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Minutes of the Annual Meeting of the Power - New York Power ...

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Part II: Public Comments, Staff Analysis and Recommendations<br />

A. Issue: Prudency <strong>of</strong> Authority’s Niagara Project Upgrade Costs and <strong>the</strong>ir<br />

Inclusion in Preference <strong>Power</strong> Rates.<br />

Public Comments:<br />

NYAPP claims that <strong>the</strong> Authority’s proposed rate increase cannot be sustained<br />

because <strong>the</strong> $298 million <strong>of</strong> <strong>the</strong> Niagara Project Upgrade costs included in <strong>the</strong><br />

CoS were imprudently incurred. (NYAPP Statement at 3; Russell at 7, 24-25).<br />

NYAPP reaches this conclusion by focusing on <strong>the</strong> 32 MW <strong>of</strong> firm power and 9<br />

MW <strong>of</strong> firm peaking capacity that was produced by <strong>the</strong> efficiency gain associated<br />

with <strong>the</strong> upgrade, and concluding that “[w]hen this 41 MW incremental gain is<br />

measured against <strong>the</strong> $298 million cost <strong>of</strong> attaining it, <strong>the</strong> per-unit charge<br />

equates to $7,268/kilowatt which is an extraordinarily high price.” (Russell at 7).<br />

NYAPP also relies on <strong>the</strong> increased “nameplate capacity” that resulted from <strong>the</strong><br />

Niagara Project Upgrade. Mr. Russell states that <strong>the</strong> 25 MW nameplate capacity<br />

increase per turbine, multiplied by <strong>the</strong> 13 upgraded turbines, should yield an<br />

additional 325 MW <strong>of</strong> Niagara Project capacity and a much lower $/kilowatt cost.<br />

(Russell at 6).<br />

NYAPP also criticizes <strong>the</strong> Authority’s recently completed report, Capacity and<br />

Energy Production Achievable at <strong>the</strong> Niagara <strong>Power</strong> Project and Niagara Load<br />

Study (“Niagara Study”) which was released on March 22, 2007 and provided in<br />

response to a NYAPP data request. In light <strong>of</strong> <strong>the</strong> Niagara Study’s findings that<br />

<strong>the</strong> Niagara Project upgrades resulted in an incremental firm capacity increase <strong>of</strong><br />

41 MW due to <strong>the</strong> increased efficiency <strong>of</strong> <strong>the</strong> units, and that <strong>the</strong> higher nameplate<br />

ratings did not increase project capacity, NYAPP contends that, with respect to<br />

customers, <strong>the</strong> $298 million in upgrade costs “was wasted” on <strong>the</strong>m. (Russell at<br />

24-25).<br />

7

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