best to you all Gail Carbiener Page 1 of 5

Similar documents
Decision on Merced Irrigation District Transition Agreement

City of Palo Alto (ID # 6416) City Council Staff Report

Merger of the generator interconnection processes of Valley Electric and the ISO;

Contents. Solar Select TM Frequently Asked Questions

Board of Directors authorization is required for all goods and services contracts obligating TriMet to pay in excess of $500,000.

TransWest Express Transmission AC and DC Project Interregional Transmission Project Submittal

Net Energy Metering and Interconnections. Community Solar in the District of Columbia

FITCHBURG GAS AND ELECTRIC LIGHT COMPANY NET METERING SCHEDULE NM

JEA Distributed Generation Policy Effective April 1, 2018

Reactive Power Requirements and Financial Compensation. Addendum to Draft Final Proposal

ENERGY STRATEGY FOR YUKON. Independent Power Production Policy

Solar Project Development in Regulated Markets. Smart and Sustainable Campuses Conference 2017

PUD ELECTRIC SYSTEM INTERCONNECTION

Attached is Idaho Power s 2013 WECC Annual Progress Report. Please contact me if you have any questions.

78th OREGON LEGISLATIVE ASSEMBLY Regular Session. House Bill 4036

Final Report. LED Streetlights Market Assessment Study

REGIONAL TRANSMISSION ORGANIZATIONS / INDEPENDENT SYSTEM OPERATORS AND THE ENERGY IMBALANCE MARKET: AN OVERVIEW OF THE PICTURE IN THE WEST

FITCHBURG GAS AND ELECTRIC LIGHT COMPANY NET METERING SCHEDULE NM

P. SUMMARY: The Southeastern Power Administration (SEPA) establishes Rate Schedules JW-

ENERGY STRATEGY FOR YUKON. Net Metering Policy DRAFT FOR CONSULTATION

CHAPTER 25. SUBSTANTIVE RULES APPLICABLE TO ELECTRIC SERVICE PROVIDERS.

Electrical District No. 3 SOLAR Q & A

Overview of ISO New England and the New England Wholesale Power Markets


Reforming the TAC and Retail Transmission Rates. Robert Levin California Public Utilities Commission Energy Division August 29, 2017

EASTERN ILLINI ELECTRIC COOPERATIVE REGULATION NO. 26A

Updates. Pat Reiten President and CEO, PacifiCorp Transmission

Portland General Electric Company Fourteenth Revision of Sheet No P.U.C. Oregon No. E-18 Canceling Thirteenth Revision of Sheet No.

Department of Market Quality and Renewable Integration November 2016

Proposed Incorporation of Merced Irrigation District into ISO Balancing Authority Area in Stakeholder Webconference February 28, 2013

Consulting Agreement Study. Completed for Transmission Customer

UM1716 Resource Value of Solar Docket Due: December 22, 2015

Proposal Concerning Modifications to LIPA s Tariff for Electric Service

December 4, Docket: ER Energy Imbalance Market Special Report Transition Period July 2018 for Idaho Power Company

Wyoming Energy Projects

Thank you for your time and attention to this matter. Please feel free to contact me if you have any questions regarding the filing.

Electrovaya Provides Business Update

Senate Bill 1547 Ordered by the House February 29 Including Senate Amendments dated February 12 and House Amendments dated February 29

The Gambia National Forum on

SunZia Southwest Transmission Project

SunZia Southwest Transmission Project

TOWN COUNCIL ACTION REPORT. May 2, 2013

Please Refer to Attached Sample Form

(2) Scope. 220 CMR applies to all Distribution Companies subject to the jurisdiction of the Department.

University of Alberta

September 9, Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E., Room 1A Washington, DC 20426

August 15, Please contact the undersigned directly with any questions or concerns regarding the foregoing.

Interconnection and Net Metering Service in Ohio

Passenger Rail Solar Electrification: A Primer. Oregon Department of Transportation Rail Division. June 2009

January 18, Docket: ER Energy Imbalance Market Special Report Transition Period August 2018 for Idaho Power Company

Decision D ATCO Electric Ltd. Decommissioning of Transmission Line 6L82

D.P.U A Appendix B 220 CMR: DEPARTMENT OF PUBLIC UTILITIES

Application for Commission Approval to Construct a Generating Station Pursuant to Public Utilities Article Section and

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

California Independent System Operator Corporation Fifth Replacement Electronic Tariff

Docket No. ER June 2018 Informational Report Energy Imbalance Market Transition Period Report Idaho Power Company

2018 American Zero Emission Bus Conference INNOVATIVE CLEAN TRANSIT PROPOSED REGULATION

Overview of S.L Competitive Energy Solutions for North Carolina

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) ) ) )

Renewable Energy System Tariffs and Pricing

March 14, Please contact the undersigned directly with any questions or concerns regarding the foregoing.

Preliminary Plan of Development

Frequently Asked Questions New Tagging Requirements

January 18, Docket: ER Energy Imbalance Market Special Report Transition Period September 2018 for Idaho Power Company

Smart Grid Update Supplier Conference. Kevin Dasso Senior Director Technology & Information Strategy. October 27, 2011

Planning Distributed Generation for Transmission Savings 1 By Kenneth Sahm White and Stephanie Wang 2 March 19, 2014

BEFORE THE PUBLIC UTILITY COMMISSION OF OREGON PACIFICORP. Exhibit Accompanying Direct Testimony of Eli M. Morris. Letters of Stakeholder Support

California s Energy Storage Summit California Energy Storage Association and Association of California Water Agencies

Joint Con Edison LIPA Offshore Wind Power Integration Project Feasibility Assessment

INTERCONNECTION STANDARDS FOR CUSTOMER-OWNED GENERATING FACILITIES 25 kw OR LESS PUBLIC UTILITY DISTRICT NO. 1 OF CHELAN COUNTY

Guide. Services Document No: GD-1401 v1.0. Issue Date: Title: WIND ISLANDING. Previous Date: N/A. Author: Heather Andrew.

PUBLIC Law, Chapter 539 LD 1535, item 1, 124th Maine State Legislature An Act To Create a Smart Grid Policy in the State

Electric Vehicle Charge Ready Program

Net Metering & Compensation Seminar

BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) APPLICATION

Participation of Beacon Power s Flywheel Energy Storage Technology in NYISO s Regulation Service Market

Proposal Concerning Modifications to LIPA s Tariff for Electric Service

1. Reference: BC Hydro Evidence - Page 5, line 12

PROMOTING THE UPTAKE OF ELECTRIC AND OTHER LOW EMISSION VEHICLES

SHORE POWER RATE BC HYDRO 333 DUNSMUIR STREET VANCOUVER, BC

SERVICE CLASSIFICATION "CEF" COMMUNITY ENERGY FACILITY

RECOMMENDATION: It is recommended that the City Council, following a public hearing, adopt the attached resolution which:

RAPPAHANNOCK ELECTRIC COOPERATIVE SCHEDULE NEM-8 NET ENERGY METERING RIDER

Topic Small Projects (< 100 kw) Large Projects (>100 kw)

Community Solar Projects: Glossary of Terms

Review of Reliability Must-Run and Capacity Procurement Mechanism BBB Issue Paper and Straw Proposal for Phase 1 Items

PREPARED REBUTTAL TESTIMONY OF BETH MUSICH SOUTHERN CALIFORNIA GAS COMPANY AND SAN DIEGO GAS & ELECTRIC COMPANY

November 16, Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C.

Frequently Asked Questions Trico Proposed Net Metering Tariff Modifications

TRANSMISSION CONNECTION CHARGING METHODOLOGY STATEMENT

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

RENEWABLE ENERGY IN JORDAN What had to be done 8 Oct 2017

May 2017 Pei Sue Ong, Capital Accounting Advice Manager Pacific Gas and Electric Company

Michigan Renewable Energy Case Study

City of Washington, Kansas Electric Department. Net Metering Policy & Procedure For Customer-Owned Renewable Energy Resources

MENARD ELECTRIC COOPERATIVE POLICY MANUAL. SECTION IV Operating Rules for Cooperative Members

Portland General Electric Company Eleventh Revision of Sheet No. 7-1 P.U.C. Oregon No. E-18 Canceling Tenth Revision of Sheet No.

Please Refer to Attached Sample Form

Dear New Clean Cities Stakeholder:

Public Information Workshop

Transcription:

Please accept this attachment as my up dated response to the B2H DEIS. If this is not acceptable, please let me know. Nice meeting last Monday in Boardman. 300316 best to you all Gail Carbiener 2 Page 1 of 5

Comments by Gail Carbiener On the Draft Environmental Impact Statement Boardman to Hemingway Transmission Line Project January 5, 2015 Tamara Gertsch BLM National Project Manager Bureau of Land Management Vale District Office 100 Oregon Street Vale, Oregon 97918 I appreciate the opportunity to provide comments relating to the Bureau of Land Management s draft environmental impact statement (DEIS) for the Boardman to Hemingway Transmission Line Project (B2H). Although an active member of the Oregon California Trails Association (OCTA), I am commenting as an individual. I expect that I will make additional comments prior to the March 19, 2015 end of 90 day public comment period. Since the first SF 299, (Application for Transportation and Utility Systems and Facilities on Federal Lands), in December 2007, Idaho Power and the BLM have worked to secure public approvals, changed routes, and worked diligently to bring this project to this point in early 2015. During these seven years, considerable funds and time have been spent, but both the BLM and Idaho Power and all the contracted consultants have failed to sufficiently justify the need for the project. I recognize that the BLM has a legal obligation to not grant, grant with modifications, or deny Idaho Power Company s (IPC) application for a right of way (ROW) on public lands as stated in DEIS 1.2.1) and amend any Resource Management Plans (RMP) that stand in the way. That is exactly what the BLM proposes to do! The BLM makes no effort to determine if the project itself is in the best interest of the public. The BLM accepts the multitude of organizations that encourage redundancy in infrastructure as reason enough to proceed. BLM implies that Idaho Power is required by Federal Energy Regulatory Commission (FERC) to build this transmission line to comply with Federal Laws (1.4.1). As quoted in the DEIS (1.4.1) Under FERC tariff requirement, public utilities, such as IPC, must plan, design, construct, operate, and maintain an adequate electric transmission system that not only meets the customer s energy demands but also meets the customer s peak load demands. IPC in their current Integrated Resource Plan (IRP) has stated they do not need this transmission for either situations. In DEIS 1.4.2 the BLM states that IPC must prepare an Integrated Resource Plan (IRP) for both Oregon and Idaho Public Utility Commissions, which they have done. The IRP (prepared for 2013) states;.. the B2H Project or a general resource similar to it has served as a critical component of every acknowledged IPC IRP since 2000. Page 2 of 5

The applicants Interest and Objectives on DEIS page S 2, states: The B2H Project is neither required to support any particular new power generation project nor justified by any particular existing power generation project. Rather, the B2H Project would meet IPC s obligations to meet Federal Energy Regulatory Commission, Oregon Public Utility Commission, and the Idaho Public Utility Commission requirements. IPC would meet these requirements by providing a high capacity connection between two key points in the existing bulk electric system, adding capacity to transmit electricity during periods of high demand and accommodate third party transmission requests. This statement certainly does not support the NEED for the B2H project. None of the obligations referred to in the statement above, require Idaho Power to build this transmission line. IPC filed with the Securities and Exchange Commission (SEC) a Form 8 K dated January 20, 2011 that estimated the total cost of the B2H project to be $820 million, and be in service by 2015. Needless to say the cost has gone up and they now estimate service to begin in 2020. The rate payers will pay for this cost in their electric rates. The BLM has an obligation to determine if this transmission line is in the public s best interest. Idaho Power s 2011 Integrated Resource Plan Update and the 2013 Integrated Resource Plan (IRP) acknowledges several points that will eliminate the need for additional power via the B2H transmission line. Examples: Special contract customers did not materialize resulting in 128 average MW of power not being needed in the future. IPC forecasts average system load lower than was forecasted in the 2011 IRP. Economic recovery is occurring at a slower pace than was forecasted. Forecasted Natural Gas prices were nearly five times current price and no analysis was done to determine benefits of new gas powered generation plants. The Gateway West Transmission line should supply sufficient power to the IPC. The Idaho Power Company partners (Bonneville Power and Pacific Corp) have made significant decisions recently that the BLM should consider in determining the need for the B2H project. Examples: Portland General Electric (PGE) and BPA have cancelled the Cascade Crossing project which would have included either the Grassland or Longhorn substations. The President of PGE is quoted; As a result of changes in demand on the BPA transmission grid, as a result of less renewables trying to get to California and just demands for transmission, Bonneville has no longer what we viewed as a constraint on the transmission grid. (6/4/2013: Oregon Public Broadcasting Web site, Earthfix.opb.org) Page 3 of 5

Portland General Electric started building the Carty Generating Station a natural gas plant. This plant will produce 440 MW enough to power 300,000 homes. How will this new generation effect the need for the B2H project? Bonneville Power Administration (BPA) has not yet determined to build the BLM s preferred northern substation, Longhorn. PacifiCorp, one of Idaho Power s partners, gave BPA notice in June 2011 that it will terminate its contractual arrangement with BPA, in June 2016. The PacifiCorp arrangement allowed BPA to service six preference customers in southeastern Idaho. BPA is currently looking at options to serve these customers. In a SEC form 8 K filing by Idaho Power on January 12, 2012, the three parties to the B2H project (Idaho Power, PacifiCorp, and Bonneville Power) agreed to a MOU that helps Bonneville Power serve the six preference customers in southern Idaho. It reads: Memorandum of Understanding, dated January 12, 2012, among Idaho Power, PacifiCorp, and BPA (2012 MOU): The 2012 MOU provides that the parties will negotiate in good faith the terms of mutually satisfactory definitive agreements that would allow BPA to meet its load service obligations in southeast Idaho. It provides that the parties will explore opportunities to establish eastern Idaho load service from the Hemingway substation in exchange for similar service from the Federal Columbia River Transmission System (FCRTS), and will consider whether to replace certain transmission arrangements involving existing assets with joint ownership transmission or other arrangements. The 2012 MOU outlines at least two potential alternatives for further negotiation, as follows: Alternative 1: BPA would obtain a network service option from the Hemingway substation to the existing BPA service points in eastern Idaho. Idaho Power would sell and PacifiCorp would acquire Idaho Power's existing assets necessary to provide BPA's long term load service. BPA would also work to plan an amount of FCRTS capacity sufficient to enable PacifiCorp and Idaho Power to utilize their capacity shares (up to 650 MW in total) of the Boardman to Hemingway transmission project pursuant to standard open access transmission tariff terms and conditions. Alternative 2: Idaho Power and PacifiCorp would together provide BPA with 600 MW of firm eastbound ownership rights of assets, or other terms and conditions associated with the combined systems of Idaho Power and PacifiCorp in southern Idaho, for the primary purpose of serving BPA service points in eastern Idaho. BPA would provide to PacifiCorp and Idaho Power an equivalent value of capacity rights, ownership rights of assets, or other terms and conditions associated with the FCRTS to the western terminus of the Boardman to Hemingway transmission project, or other interconnection points determined by the parties. The parties would evaluate and consider a number of strategies to effect the proposed transactions, including, but not limited to, joint ownership of portions of the Gateway West project. The 2012 MOU is a non binding statement of intent to explore a larger coordinated solution for all parties to meet the parties' respective service needs. Any party may terminate the 2012 MOU at any time, without penalty, and the 2012 MOU automatically expires on December 31, 2014. Page 4 of 5

I have not been able to determine what has happened since the expiration date, but it is interesting to know that these three power providers can find alternative means to supply electric power to the BPA s six preference customers. Bonneville Power Oversupply Management: Mr. Mainzer, Administrator at BPA on March 25, 2014 before the Subcommittee on Water and Power, US House of Representatives, described how BPA proposes to recover these costs. The Oversupply Management occurs when Bonneville displaces wind generation in certain oversupply conditions and compensates (wind) generators for lost production tax credits, renewable energy credits, and losses under certain power sales agreements. BPA proposes to allocate oversupply costs to generators in Bonneville s balancing authority area, proportional to their scheduled use of the transmission system during oversupply events. Multiple parties have challenged BPA s right to curtail wind during oversupply situations. In summary, even though the BLM has over 2000 pages of analysis to comply with environmental concerns, it has skipped over the fundamental question is the B2H needed at all. I believe that the BLM limited their approval of this project to the Right of Way and then relies upon consultants to provide the necessary study and documentation to support their preferred alternative. The BLM has not determined if alternatives such as natural gas plant generation, conservation or other transmission line construction are options. These options, if feasible, would eliminate degradation of both public and private lands, while reducing significant costs to Oregon and Idaho ratepayers. The Boardman to Hemingway transmission line warrants further examination by the BLM and its consultants to provide to the public a more complete needs analysis. Respectfully submitted Gail Carbiener 19506 Pond Meadow Avenue Bend, OR 97702 3324 541 678 5634 Page 5 of 5