OVERVIEW

The NW Energy Coalition (NWEC) appreciates the opportunity to provide these comments. We view the draft as making solid progress in the first planning cycle following the consolidation of Northern Tier Transmission Group and ColumbiaGrid into NorthernGrid. Our recommendations fall into two categories: additions of summary tables that would substantially improve the final report, and early consideration of factors that should be incorporated into the next planning cycle in 2022-2023.

Editorial Comments

We recommend the inclusion of several summary tables in the final report to document the findings more completely and provide helpful context for readers:

In the main text:

• A table summarizing all transmission expansion projects studied, including the owner/proponent, end point substations or locations, voltage, approximate distance and MW capacity, and estimated year of entry into service.
• A table summarizing the full list of all regional combinations (RC) and their variants, showing which projects are included with each RC and any additional distinguishing details.  Even Figure 12 showing ranked contingency results contains “the entire set of results for the majority of the combinations considered” and is not apparently complete.  Also, if all base cases were not run for each RC, the ones that were used should also be indicated.

In an appendix:

• A table for each of the 8 Planning Cycle base cases showing, for each RC studied, the results for the contingency analysis (number of high/low voltage and thermal violations and the overall totals).
• A table for each of the 8 Planning Cycle base cases showing, for each RC studied, the results from the production cost analysis, including overall production cost and other useful metrics such as unserved energy, CO2 emissions and utilization rates for key paths.

Technical Findings

No response submitted.

Regional Projects

No response submitted.

Interregional projects

No response submitted.

Needs More of the Following: Describe

No response submitted.

Graphics

No response submitted.

Open Topic

NWEC recognizes that NorthernGrid members and stakeholders have devoted considerable time to developing a new study plan, reviewing data submissions, preparing assumptions and making other adjustments necessary to run the modeling for the 2020-2021 Regional Transmission Plan. 

With the draft report now in hand and the next planning cycle starting in a matter of months, we offer the following observations on enhancements that should be considered to substantially improve the “actionable information” in the 2022-2023 Regional Transmission Plan.

State and federal policy.  It will be important for NorthernGrid to be nimble in the next planning cycle to incorporate ongoing policy changes relevant to regional transmission planning.  Rulemaking continues for existing policies such as the Clean Energy Transformation Act (CETA) in Washington, and significant changes will be coming from the Climate Commitment Act (CCA) in Washington and the 100% Clean Energy law (HB 2021) adopted by Oregon earlier this year.  In addition, Congress is considering a Clean Energy Standard along with other relevant legislation.  And both Congress and FERC are considering reforms that may directly affect Order 1000 regional transmission planning.  In addition to preparation of the initial Study Plan in 2022, NorthernGrid should consider a more robust update to the Study Plan in early 2023 to accommodate ongoing changes.

Additional scenarios and sensitivities.  In the next cycle, NorthernGrid should consider studying a wider range of scenarios and sensitivities based on the ongoing changes in the regional demand pattern and resource mix:

• Climate impacts.  Two events this summer illustrate the rapidly changing context for the bulk electric system in the NorthernGrid footprint.  On June 26-28, an unprecedented heat wave raised demand to historically high levels for multiple utilities.  And less than two weeks later, wildfire smoke caused outages on three lines of the AC Intertie (California-Oregon Intertie), leading to a 90% reduction in path capacity and a precautionary reduction of more than 50% of capacity on the DC Intertie.  Furthermore, this occurred in a context of a low water year in the west, with reduced hydropower output across the region.  There are indications that climate change has already been resulting in more variability of aggregate demand patterns and the performance of hydro and other renewable resources, and will continue at a more rapid pace in the near future.  These occurrences suggest additional sensitivities for studying correlated impacts on the bulk electric system beyond the set of standard contingencies currently being considered.
• Gas-electric interface.  Events of the last several years also highlight the increased vulnerability of the NorthernGrid footprint to price and supply disruptions for gas transportation used by natural gas power plants.
• Transportation and building electrification.  Significant changes to regional demand shapes are anticipated over the next decade from new sources of load.  A further important question is whether such new loads will be actively shaped for both economic reasons and to reduce reliability risks.
• Market development.  Numerous efforts are underway to improve economic dispath and reliability through extension or development of new markets in the Western Interconnection.  Consideration should be given to modeling different development approaches and provide important feedback to those development efforts.
• Modeling of inverter based resources.  The rapid uptake of inverter based resources, for example in wind, solar and battery storage facilities, requires further consideration of both the challenges and the opportunities offered by resources interfacing with the grid through power electronics.
• Location of new renewable resources.  In the past, transmission expansion has generally focused on well-delineated development areas.  Going forward, the capability of new renewable resources is rapidly improving and economically viable development can occur across a wider landscape, which is also beneficial for resource diversity and performance.  In the next cycle, NorthernGrid should consider where new transmission might most effectively be placed to capture the value of more diverse renewables, particularly offshore wind.
• Storage as a transmission asset.  With the rapidly declining cost of battery storage and the maturation of several pumped storage projects, NorthernGrid should consider the potential benefits of transmission-related storage in enhancing the reliability and carrying capacity of the existing system and optimizing transmission expansion.