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

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electromechanical equipment being superseded by programmable logic<br />

controller-based equipment.<br />

All <strong>of</strong> <strong>the</strong>se activities were documented and received thorough scrutiny from<br />

NYPA management and <strong>the</strong> Trustees. 8<br />

Although Mr. Russell (at 14, n.5) briefly acknowledges <strong>the</strong> “benefits <strong>of</strong> life<br />

extension” he none<strong>the</strong>less asserts, without any support whatever, that <strong>the</strong> $298<br />

million could have been accomplished “at a substantially lower capital cost than<br />

NYPA actually incurred in replacing <strong>the</strong> units, through such measures as<br />

rewinding <strong>the</strong> generators without replacing each entire turbine-generator unit.”<br />

The Authority’s decisions over a decade ago to extend <strong>the</strong> life and modernize <strong>the</strong><br />

generator-turbines at <strong>the</strong> Niagara Project, was a prudent exercise <strong>of</strong> its<br />

management and engineering judgment intended to assure <strong>the</strong> continued<br />

operation <strong>of</strong> <strong>the</strong> Project for <strong>the</strong> benefit <strong>of</strong> Mr. Russell’s clients and <strong>the</strong> o<strong>the</strong>r<br />

customers that enjoy <strong>the</strong> benefits <strong>of</strong> <strong>the</strong> Project. 9 As shown above, <strong>the</strong>re is<br />

ample evidence that its $298 million expenditure was prudent, and NYAPP’s<br />

suggestions to <strong>the</strong> contrary have no merit.<br />

2. Based on its Flawed Analysis <strong>of</strong> Niagara Project Capacity,<br />

NYAPP Mistakenly Asserts that <strong>the</strong> Niagara Project Upgrade was<br />

Imprudent.<br />

NYAPP mistakenly assumes that increase in <strong>the</strong> nameplate capacity <strong>of</strong> <strong>the</strong><br />

Niagara Project that resulted from <strong>the</strong> Upgrade necessarily enables <strong>the</strong> Project to<br />

produce more firm capacity. See Russell at 6, 18, 23-25. This is not <strong>the</strong> case,<br />

8<br />

See, e.g., 1993 RMNPP Upgrade Analysis and “Report to <strong>the</strong> Capital Review Committee,<br />

Niagara Project Upgrade” (April 15, 1994), which also available upon request.<br />

9<br />

Mr. Russell’s assertion is also marred by his reliance on <strong>the</strong> 1987 License Amendment which<br />

estimated a total project cost <strong>of</strong> $568 million, <strong>of</strong> which $49 million was for life extension benefits.<br />

(Russell at 14 n.5). Because that license amendment described an expansion project that was<br />

abandoned, those numbers have practically no value in determining whe<strong>the</strong>r NYPA’s life<br />

extension and modernization expenditures were reasonable. It is also worth noting that NYPA’s<br />

Niagara Project Upgrade did not replace <strong>the</strong> entire turbine, but only <strong>the</strong> runner and limited<br />

embedded worn components, thus minimizing costs.<br />

12

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