OVERVIEW

Please see below for comments on behalf of the Cascade Renewable Transmission System (“CRTS”).

Regional Loads

Particularly in Oregon and Washington, there has been significant discussion and action around public policy goals for electrification of the transportation sector and building heating.  CRTS is requesting a sensitivity, described below, to study this impact.

Regional Resources

CRTS is concerned that public policy and Integrated Resource Plan (“IRP”) preferred resource plans, specifically in Oregon and Washington, have not been fully accounted for in Member data submittals.

Since several of the Members most recently approved IRPs do not seem to reflect new public policy requirements, such as Washington’s Clean Energy Transformation Act (“CETA”), will there be an opportunity during the planning process to update data in the model to reflect new IRPs?  If so, what is the outside date by which any revised data must be submitted to NorthernGrid in order to be reflected in the model while maintaining the overall planning schedule? 

During its 2019 IRP process, which was subsequently delayed, Puget Sound Energy (“PSE”) estimated the quantity of new renewable resources needed in order to comply with CETA.  Since PSE’s 2021 IRP is not expected to be finalized until April 2021, CRTS is requesting a sensitivity, described below, to study this impact.

Regional and Inter-regional Transmission Projects

Cascade Renewable Transmission should be 400kV DC in Figure 11.

Request that the impact to West of Cascades – North also be monitored for CRTS.

Production Cost and Power Flow Models

CRTS respectfully requests three sensitivity studies in NorthernGrid’s 2020-2021 Planning Cycle. CRTS is seeking to understand the transmission impacts associated with public policy driven renewable energy requirements and electrification in Oregon and Washington.

The public policy justifications for this transmission study request include:

1. Washington StateClean Energy Transformation Act (“CETA”)
   • Requires Washington utilities to eliminate coal generation by 2025, have 100% carbon neutral electricity by 2030, and 100% carbon free electricity by 2045
2. Oregon Clean Electricity and Coal Transition Plan (Senate Bill 1547-B)
   • Sets Oregon Renewable Portfolio Standard requirement to 50% of electricity from renewable resources by 2040
   • The RPS requirements are staged with 35% qualifying renewable generation required by December 31, 2030
3. Executive Order NO. 20-04
   • Signed by Governor Kate Brown in March 2020, this Executive Order directs state agencies to take action to reduce and regulate greenhouse gas emissions and calls for the State of Oregon to reduce greenhouse gas emissions at least 45% below 1990 levels by 2035
4. Multnomah County Resolution NO. 2017-046
   • Establishes a goal of meeting 100% of community-wide electricity needs in Multnomah County with renewable energy by 2035
5. Zero-Emission Vehicle (“ZEV”) Target (Senate Bill 1044)
   • Establishes targets for ZEV adoption in Oregon, aiming for at least 50,000 registered ZEVs by the end of 2020 and 250,000 by 2025. By 2035, targets ZEVs representing at least 90% of new vehicle sales

Study Sensitivities:

Sensitivity I – Add 5,362 MW of renewable energy generation capacity to the NorthernGrid Base Cases.

• 100% of the renewable generation to be added in Washington and Oregon east of the Cascades
• 19% Washington utility scale solar, 16% Washington utility scale wind, 33% Oregon utility scale solar, 32% Oregon utility scale wind
• Assume the generation is installed and operating for modeling the 2030 cases
• Assume generic wind and solar resource production profiles 

Sensitivity II – Assume load growth rate of 2.6% for PSE and 2.1% for PGE, 1.1% higher than each Member’s  NorthernGrid submittal.

• Assume this accelerated load growth rate is driven by electrification of building heating and transportation
• Assume this begins in 2020 and is a compounding growth rate through 2030

Sensitivity III – Run Sensitivities I and II at the same time.

Study Assumption Backup:

1. Renewable energy generation need is based on PSE and PGE IRP documentation
   • For PSE: assumed incremental renewable energy need of 4,117 MW by 2030
     •  See PSE May 29, 2019 TAG Meeting #6, page 38. Assuming 30% average resource capacity factor
   • For PGE: assumed incremental renewable energy need of 1,245 MW by 2030
     • PGE 2019 IRP identifies a need of 25 – 58 aMW of renewable energy per year beginning in 2022 in order to meet RPS requirements. The calculation assumes 41.5 aMW, the mid-point of need range, and a 30% average capacity factor for new renewable resources.
2. These renewable energy needs are in addition to the 137 MW submitted by PSE to NorthernGrid and the 350 MW submitted by PGE to NorthernGrid
3. Given the significant level of renewable generation in the Study Scope proposed to be built in Wyoming and Montana, we suggest this incremental renewable generation, designed to meet public policy requirements, is built in Oregon and Washington east of the Cascades
4. The resource type and distribution between Oregon and Washington is based on the average distribution in BPA’s active Generator Interconnection Queue.  BPA’s active Generator Interconnection Queue totals over 14,000 MW of Washington and Oregon solar and wind alone, nearly triple the amount assumed in the proposed sensitivities
5. PGE’s 2019 IRP High Electrification Case showed a 2.1% annual load growth rate, which is 1.1% greater than their NorthernGrid data submittal. To reflect a similar electrification scenario for PSE, add 1.1% to the 1.5% annual load growth rate PSE submitted to NorthernGrid.

CRTS is seeking to understand the transmission implications, particularly on WECC Paths 4, 5, and 71 of these sensitivities. CRTS is interested in whether the current ratings of WECC Paths 4, 5, and 71 are sufficient to meet renewable public policy requirements with utility scale generation located east of the Cascades and maintain reliability in the face of electrification driven load growth west of the Cascades.

Analysis Methods

Does the model have an output capability to demonstrate the production cost model is dispatching the generation in a way that is also meeting all of the 2030 public policy requirements of Members?

Cost Allocation

No response submitted.

Other

Thank you for considering our comments and please do not hesitate to contact us with any questions.

Corey Kupersmith – Sun2o Partners – Corey@sun2o.com

Jeff Wood – PowerBridge – Jwood@powerbridge.us