OVERVIEW
The Cascade Renewable Transmission System (“CRTS”) team is grateful for the opportunity to provide comments on NorthernGrid’s first Draft Regional Transmission Plan (“D-RTP”) for the 2020 – 2021 Planning Cycle.
Editorial Comments
No response submitted.
Technical Findings
CRTS appreciates the transparency of the NorthernGrid process and the hard work of Members in developing the D-RTP. Driven largely by renewable public policy and other critical trends, the Pacific Northwest’s energy mix is expected to enter a period of historic change, which makes the creation of NorthernGrid and execution of its intended objectives particularly valuable.
The importance of NorthernGrid’s efforts is underscored by recent events and ongoing trends. The passage of groundbreaking public policy -- the Clean Energy Transformation Act (“CETA”) in Washington, requiring 80% renewable electricity supply by 2030, and HB 2021 in Oregon, also requiring 80% renewable electricity supply by 2030 -- will accelerate regional decarbonization and expedite a significant build-out of renewable energy generation during this NorthernGrid cycle’s planning horizon of 2030. At the same time, as the D-RTP was in development, wildfires and record heat waves have highlighted the critical importance of infrastructure resiliency and the need for robust, long-term, transmission planning to adequately serve customers as the impacts of climate change continue to reverberate throughout the region.
As the D-RTP states, “The objective of the planning process is to identify the projects that more cost effectively or efficiently meet the needs of the NorthernGrid members in a 10-year future.” All stakeholders and interested parties would certainly agree that projecting anything, let alone regional energy loads and resources, 10 years into the future is riddled with uncertainty. For that reason, the quality and credibility of the D-RTP is strongly dependent upon the assumptions used to make it. We are concerned that public policy requirements, Member planning documents, and recent system load data paint a different picture than that drawn in the NorthernGrid Study Scope. Without robust Study Scope assumptions that are aligned with actual data, events, and evident trends, identifying the projects that will meet actual Member needs in the future becomes that much more difficult.
CRTS understands that Study Scope assumptions are determined earlier in the Planning Cycle. That said, if new transmission is necessary to meet the 2030 public policy requirements established in CETA and HB 2021, losing two years between the current Planning Cycle and the upcoming 2022-2023 Planning Cycle to establish that fact could be highly detrimental to meeting the requirements and needs of 2030 and beyond. Given the unprecedented change to the Pacific Northwest’s energy mix that is already underway, load and resource assumptions used to develop the D-RTP appear to be both meaningfully outdated and insufficient for satisfying public policy requirements. The performance of a sensitivity analysis in this Planning Cycle would strengthen the Study and add weight and relevance to the Draft Plan.
Regional Projects
No response submitted.
Interregional projects
No response submitted.
Needs More of the Following: Describe
CRTS continues to be concerned that Public Policy requirements and Integrated Resource Plan (“IRP”) preferred resource plans, specifically in Oregon and Washington, have not been accounted for in Member data submittals.
Currently, in the NorthernGrid modeling, PSE is assumed to add a mere 137 MW of new resources by 2030, and PGE is assumed to add 350 MW of new resources. These projects, the Skookumchuck wind farm and the Wheatridge Renewable Energy Facility respectively, are in construction or already operational -- meaning that no new renewable energy projects are studied as coming online throughout the rest of the decade. However, substantially more projects will need to be built by 2030 for these Members to meet their public policy requirements.
PSE’s Final 2021 IRP, which for the first time incorporates the impacts of CETA, plans for the procurement of ~1,800 MW of utility scale solar and wind through 2030 to meet its public policy requirements[1]. This new renewable generation capacity is not reflected in the Study Scope and is in addition to the 137 MW project submitted to NorthernGrid.
In testimony to HB 2021, PGE stated it will need 1,700 MW of new renewables, in addition to Wheatridge’s 350 MW modeled in the Study Scope, to meet its public policy requirements with the passage of HB 2021[2].
Thus, taken together, NorthernGrid new resource assumptions are ~3,500 MW short of what PGE and PSE alone will need to procure through 2030 to meet their public policy requirements. The majority of this ~3,500 MW of new resources will be constructed east of the Cascades, as evidenced by BPA, PSE, and PGE generator interconnection requests. As PSE states in their 2021 IRP, “[I]n the long term, the Pacific Northwest transmission system may need significant expansion, optimization and possible upgrades to keep pace. The main areas of high-potential renewable development are east of the Cascades (Washington and Oregon), in the Rocky Mountains (Montana, Wyoming), in the desert southwest (Nevada, Arizona) and in California.[3]” To fully meet its stated objective, NorthernGrid should determine in this Planning Cycle if the existing transmission system is sufficient to deliver to load these new resources, needed for Members to meet their public policy requirements, and if not, where any constraints exist.
We understand that PSE’s Final IRP was not complete when the Study Scope was finalized and that HB 2021 is not yet included in PGE’s IRP. Regardless, we are concerned with how far apart the Study Scope assumptions are to the current planning reality. This divergence creates risk for customers and utilities by hindering the development of projects that can meet these imminent Member needs, and exacerbates the risk that by the time a transmission need is identified, it will be too late.
CRTS is also concerned that Member peak load assumptions used to create the D-RTP do not fully account for recent climate related events and long-term growth trends.
Three major trends are driving general load growth and peak demand for Oregon and Washington utilities. The first is industrial demand driven primarily by data centers and other high-tech industry. The second is record heat waves, occurring with increasing frequency due to climate change, which also accelerate the adoption of air conditioning by utility customers. The last is the electrification of buildings and transportation, both of which will see long-term public policy driven growth.
PGE’s 2030 peak summer load assumptions are a good example of the gap between NorthernGrid assumptions and independent data sources. NorthernGrid’s Study Scope uses a 2030 peak summer load assumption for PGE of 3,949 MW. PGE’s Local Transmission Plan assumptions and system data from the record June heatwave highlight a substantially different need. In PGE’s 2020 Near Term Local Transmission Plan, PGE studied a summer peak system load in 2030 of 4,711 MW, over 750 MW greater than the load studied by NorthernGrid[1]. During the recent heatwave, PGE twice set new peak load records, with the highest of 4,441 MW on June 28th, 2021, a peak demand ~500 MW greater than that studied by NorthernGrid[2]. Clearly, it is difficult to project the need for projects to meet PGE’s future peak loads if load assumptions are flawed or outdated.
All the important work completed to date in the inaugural NorthernGrid Planning Cycle could be undermined if these efforts stop short of considering alternative scenarios that may better reflect current public policy realities and ongoing trends. We respectfully suggest that running a sensitivity analysis would provide very meaningful information regarding the potential to achieve the 2030 public policy requirements and determine if any significant transmission constraints exist:
The sensitivity would reflect an incremental 3,500 MW of new renewable resources being constructed by 2030. In this sensitivity, we would propose using PGE peak summer demand of 4,711 MW, which is used in their own local transmission studies. We suggest the resources be modeled to reflect the production characteristics of 1,000 MW of Wyoming wind, 800 MW of Montana wind, 1,000 MW of Columbia Gorge wind and 700 MW of eastern Oregon solar. In order to minimize the modeling complexities and the implications which may stem from other system constraints, we suggest the resources are assumed delivered to Mid-C.
CRTS believes this sensitivity will help the stakeholders of NorthernGrid to understand the transmission implications, particularly on WECC Paths 4, 5, and 71 of meeting the current public policy requirements.
We note that nothing in NorthernGrid’s approved tariff would prevent the inclusion of such a sensitivity in the D-RTP, and further believe that doing so could materially enhance its credibility and relevance to the planning efforts of its Members, the states, and the region as a whole.
Thank you for considering our comments, and please do not hesitate to contact us with any questions
[1] PSE 2021 Final IRP, Figure 1-4 Electric Preferred Portfolio.
[2] Brooke Brownlee on behalf of PGE, submitted to Oregon House Energy & Environment Committee 4/7/2021.
[3] PSE 2021 Final IRP, 2-20.
[4] PGE 2020 Near Term Local Transmission Plan, Figure 6.
[5] Per PGE spokesperson Allison Dobscha, as published in The Oregonian July 29th.
Graphics
No response submitted.
Open Topic
No response submitted.
