEPCO application in full with a permanent injunction to stop them from trying again

next year.

We have better things to do.

Thank you very much.

Respectfully,

Dr. Luis C o n t r e r a s

Eureka Spr ings , AR

a

References

1. Bad n e w s : The U . S . Grid is getting pricier, less reliable

Washington Post

Brad Plumer, March 8, 2013

h t t p : / / ~ . w a s h i n g t o n p o s t . ~ a m / b l ~ ~ / w ~ ~ ~ l ~ ~ / ~ / ~ ~ ~ 3 / ~ 3 / ~ ~ / s ~ ~ ~ r

ise-the-u-s-pow~r-qri~-is-~~~ting-pricie~-l@~s-~eli~~l~/

U . S . electric customers are now paying 4 3 percent more to huild

and maintain local power grids than they did back in 2002. At

the same time, the g r i d is also becoming less re l iable , with

blackouts now t a k i n g 20 percent longer to f i x .

2 . Brownouts to continue: Veco

November 12, 2013

ht~p://newsinfo.inquirer.net/525699/browuts-to-c~~~in~e-veco

Lacest news of rolling brownouts due to damaged transmission lines.

3. German grid reaches record reliability in 2011

h t t p : / / ~ . r e n e r a a b ~ ~ s ~ ~ ~ ~ ~ ~ ~ t i o ~ a l . ~ e t / g e ~ m a ~ - g r i d - r ~ a c h ~ ~ -

record-~eliability-in-2011/150/537156183/

Germany's N e t w o r k Agency announced that t he German g r i d only had

a downtime of 15.31minutes per year in 2011 even l o w e r than the

already impressive 17.44 minutes of downtime during the period

from 2006 the 2010.

L a s t spr ing, when t h e G e r m a n government resolved to s h u t down

eight of the country's 17 nuclear plants w i t h i n a week, there

was concern about whether the country's g r i d would remain

reliable. Not only did the country avoid a major b lackou t during

the w i n t e r , bu t i t s availability actually increased over t h e

average going back to 2006, when reporting began.

In 2006, the Network Agency began calculating the System Average

Interruption Dura t ion Index (SAIDI), which can be seen on this website in German. The index does not include planned

interruptions or downtime due to natural disaskers; rather, it

only includes unplanned interruptions lasting more than three

minutes.

The German g r i d h a s proven to be the most reliable among

r e p o r t i n g European Union (EU) member s t a t e s year after year

since it began reporting in 2006 .

Germany's performance can only be properly appreciated i n t h e

contex t of o t h e r countries. Germany has consistently been t h e

leader among reporting EU m e m b e r states since it began reporting

in 2006. The number of minutes of g r i d interruptions i n o t h e r

countries such as France, which had 62 minutes of SAIDI downtime

in 2007, is several times the German l e v e l . The United States

had a S A I D I of 240 minutes in 2007 which p u t s the US at the

bottom of the chart; grid downtime in the United S t a t e s c o s t s

the U S economy around 150 billion dollars a year.

Importantly for international readers , t h e Network Agency

reports specific f i g u r e s f o r the number o f g r i d o p e r a t o r s in

Germany: 8 6 4 g r i d opera tors reported 206,673 grid interruptions on 928 separa te g r i d s . These figures c l e a r l y show that the

German g r i d is as splintered as those in o t h e r countries and is

n o t a monolithic state-driven e n t i t y .

Germany clearly demonstrates that a very high level of grid

reliability is feasible w i t h a high penetration level of

intermittent wind and solar power. Indeed, Denmark, which has an

even grea te r share of wind power in Germany, a l s o has a

10

similarly reliable gr id , and as the c h a r t shows above grid

reliability in Spain has actually improved dramatically over the

p a s t f e w years even as it ramped up i t s wind and solar power.

5 . SPP: keeping the lights on

Wldw spp . orq

Our major services include monitoring t h e g r i d to maintain

electr ic r e l i ab i l i t y , operating a wholesale energy market,

c rea t ing regional reliability standards, planning €or future

transmission needs, processing requests for use of the

transmission g r i d under a tariff w i t h consistent rates and terms

f o r all participants, and ensuring the bulk transmission

system's users, owners, and operators camply with reliability standards.

6 . Cause Revealed in Arvest Bank Outages

November 08, 2013

h t t p : / / ~ . n ~ a h o ~ ~ ~ ~ ~ ~ . ~ ~ ~ / f u l l t e ~ t - ~ e w ~ / u p ~ a t ~ - c ~ ~ ~ ~ - ~ ~ v e a ~ ~ ~ -

in-arve~t-bank-outages/d/fulltext-~~ws/6 WrWuwHSEuj7mklkbrxH-Q The power is back on for thousands of Arvest Eank cus tamers ' in

Arkansas, Missouri, Kansas and Oklahoma. A widespread outage

caused some transaction troubles for many Thursday night. Arvest

marketing director Jason Kincy tells us one of the bank's

systems that normally accounts far routine power outages, failed

Thursday. Kincy says it affected online, mobile, ATM, and some

debit transactions for about 2.5 hours. There were still some

lingering issues overnight and into t h e morning Friday at local branches. Everything should be back to normal now. If you have

11

any questions you can c a l l Arvest customer service a t 866-952-

9523.

Kincy tells us those system outages were caused by a SWEPCO

outage in Lowell Thursday night. SWEPCO'S Peter Main tells us

more than 3 , 0 0 0 customers lost power a t around 5:30 Thursday

n i g h t i n the Rogers/Lowell area. Several t r a f f i c l i g h t s and

other l i n e s w e r e affected f o r about four hours while crews

restored power. So far , there is no word on a definitive cause.

N o v . 8 , 2013: Arvest Bank announcing over n i g h t v i a Twitter,

o n l i n e banking services have been restored, b u t it's s t i l l

working to resolve other i s sues . L a t e Thursday n i g h t , the bank

said it was experiencing system outages a f f e c t i n g ATM's, d e b i t

cards, and their c a l l cen ter . The outage a f fec t ed thousands of

customers in Arkansas, Missouri, Kansas, and Oklahoma. We spoke

with Dennis Smiley, President of Arvest Bank in Bent011 County,

who told us they hope to have the system back up and running as

q u i c k l y as possible.

O r i g i n a l S t o r y Nov. 7 , 2013: Northwest Arkansas - Arvest bank confirming with KNWA and Fox 2 4 t h e company s t a r t e d experiencing

some technical d i f f i c u l t i e s around 6 : 3 0 o r 7:OOpm Thursday

night. According to Jason Kincy , Director of Marketing and Web Marketing for Arvest Bank Operations, the i s sue a f f e c t e d ATMs,

o n l i n e banking, mobile banking, and some of the company's call

center services in A r k a n s a s , Missouri, Oklahoma, and Kansas.

Kincy t e l l s us i t i s hard to p u t an e x a c t number on t h e amount

of people a f fec ted by t h e issue, bu t says it could be in the

thousands. Dennis Smiley, President Arvest Bank Benton County

t e l l s u s , "Yes we can confirm t h a t our systems are down and we

12

a re working to r e c t i f y t h e situation and expect to have them up

and running very soon."

As of 8:37 pm A r v e s t Bank's website was b a c k up, b u t you s t i l l

could not l o g in to your account. Late1 Thursday night t he

company alerted customers v i a Twitter; their online system was

back up and running. The company is currently w o r k i n g to restore

a l l services as quickly as possible. Arvest will post via social

media once t h e issues a r e resolved.

7 . Squirrel Knocks O u t Power for Thousands in NHA

November 7 , 2013

h ~ t p : / / ~ . n w a h o m ~ ~ a q e . c ~ m ~ f u l ~ t e ~ t - ~ ~ w s / s q u ~ ~ e l ~ - k ~ c ~ - u u t - p 6 w ~ - f o r-thousands-i~-~~~/d~ful~t~x~-~~ws/~M A4icNZE-

6PsyCDSpdlA

Yes, it was a squirrel, what else can we say?

8 . M a n indicted in sabotaging of p o w e r grid

November 7 , 2013

h t t p : / / ~ , a r k a n ~ a ~ o ~ ~ ~ ~ e . ~ ~ ~ ~ ~ e ~ ~ / Z O l 3 / n ~ ~ / O ? / m ~ ~ - ~ n ~ ~ c t ~ ~ d -

sabotaging-puwer-grid-~01311~7/

N o t a good idea, you may be accused of being a terrorist, and

Homeland Security has a b i g budget. Don't mess w i t h the G r i d .

9. Germany leads the .world in Solar Research & Technolagy I

The companies t h a t make inverters, t he devices that reverse the

flow of e l e c t r i c i t y and feed power f r o m rooftop solar panels

back into national g r i d s , a r e almost a11 German. On a sunny day

13

last May, Germany produced 22 gigawatts of energy from the sun-

half of the world's total and the equivalent of 20 nuelear p o w e r

plants f

T h e "feed-in" laws and subsidies gushed innovation to the point

where solar p a n e l s a r e cheap enough to compete on the open .

market in Germany and elsewhere. T h e price for solar panels has

f a l l e n 66 percent since 2006, and the cost of solar-generated

power may be competitive with coal in a few years, according to

a study by UBS. Already, s o l a r p ro j ec t s are thriving in places

l i k e India and Italy despite a l a c k of gavernment subsidies or

support, and a recent Deutsche Bank report predicted "grid

parity" in Bavaria by next year.

10. Versorgungsqualitat - SAIDI-Wert 2006-2012

I Versorgungsqua.litat - Ubersicht SAIDI-Werte Strom 2006 - 2011

Bundesnetzagentur veroffentlicht Zahlen zur Versosgungsqualitat

i r n Strombereich

Deutsche Elektrizitatsnetzbetreiber t i b e r m i t t e l n der

Bundesnetzagentur gemal3 § 52 Energiewirtschaftsgesetz (EnWG)

jahrlich einen Bericht uber die in ihrem Netz aufgetretenen

Vers~rgungsunterhrechungen. Dieser Bericht enthalt Zeitpunkt,

Dauer, AusrnaR und Ursache der Versorgungsunterbrechungen.

14