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direct testimony of the capital expenditures, reliability, and - nyseg

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Case 09-E-____; Case 09-G-____ (NYSEG)DIRECT TESTIMONY OF THE CAPITAL EXPENDITURES,RELIABILITY, AND OPERATIONS PANEL123456789101112131415161718192021cost estimates. It is not known how long FERC would give entities to bring newBES facilities into compliance, but <strong>the</strong>re is likely to be a multi-year phase inperiod. If changes occur in <strong>the</strong> ERO st<strong>and</strong>ards at a later date, additional <strong>capital</strong>projects may be required. The operating <strong>and</strong> maintenance costs are annual coststhat would continue as long as <strong>the</strong> ERO st<strong>and</strong>ards are considered to be m<strong>and</strong>atoryby FERC.Q. Why are <strong>the</strong>re differences between <strong>the</strong> previous estimates provided to <strong>the</strong>Commission <strong>and</strong> <strong>the</strong> current estimates?A. The original estimates assumed that <strong>the</strong> 100 kV bright line definition would haveno exceptions, thus more substations were included in <strong>the</strong> original estimates. Forexample, estimates for PRC st<strong>and</strong>ards compliance was based on upgrades at 113NYSEG substations. Current estimates are based on 45 to 82 NYSEGsubstations.In addition, compliance costs for <strong>the</strong> Vegetation Management St<strong>and</strong>ard(FAC-003) have been reduced because this st<strong>and</strong>ard specifically applies totransmission lines over 200 kV. The new BES definition would not change <strong>the</strong>applicability level for this st<strong>and</strong>ard. Finally, estimates for compliance withsystem redundancy requirements <strong>of</strong> <strong>the</strong> TPL (TPL-002-0 <strong>and</strong> TPL-003-0) aredifferent because <strong>of</strong> <strong>the</strong> change in <strong>the</strong> proposed BES definition, resulting in fewerprojects needed to come into compliance. However, <strong>the</strong> project <strong>capital</strong> estimateshave been updated, resulting in slightly higher estimates.52

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