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

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increased output that resulted from <strong>the</strong> Niagara Project Upgrade. The Niagara<br />

Study is not subject to Trustee review in this rate action. 5<br />

1. The Niagara Project Upgrade was Prudent and Necessary to<br />

Assure <strong>the</strong> Continued Viability <strong>of</strong> <strong>the</strong> Project.<br />

Contrary to NYAPP’s assertions, <strong>the</strong> Niagara Project Upgrade was demonstrably<br />

prudent. It involved extensive overhaul and replacement <strong>of</strong> aging equipment at<br />

<strong>the</strong> Niagara Project’s primary generating station that houses <strong>the</strong> thirteen<br />

generating units, also referred to as <strong>the</strong> Robert Moses Niagara <strong>Power</strong> Plant<br />

(“RMNPP”). This work was necessary to maintain <strong>the</strong> reliability <strong>of</strong> <strong>the</strong> plant. In<br />

addition, NYAPP ignores <strong>the</strong> fact that <strong>the</strong> Niagara Project Upgrade evolved from<br />

an expansion plan into a life extension and modernization plan, and that such<br />

upgrades were necessary and beneficial to customers.<br />

Although NYAPP briefly acknowledges <strong>the</strong> life extension and modernization<br />

benefits <strong>of</strong> <strong>the</strong> Niagara Project Upgrade (Russell at 14 n.5), Mr. Russell pretends<br />

that this work was a minor activity, and that <strong>the</strong> bulk <strong>of</strong> NYPA’s expenditures was<br />

devoted to increasing <strong>the</strong> capacity <strong>of</strong> <strong>the</strong> hydropower turbines. Not only is this<br />

incorrect, at times Mr. Russell relies upon <strong>the</strong> claimed benefits stemming from<br />

<strong>the</strong> Authority’s 1987 License Amendment, see, e.g., Russell at 13-14, 24-25, for<br />

purposes that do not relate to <strong>the</strong> actual upgrade that was performed. In fact, <strong>the</strong><br />

entire nature <strong>of</strong> <strong>the</strong> Niagara Project Upgrade was modified substantially in <strong>the</strong><br />

early 1990s, all <strong>of</strong> which is a matter <strong>of</strong> public record.<br />

It is true that <strong>the</strong> Niagara Project Upgrade was originally planned as an<br />

expansion project in <strong>the</strong> early 1980s, shortly after <strong>the</strong> 1979 oil embargo. NYPA’s<br />

engineers had conceived <strong>of</strong> a program in which both <strong>the</strong> RMNPP and <strong>the</strong><br />

Lewiston Pumped Storage Generating Plant (“LPGP”) were to be expanded.<br />

This would allow <strong>the</strong> Project to increase production during peak demand periods<br />

5<br />

Although this rate proceeding is not <strong>the</strong> proper forum for review <strong>of</strong> <strong>the</strong> Niagara Study, NYPA<br />

has communicated to NYAPP and <strong>the</strong> o<strong>the</strong>r Public Customers that it will set up meetings with<br />

Authority staff to explain <strong>the</strong> Niagara Study’s findings.<br />

9

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