BPA issues Draft EIM Phase V Close-out Letter
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 released a draft decision on July 29 to join the Western Energy Imbalance Market. This proposed draft decision follows an extensive EIM assessment and public process over the last three years where BPA worked closely with customers and constituents to fully assess the impacts and make necessary policy decisions to enable the agency’s participation. In the Draft EIM Close-out Letter, Administrator John Hairston said he does not see any barriers or concerns preventing BPA from joining the market. However, he will not make a final decision until after reviewing all input from the public in this final phase of the decision process. BPA is accepting comments on its Draft EIM Close-out Letter until Aug. 23 and expects to release the Final EIM Close-out Letter on Sept. 28.
For More Information:
Close of comment: 8/23/2021
- EIM-V21 0003 -
Russell/Tacoma PowerSee attached
- EIM-V21 0004 -
Arnold/Renewable NorthwestComments attached
- EIM-V21 0005 -
Heutte/NW Energy CoalitionComments attached
- EIM-V21 0006 -
Weber/AWECPlease find attached the Alliance of Western Energy Consumers; Comments regarding BPAs Draft EIM Close-Out Letter.
- EIM-V21 0007 -
MacDougall/PowerEx CorporationSee attached
- EIM-V21 0008 -
Walter/Seattle City LightSeattle City Light, an EIM participant since April 2020, supports BPA’s proposed decision to join the Western EIM. BPA’s structured and measured approach to joining the EIM has allowed BPA and customers to become more familiar with the EIM and how it may affect participants directly and indirectly. Seattle believes that this decision is a sound strategic and business decision in light of regional dynamics and the evolving landscape of organized markets in the West and stands to position BPA favorably in both respects.
Seattle City Light shares many of BPA’s perspectives about the benefits of joining the market: better information about transmission system use, more transparency on short term incremental prices by time and location, and increased marketing intelligence. Seattle City Light’s own analysis during our decision process to join the EIM also highlighted some other expected benefits: positive environmental impacts from integrating additional renewables; achieving greater future readiness by developing capabilities to leverage dynamic market energy; and benefit to its core business functions through employee growth and development along with improved and updated operational processes and coordination.
Like many stakeholders across the West, BPA is forecasting an increasingly dynamic and uncertain wholesale energy market. With that in mind, Seattle would like to provide the following feedback for consideration:
• The study by E3 (which Seattle also used to perform a similar analysis for our entry evaluation process), is a simplification of how the market works and does not provide complete information about how BPA’s participation will affect costs and revenue. Similarly, while the ISO’s Quarterly Benefit Report provides considerable and valuable information about gross benefits to market participant, Seattle has found that that report is not sufficient to account for costs and revenues. Seattle encourages BPA to establish a methodology for tracking costs and benefits associated with its EIM participation, and to publish this information regularly.
• Seattle would like BPA to formally commit to re-evaluating the cost allocation mechanisms related to EIM costs and revenues that BPA adopted in BP-22. As discussed during the pre-rate case workshops, BPA does not yet have any data on its participation and its experience will likely be different from the modeled estimates. As also discussed in those workshops, BPA’s participation will not affect all customers in the same manner. Seattle further recommends that BPA formally commit to re-examining estimating and allocating of EIM-related costs and revenue in future rate cases.
• Seattle is a member of the Public Power Council and has participated in numerous discussions regarding BPA’s EIM decision. Several additional points have been elevated by PPC members and staff that are worthy of consideration and thoughtful dialogue between BPA and its customers. Seattle encourages BPA to review and respond meaningfully to questions raised by PPC members.
Thank you for the opportunity to comment on BPA’s EIM implementation closeout decision. Seattle City Light looks forward to continue working with BPA as the agency moves closer and closer to participating in the Western Energy Imbalance Market.
- EIM-V21 0009 -
Schneider/WPAGPlease see the attached comments of Western Public Agencies Group
- EIM-V21 0010 -
- EIM-V21 0011 -
Cornelius/Snohomish County PUDsee attached
- EIM-V21 0012 -
Tenney Denison/Public Power Councilsee attached
- EIM-V21 0013 -
Cutter/Idaho Conservation League & Columbia RiverkeeperSee attached.