Western Energy Imbalance Market Letter to the Region
The following comments were submitted in response to the open comment period described below.
Comments are numbered consecutively as they are received. Breaks in the number sequence result when comments are deleted because they
were submitted in error or have inappropriate content (such as SPAM). If you do not see your comment two business days after
you submit it, please contact (800) 622-4519.
BPA invites you to comment on the Letter to the Region issued on June 20, 2019 that captures the business case for signing an implementation agreement with California Independent System Operator. The implementation agreement would obligate BPA to spend funds specific to EIM participation. The letter also summarizes principles, proposes decisions on some specific issues and discusses the legal authority that are foundational to making this decision. Bonneville requests stakeholder comments on the letter by July 22.
For More Information:
https://www.bpa.gov/Projects/Initiatives/EIM/Pages/Energy-Imbalance-Market.aspx
Close of comment: 7/22/2019
- WEIML19190001 -
AdcockI would like BPA to in addition clarify *explicitly* in this agreement that neither CAISO and/or BPA can:
1) take any action that does not put the consumers of the PWN first [16 U.S.C 832 and following], and
2) can take any action that further increases damages to salmon. [2.(6) Northwest Power Act]
- WEIML19190004 -
Schlekeway/NV EnergySee attachment.
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- WEIML19190006 -
Zichella/NRDCSee attachment.
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Anyanwu/Seattle City LightSee attachment.
View Attachment
- WEIML19190008 -
PaceThe letter to the region fails to address the adverse modification to shoreline habitat that is designated as critical; for a number of ESA listed salmon esu's and steelhead dsp's. And the Appendix (page 45) mentions only NEPA compliance and, even then, indicates that it doesn't appear that NEPA documents would be required. All of this is ****. BPA needs to consult NMFS and USFWS re participation in the energy imbalance market. This should be part of a larger effort that considers the impacts of load following, power peaking and wind integration on designated critical habitat in the mainstem. None of these have yet been addressed. In fact, when USGS proposed to study impacts on sturgeon habitat of load following, etc., Steve Kerns and Steve Oliver begged them not to do it. This was in 2009 if my memory serves me right. Nothing has been done in this regard. And the 2009 and 2014 biological opinions do not address any of these problems. Failure to do so invites litigation in the 9th Cir., as well as implicates FERC jurisdiction. All that is one heck of a risk for a paltry return of about $30 million. Not worth it! Now this is NOT to say that BPA should not participate. The key to successful participation, however, lies in development of the new market products that would allow BPA to be compensated when out of region utilities lean on BPA's system. That needs to change. But as presently constituted there is little value in bidding into the EIM as presently constituted.
- WEIML19190009 -
Ramsey/BEFJuly 22, 2019
Elliot Mainzer,
CEO
Bonneville Power Administration
PO Box 14428
Portland, Or 97293-4428
Dear Elliot,
The Bonneville Environmental Foundation (BEF) appreciates the opportunity to comment on your June 20 letter to the region on BPA’s intention to sign an Energy Imbalance Market (EIM) Implementation Agreement with the California Independent System Operator (CAISO). BEF has long recognized the value of BPA’s carbon free hydroelectric energy and joining the EIM could provide significant benefits to BPA, its customers and increased renewable energy production.
BPA has already deployed a significant amount of effort and resources delving into the costs and benefits of this move and initial results show that the region could benefit greatly from BPA’s participation. BPA has been very transparent to interested parties in the region and the planning process going forward will continue meaningful stakeholder engagement. And BPA’s exceptional leadership in the development of our own regional EIM mechanisms, with the clear showing of benefits across the range of Pacific Northwest utilities, should be taken by all parties as encouraging prudent pursuit of similar westwide gains.
BPA commissioned a third-party analysis of their joining the EIM which identified $29-$34 million annual net dispatch benefits for BPA’s participating hydro resources. This is a significant amount of value that could benefit the region’s economy by BPA’s participation. The magnitude of these dollars makes BPA’s decision to sign an Implementation Agreement a very prudent action for BPA to undertake.
While we understand that there will be many new decision points before BPA will become an actual member of this market, we feel that the transparent approach that BPA has taken up to this point will serve the region well going forward.
We applaud BPA’s efforts in getting to this point. We feel that this project supports BPA’s Strategic Plan and could generate significant benefits for the entire region.
Sincerely,
Evan Ramsey
Director, Renewable Energy Group
Bonneville Environmental Foundation
eramsey@b-e-f.org
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Dockery/Clatskanie Peoples Utility DistrictSee attachment
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- WEIML19190013 -
Tilghman/Tilghman AssociatesSee attachment.
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- WEIML19190016 -
Walter/Seattle City Light
- WEIML19190017 -
Peacock/Oregon Public Utility Commission and Oregon Department of Energy
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Useldinger/Portland General Electric
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Garcia/WPUDA
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Stratman/Northwest Requirements Utilities
- WEIML19190022 -
Inslee/Governor
- WEIML19190023 -
Galle
- WEIML19190024 -
scanlon/The M-S-R Public Power Agency
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Heutte/NW Energy Coalition
- WEIML19190026 -
Tanner/Renewable Northwest
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Darin/AWEAThe American Wind Energy Association is a national trade association for the US wind industry with thousands of members. AWEA is the national trade association representing a broad range of entities with a common interest in encouraging the deployment and expansion of wind energy resources in the United States. AWEA’s members include wind turbine manufacturers, component suppliers, project developers, project owners and operators, financiers, researchers, renewable energy supporters, utilities, marketers, customers, and their advocates. Increasingly, AWEA’s developer and other members are actively involved in the development, deployment and implementation of wind, solar and storage technologies.
AWEA supports the development of a fully integrated western power market, as a regional market structure will capture the benefits and overall efficiencies gained from the consolidation of balancing authorities and market functions, as well as allowing western states to more readily access some of the highest quality wind in the country to efficiently and cost-effectively achieve renewable portfolio standards and clean-energy goals. Therefore, AWEA has supported the development of the Energy Imbalance Market (EIM) and various other market constructs throughout the country.
AWEA is pleased that BPA has issued a letter to the region proposing to sign an Implementation Agreement to begin joining the Western EIM. The Western EIM has been growing rapidly in recent years, a clear sign that it has delivered the expected benefits and, in many cases, exceeded expected benefits for its participants.
While the EIM’s general benefits are well understood, BPA has undergone a stakeholder process and significant evaluation exercises in order to arrive at the Letter to the Region recommending that BPA sign an EIM Implementation Agreement. AWEA appreciates the thoughtful analysis and assessments that have gone into BPA’s proposed direction.
BPA has conducted a comprehensive benefits assessment, along with an analysis of the costs of joining the EIM. These two pieces of information clearly demonstrate that, on the whole, BPA and its customers are expected to achieve substantial net benefits from EIM participation. The quantified benefits are expected to range between $29-34M/year. While these benefits are significant, there is reason to believe they may be conservative. Many other EIM Entities have actually realized EIM benefits over and above what the amount of EIM benefits that were projected in similar benefit quantification exercises.
Additionally, there are a number of unquantified benefits that would come with BPA’s participation in the EIM, including: enhanced reliability, improved transparency into pricing and congestion issues on the BPA system, better congestion management, improved technology/automation across the BPA system, and more. Given the substantial financial benefits and the non-financial benefits that will results from EIM participation, AWEA strongly supports BPA’s proposal to sign an EIM Implementation Agreement and begin working towards EIM “go-live” in 2022.
While BPA has already done substantial work to move forward with the next step in EIM implementation, there remains substantial work to be done. BPA and its stakeholders must continue to develop policies to implement the EIM. Decisions regarding transmission usage on the BPA network, allocation of EIM charges, participation requirements, settlement/billing mechanics and more, remain to be developed in the next phase of BPA’s EIM stakeholder process. The next phase of BPA’s EIM implementation, where these types of decisions are made, will be critically important to ensuring that EIM benefits are maximized and costs and benefits are properly allocated among customers. AWEA looks forward to participation in the next phase of EIM policy development and encourages BPA to continue to use an open and transparent forum for discussing these items and making these decisions.
As BPA moves toward the next phase of policy decisions regarding EIM participation, AWEA encourages BPA to strive for as much consistency with other EIM Entities as possible. In order to reduce seams issues, and unintended consequences, BPA should seek, to the greatest extent possible, to replicate the EIM policy decisions that have been made across other EIM Entities. For instance, if BPA has more onerous EIM participation requirements (or charges) than other EIM Entities, there may be market price impacts and even incentives for resources to change their participation status or Balancing Authority Area. Therefore, consistency in EIM policy decisions and participation requirements will be key. Generally, BPA should seek to encourage non-federal EIM resource participation, as such participation will provide benefits to all load within the EIM.
AWEA looks forward to working with BPA on EIM implementation, including participation in policy decisions going forward and wishes to express support and appreciation for the work BPA has done so far.
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Russell/PNGC
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Weber/Alliance of Western Energy ConsumersPlease find attached the Comments of the Alliance of Western Energy Consumers. Thank you.
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Neale/WPAG
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Trolese/Public Generating PoolSee attachment.
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Schroettnig/Eugene Water & Electric BoardSee attachment.
View Attachment
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Kytola/Slice Customer GroupThe Slice Customer Group appreciates the opportunity to provide the attached comments on Bonneville Power Administration’s June 20, 2019 Letter to the Region and associated Proposal regarding its future role in the Western Energy Imbalance Market (EIM).
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Applegate/Tacoma PowerSee attachment.
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Tenney Dennison/Public Power CouncilSee attachment.
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Berg/Snohomish County PUD No. 1See attachment.
View Attachment
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