Draft Record of Decision on Environmental Redispatch and Negative Pricing
The following comments were submitted in response to the open comment period described below.
BPA has released its draft record of decision on Environmental Redispatch and Negative Pricing Policy for public comment. Comments are due by Friday March 11, 2011 at 5:00 p.m.. You will find BPA’s draft policy here http://www.bpa.gov/corporate/AgencyTopics/ColumbiaRiverHighWaterMgmnt/Draft%20ROD%20ERNP.pdf .
As participants in the October and December workshops noted, BPA needs more tools to protect endangered species. That’s why the agency is proposing environmental redispatch. By displacing non-hydro generation in the region with renewable federal hydropower, BPA could maximize hydro generation, reduce spill to protect fish, and allow generators to continue serving their customers. Our proposed policy addresses several key points, including:
BPA is working on other actions that have long-term potential to take advantage of an over-supply of generation, such as: improving transmission capacity when we have excess power, modifying maintenance schedules, and diverting water to replenish irrigation aquifers.
As a last resort, if other voluntary and marketing solutions are not sufficient to help us uphold our environmental and statutory obligations, BPA will direct generators to reduce generation and replace it with federal hydropower at no cost.
BPA is committed to minimizing the impact of environmental redispatch on the generators involved. We would curtail their production only after displacing other available generation.
BPA is hosting an Overgeneration Management workshop on Friday Feb. 25, 2011 from 9:30 to 4:30 in the Rates Hearing Room. For more information,
The meeting will cover a wide range of issues, including the draft record of decision and our overgeneration financial analysis. We will provide an update on the actions the agency is evaluating to avoid having to take these actions. The workshop will include time for questions and input from participants.
For More Information:
http://www.bpa.gov/corporate/AgencyTopics/ColumbiaRiverHighWaterMgmnt/Draft%20ROD%20ERNP.pdf
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.
Close of comment: 3/11/2011
- ERP110002 -
Cromwell, Jr./Seattle City Lightview attachment
View Attachment
- ERP110003 -
Barker/Wild River Consulting for Sybioticsenergy.comview attachment
View Attachment
- ERP110004 -
Woodin/Community Renewable Energy Associationview attachment
View Attachment
- ERP110005 -
CrosslerTo absorb excess power, do one of two things: Spill more water or (more obviously) create a battery back-up system.
- ERP110006 -
Galleview attachment
View Attachment
- ERP110007 -
Birgisson/NextEra Energy Resources, LLCview attachment
View Attachment
- ERP110008 -
Ford/Save Our Wild Salmonview attachment
View Attachment
- ERP110009 -
Garcia/Tacoma Powerview attachment
View Attachment
- ERP110010 -
Andrea/Avista Corporationview attachment
View Attachment
- ERP110011 -
Nelson/Springfield Utility BoardPlease see attached comments
View Attachment
- ERP110012 -
Saven/Northwest Requirements Utilitiesview attachment
View Attachment
- ERP110013 -
Jacobs/Public Generating Poolview attachment
View Attachment
- ERP110014 -
Deren/Snohomish PUDview attachment
View Attachment
- ERP110015 -
Nelson/Springfield Utility BoardIberdrola Renewables Study 2 (Attachment to SUB's comments)
View Attachment
- ERP110016 -
Nelson/Springfield Utility BoardIberdrola Study 1 (Part 1) - Attachment to SUB comments
View Attachment
- ERP110017 -
Nelson/Springfield Utility BoardIberdrola Study 1 (Part 2) - Attachment to SUB comments
View Attachment
- ERP110018 -
Springer/Vestas AmericasVestas-Americas Wind Technology, Inc. ("Vestas Americas)is pleased to submit these comments to the Bonneville Power Administration (“BPA”) on the Draft Record of Decision (“ROD”) on Environmental re-dispatch (“ER”) and Negative Pricing Policy. Vestas Americas strongly supports the comments submitted by the Renewable Northwest Project (“RNP”) and agrees with RNP that the proposed policy creates uncertainty and is potentially discriminatory against wind energy generation. Vestas Americas also encourages the BPA to postpone finalizing the ROD and respectfully request that the BPA consider the recommendations in the RNP comments for further study . We would appreciate the opportunity to provide feedback to BPA on this subject.
- ERP110019 -
Baker/Public Power Councilview attachment
View Attachment
- ERP110020 -
Neale/Western Public Agencies Groupview attachment
View Attachment
- ERP110021 -
Lincoln/TransAltaview attachment
View Attachment
- ERP110022 -
Hall/enXco Development Corporationview attachment
View Attachment
- ERP110023 -
Hall/Horizon Wind Energy LLCview attachment
View Attachment
- ERP110024 -
Lynch/Constellation EnergyComments of Constellation Energy on Administrators’ Draft Record of Decision on Environmental Redispatch and Negative Pricing Policy Dated February 18, 2011 The administrator of the Bonneville Power Administration (BPA) has requested comments on the Draft Record of Decision on Environmental Redispatch and Negative Pricing Policy, dated February 18, 2011. Constellation understands that the purpose of the policy decision is to address over generation conditions that may occur due to the increasing amounts of wind generation on the BPA system. Constellation Energy (Constellation) appreciates the opportunity to submit these brief comments. In addition to the proposed Environmental Redispatch, BPA’s tariff also contains Disptach Standing Order (DSO) 216. Under DSO 216, BPA can require wind generators to reduce their output to scheduled volumes. It is not clear to Constellation whether BPA’s proposed Environmental Redispatch would be implemented before or after BPA has issued directives under DSO 216. Therefore, Constellation requests that BPA provide additional clarity with respect how and when each of these protocols would be deployed. For instance, would the environmental redispatch protocols only be invoked after BPA has issued directives under DSO 216? Or would the environmental redispatch protocols be invoked in order to avoid issuing DSO 216 directives? Constellation believes that clarity on this topic will assist market participants gain a full understanding of the Environmental Redispatch proposal, and looks forward to further discussion on this topic. If you have questions, please call Mary Lynch (Vice President, Regulatory and Legislative Affairs, West Region) at 916 606 0783, or Debbie Emerson (Vice President, Hourly Trading) at 410 468 3621.
- ERP110025 -
Towner/PNGC PowerComments attached. Thank you.
View Attachment
- ERP110026 -
KiefferMy wife and I, and our children and grandchildren, are lineal descendants who trace our ancestry directly and without interruption, by means of traditional kinship systems, to Native Americans who, since time immemorial, were buried along the shores of the main channels and tributaries to the upper Columbia River, and the Spokane River, in the state of Washington. The gravesites of many of our ancestors buried along the Columbia River and the Spokane River were inundated by the construction of the Grand Coulee project for water storage, power production, flood control, and other purposes. The day-to-day operation and seasonal operation of the Grand Coulee project for multiple purposes, including water storage, flood control, generation of hydroelectric power, support for the high-voltage transmission grid, providing water for augmenting flows for threatened and endangered species—a and, now, using Grand Coulee as a “wind balancing” resource for integrating wind powered generating stations that sell an estimated 80% of the energy produced outside of Bonneville’s balancing area—exposes the gravesites of our ancestors, funerary objects, sacred objects, and other items, leaving their human remains and other items vulnerable to intentional and inadvertent discovery, as well as deliberate looting. The provisions and priorities established in 25 U.S.C. § 3001 et seq. for the protection and repatriation of Native American graves, particularly section 3002(a)(1)-(2), vests ownership and control of Native American human remains and related objects, which are excavated or discovered on federal or tribal lands after the 16th day of November, 1990, first, in the lineal descents of the Native Americans whose human remains or gravesites are excavated or discovered, and second, in the Indian tribe on whose land such human remains or objects have been discovered if the lineal descendants cannot be ascertained. I am called upon often by traditional religious leaders to assist in proper burial of my relations and other tribal members in a way that goes back to time immemorial. These religious leaders who request my assistance in proper burial of the remains of the Spokane Tribe’s members are recognized by as being responsible for performing cultural duties relating to ceremonial and religious traditions and practices that can be traced historically and prehistorically from our shared group identity based on geography, kinship, biological, archeological, anthropological, linguistic, oral tradition, historical evidence and other information, including expert opinion, to earlier groups of Native Americans whose members were buried along the main channels and tributaries of the Columbia River and Spokane River, and whose remains are exposed by the day-to-day and seasonal operation of the Grand Coulee project to support the integration of wind power and for a variety of other purposes. I am submitting this comment on wind over-generation to provide you with written notice the activities of your agency have, including but not limited to the operation of Grand Coulee to provide wind balancing services, has severe impacts on the Native Americans who were buried on and adjacent to lands inundated by construction of the Grand Coulee dam and power generation and transmission facilities. It is incumbent on Bonneville Power Administration and the U.S. Bureau of Reclamation to avoid altogether, minimize and/or mitigate for these impacts in planning and in carrying out your wind over-generation policy and other activities that result in the inadvertent discovery or excavation of human remains, funerary objects, sacred objects or objects of cultural patrimony on federal lands in the Columbia Basin Project, of which Grand Coulee dam is the central feature. I am requesting the U.S. Bureau of Reclamation, which operates the Grand Coulee project, and yourself, as the official responsible for the agency engaged in using the Grand Coulee project as a wind balancing resource, consult with me regarding the proper disposition of human remains, funerary objects, sacred objects and items of cultural patrimony, which have been or are likely to be, discovered, either intentionally and/or inadvertently, so that I may confer with the traditional religious leaders to identify the specific lineal descendants affiliated with any human remains, funerary and other objects with the goal of producing a detailed written plan of action for how the human remains, funerary objects, sacred objects and/or objects of cultural patrimony will be traditionally treated with respect due them, cared for, and handled, including the planned archeological recording, if any, the kinds of analysis planned, if any, for each kind of object, and the planned disposition of such human remains and objects. Finally, I note that the day-to-day and seasonal operation of the Grand Coulee project for multiple purposes, including but not limited to production of electric energy, adversely impacts resident fish in Lake Roosevelt, which I harvest for subsistence and other purposes, as well as degrades water quality, disrupts the establishment of vegetation along the shoreline, leads to sloughing of tribal lands, in addition to exposing gravesites to discovery and looting. It is important for Bonneville Power Administration to take all of these adverse impacts into account.
- ERP110027 -
Apperson/PacifiCorpview attachment
View Attachment
- ERP110028 -
Skidmore/Iberdrola Renewables, Inc.view attachment
View Attachment
- ERP110029 -
Heutte/NW Energy Coalitionview attachment
View Attachment
- ERP110030 -
Skeahan/Cowlitz PUD
view document
View Attachment
- ERP110031 -
Ryan/WeyerhaeuserMarch 14, 2011 Stephen Wright, Administrator Bonneville Power Association PO Box 3641 Portland, OR 97208 We want to thank BPA for providing this opportunity to share our views. Our goal is to present some of the reasons why CHP generation should either excluded from the Environmental Redispatch ROD or be the last to be curtailed. 1. All our electric output is tied to plant production. We are not a dispatchable plant. Our production system is tied to the steam output of the boilers and generation system. 2. While generation can usually be reduced if necessary, it needs to be a slow, planned process or we risk tripping our internal “steam customers”. Upset conditions like that are the times when safety incidents and environmental incidents are more likely and endanger our operating personnel at the mill. People safety is our #1 goal at Weyerhaeuser. 3. Most of our electricity production is Green, using biomass a fuel for the boilers. 4. Stopping the electric output in a planned deliberate way does not stop the boilers which produce the steam for the process; it just makes the overall utilization of the biomass fuel used less efficiency. 5. Upsets can be dangerous and cost green benefits and production. Although Weyerhaeuser believes that BPA is correct in prioritizing redispatch based on a “least-cost" generation approach, it appears that BPA did not consider the economics specific to cogeneration thermal facilities. Cogeneration facilities typically have lower avoided costs compared to other thermal facilities due to less expensive and have green fuel sources. We ask that BPA take these factors into consideration and differentiate cogeneration thermal facilities from standard thermal facilities and wind generators when determining the ultimate redispatch priority that will be conveyed in the final Record of Decision. Weyerhaeuser appreciates the work and thought BPA put into developing the Draft ROD. We look forward to continuing work with BPA on these issues. Please contact me if you have any questions or need more information. John Ryan Energy Manager
- ERP110032 -
Lenfest/Sea Breeze Pacific Regional Transmission Systemview attachment
View Attachment
- ERP110033 -
Mills/Puget Sound Energyview attachment
View Attachment
- ERP110034 -
Shimshak/Renewable Northwest Projectview attachment
View Attachment
- ERP110035 -
Duncan/Oregon Global Warming Commissionview attachment
View Attachment
- ERP110036 -
Krueger/Oregon Department of Fish and Wildlifeview attachment
View Attachment
- ERP110037 -
Lane/Northwest and Intermountain Powr Producers Coalitionview attachment
View Attachment
- ERP110038 -
Jamieson/Portland General Electric Companyview attachment
View Attachment
- ERP110040 -
MacDougall/Powerex Corp.view attachment
View Attachment
- ERP110041 -
Pace, PhDview attachment
View Attachment
|
|
|
Finance & Rates
