Post-2028 Working Group Recap
The Post-2028 Working Group met this week for the sixth time in 2021. The post-2028 conversations are becoming increasingly more substantive and while the Working Group will continue to be the first point of contact for NRU staff on this effort, we want to ensure the entire membership is kept fully informed and has every opportunity to give feedback on and participate in this crucial effort. To accomplish this, staff will be distributing more detailed recaps following each Working Group meeting through the Portland Update.
To cover the meeting this week, Megan Stratman crafted an exceptional memo that outlines the topics addressed by the Working Group and the potential policy leanings that were discussed at the meeting. Please review the memo attached to this update and ask any and all questions you have regarding the contents of the memo or the post-2028 process in general. It is extremely important to note that the meeting recap memo contains very early thinking from the Working Group and staff on the issues contained within and should not be distributed or discussed beyond NRU membership; the memo also contains some proprietary analysis performed by NRU.
Northwest Power and Conservation Council Energy Efficiency Discussions Cause Concern
As the Council continues to develop its 2021 Power Plan, a key issue for NRU and its members is the energy efficiency targets in the plan. Historically, energy efficiency targets in the Council’s power plans have created a blueprint for the region for obtaining energy efficiency as a resource and have informed, to varying degrees, Bonneville’s energy efficiency program.
The Council’s preliminary models for the 2021 Power Plan show a significant decrease in available cost-effective energy efficiency in the region as compared to previous power plans. The preliminary models show about 500 aMW of available cost-effective energy efficiency over the six-year term of the plan, compared to, for example, 1400 aMW in the most recent power plan. This is due to several factors, including drastically reduced costs of renewable resources and the region already having acquired much of the least expensive energy efficiency.
Despite these preliminary model results, or perhaps in reaction to them, Council members and staff have recently expressed an interest in setting a higher efficiency target, one that considers non-energy factors and perceived policy interests that the model does not support. This is alarming to NRU staff, as it could lead to Bonneville and the region paying for increasingly costly energy efficiency measures at the expense of customers.
NRU plans to submit (unsolicited) comments to the Council next week pointing out our concerns. We will make both legal and policy arguments, with the legal arguments pointing to the Northwest Power Act requirements on the Council in determining what qualifies as cost-effective energy efficiency and the statutory framework that the act creates for Bonneville in how it uses the Council’s work. We are coordinating closely with PPC, which also plans to submit comments to the Council. We will share a copy of the NRU comments in next week’s Portland Update.
Energy efficiency targets are not the only component of the draft plan that are cause for concern with NRU staff. The modeling around resource adequacy utilizes a number of assumptions that are hard to reconcile with the assumptions of other regional work on this topic. NRU staff are collaborating with at least PPC and PNUCC to better understand the reasons Council staff are pursuing a path that results in findings that are widely divergent from the findings of other regional bodies and utilities. We will report out as we progress on this effort.
NRU Submits Comments to the CAISO Governance Review Committee on Joint Authority
On Thursday, NRU filed the attached comments with the CAISO Governance Review Committee (GRC) urging the GRC to move forward in implementing a joint authority governance model for the Western EIM. As discussed in last week’s Portland Update, joint authority would be a positive step forward in improving EIM governance within the limitations of current California law.
BPA Publishes Final Public Safety Power Shutoff (PSPS) Policy
BPA published their entire Wildfire Mitigation Plan with the PSPS policy embedded inside the plan. BPA also published an FAQ document addressing feedback they received in response to the workshop on April 27. The Wildlife Mitigation Plan can be found here and the FAQ here. BPA’s entire wildlife mitigation webpage can be accessed here.
Recall that NRU submitted comments that were supportive of the safety aspect of PSPS, offered numerous suggestions on how BPA could improve the communications around a potential or actual PSPS event, encouraged testing of the process, urged BPA to notify customers served by assets in the highest risk category, and asked for a workshop at the end of the wildfire season to assess how the PSPS policy performed.
BPA’s response to NRU’s concerns, and those of others, was underwhelming. BPA did notify customers who are served by assets in the highest risk category and has committed to holding a workshop at the end of the wildfire season but largely did not address much needed improvements in their planned communications protocols. BPA’s final plan fails to adopt a method of communication that rapidly and consistently disseminates information regarding a PSPS to a broad swath of impacted parties. Instead they remain committed to relying on existing communications channels that are subject to too many possible points of failure or delay. We are most concerned with the potential for delay as account executives charged with carrying out the communications can only speak with one person at a time.
Given the impact a PSPS will have on affected customers, NRU will pursue further discussions with BPA decision makers to reemphasize the need for structured and consistent communications around PSPS events and get some clarity around why BPA seems reluctant to utilize technology tools to improve communications during a PSPS event.