|PUBLIC SERVICE COMMISSION OF WEST VIRGINIA
CASE NO. 12-0993-E-T-W-GI
Comments by Bill Howley at November 15, 2012 Public Comment Hearing
I appreciate the Commission’s decision to hold public hearings in this general investigation and thank you for accepting my comments.
Throughout the PATH transmission line case, we heard lots of power company and PJM fear mongering about blackouts and brownouts if we didn’t build PATH. Meanwhile, West Virginia’s distribution system, with some local transmission problems, has been through three major blackouts in 2009, June/July 2012 and again as recently as October/November 2012. It is clear that our Ohio-owned power companies are not very good at predicting system failures, nor are they good at identifying their causes. Unless the PSC and the power companies respond to the current distribution system crisis with some real change, our state will remain in its current cycle of under-investment in infrastructure followed by emergency quick fixes that do nothing to address real reliability questions.
The 2009 blackout, and the following 2010 investigation did result in the recently settled reliability standards case. Although these standards are not nearly tough enough, the PSC engineering staff came up with a good compromise system that will generate improvement over time. This is an important step that can have some limited impact on preventing the catastrophic failures that have been the rule for the last three years.
My wife and I live in a very rural part of Calhoun County, way out on the outer end of our distribution circuit. Right of way maintenance is spotty, and confined mainly to trimming during emergencies. Short blackouts are relatively common, and in big blackouts, we are among the last to be restored. In the 2009 blackout, we were without power for 6 days, in the June/July blackout we were out 13 days and in the recent storm we were without power for 3 days, when almost 90% of Mon Power’s Calhoun County customers never experienced a problem.
As a result of our history of problems with Mon Power’s reliability, we decided to invest in a small solar generating system with a battery system that would automatically kick in when Mon Power failed. Our back up system does not replace all of our power during a blackout. Our batteries serve only four circuits in our house that serve our critical needs: our refrigerator, freezer, water pump and some limited lighting, as well as our satellite Internet connection.
The Commission has plenty of information about my system, both from my written comments in this case and in the somewhat puzzling case of our struggle to have our system certified to produce renewable energy credits in West Virginia.
Our decision to invest in our own system was based as much on our need to provide for our own power reliability as it was our commitment to renewable energy. With a few exceptions, West Virginia and its centralized electric power industry has very little experience or expertise in the most reliable electrical system technologies available today. Decentralized power generation organized around microgrid distribution structures provides for real reliability. Our one-family PV/battery system contains within it all the elements of microgrid technologies.
Because West Virginia’s Ohio-owned power companies have so little experience with microgrid technologies, the West Virginia installers and owners of PV systems can provide valuable insights into the practical operation and applications of those technologies. For this reason, I was extremely disappointed that the Commission believed my intervention in this case was outside the scope of this general investigation. Questions 7 and 8 which you addressed to utilities in your initial order dealt specifically with system improvements and preventing future blackouts.
Isolatable microgrids have now proven themselves in the massive blackouts following Hurricane Sandy. New York University and Co-op City are located at what was almost ground zero for Sandy’s impact on the New York electrical system. Both entities operate combined cycle natural gas generators which also provide heat for their buildings, in what is called combined heat and power or CHP. The microgrid switching systems in both locations kicked in automatically when ConEd’s power failed, just the way the inverter on my system kicks in when Mon Power fails here. NYU’s system is limited to the university’s critical functions, while the New York Times reported that all of Co-op City’s system remained fully functional, and never even flickered.
The New York microgrids operate on NGCC generators. The kind of generation used on the microgrid is important, because it should not be subject to fuel disruption in times of emergency. NGCC is scalable down to very small units and, for now, natural gas is plentiful and its infrastructure is largely underground. Diesel generation is subject to fuel disruptions and also generates large amounts of local source air pollution. The most reliable and safe generation source is solar or wind power combined with battery storage. Both the generation capacity and storage capacity must be sized to allow for extended operation with exactly the right combination of battery storage capacity and enough generation capacity to maintain battery operation. The cost of both of these capacities can be reduced if critical loads are identified, and the system is designed only to serve those loads during emergencies.
These steps are exactly the steps we went through in designing our home mini-microgrid. We started using a gasoline generator in blackouts, which gave us very limited generating capacity, lots of noise and exhaust and a fuel that was subject to long lines and high expense during emergencies. We moved to a PV/battery system that serves our critical loads seamlessly and with no noise or pollution. Larger microgrids obviously require more technical additions and refinements, but the difference is still only one of scale.
So let’s get to what the Commission can do right now to really improve reliability by making microgrids a reality in West Virginia.
Expand virtual metering: In the Commission’s current net metering regulations, there is provision for virtual metering if primary loads are on a different meter from the meter circuit that contains solar power generation. The regulations, however, limit the creation of a virtual meter to meters located on contiguous property. By expanding virtual metering to a single customer entity, but for loads in different non-contiguous locations, the Commission could create long term viability for municipal and county emergency backup systems that could locate solar arrays at water or sewer plants that could then be used to charge battery systems at various first responder and emergency services locations owned by a county or city.
Expand power sales opportunities: The Commission could also create a new tariff structure for small scale power producers from local microgrids using renewable or NGCC generation that would allow them to generate revenue from their local systems during normal, non-emergency operation. Current tariffs in West Virginia do not provide enough revenue to make the kinds of investments in these systems which would dramatically increase the reliability of emergency systems needed in power company failures.
Identify appropriate microgrid opportunities in West Virginia: The Commission took the initiative in the 2009 blackout general investigation that led directly to the establishment of the new reliability standards. The Commission should initiate a new case to study appropriate microgrid technologies and strategies for using microgrids in West Virginia to strengthen critical services during power company failures. This study case is vital, because there is so little microgrid expertise in West Virginia or its Ohio-based power companies. In 2008, Allegheny Energy received a multi-million dollar grant from the US Dept. of Energy to build and test a microgrid at WVU called the Super Circuit. The project was to begin in the fall of 2009 and continue for 4.5 years. To date, FirstEnergy has revealed no practical applications for West Virginia developed in this project. By now, FirstEnergy should be able to share many useful results of the Super Circuit project.
Initial steps toward microgrid reliability are perfectly suited to building a stronger emergency response capability in West Virginia. These are steps that the Commission can take right now to move us forward. When will we face the next major power blackout? Back in 2010, my wife and I thought we may have been too cautious in investing in our system. Our 13 days without Mon Power’s power last June and July, convinced us that we had made the right decision.
The West Virginia PSC is now at a similar decision point that my wife and I faced after the 2009 blackout. You can remain in the cycle of distribution system decay and emergency response, or you can begin building real reliability into West Virginia’s electrical system. West Virginia rate payers already face rising rates from emergency cost recovery and increased maintenance costs, why not invest in real change that pays dividends in real reliability?