NRU Comments to the Northwest Power and Conservation Council on Energy Efficiency Targets
As promised, today NRU submitted comments to the Northwest Power and Conservation Council detailing legal concerns as the Council sets energy efficiency targets in the upcoming Power Plan. NRU’s comments point out that the Northwest Power Act and Ninth Circuit Court of Appeals caselaw require the Council to follow its own forecasts when setting energy efficiency targets and establish only cost-effective energy efficiency standards. Our goal with the comments is to warn the Council that the law does not allow it to create energy efficiency standards that are higher than the models support or write standards that are not cost effective. Bonneville’s energy efficiency program must be “consistent” with the Council’s Power Plan, and, although the Administrator has the final say in determining what this means, unlawful efficiency standards in the upcoming Power Plan could ultimately be costly to NRU members. A copy of NRU’s comments to the Council are attached to this update.
Post-2028 Forum: Education on Non-Federal Resources
At this week’s BPA and public power post-2028 forum, the topic was use of non-federal resources under the Regional Dialogue contracts. As usual, the background materials provided by BPA were informative; we encourage you to review the materials when you have a chance.
Most of the dialogue beyond asking clarification questions was on the current 200 kW threshold requirement, which requires all non-federal resources greater than 200 kW nameplate be added to Exhibit A of a customer’s Regional Dialogue contract. This triggers requirements for transmission, metering, resource support services, etc. There is an exemption to not purchase resource support services for a small, non-dispatchable (i.e., renewable) resource with a nameplate of 1 MW or less.
NRU staff and members pointed out the opportunity to increase resource integration and flexibility by increasing the threshold to greater than 200 kW or 1 MW. A couple of NRU members suggested a new threshold of 10 MW. Megan Stratman observed that there could be different thresholds for different purposes – just because transmission might have reasons for a lower threshold, doesn’t mean power needs to use the same threshold. BPA staff will share some analysis of potential risks and cost shifts if the threshold were raised during the next meeting on this topic, which is scheduled for July 27.
As a reminder, BPA’s Provider of Choice website contains the materials from these BPA/public power forums, plus an assortment of background materials on a variety of topics related to BPA power supply.
Columbia Basin Collaborative (CBC) Holds Second Webinar
Yesterday the CBC held its first webinar since the February kickoff webinar. The webinar was well attended with over 200 attendees even though the agenda looked surprisingly like the agenda from the February kickoff. Attendee names and affiliations were not listed but a poll of the attendees showed that the vast majority were from some level of government or an NGO and only 13 were from utilities; NGOs are typically environmental advocacy groups.
The webinar lasted for three hours but covered only one topic. That topic was a high-level overview of the CBC purpose and proposed approach. The webinar allowed ample time around that topic for comments and feedback by attendees as a nod to the collaborative intent of the process.
A key construct of the CBC is the intent for there to be a plenary group, now called the Integration/Recommendations Group (IRG) who will collect input primarily from topic specific workgroups and from regional and sector caucuses. The flow is depicted in the graphic below:
What caught the attention of myself and several others listening to the webinar was the ability to self-select for inclusion on a topic-specific workgroup. This means that anyone with an interest could submit their name to be included on a workgroup. The obvious concern when looking at the affiliations of attendees from the poll results is that each workgroup is almost certain to be populated primarily by non-utility participants. Consequently, it is reasonable to assume that information fed up to decision makers on the IRG will be weighted in favor of environmental interests or more bluntly said, against energy interests. We will be keeping an eye on this as the process develops and looking for opportunities to ensure fairness within the process. Luckily, two long time stalwarts of public power, Debra Smith and Joe Lukas, have been submitted as utility representatives on the IRG.
State representatives speaking at the webinar announced their intentions to move the process forward at a fairly quick pace, as shown in the graphic below, but several attendees voiced concern over the ability to conduct a valid process on this schedule while others voiced skepticism that the proposed schedule could be adhered to. Given that over three months passed between the first and second webinars, I would expect the schedule to lag considerably. NRU will continue to monitor activity of the CBC as it progresses.