Several of us attended an informal meeting on "Purpose and Need" at the FRCC Wednesday, July 8th. It was, in essence, a follow-up to the March 26th Oregon PUC meeting in which Idaho Power's planning managers showed us Powerpoint presentations of figures primarily having to do with capital costs, current resources and requirements, firm energy transmission, renewable resource responsibilities and the very unfixed art of load forecasting. Did they make a better case this time? Read on . . .
Reading over the 2006 Integrated Resources Plan, one can observe in retrospect just how little IPCo's forecasts actually meshed with reality. Whether the current figures are any better is anyone's guess; what is apparent is that the new load forecast figures, which went unitemized for the meeting (there was no time after more than two hours of presentations for real discussion) left us uninformed on the subject of getting a handle on accurate load forecasting, despite Jean Findley's question, "How do you know that you're anywhere close here?"
Mark Stokes, Manager of Power Supply Planning, gave the "Our Best Guess" answer: "There's a ton of assumptions with any of this stuff."
Hardly reassuring, especially when Idaho Power assumes that Oregon real estate will be bearing the brunt of 500 kV powerline construction, even though it is obvious that
Reading over the 2006 Integrated Resources Plan, one can observe in retrospect just how little IPCo's forecasts actually meshed with reality. Whether the current figures are any better is anyone's guess; what is apparent is that the new load forecast figures, which went unitemized for the meeting (there was no time after more than two hours of presentations for real discussion) left us uninformed on the subject of getting a handle on accurate load forecasting, despite Jean Findley's question, "How do you know that you're anywhere close here?"
Mark Stokes, Manager of Power Supply Planning, gave the "Our Best Guess" answer: "There's a ton of assumptions with any of this stuff."
Hardly reassuring, especially when Idaho Power assumes that Oregon real estate will be bearing the brunt of 500 kV powerline construction, even though it is obvious that
- Malheur County's energy Need has little, if any, effect on the load forecasts;
- Any local service area forecast increase will be consumed by Idaho customers; and
- Much of the load forecast has to do with regional wheeling and not with local service area need at all, underscoring the public versus private argument.
We thought could be most helpful outlining Oregon's PUC administrative rules concerning the "Standard for Need" IPCo will have to meet in order to reapply for transmission line for the Energy Facility Siting Council's permission to cross Oregon real estate.
http://www.oregon.gov/ENERGY/SITING/docs/rules/div23.pdf
DIVISION 23
http://www.oregon.gov/ENERGY/SITING/docs/rules/div23.pdf
DIVISION 23
NEED STANDARD FOR NONGENERATING FACILITIES
345-023-0005 Need for a Facility This division applies to nongenerating facilities as defined in OAR 345-001-0010, except nongenerating facilities that are related or supporting facilities.
To issue a site certificate for a facility described in sections (1) through (3), the Council must find that the applicant has demonstrated the need for the facility. . .
The applicant shall demonstrate need:
(1) For electric transmission lines under the least-cost plan rule, OAR 345-023-0020(1), or the system reliability rule for transmission lines, OAR 345-023-0030. . .
(1) The Council shall find that the applicant has demonstrated need for the facility if the capacity of the proposed facility or a facility substantially similar to the proposed facility, as defined by OAR 345-001-0010, is identified for acquisition in the short-term plan of action of an energy resource plan or combination of plans adopted, approved or acknowledged by a municipal utility, people's utility district, electrical cooperative, other governmental body that makes or implements energy policy, (think Malheur County Energy Council) or electric transmission system operator that has a governance that is independent of owners and users of the system and if the energy resource plan or combination of plans:
(a) Includes a range of forecasts of firm energy and capacity demands and committed firm energy and capacity resources, as defined in OAR 345-001-0010, over the planning period using a reasonable method of forecasting; May 2007 − 1 − Division 23
(b) Considers and evaluates a reasonable range of practicable demand and supply resource alternatives over the planning period on a consistent and comparable basis. Practicable alternatives are those that are demonstrated to be technically and economically achievable within the time frame considered to meet potential energy or capacity needs;
(c) Uses financial assumptions, including discount rates and treatment of resource lifetimes and end effects that are consistent and comparable between resources;
(d) For electric transmission line facilities, considers alternatives that include but are not limited to:
(A) Implementation of cost-effective conservation, peak load management and voluntary customer interruption as a substitute for the proposed facility;
(B) Construction and operation of electric generating facilities as a substitute for the proposed facility;
(C) Direct use of natural gas, solar or geothermal resources at retail loads as a substitute for use of electricity transmitted by the proposed facility; and
(D) Adding standard sized smaller or larger transmission line capacity. . .
(g) Includes the development and evaluation of alternative resource plans to meet forecast energy or capacity needs over the planning time period; May 2007 − 2 − Division 23
(h) Analyzes the uncertainties associated with alternative resource plans or strategies. . .
(i) Aims to minimize long-run total resource costs while taking into account reliability, compatibility with the energy system, strategic flexibility, as defined in OAR 345-001-0010, and external environmental costs and benefits. The value provided by reliability, compatibility with the energy system, strategic flexibility and external environmental costs and benefits may justify actions that increase the total resource cost of the plan.
The Council finds that the goals of a least-cost plan are to minimize expected total resource costs for society and the variance in those costs due to uncertainty about future conditions;
(j) Includes a short-term plan of action;
(k) Is consistent with the energy policy of the state as set forth in ORS 469.010. An energy resource plan is consistent with the energy policy of the state if its short-term plan of action describes actions that must be taken within a two to three year time frame to provide a reasonable assurance that future energy or capacity demands can be met while aiming to minimize total resource cost; and
(L) Was adopted, approved or acknowledged after a full, fair and open public participation and comment process. Such a process is one in which the public has reasonable and timely access to the decision-maker and to information and records legally available to the public.
A good start to providing information to the public would include an itemization of load forecast assumptions. Another question might be asked of the Malheur County Energy Council as to what their assumptions are concerning energy Need for the foreseeable future.
345-023-0005 Need for a Facility This division applies to nongenerating facilities as defined in OAR 345-001-0010, except nongenerating facilities that are related or supporting facilities.
To issue a site certificate for a facility described in sections (1) through (3), the Council must find that the applicant has demonstrated the need for the facility. . .
The applicant shall demonstrate need:
(1) For electric transmission lines under the least-cost plan rule, OAR 345-023-0020(1), or the system reliability rule for transmission lines, OAR 345-023-0030. . .
(1) The Council shall find that the applicant has demonstrated need for the facility if the capacity of the proposed facility or a facility substantially similar to the proposed facility, as defined by OAR 345-001-0010, is identified for acquisition in the short-term plan of action of an energy resource plan or combination of plans adopted, approved or acknowledged by a municipal utility, people's utility district, electrical cooperative, other governmental body that makes or implements energy policy, (think Malheur County Energy Council) or electric transmission system operator that has a governance that is independent of owners and users of the system and if the energy resource plan or combination of plans:
(a) Includes a range of forecasts of firm energy and capacity demands and committed firm energy and capacity resources, as defined in OAR 345-001-0010, over the planning period using a reasonable method of forecasting; May 2007 − 1 − Division 23
(b) Considers and evaluates a reasonable range of practicable demand and supply resource alternatives over the planning period on a consistent and comparable basis. Practicable alternatives are those that are demonstrated to be technically and economically achievable within the time frame considered to meet potential energy or capacity needs;
(c) Uses financial assumptions, including discount rates and treatment of resource lifetimes and end effects that are consistent and comparable between resources;
(d) For electric transmission line facilities, considers alternatives that include but are not limited to:
(A) Implementation of cost-effective conservation, peak load management and voluntary customer interruption as a substitute for the proposed facility;
(B) Construction and operation of electric generating facilities as a substitute for the proposed facility;
(C) Direct use of natural gas, solar or geothermal resources at retail loads as a substitute for use of electricity transmitted by the proposed facility; and
(D) Adding standard sized smaller or larger transmission line capacity. . .
(g) Includes the development and evaluation of alternative resource plans to meet forecast energy or capacity needs over the planning time period; May 2007 − 2 − Division 23
(h) Analyzes the uncertainties associated with alternative resource plans or strategies. . .
(i) Aims to minimize long-run total resource costs while taking into account reliability, compatibility with the energy system, strategic flexibility, as defined in OAR 345-001-0010, and external environmental costs and benefits. The value provided by reliability, compatibility with the energy system, strategic flexibility and external environmental costs and benefits may justify actions that increase the total resource cost of the plan.
The Council finds that the goals of a least-cost plan are to minimize expected total resource costs for society and the variance in those costs due to uncertainty about future conditions;
(j) Includes a short-term plan of action;
(k) Is consistent with the energy policy of the state as set forth in ORS 469.010. An energy resource plan is consistent with the energy policy of the state if its short-term plan of action describes actions that must be taken within a two to three year time frame to provide a reasonable assurance that future energy or capacity demands can be met while aiming to minimize total resource cost; and
(L) Was adopted, approved or acknowledged after a full, fair and open public participation and comment process. Such a process is one in which the public has reasonable and timely access to the decision-maker and to information and records legally available to the public.
A good start to providing information to the public would include an itemization of load forecast assumptions. Another question might be asked of the Malheur County Energy Council as to what their assumptions are concerning energy Need for the foreseeable future.
