OVERVIEW

Gallatin Power Partners, LLC (Gallatin Power) appreciates the work that NorthernGrid is doing to further the interests of Regional Transmission Planning and the opportunity to provide comment on the 2022-2023 Draft Regional Transmission Plan.

Please submit your thoughtful and constructive comment here.

Gallatin Power Partners, LLC (Gallatin Power) appreciates the work that NorthernGrid is doing to further the interests of Regional Transmission Planning and the opportunity to provide comment on the 2022-2023 Draft Regional Transmission Plan.  

Gallatin Power is a renewable energy development group based in Bozeman, Montana. The Gallatin Power team has historically developed utility scale, solar and battery energy storage projects in the WECC.  Gallatin Power is currently involved in the development of a large, interregional transmission project in the WECC region. 

Gallatin Power encourages NorthernGrid to expand its planning horizon to a minimum of 20 years in future cycles to align with the FERC NOPR RM21-017 issued April 21, 2022[1], the California Independent System Operator (CAISO) 20-Year Transmission Plan, and with similar efforts at WECC in the 20+ Year Long-Term Transmission Planning Task Force.  The regional and interregional transmission projects needed to deliver large amounts of renewables throughout the Western Interconnection, are long-lead time infrastructure projects that can take decades to develop and construct.  Gallatin Power believes that the change proposed in the FERC NOPR RM21-017 to require a minimum 20-year regional transmission planning horizon would allow NorthernGrid to proactively identify future transmission needs. 

Gallatin Power also encourages NorthernGrid to model sensitivities that expand the amount of renewable resource additions in the Regional Planning evaluation beyond utilities’ most recent stated needs.  Forecasted renewable demand in the Pacific Northwest is increasing in each subsequent planning  cycle for utilities and planning groups alike.  Pacific Northwest Utilities Conference Committee’s (PNUCC) 2023 Northwest Regional Forecast found that utilities in the Northwest Regional Planning Area[2] are planning to add 17,000 MW of renewable resources between 2023 and 2033, and will face a 5,000 MW deficit during summer peak load net of the 17,000 MW in 2033[3].  The same PNUCC 2023 Northwest Regional Forecast notes that Pacific Northwest load is forecasted to increase 20% by 2028 from 2023 levels, attributed to new industrial loads and electrification. For comparison, the PNUCC 2022 Northwest Regional Forecast[4] found that utilities in the Northwest Regional Planning Area were planning to add 11,000 MW of renewable resources between 2022 and 2032. The 6,000 MW increase between the 2022 and 2023 Northwest Regional Forecast highlights the significant increase in resource additions that can occur from one planning cycle to the next.  In light of the load growth, significant increase in resource additions between 2022 and 2023 and the forecasted 5,000 MW deficiency in 2033 projected by the PNUCC, Gallatin Power encourages NorthernGrid to study sensitivities that expand the amount of necessary future renewable resources beyond each NorthernGrid member’s submitted load forecasts and resource additions in subsequent planning cycles.  Only including utilities’ prior planned resource additions and load forecasts will perpetuate a shortfall in the Regional Planning Process.  Modeling sensitivities beyond utilities’ planned resource additions and load forecasts is necessary to account for the trend towards higher than expected load growth, and also to ensure that NorthernGrid is not left unprepared for the transmission needs that this load growth requires.

Gallatin Power supports the inclusion of a High Wyoming Wind Export Case sensitivity in the 2022-2023 Draft Regional Transmission Plan.  For future planning cycles, Gallatin Power encourages NorthernGrid to evaluate a similar scenario for Nevada Renewable Generation.  There is significant renewable energy development interest in Nevada, particularly in northern and central Nevada. This generation is non-coincident generation for the Pacific Northwest utilities, is largely on public lands, and faces less permitting challenges than other areas of the WECC.  Gallatin Power presents the following summary of the favorable position of Nevada renewable resources and urges the consideration of a similar Nevada Renewable Generation scenario for inclusion in subsequent cycles. 

The U.S. Department of Interior (DOI), Bureau of Land Management (BLM) and Argonne National Laboratory prepared a map titled “Wind Resources, Exclusions, and Resource Sensitivities on BLM Administered Lands in Nevada”[5] which illustrates the substantial wind potential areas in central and northern Nevada. It is important to note that the wind speed data presented in the map assumes a wind turbine height of 80 meters. Even with a relatively low hub height of 80 meters, there are 6,788,647 acres of BLM land with a wind speed of 5 m/s or greater that have a “Moderate Level of Siting Considerations”, with almost all of the land located in central and northern Nevada. Wind development interest in central and northern Nevada is already very high. As of November 2023, the BLM Mineral & Land Records System showed 22 active Nevada wind projects within the BLM Bristlecone Field Office, Eagle Lake Field Office, Humboldt River Field Office, Sierra Front Field Office, Stillwater Field Office, Tonopah Field Office, and Wells Field Office territories.[6]

There is also substantial potential for geothermal energy in central and northern Nevada. A map prepared by the National Renewable Energy Laboratory (NREL) titled “Geothermal Resources of the United States”[7] illustrates the relative favorability for geothermal potential in the greater Nevada area. Favorability is generally greatest in northwestern Nevada, with high favorability ratings in Esmeralda County continuing to the north. On November 14, 2023, the BLM held a competitive lease auction for geothermal leases[8], predominantly in central and northern Nevada, through which 96,605.5 acres of BLM lands were secured by geothermal developers.[9]

Esmeralda County is also a center for solar and storage development in Nevada. As of November 2023, there are 14 active applications for large-scale solar and storage facilities on BLM lands in Esmeralda County, totaling over 11,000 MW. This area is particularly attractive for solar development due to its strong solar resource, low environmental and cultural sensitivity and the low-cost land lease rates available on BLM lands.

Furthermore, Gallatin Power would like to draw attention to the Energy Community designation for almost the entire state of Nevada. This classification renders the region eligible for bonus Investment Tax Credit (ITC) and Production Tax Credit (ITC) under the Inflation Reduction Act. The U.S. Department of Energy maintains an interactive online map identifying the Energy Community Tax Credit Bonus locations[10] and as of November 2023 the majority of Nevada qualifies. Leveraging the federal Energy Community bonus incentive would lead to lower cost renewable energy resources for ratepayers when compared to resources in states with little or no designated Energy Community areas, such as Idaho, Oregon and Washington.  

In conclusion, Gallatin Power appreciates the work that NorthernGrid is doing to further the interests of Regional Transmission Planning and the opportunity to provide comment on the 2022-2023 Draft Regional Transmission Plan. For future cycles, Gallatin Power recommends that NorthernGrid expand its planning horizon to a minimum of 20-years.  Extending the planning horizon would establish a framework that supports the long-term needs required for significant regional and interregional transmission projects necessary to support the additions projected for the NorthernGrid region and the entire Western Interconnection. NorthernGrid should also model sensitivities with load and resource addition assumptions greater than those of the most recent study plans submitted by utilities to account for the observed annual trend towards increasing load growth and accompanying resource need. Lastly, Gallatin Power recommends that NorthernGrid include a high Nevada Renewable Generation scenario in future cycles. 

 

[1] https://www.federalregister.gov/documents/2022/05/04/2022-08973/building-for-the-future-through-electric-regional-transmission-planning-and-cost-allocation-and#h-27

[2] The Northwest Regional Planning Area is the area defined by the Pacific Northwest Electric Power Planning and Conservation Act (the Act). It includes: the states of Oregon, Washing, and Idaho; Montana west of the Continental Divide, portions of Nevada, Utah, and Wyoming that lie within the Columbia River drainage basin; and any rural electric cooperative customer not in the geographic area descried above but served by BPA on the effective date of the Act.

[3] https://www.pnucc.org/wp-content/uploads/2023-PNUCC-Northwest-Regional-Forecast-final.pdf

[4] https://www.pnucc.org/wp-content/uploads/2022-PNUCC-Northwest-Regional-Forecast-final.pdf

[5] https://wwmp.anl.gov/downloads/Nevada_State_Map.pdf

[6] https://mlrs.blm.gov/s/research-map#3,39.26108512157382,-119.64061973328837

[7] https://www.nrel.gov/gis/assets/images/geothermal-identified-hydrothermal-and-egs.jpg

[8] https://www.blm.gov/press-release/blm-hold-november-geothermal-lease-sale-nevada 

[9] https://www.blm.gov/sites/default/files/docs/2023-11/NV_Geot_20231114_Comp_Sale_Results.pdf 

[10] https://arcgis.netl.doe.gov/portal/apps/experiencebuilder/experience/?id=a2ce47d4721a477a8701bd0e08495e1d

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