20151002Comment.pdf

Jean Jewell
From:Gene Fadness
Sent:Friday,October 02,2015 11:08 AM
To:Jean Jewell
Subject:FW:Comment for Idaho Power Co.IRP CASE NO.IPC-E-1 5-19 ORDER NO.33381
Attachments:IdaCorp 2015 IRPs Missing Piece.pdf
From:[e-mail] [mailto:[e-mail]
Sent:Monday,September 28,2015 10:27 AM
To:Gene Fadness <[e-mail]>
Cc:[e-mail]
Subject:Comment for Idaho Power Co.IRP CASE NO.IPC-E-15-19 ORDER NO.33381
IDAHO POWER COMPANY’S 2015 INTEGRATED RESOURCE PLAN
CASE NO.IPC-E-15-19
ORDER NO.33381
Gene.Fadness @ puc.idaho.gov
Gene Fadness
Policy Strategist/Public Information Officer
Idaho Public Utilities Commission
From:
Steve Nelson
19810 E.Onyx Ln.
Spokane,WA 99217
email [e-mail]
phone -509-995-2043
I am a land owner in Pocatello,ID
Name of Power Company:Idaho Power Co.,Pocatello,ID
I am submitting the attached analysis as my comments for this case.
Please add my comments to the
IDAHO POWER COMPANY’S 2015 INTEGRATED RESOURCE PLAN
CASE NO.IPC-E-15-19
ORDER NO.33381
1
IdaCorp’s 2015 IRP Missing Piece
Sept 28,2015
Will Idaho Agriculture and/or Businessess Experience Electrical
Brown-Outs or Significant Primary Utility Voltage Loss?
The following provides the background to answer the question:
Why should Idaho Agriculture and/or Business investigate these assertions?
Coal-fired Generation
(See IdaCorp Annual Report 2014,pg.12)
Idaho Power co-owns the following coat-fired power plants.
•Jim Bridger located in Wyoming,in which Idaho Power has a one-third interest,
•North Valmy located in Nevada,in which Idaho Power has a 50 percent interest,and
•Boardman located in Oregon,in which Idaho Power has a 10 percent interest
Idaho Power is the parent ofIdaho Energy Resources Co.(IERCo),ajoint venturer in Bridger
Coat Company (BCC),which mines and supplies coal to the Jim Bridger generatingplant
owned in part by Idaho Power.Idaho Power also has a coal supply contract providingfor
annual deliveries ofcoal through 201 7from the Black Btttte Coat Company ‘s Black Butte mine
located near the Jim Bridger plant.
NV Energy is the operator of the North Vatmy power plant.NV Energy and Idaho Power have
contracts with a coat supplier throttgh 2015.Idaho Power’s share ofthese contracts along with
existing coal inventory at the plant are expected to meet Idaho Power’s projected coal s;tpply
needs for 2015 and approximately 60 percent of its sitpply needsfor 2016.Berkshire Hathaway
Energy owns NV Energy.
Berkshire Hathaway Energy’s Climate Pledge
Retire more than 75 percent ofour coal-fueled generating capacity in Nevada by 2019.
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IdaCorp’s 2015 IRP Missin2 Piece
Sept 28,2015
The Clean Power Plan compliance period starts in 2022,and each state is required to
meet its carbon redttction goals within thefollowing eight years.
Ten power plants within Washington State wilt be affected directly by the Clean Power
Plan,Washington States Department ofEcology’s website shows.
All of the affected plants are on the west side ofthe state,including the Centralia
Generating Complex,which has tizvo coal-b urning steam generators that together make
up the largest baseloadpower source in the state.The coal itnits contribute more carbon
emissions than the nine affected natitral gas-fired generation plants combined,according
to US.Department ofEnergy data.
Phasedplans to halt coal-power prothtction in Centralia,though,could help Washington
meet its carbon-reduction goal.Canada-based TransAlta USA Inc.,which operates the
Centralia complex,says on its website that it’s scheduled to retire one ofthe coal itnits in
2020 and the other in 2025 to comply with Washington state ‘s TransAlta Energy
Transition Act of2Oll.
—See mote at:http://wwwspokanejournal.com/Iocal-news/washington-state-statts-power-plant-catbon-reduction
strategy/#sthash UMPWcuQI.dpuf
When the drought,due to Climate Change,reduces the available WATER for
hydroelectric generation and EPA reduces the available Coal generation,which of
the remaining other sources of electricity will Idaho Power turn to to make up the
difference in electrical generation capacity?
Bonneville Power Administration Climate Change Fact Sheet
There is growing evidence thatglobal and regional climates are changing.These climate
changes are expected to impact the Northwest and,in particular,the Columbia River Basin.
Weather,load demand,economic conditions,and availability ofgeneration resources impact
power supply costs....Warmer temperatures will result in less snow and more rain in the
winter,increasing riverflows in the winter and early spring,and reducing them in the
summer.This will impact how the Columbia River and its tributaries will be managedfor
flood control,powergeneration and the protection offish listed under the Endangered Species
Act.
Idaho Power’s Available Hydrogeneration is Drying UP
The Swan falls Agreement was signed in 1984 and was reaffirmed by the Idaho State
Legislature in 2009.Setting the minimum flows at Swan falls of3900 cfs (April thru
October)and 5600 cfs (November thru March).
Snake River Ilows at Swan Falls are 110W cipproaetiing those/lows.
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IdaCorp’s 2015 IRP Missing Piece
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Does Idaho Power have a Back UP Plan?
Idaho Power’s chiefsays coalplant closttres are tied to Boardman to Hemmingway power
line construction.
By Rocky Barker,[e-mail] 2],2015
Read more here:http:/AI’lew.idahostatesn?an.coni/2015/O5/21/3814216 idaho-power-chief-says-coal
plants.html?th=]#storylink=cpy
Idaho Power is studying dfferent scenarios for shutting down the Valmy coal-firedpower
plant in Nevada,and getting its new transmission line ...connected,said IdaCorp CEO
Darret Anderson.
Anderson,speaking at what would be Idaho Power 100th annttal meeting ...,said
constrttction of the 300-mite Boardman to Hemingway high-voltage power line is needed to
replace the coal plant’s reliable,on-demandpower.
“The sooner we are able to get that project permitted and constructed,the sooner we may
have a replacement resourcefor the Valmy plant,“Anderson told shareholders.
Anderson also committed the company to reduce its carbon intensity goals,which it extended
for two years to 20]7.He said the company is working with the state and the Environmental
Protection Agency on new power plant rttles to minimize their impact on customers.
But the proposed rules,under Section 111(d)ofthe Clean Air Act,present Idaho Power with
uncertainty for its old coal plants and even its new Langley Gttlch natural gas plant.
‘The proposed ritle,in its currentform,has what we believe would be an unanticipated
result in Idaho,which would involve backing down generationfrom ottr relatively new
Langley Gulch natural gas-firedpower plant,“Anderson said.“From a carbon emission
perspective,that does not make sense.”
Anderson said the company will continue to redttce its carbon emissions over time,bitt he
doesn ‘t see a carbon-free Idaho Power in his flfetime.
“Isee us moving to a carbon-light world,“he said.
Solar has a place in Idaho Power ‘s portfolio.
Read more here:http://www.idahostatesmancom/2015/05/21/3814216idaho-power-chief-says-coal-plants.html?rh=1#sto,yllnk=cpy
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IdaCorp’s 2015 IRP Missing Piece
Sept 28,2015
BUT THE FACTS DON’T SUPPORT IDAHO POWER’s
INTEGRATED RESOURCE PLAN CONCLUSION
THAT NEW GENERATION ISN’T NEEDED
As was mentioned earlier,with coal fired power plants closing and hydropower getting more and
more limited,the only fall back Idaho Power has is natural gas,interstate transmission expansion
and/or renewables.Idaho Power just killed any further renewable energy development in
Idaho via the Idaho Public Utility Commissions recent decision in Case #:IPC-E-15-0l.
And since the President of Idaho Power states that “backing down generationfrom our relatively
new Langley Gulch natural gas-firedpower plant,”is also likely to meet Clean Air Standards,
then the only option is transmission line expansion via Hemmingway to Boardman.So what
FACT does the Hemmingway to Boardman Transmission Line Construction OVERLOOK?
The Hemmingway to Boardman Transmission Line assumes (according to the Idaho Power 2014
Annual Report)the Energy Imbalance Market (EMI)has energy available via the Northwest
Energy Pool.
BIG PROBLEM WITH EMI
THE FREE MARKET OFTEN DOES NOT
ANTICIPATE PROBLEMS VERY WELL
Utilities in the western United States outside the California Independent System Operator
(California ISO)have traditionally relied upon a combination of automated and manual dispatch
within the hour to balance generation and load to maintain reliable supply.These utilities have
limited capability to transact within the hour outside their own borders.In contrast,energy
imbalance markets use automated intra-hour economic dispatch of generation from committed
resources to serve loads.The California ISO,PacifiCorp,and other parties implemented a new
energy imbalance market in the fourth quarter of 2014 (California ISO-PAC ElM)under which
the parties enabled their systems to interact for dispatch purposes.Similarly,the Northwest
Po\\er Pool (NWPP)tvlembers Market Assessment and Coordination Committee has stated that
it intends to implement the Securitv Constrained Economic Dispatch (NWPP SCED).an intra—
hour enen.z’balancing market.in 2t)I 6.The California ISO-PAC ElM and the NWPP SCED are
similar but not identical approaches to balancing services and each are intended to reduce the
costs to serve customers through more efficient dispatch of a larger and more diverse pool of
resources,to integrate intermittent power from renewable generation sources more effectively,
and to enhance reliability.Participation in both the California ISO-PAC ElM and the NWPP
SCED are voluntary and available to all balancing authorities in the western United States.Idaho
Power is an active participant in the development stage of the NWPP SCED project and is also
evaluating the potential opportunities and challenges associated with the NWPP SCED and the
California ISO-PAC ElM.
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IdaCorp’s 2015 IRP Missing Piece
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SECURITY CONSTRAINED ECONOMIC DISPATCH:
DEFINITION,PRACTICES,ISSUES AND
RECOMMENDATIONS
A Report to Congress
Regarding the Recommendations of Regional Joint Boards
For The Study of Economic Dispatch
Pursuant to Section 223 of the Federal Power Act
As Added by Section 129$of the Energy Policy Act of 2005
federal Energy Regulatory Commission
July 31,2006
West
Dispatch in the West is primarily accomplished by individual utilities,but with a number of
coordination arrangements to address specific resource characteristics and trading opportunities.
The presence of significant hydropower resources in the Northwest makes Western
Interconnection generation dispatch significantly different from dispatch in the Eastern
Interconnection.The West also has a long history of coordination in the Northwest aimed at
optimizing power and non-power river demands.Another factor affecting Northwest dispatch is
the operation of the Bonneville Power Authority transmission assets,which are closely
connected to the operation of the hydropower resources.Although the presence of significant
hydropower resources in the Northwest affects the overall operation and dispatch of the system,
the basic dispatch remains decentralized.
The California ISO (CAISO)is the only multi-utility market area in the West that is centrally
organized and dispatched.The CAISO performs a dispatch covering most of California by using
market bids to balance generation and load.
To Justify the Energy Imbalance Market the following logic was utilized
The overall pattern of dispatch in the West also depends to a large extent on differences between
the resources and loads in each sub-region.The Northwest has an abundance of hydropower and
a load that peaks during the winter,while the Southwest has a load that peaks during the
summer.As a result,via the north-south DC 500KV Intertie,a historical pattern of flows has
developed where the power in the summer flows from available hydropower in the north to peak
loads in the south,while power in the winter flows from south to north to meet the peak loads in
the Northwest.
Page 5 of 17
IdaCorp’s 2015 IRP Missing Piece
Sept 28,2015
But here’s the RUB
Bonneville Power Administration Climate Change Fact Sheet
There is growing evidence that global and regional climates are changing.These climate
changes are expected to impact the Northwest and,in particular,the Columbia Rivet Basin.
Weather,load demand,economic conditions,and availability ofgeneration resources impact
power supply costs....Warmer temperatures will result in less snow and mote rain in the
winter,increasing riverflows in the winter and early spring,and reducing them in the
summer.This will impact how the Columbia Rivet and its tributaries will be managedfor
flood control,power generation and the protection offish listed undet the Endangered Species
Act
According to the Northwest Power and Conservation Council the water versus electrical
generation looks like this:
Summary of Impacts to Generation -2030
tillustrative Only)
,-
Changes to:J February July
Generation (MWa)T +700 -2,200
Demand (MWa)I -350 +1050
Balance (MWa)+1,050 -3.250
This means that there will be too much water in the winter and not enough in the summer.
California needs less in winter and Idaho needs more in summer.The future norm will be the
opposite of the historical norm.Idaho Power’s IRP does not take this into consideration.
According to Idaho Power’s IRP the Boardman to Hemingway Transmission Line will provide
500MW and should make up any deficiencies from lack of water.The problem with this
conclusion is that the power coming from the Boardman to Hemingway Transmission Line has
to come from somewhere else.Idaho Power assumes the Security Constrained Economic
Dispatch (SCED)provided by the Northwest Power Pool (NPP)via the Energy Imbalance
Market (ElM)will provide.The problem v ith this assumption is that it is an ASSUMPTION.
and von know that that can make if ‘iou i’clv upon it.The ElM v ill promote in other utilities
what it is promotilw in Idaho Poer.The result of a compIacenc that will lead to lack of
development of new enerv generation.And when a bad summer or winter comes to the
northwest.the heat or the A/C will not go on.
FOR IDAI-lO AGRICULTURE AND BUSINESS THAT CAN BE DISASTROUS.
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IdaCorp’s 2015 IRP Missing Piece
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IDARO RATE PAYERS WILL BE THE VICTIMS OF A SHAKESPEARIAN
TRA&EDY IF IDACORP’S INThGRATED Risouzc PLAN (IRP)IS ACCEPTED
Remember in Shakespeare’s Julius Caesar “Beware the Ides of March”.The coming tragedy of
Northwest Power begins with the Regular Meeting of the Snohomish County Public Utility
District,Regular Meeting,March 17,2015
Agenda Item D.Northwest Power Pool Market Coordination Initiative Update
Assistant General Manager Power Rates and Transmission Management Craig Collar and
Anna Berg,Senior Manager Power Supply,delivered the briefmg on the Northwest PowellPool(NWPP)Members’Market Assessinènt and Coordination Cmmittee (MC),provided
at places by reference made a part of the packet.Mr.Collar provided an overview,the
funding organizations,and elements of the 2012 problem statement.As a reminder,
Mr.Collar stated the purpose was to look at the challenges the region faces,develop a
portfoiio of tools or approaches that could help address those issues,and make a
recommendation on the most effective and efficient path forward.A number of initiatives
are underway,including investigation of a security constrained economic dispatch (SCED)
to address some of the regional issues.
Updates of activities from february 2013 to March 2015 were discussed.(1)PacifiCorp
announced the formation of an ElM (energy imbalance market)with CAISO (California
Independent System Operator).(2)NV Energy files to join CMSO beginning October
2015.(3)NWPP MC isues a RFP (Request for Proposal)for a SCED market operator for
a Northwest-based ElM.(4)PacifiCorp CMSO (PAC-CAISO)market went live.
(5)NWPP MC closed the RFP without selecting either of two bidders —Southwest Power
Pool and CAISO.(6)PAC-CAISO announced an identified $6 million in savings in the
first two months of operation inline with expectations.(7)Puget Sound Energy announced
its intention to join the CAISO ElM beginning October 2016.And (8)the NWPP EC
(executive committee)will be meeting to roadmap a path forward for the Northwest.
The FERC (Federal Energy Regulatory Commission)declaratory order request is
important to the District,the BPA (Bonneville Power Administration)and to the other
paiticipants.The declaratory order covers five broad categories about how a market would
operate in the Northwest:the market would be entirely voluntary;market oversight would
he tailored to the Northwest’s unique resource mix (hydro);the market operator would not
become a FERC-regulated transmission service provder (TSP)Jparticipation by J,
non-jurisdictional utilities,such as BPA,for example,would not diminish its
non-jurisdictional status;and the region may rely on the stability of the market model
proposed and there would not be imposition of other market models or mechanisms.The
complementary initiatives were reviewed,which are those tools that could be accomplished
for re1ative1y small cost and impact.Discussion ensued regarding FERC’s involvement
in the process,jurisdictional concerns with FERC,how BPA would work within this
marketand continue to meet its statutory requirements,and the urgency to get an energy
imbalance market by the end of the year.-
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IdaCorp’s 2015 IRP Missing Piece
Sept 28,2015
Ms.Berg reviewed BPA’s analysis and scenarios.The two scenarios are to continue as is
and wheie investor owned utilities fIOUs)and independent power producers (WPs)join an
ElM leaving BPA and publics behind.A SCED low is where the benefits are low but the
cost of entry into that market is high.Conversely,SCED high is where the dollar benefits
are moderate to high and the cost to enter that market is low.From this BPA identified the
significant cost impacts and benefits for power customers moving into a SCED
eñvironment.The frimary costs are:BPA vould have to pay its share of the SCED
operator costs,as a participant BPA would have market participant costs for startup and
ogoing expenses,and impact or loss of ancillary service revenues.The benefits include
the reduction in quantity of balancing reserves held to integrate wind,which would free up
capacity and flexibility on the FCRPS (federal Columbia River Power System)that BPA
cotild sell into a SCED;cost savings derived from incremental trading floor revenue;more
accurate compensation for transmission losses,due to timing;and limit the cost impacts if
BPA does no join a SCED when others do.
To REPEAT -Ms.Berg issued her “Beware the Ides of March”statement as:
“The two scenarios are to continue as is and where investor owned utilities (lOUs)and
independent power producers (IPPs)join and ElM leaving BPA and publics behind.etc.”
“The benefits include the reduction in quantity of balancing reserves held to integrate wind
(solar),which would free up capacity and flexibility on the FCRPS (federal Columbia River
Power System)that BPA could sell into a SCED;”
I believe this statement reflected an HONEST economic analysis by Ms.Berg but leaves out
REF[ECT1ON AND ANALYSIS OF HISTORICAL EVENTS
I believe it is important to reflect upon the history of the Snohomish County Public Utility
District.
If you would review:
The New York Times
June 13,2004
LAST month,the Snohomish County Public Utility District,outside Seattle,released audiotapes
of Enron energy traders discussing “stealing”from California,sticking it to “Grandma Millie”
and other ways of manipulating the energy market.
http:‘/w w \.n\times.com/200406’13/w eekinrc iew ‘w ord—tor—word—enert\—hos—etiron—traders—
randnia—m ill ie—rnakin i—I ike—handits.html
My question to the Idaho Public Utility Commission is:
Will history repeat itself through the CASIO-PacifiCorp-NVEnergy-Puget Sound Energy-
Arizona Public Service,and IdaCorp’s Energy Imbalance Market?
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IdaCorp’s 2015 IRP Missing Piece
Sept 28,2015
Will “Gandma Millie tapes take place in the future given the following:
CAISO to FERC:Energy Imbalance Market problems found,reforms coming
w
re Forms—corn in /3 9 I 556/
April 28,2015
•The California ISO believes it has identified the source of price spikes in its fledgling energy
imbalance market,and told federal regulators last week that it would need
to implement certain changes to better recognize capacity available in the market.
•The grid operator told FERC that a failure to recognize capacity held by PacifiCorp led to
apparent shortages and subsequent price spikes.
FERC opened an investigation into the imbalance market last month,which had experienced
problems since it launched late last year.
http://vww.cbsne s.com/nevvs/enron—traders—cauiht—oii—tape/
When a forest fire shut down a major transmission line into California,cutting power supplies
and raising prices,Enron energy traders celebrated,CBS News Correspondent Vince Gonzales
reports.
“Burn,baby,burn.That’s a beautiful thing,”a trader sang about the massive fire.
Four years after California’s disastrous experiment with energy deregulation,Enron energy
traders can be heard —on audiotapes obtained by CBS News —gloating and praising each other
as they helped bring on,and cash-in on,the Western power crisis.
“He just f---s California,”says one Enron employee.“He steals money from California to the
tune of about a million.”
“Will you rephrase that?”asks a second employee.
“OK,he,um,he arbitrages the California market to the tune of a million bucks or two a day,”
replies the first.
The tapes,from Enron’s West Coast trading desk,also confirm what CBS reported years ago:
that in secret deals with power producers,traders deliberately drove up prices by ordering power
plants shut down.
“If you took down the steamer,how long would it take to get it back up?”an Enron worker is
heard saying.
“Oh,it’s not something you want to just be turning on and off every hour.Let’s put it that way,”
another says.
“Well,why don’t you just go ahead and shut her down.”
Officials with the Snohomish Public Utility District near Seattle received the tapes from the
Justice Department.
“This is the evidence we’ve all been waiting for.This proves they manipulated the market,”said
Eric Christensen,a spokesman for the utility.
https://\\v \.outuhe.com/w atch?=n \VCiKqYnlXA
That utility,like many others,is trying to get its money back from Enron.
Page 9 of 17
IdaCorp’s 2015 IRP Missing Piece
Sept 28,2015
“They’re f------g taking all the money back from you guys?”complains an Enron employee on
the tapes.“All the money you guys stole from those poor grandmothers in California?”
“Yeah,grandma Millie,man”
“Yeah,now she wants her f g money back for all the power you’ve charged right up,jammed
right up her a for f g $250 a megawatt hour.”
And the tapes appear to link top Enron officials Ken Lay and Jeffrey Skilling to schemes that
fueled the crisis.
“Government Affairs has to prove how valuable it is to Ken Lay and Jeff Skilling,”says one
trader.
“Do you know when you started over-scheduting load and making buckets of money on that?
Before the 2000 election,Enron employees pondered the possibilities of a Bush win.
“It’d be great.I’d love to see Ken Lay Secretary of Energy,”says one Enron worker.
That didn’t happen,but they were sure President Bush would fight any limits on sky-high energy
prices.
“When this election comes Bush will f g whack this s--t,man.He won’t play this price-cap
Crude,but true.
“We will not take any action that makes California’s problems worse and that’s why I oppose
price caps,”said Mr.Bush on May 29,2001.
from IdaCorps.2014 Annual Report Idaho Power gets 35.1%of its power from coal and 43.2%
from hydro.
To Summarize the Previous Discussion
The Draught will reduce hydro
I believe the federal Governments,Clean Power Plan,will cause closure of the Washington,
Oregon,and Wyoming Coal Power plants that provide the 35.1%of IdaCorp’s coal power thus
forcing IdaCorp’s customers into the Mid-Columbia Balancing Authority Market or the
Northwest Power Pools Energy Imbalance Market.
Ms.Berg of the Snohomish PUD stated:“benefits include the reduction in quantity of balancing
reserves”.This means the Northwest Power Pool —Energy Imbalance Market (NWPP-EMI)is a
net advantage to the PUD because Snohomish PUD has a contract with BPA that guarantees
them power.If there is a regional shortage of power,BPA will utilize their Demand/Supply
SWITCH and cut off power (remember BPA’s participation in NWPP-EMI is voluntary)to the
Northwest Power Pool —Energy Imbalance Market (NWPP-EMI)and where does that leave
IdaCorp,Boardman to Hemingway Transmission (B2H)Line and Idaho residents?
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When IdaCorp comes looking for more power the Mid-Columbia Balancing Authority will be
booked.
and
I believe the NWPP -ElM will then be able to control electrical power pricing
JUST LIKE ENRON DID!!!
You ask
“What is the comparison between Energy Imbalance Market and WPPSS\ENRON”?
Mismanagement and Greed
WPPSS was supposed to provide more cheap energy based on the model that every new
hydroelectric dam that was built and every new nuclear power project that was built would
provide cheaper electricity.That scenario worked well until the 3 Mile Island (March 28,1979)
Beware the Ides March
disaster caused electric rates in the Northwest to skyrocket.(IE.,Resource Instability due to
“(UN)”FORSEEN CIRCUMSTANCES)Investors,the northwest electric systems managers and
construction companies saw lots of dollar signs without understanding the scalability of
technology and future costs.(This disaster forced the U.S.Congress to act and the PACIFIC
NORTHWEST ELECTRIC POWER PLANNING AND CONSERVATION ACT of 1980 was
the result.We will discuss this later.)
President Ronald Reagan (referencing ENRON)in his radio address to the Nation on Proposed
Natural Gas Deregulation Legislation of February 26,1983
(Now think of NWPP-EIM)
“I’m convinced—and I believe that the evidence backs me up—that just as deregulation of oil
(electricity)has led to a better deal for the American consumer,a freer market in natural gas
(electricity)will have the same beneficial effect for you.So,next week I’m sending the Congress
a proposal for correcting the problems that have resulted from past excessive regulation
(NWCouncil.org)of the natural gas market (Northwest Electrical Energy Market).”
(FERC did this for the NWPP-EMI in the name of integrating Wind and Solar)
tS 1iierg I ntbrtn.tio,i cIniinistration
--&—
17O lQ ZJIO
-U S Nac1aI Gas WKead Pee
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Mr.Kenneth Lay was the CEO and chairman of Enron from 1985.ENRON grew from a
company dedicated to providing natural gas to a nation that had an infinite supply of natural gas
when natural gas prices were so low that producing more natural gas would only continue
lowering the price to the nation.
That’s a good thing RIGHT????
Lower prices for utility products are GOOD for consumers but not so good for a stockholder
owned corporations.The only way to drive up prices would be to get suppliers to limit the
resource and raise prices to reflect a lack of supply.(Remind you of OPEC and we will soon be
at PEAK OIL)Limiting supply is a crime.Collusion and Setting Prices is a crime.
See https:/!en.wikipedia.orgA iki/Enron
for more details on ENRON’s criminal activity.
From Conspiracy of fools,Author -Kurt Eichenwald
But nothing was quite ‘what it appred.The Enron aid1did
not burst out,ftilly grown,from the corporate landscape in a matter
of days.Across corporate America,widespread corner cutting,
steadily falling standards,and compromised financial discipline
had been festering for close to a decade.Warnings about funny
numbers,about unrealistic expectations,about the coming pain
of economic reality,went unheeded as investors celebrated
corporations pursuing reckless or incomprehensible business
strategies that helped their stock prices defy the laws of gravity.
Tt WaS in that enviràñmënt,ând öñly that enviröñn ent,thafffié
Enron debacle could emerge.It was not simply the outgrowth
of rampant lawbreaking.The true story was more complex,and
certainly more disturbing.For ctime at Enron—and,no doubt,
there was ciime—was just one ingredient in the toxic stew that
poisoned the company.Shocking incompetence,unjustified
arrogance,compromised ethics,and an utter contempt for the
market’s judgment all played decisive roles.Ultimately,it was
Enron’s tragedy to be filled with people smart enough to know
how to maneuver around the rules,but not wise enough to
understand why the rules had been written in the first place.
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It is a portrait of an America in upheaval at the turn of the twenty-
first century.a country torn between its worship of fast money and
its zeal for truth,between greed and high-mindedness,between
Wall Street and Main Street.Ultimately,it is the story of the untold
damage wreaked by a nation’s folly—a folly that,in time,we are
all but certain to see again,
EDMUND BURKE
Those who don’t know history are doomed
to repeat it.
And here is how the Investor Owned Utilities (IOU’s)in our region have significantly violated
the law,via the PACIFIC NORTHWEST ELECTRIC POWER PLANI\l[NG AND
CONSERVATION ACT of 1980.
Energy Imbalance Market (ElM)will experience the same destructive forces.
Ask yourself “What created the need for the Energy Imbalance Market?”
http://www.nrel.gov/electricity/transmission/energyimbalance.html
“The anticipated growth of variable renewable generation,such as solar and wind power,in the
West has raised concerns about how system operators will maintain balance between electricity
NoiñjIe person n siiigle
erson possibly could.Instead,the shortcomings of a handful of
xecutives—a1ong with a community of bankers,lawyers,and
tccountants eager to win the company’s fees;a government
villing to abide absurdly lax rules;and an investor class more
nterested in quick wealth than long-term rewards—merged to
reate an enterprise destined to fail.But in the end,for all the
nind-numbing accounting ploys and financial maneuvers that
:ame to light in Enro&s wake,the underlying cause of the collapse
vas fairly simple:the company spent much of its money on lousy
)usmesses.And the market exacted its revenge.
-
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production and demand in the Western Interconnection—and especially in its smaLler balancing
authority areas.This concern helped motivate a proposal to develop an energy imbalance market.
An energy imbalance market aggregates the variability of electricity generation and load for
multiple balancing authority areas and utility territories,and performs a 5-minute security
constrained economic dispatch.This can increase the economic efficiency of the power system.
This subhourty,real-time energy market provides centralized,automated,and region-wide
generation economic dispatch.By increasing the temporal and geographic footprint of the total
balancing authority area,the market could moderate the variability of renewable generation
resources and electricity demand.
The National Renewable Energy Laboratory (NREL)has worked with the Western Electricity
Coordinating Council and others to assess the potential ramping and reserve benefits of several
forms of an energy imbalance market.At the request of public utility commissioners in the West,
NREL used a detailed electricity production simulation model to obtain deeper insights into the
potential benefit of alternative forms of an energy imbalance market.The results were shared
with utility commissioners and other stakehotders to inform future decision making for Western
Interconnection operations.In 2014,the California Independent System Operator (CAISO)and
PacifiCorp wilt begin operating an energy imbalance market and NV Energy (Nevada Energy)is
expected to join in 2015.Through the MC Initiative,the Northwest Power Pool is currently
investigating similar wide-area economic dispatch models,and will evaluate whether an energy
imbalance market or similar market will be developed.”
This sounds like a reasonable direction to take,given the variability of
renewable solar and wind generating resources.
But the Energy Imbalance Market isn’t made ofjust solar and wind.It’s an all resources
available market and that’s how the Organization of Petroleum Exporting Countries (OPEC)
works.OPEC used to work in unison.All the parties would get together and set the price they
would sell at and the rest of the world followed because they had captured the largest customer
base (ratepayers in our case).That customer base had nowhere to turn to for energy.
What do you think is going to happen when Berkshire Hathaway Energy owns all the marbles?
(See Appendix A)
The Bonneville Power Administration via the PACIFIC NORTHWEST
ELECTRIC POWER PLANMNG AND CONSERVATION ACT
(An organization responsible to the Federal Government)used to hold all the
CARDS.
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In discussion with the Northwest Power and Conservation Council
Elliot Mainzer,Bonneville Power Administration Administrator
Historic Era For Electricity Industry -May 14,2015
“The changes that are happening,particularly in California,with the creation of an
energy imbalance market by PacifiCorp,the California ISO and the other utilities
that are joining,should not be underestimated in terms of its impact on the West,”
he said.“It will be a very,very significant change in the operating environment,
and it has major implications for all of us in the region.”
But when the Northwest Power Pool (NWPP)goes on line the game will be rigged
Violating the
PACIFIC NORTHWEST ELECTRIC POWER PLANNING AND
CONSERVATION ACT of 1980
If this was the only card the INVESTORS were going to play,I wouldn’t have much of a story to
tell.But as time passes more cards are revealed.
Supply and Demand
The supply is provided by profit motivated stock holder motivated corporations who claim they
are motivated by providing electrical service as PULIC GOOD but they are incentivized to think
of their needs before the ratepayers.(The Swan Falls and Renewable Energy cases prove my
point)
The Supply has been restricted to create market demand
Renewable energy supply is flooding the market.What happens when there is an oversupply?
Corporate forces act to reduce the supply.Idaho Power submitted Case No.IPC-E-15-0 Ito the
Idaho Public Utility Commission on Jan.30,2015 to restrict supply.(Does this sound a little like
ENRON)What happens in corporate America,the suppliers form a Cabal?
Northwest Power Pool —http://.n\\pp.or1/our—resourees/r\1C—lniuau\e
I believe the NWPP -ElM should be illegal under the terms dictated via the Pacific Northwest
Electric Power Planning and Conservation Act of 1980 for the reasons given above.
The Idaho Public Utility Commission should require Idaho Power to go back to the drawing
board with respect to IRP to develop a power supply plan that puts the environment and
ratepayers at the front of the stakeholder line.
Steve Nelson email —perr\neIsonraneIiaaol.eom
198 10 E.Onyx Ln.phone -509-995-2043
Spokane,Wa.99217
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Appendix A
Berkshire Hathaway’s Marbles
(From Berkshire Hathaway Energy Holding Company 2014 Annual Report)
BHE -Berkshire Hathaway Energy Company
Company -Berkshire Hathaway Energy Company and its subsidiaries
PacifiCorp -PacifiCorp and its subsidiaries
MidAmerican -Funding MidAmerican funding,LLC and its subsidiaries
MidAmerican Energy -MidAmerican Energy Company
NV Energy -NV Energy,Inc.and its subsidiaries
Nevada Power -Nevada Power Company
Sierra Pacific -Sierra Pacific Power Company
Nevada Utilities -Nevada Power Company and Sierra Pacific Power Company
Northern Natural Gas -Northern Natural Gas Company
Kern River -Kern River Gas Transmission Company
AttaLink -BHE AltaLink Ltd.
ALP -AltaLink,L.P.
BHE U.S.Transmission -BHE U.S.Transmission,LLC (formerly MidAmerican Transmission,
LLC)
BHE Renewables,LLC -BHE Renewables,LLC (formerly MidAmerican Renewables,LLC)
HomeServices -KomeServices of America,Inc.and its subsidiaries
BHE Pipeline Group or Pipeline Companies -Consists of Northern Natural Gas and Kern River
BHE Transmission -Consists of AltaLink and BHE U.S.Transmission
BHE Renewables -Consists of RHE Renewables,LLC (formerly MidAmerican Renewables,
LLC)and CalEnergy Philippines
ETT Electric -Transmission Texas,LLC
Domestic Regulated Businesses -PacifiCorp,MidAmerican Energy Company,Nevada Power
Company,Sierra Pacific Power Company,Northern Natural Gas Company and Kern River Gas
Transmission Company
Regulated Businesses-PacifiCorp,MidAmerican Energy Company,Nevada Power Company,
Sierra Pacific Power Company,Northern Natural Gas Company,Kern River Gas Transmission
Company and AltaLink,L.P.
Utilities -PacifiCorp,MidAmerican Energy Company,Nevada Power Company and Sierra
Pacific Power Company
Northern Powergrid Distribution Companies -Northem Powergrid (Northeast)Limited and
Northern Powergrid (Yorkshire)plc
Northern Powergrid
Northern Powergrid Holdings Company
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Berkshire Hathaway -Berkshire Hathaway Inc.and its subsidiaries
Topaz -Topaz Solar Farms LLC
Topaz Project -550-megawatt solar project in California
Agua Caliente -Agua Caliente Solar,LLC
Agua Caliente Project -290-megawatt solar project in Arizona
Bishop Hill II -Bishop Hill Energy II LLC
Bishop Hill Project -$1-megawatt wind-powered generating facility in Illinois
Pinyon Pines I -Pinyon Pines Wind I,LLC
Pinyon Pines II -Pinyon Pines Wind II,LLC
Pinyon Pines Projects -1 68-megawatt and 132-megawatt wind-powered generating facilities in
California
Jumbo Road J-umbo Road Holdings,LLC
Jumbo Road Project -300-megawatt wind-powered generating facility in Texas
Solar Star -Funding Solar Star Funding,LLC
Solar Star Projects A-Combined 579-megawatt solar project in California
Solar Star I -Solar Star California XIX,LLC
Solar Star II -Solar Star California XX,LLC
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