NW Power and Conservation Council
The draft of the NW Power Council’s 2021 Regional Power Plan was released at the end of September. The Coalition has been deeply involved in the plan development. We encourage the Council to adopt a more balanced strategy that better reflects the role of energy efficiency in the clean energy future, continues BPA’s leadership role, incorporates other clean energy technologies, and recognizes the role of customer-side resources, distributed generation, and electrification. In October, the NW Power Council completed its four-state hearings on the 2021 Northwest Power Plan. Turnout from organizations and people supporting NWEC’s priority points was consistent across the states.
We are currently in a 60-day comment period ending on Nov. 19, where we encourage members and our broader community to have their voices heard. The Coalition hosted two webinar sessions in October, to inform the public on the Power Plan process and how to provide public input. For more information on these sessions click here.
The COVID-19 pandemic has impacted communities throughout the NW in different ways. State governments in Montana and Idaho did not address disconnections and arrearages as a result of the pandemic, while Washington and Oregon did. The Washington utility shutoff moratorium ended on September 30, and the Oregon disconnection moratorium ended on July 16. We encourage people to stay in touch with their utility company, as some are extending protections for special cases and have access to COVID-19 assistance funds for bill payment support.
- The Washington Department of Commerce and the Utilities and Transportation Commission have put together a partner toolkit on utility bill assistance services and support programs, translated into different languages.
- The Oregon Public Utility Commission has a summary page for all its COVID-19-related information.
Salmon and Energy
Governor Inslee and Senator Murray released an announcement on October 22, on a collaborative initiative to identify how to replace the services provided by the lower Snake River dams and to develop a comprehensive solution for salmon recovery. There are reliable and affordable clean energy options that can help restore salmon and protect the environment. In 2018, the Coalition undertook an investigation as to the technical feasibility and cost of replacing the power and energy services provided by the Lower Snake River Dams with a portfolio of clean and renewable energy services. To learn more about this study, click here. Since 2018, more clean energy options have become available and accessible, making the possibility of a balanced clean replacement portfolio even greater. The Coalition is working to update its analysis showing that there are adequate, affordable and zero greenhouse gas power solutions available to replace the energy services provided by the lower Snake River hydropower projects.
The NW Energy Coalition is ready to sit down with utilities, BPA, the Power Council, and other stakeholders to examine what energy services are needed and what alternatives can provide the same services and system reliability.
Regional Coordination and Market Development
Resource adequacy is the ability of the power grid to provide enough resources for customer demand in every hour. The Northwest Power Pool Resource Adequacy program is expected to start with a voluntary phase in 2022 and a full program by 2024. Currently, 23 utilities and other organizations are working together to move into the active but voluntary phase over the next year. With a new committee structure, this will be a way for utilities to plan and coordinate when the system is stressed.
The California Independent System Operator (CAISO) operates the power and transmission system for about three-quarters of California, and the Energy Imbalance Market (EIM) for much of the west. CAISO currently has a proposal for an Enhanced Day Ahead Market (EDAM), with an expected go-live date in 2024, providing the next step forward toward a full western power market. There is also a competing market effort by the Southwest Power Pool (SPP), which is preparing “RTO West” to go into effect in parts of Colorado and other states in 2024. This October, a dozen utilities, including Seattle City Light, PacifiCorp, PGE and Idaho Power, formed a Western Electricity Markets Group (WEMG) to be a discussion forum considering EDAM and SPP efforts.
The Federal Energy Regulatory Commission (FERC) has issued an Advance Notice of Proposed Rulemaking (ANOPR) on transmission planning and cost allocation. This is a major initiative given the need to expand the ability of the transmission system to meet climate and clean energy goals. Over 170 comments were submitted. NWEC, along with others, co-signed a filing from the Sustainable FERC Project representing Public Interest Organizations. Reply comments are due in November, and then FERC will issue the formal NOPR (Notice of Proposed Rulemaking) early next year.
The Bonneville Power Administration (BPA) is launching a financial plan update process to be completed in the middle of 2022. This will be helpful for BPA’s borrowing authority and the possibility for better information systems and infrastructure improvements. BPA is also joining the Western Energy Imbalance Market (EIM) in March 2022. Although BPA has been supportive of the EIM, it has never been a part of it. Joining the EIM will help the BPA system provide more value, help with reliability, and with renewable energy integration.
State Regulatory and Policy Highlights
- Department of Ecology Rulemakings:
- Clean Vehicles Program: Ecology plans to adopt the Zero Emission Vehicle standard and Advanced Clean Truck rule by November 29/30, 2021 (rulemaking information). Stakeholder comments can be found here. NWEC, along with other organizations, is also advocating for Ecology to adopt fleet reporting requirements.
- Clean Fuels Program: Ecology released a CR 101 for the Clean Fuels Program and is holding a series of stakeholder meeting. Informal public comment is open through April 10, 2022.
- Climate Commitment Act: Ecology held their first stakeholder meeting on November 8, 2021. More information about the rulemaking can be found here.
- Updates on Accessible Public Charging (SB 5192): Washington State Department of Agriculture has kicked off a rulemaking as a result of SB 5192 (2021). The rules will require EV charging providers to make certain payment methods available, maintain interoperability standards, and report to the alternative fuel data center. Rules must be adopted by January 1, 2023.
- BGA Zero Emission Vehicle Working Group: We are participing in BlueGreen Alliance’s Zero Emission Vehicle Working Group with IBEW to discuss an Electric Vehicle Infrastructure Training Program (EVITP) policy that would advance labor standards at EVSE installations. The Coalition is working to understand the impacts of an EVITP policyand how complementary policies could increase access for women and Black, Brown, and Indigenous folks to careers in the clean transportation sector.
- Washington State Energy Code updates are underway for the commercial energy code. A number of energy efficiency improvements have been proposed, including requiring heat pumps for most space and water heating uses. A public comment period will open later this year, to last for 60 days and include two public hearings; we will keep you updated with these details.
- There are a number of discussion and rulemaking dockets open at the Utilities and Transportation Commission (UTC) that Coalition staff is participating in or plans to track.
- U-210553 will assess the pathways for gas utilities to meet their share of the state’s greenhouse gas emission reduction targets.
- U-210590 is a proceeding to develop a policy statement addressing alternatives to traditional cost of service rate making, including performance measures or goals, targets, performance incentives, and penalty mechanisms, as authorized by 2021’s SB 5295.
- U-210595 is assessing the policy around intervenor funding, authorized by 2021’s SB 5295.
- UG-210729 was an open meeting regarding the methodology for natural gas line extension allowances.
- U-210800 is a staff investigation to consider possible changes to customer notice, credit and collection rules, late fees, disconnection fees, reconnection fees, and deposits
- UE-210804 is going to discuss a UTC jurisdictional specific cost-effectiveness test incorporating CETA policies.
- Seattle Building Performance Standard: On Monday, November 1, Seattle Mayor Durkan issued an executive order directing city agencies to take action on a number of climate policies and programs, including developing a carbon-based building performance standard. NWEC in partnership with the 2050 Institute, and as part of the American Cities Climate Challenge, developed a Blueprint for how the city of Seattle could design this kind of policy, as well as the needed supportive policies to ensure that this policy supports other public policy goals, including housing protection and workforce development. You can take a look at the Blueprint here.
- CETA: The UTC released the proposed Clean Energy Transformation Act (CETA) “use” rules. Comments on the rules are due November 12th, with a hearing expected sometime in December. NWEC is concerned about the direction of the proposed rule and its potential impact on clean energy development.
- Clean Energy Implementation Plan: The Consumer-owned utilities (COUs) are working on their Clean Energy Implementation Plans (CEIPs) that are due by January 1st. Puget Sound Energy (PSE) submitted the draft CEIP on October 15th, and is requesting comments to PSE by November 12th, with the final due December 17th. We are closely reviewing the draft. Avista submitted its final CEIP on schedule; we are now reviewing the final CEIP, with comments due January 28th. Pacificorp’s draft CEIP is due November 1st.
- Governor Inslee signed Executive Order 21-04 directing state agencies to transition towards 100% zero emission vehicle fleets.
Coalition staff are tracking a number of proceedings underway at the Oregon Public Utilities Commission (OPUC):
- UM 2005 (distribution system planning) – On October 15 the first part of the DSP was filed by Pacific Power, PGE and Idaho Power; the second part will be filed in August 2022. The OPUC will do an acceptance process and Coalition staff are going through these detailed filings and will submit comments. NWEC is looking to get more groups involved in this process. To get involved contact Marli Klass at email@example.com.
- UM 2011 (general capacity investigation) covers Effective Load Carrying Capability (ELCC),cost for capacity, and more. The Oregon commission has had this docket open for nearly three years. NWEC and partners objected to the continued effort to push this through before the full range of issues has been covered. OPUC Staff submitted a proposal on Sep. 30, and the Coalition and others submitted comments. In a Nov. 4 review, Commissioners expressed concerns about the overall direction of the docket, and a follow-up technical workshop is scheduled for Nov. 16. It now appears that a standardized capacity value will be developed using the ELCC method but not applied to IRPs, RFPs and Resource Adequacy, but much remains unclear.
- UM 2165 (Transportation Electrification Investment Framework) – Identified as a priority within the PUC EO 20-04 Work Plan, the Transportation Electrification Investment Framework (TEIF) is intended to address barriers to utility investments in transportation electrification (TE) and develop a process for the Commission to approve utility TE investments. With the passage of HB 2165 (2021) that directs PGE and PAC to collect a monthly meter surcharge equal to .25% of total revenues from all retail electricity customers to support TE, the scope of UM 2165 expanded to develop guidance on how to implement this. On October 20th, staff presented on next steps including draft interim guidance, the potential framework to ensure 50% of TE investments from the monthly meter surcharge benefit environmental justice communities, and options for a rulemaking in 2022. NWEC is currently collaborating with other advocacy organizations and PGE to provide input and develop performance metrics.
- UM 2114 (COVID-19)/HB 2475 (Energy Affordability) – Advocates are finishing up comments on how to handle disconnections (or even whether to have disconnections) as part of the “alternatives to disconnection” process the PUC’s DEI director is running. A report from this process is expected to be done by mid-December. Advocates are also continuing to monitor utility Arrearage Management Programs and ensuring that disconnections remain few following the end of the disconnection moratorium earlier this year. Utilities continue to report data in their ongoing Arrearage Management Plans. Connected to that and also in anticipation of the start of the HB 2475 implementation process, PGE is developing a bill discount program.
- UM 2195 (HB 3141 Implementation – Public Purpose Modernization) – The Oregon PUC has opened a docket to begin the implementation of HB 3141. There was a workshop on Oct. 27 to begin to discuss how to define “low- and moderate-income customers” (LMI) and “distribution system-connected technologies” (DSCT), which the Energy Trust will need to include. “The LMI and DSCT definitions will be used by Energy Trust in its administration of the renewables portion of the PPC. The DSCT definition may also be referenced by ODOE in its oversight of large electricity consumers that apply to self-direct the renewable portion of their public purpose charge.”
- HB 2475 (energy affordability bill) Updates: This allows the PUC to take into account EJ issues and economic issues and existing intervenor funding to include orgs that are practicing or for the commission with low-income focus. The dockets are not open yet, but the PUC will have its first implementation workshop on November 10.
- HB 2021 Updates – requires electric utilities to cut emissions. Not officially underway.
- UM 2178 (natural gas fact finding) – Comments on the modelling alternative scenarios were due September 24. The NW Energy Coalition has participated in the various workshops for this docket. Staff will be posting alternative scenario compliance models on November 17 and a draft report December 10; comments will be accepted on both of these.
- SB 589 (Oregon Dept. of Energy RTO study) – requires ODOE to provide an initial report to the legislature by December 2021 on the prospects for developing a regional transmission organization. Senior Policy Associate, Fred Heutte, is serving on the advisory committee. Comments are available here.
- The Oregon Environmental Quality Commission is scheduled to take action on the Clean Truck Rules on November 17, 2021. DEQ is proposing to adopt CA’s Advanced Clean Trucks rule, including the fleet reporting requirement, and the Heavy-Duty Omnibus rule. NWEC submitting comments in support of the rule and the Clean Air Healthy Communities coalition is supporting adoption.
- Net Metering – The Idaho PUC continues to wrestle with net metering issues as various utilities attempt to quash the resource. The PUC is currently taking comments on a study commissioned by Idaho Power looking at the costs, benefits, and potential compensation rates for energy delivered to the grid.
- NorthWestern Energy (NWE) gas pre-approval docket (Docket 2021.02.022): This docket is officially over after NWE withdrew their application citing supply chain issues. NWE plans to accelerate the construction timeline for the Laurel Generating Station (gas) with an in-service date prior to the 2023-2024 heating season. Despite intervenor’s attempts to get more information as well as admonish the utility for filing and withdrawing an application twice in two years, Commission staff agreed with NWE’s argument that withdrawal of the application means no further action/process can legally be taken by the Commission. NWE will attempt to rate-base the asset through a general rate case once operational.
- NWE Electricity Technical Advisory Committee (ETAC) /Resource Procurement Plan NWE has begun its next round of planning, with a filing expected at the end of 2022. Additional resources in the plan include166 MW of QF solar and 314 MW of QF wind in 2022. It currently has 17MW of solar online – assign 1MW of peak load contribution (5:00-7:00 pm in winter). The planning process and completeness/findings of the final plan could hinge on the new planning rules, currently being developed by the Commission after the passage of HB 597 in the 2019 legislative session.
- NWE DSM: After incorporation of capacity contributions, as well as slightly higher avoided costs, and consistent pressure by the Coalition, NWE has finally restarted its residential DSM program. Questions on cost-effectiveness calculation remain, and the DSM Advisory Committee continues to work through them. The utility plans on commissioning a new Conservation Potential Assessment in the near future, though it remains unclear if it will be done in time for the 2022 IRP.
- Fixed Cost Recovery Mechanism (FCRM) implementation: Implementation of the FCRM is delayed until at least July 1, 2022. NWE once again filed a motion for delay, citing the ongoing pandemic as causing instability in loads Residential customers would have received over $10M in rebates had the mechanism been in place when originally scheduled.
- Planning Rules: The Commission is currently taking comments on the second draft – comments due December 7th.
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In the news
Seattle Climate Action on Building Standards and Transportation Electrification, NWEC, Nov. 1, 2021.
Seattle mayor issues executive order aimed at reducing city’s greenhouse gas emissions, KING5, Nov. 1, 2021.
Mayor Jenny Durjan Announces New Executive Order at COP26 Climate Summit to Drastically Reduce Greenhouse Gas Emissions, Office of the Mayor, Nov. 1, 2021.
Readers respond: Clean energy is a win-win, The Oregonian, Oct. 22, 2021.
A closer look at grid reliability and clean energy, Washington State Wire, Aaron Kunkler, Oct. 11, 2021.
Avista first utility to file Washington clean energy plan, with focus on demand response, energy efficiency, Utility Dive, Kavya Balaraman, Oct. 7 2021.
Intervenors: NorthWestern should reimburse costs for Laurel docket, Missoula Current, Keila Szpaller, Oct. 4, 2021.
Call for major investment in renewable energy worries Montana utilities, Billings Gazette, Tom Lutey, Oct 2, 2021.
More renewable energy, less energy efficiency in new Northwest power plan, OPB (Oregon Public Broadcasting), Courtney Flatt, Sept. 27, 2021.