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

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Staff Analysis:<br />

As explained in detail below, <strong>the</strong> Niagara Project Upgrade was primarily a life<br />

extension and modernization project designed to ensure <strong>the</strong> continued viability <strong>of</strong><br />

<strong>the</strong> entire 1880 MW <strong>of</strong> firm capacity <strong>of</strong> <strong>the</strong> Niagara Project after some 40 years <strong>of</strong><br />

continued operation. As such, <strong>the</strong>se costs were prudently incurred in <strong>the</strong><br />

exercise <strong>of</strong> <strong>the</strong> Authority’s stewardship <strong>of</strong> <strong>the</strong>se facilities and its broad discretion,<br />

discretion to which each <strong>of</strong> <strong>the</strong> in-state municipal system and rural electric<br />

cooperative customers consented in <strong>the</strong>ir settlement agreements with <strong>the</strong><br />

Authority in 2003. 3 The increased firm capacity and firm peaking capacity that<br />

arose from <strong>the</strong> upgrade were <strong>the</strong> result <strong>of</strong> efficiency gains <strong>of</strong> <strong>the</strong> new turbines.<br />

Increases <strong>of</strong> this sort were not, nor were ever intended to be, <strong>the</strong> primary<br />

objective <strong>of</strong> <strong>the</strong> Niagara Project Upgrade.<br />

Authority staff notes that it never purported to base its proposed rate increase on<br />

<strong>the</strong> Niagara Study, which was only provided in response to data request NYAPP-<br />

5, which concerned <strong>the</strong> Authority’s “marketing policy” for increased capacity or<br />

efficiency gains from <strong>the</strong> Hydro Projects. 4 NYPA responded by noting that <strong>the</strong><br />

issue <strong>of</strong> such increases is unrelated to <strong>the</strong> proposed rates, and included <strong>the</strong><br />

Niagara Study as additional material relevant to that data request. However, <strong>the</strong><br />

Niagara Study was produced solely in accordance with <strong>the</strong> Authority’s<br />

contractual commitment to provide preference customers with <strong>the</strong>ir share <strong>of</strong><br />

3<br />

These settlements allow for <strong>the</strong> Authority’s “recovery in rates <strong>of</strong> all prudent Hydro Project<br />

relicensing, life extension and modernization costs incurred by NYPA in <strong>the</strong> exercise <strong>of</strong> its broad<br />

discretion.”<br />

4<br />

NYAPP-5 states:<br />

Please explain <strong>the</strong> bases for <strong>the</strong> marketing policy <strong>of</strong> NYPA under which NYPA allows<br />

increased capacity or efficiency gains from <strong>the</strong> projects to be marketed as increased firm<br />

peaking power.<br />

8

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