Proposed Oversupply Management Protocol
The following comments were submitted in response to the open comment period described below.
BPA is seeking comments on a draft proposal to address seasonal electricity oversupply by paying wind energy producers to curtail their output if necessary. There is also an associated proposal for how BPA would recover the new costs that would be incurred.
BPA has been engaged in discussions with a number of key stakeholders since last spring to find an equitable solution to oversupply. The proposal is based on concepts developed in these discussions. BPA is releasing the proposal now to allow for broader public input before we file tariff language.
BPA is seeking comments on the proposal, which is described in two documents: a) new tariff language for addressing oversupply (Attachment P); and b) a more detailed narrative which explains the proposed methods for managing oversupply and allocating the associated costs.
BPA is accepting comments on the proposal through noon Feb. 21 and will host a workshop on Feb. 14, from 9 a.m. to noon in the BPA Rates Hearing Room.
For More Information:
http://www.bpa.gov/corporate/AgencyTopics/ColumbiaRiverHighWaterMgmnt/
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: 2/21/2012
- OMP12 0001 -
AndersonDear Sirs, I would like to comment on BPA paying wind energy producers to curtail their output if necessary. Don’t pay wind energy producers. BPA was set up to handle power from hydroelectric sources. Wind energy needs to build their own transmission lines. It needs to be a continental system that can provide a continuous source of power. They need to be located in zones of consistent wind. I see many wind generators located along the BPA transmission lines and not turning. Mountains are not a good location for wind generators. It is like locating a hydropower dam in a desert. Wind generators need to be located in zones of consistent wind. They should be in the great flat plains of the earth. Hydropower is plentiful and cheap and should have priority to provide public power without penalty from other power sources. Hydro should definitely not subsidize the poorly engineered wind powering our Northwest. It is a waste of my money. Sincerely, Roy Anderson
- OMP12 0002 -
PickardHydroelectric power in this region is abundant and should be used to the maximum. Wind power is not an efficient means of electricity and never has been, government sponsered or not. The land owners who were lucky enough to get wind turbines on their land get paid very well for land that was mostly non productive anyway. The wind turbine supporters are like any other business who invested with option to sell their product, and if the product isn't needed all the time they should accept that. I don't think they should be compenstated at all for a product that wasn't purchased.
- OMP12 0003 -
KepleyMr. Dale Kepley called to say that he saw in the Yakima paper that BPA is proposing to pay the wind operators to stop their wind farms when needed. He said: " Someone needs to tell them to stop this foolishness. Who has to pay for this? Not BPA, not the big companies -- the little people have to pay. The wind companies will not accept that and they will milk BPA for all they can get. We don't need wind, and we don't need more electricity. PPL has another rate increase, and when this deal gets settled they will ask for more. Someone needs to stop these stupid wind machines. Why do the customers have to keep paying for this? It's ridiculous. People on fixed incomes cannot keep dealing with this. Why do they keep building these wind farms. I don't understand. This whole dispute has to stop. I want to talk to someone higher up -- the higher the better! I need some justification"
- OMP12 0004 -
BerkaWhat about pumping water uphill to cope with an over-supply of electricity? Reservoirs can be built on hilltops, or even existing lakes can be used. The affected region is hilly, so there should be ample places for such reservoirs nearby. When the electricity production is excessive, electric pumps can be used to pump the water into these reservoirs. These pumps can be powered by either the hydro turbines or the wind machines. When needed, the water can then be routed back downhill and passed through hydro turbines to generate electricity. This way the energy is not wasted. The efficiency of such systems can range from 70 to 80 percent, and they can be cheaper to build than battery storage. (You're probably already quite familiar with this, but I just thought it was worth mentioning anyway... ;-)
- OMP12 0005 -
Regarding the recent statement by BPA to propose a structure where it reimburses variable resource generators in high water/high wind events, has BPA looked into the legitamacy of including the cost of foregone PTC when prices are zero or negative? The concern is that BPA is compensating variable generators for lost PTC that generators are not eligible to claim in zero or negative pricing markets. This concern is based on the IRS Code for PTC that requires renewable energy to be eligible for the PTC to be both produced and sold; having to pay a counterparty to take a produced product does not qualify as "sold" under tax law.
- OMP12 0006 -
PetersonI applaud the good faith efforts of BPA to provide cost effective systems for delivery of power. However, it is simply wrong to pay money to wind power generators for not delivering power. It is wrong to demand that private citizens, through their rates, pay companies for excessively expensive,unneeded and undelivered power.
- OMP12 0007 -
Gilbert/Friends of Grande Ronde ValleyOregon Statutes and rules say "that the need for new generating facilities, as defined in ORS 469.503, is sufficiently addressed by reliance on competition in the market rather than by consideration of cost-effectiveness and shall not be a matter requiring determination by the Energy Siting Council in the siting of a generating facility, as defined in ORS 469.503" The determination about whether or not to allow a wind farm to be built does not address need because market forces are expected to control their development. If wind farm developers are not assessing the market to make sure there is a need for their energy, then that is their problem. Taxpayers and ratepayers should not have to bail out these foreign companies who did not do their homework regarding problems with overdevelopment of wind farms. I strongly disagree with any arrangement that requires BPA to deny electric users the use of low cost hydro-power in favor of expensive, intermittent and environmentally destructive wind power. In the event that there is a determination that this should be done, I am requesting a hearing due to the fact that the above Oregon Statute places responsibility for assessing market forces on the developer, not on the Energy Facility Siting Counsil, the ratepayers, or Bonneville Power Administration. Irene Gilbert, Legal Research Analyst/ Friends of the Grande Ronde Valley/ Mailing Address: Irene Gilbert/ 2310 Adams Ave/ La Grande, Or. e-mail: ott.irene@frontier.com phone: 541-963-8160
- OMP12 0008 -
Grendahl
My name is Gary Grendahl and my wife and I reside in Columbia County, Washington. It’s just unbelievable to us that the BPA and subsequently the consumer would pay for power they didn’t need or receive. This is just another example of our Government run amuck! We didn’t need Wind power in the first place and it’s certainly not cost effective.
- OMP12 0009 -
Thompson
- OMP12 0010 -
MartinoFollowing are comments on BPA's Proposed Oversupply Management Protocol. BPA proposes to pay wind generators and other non-hydro producers not to produce and instead rely solely on Columbia/Snake hydropower generation in order to avoid an oversupply of power on the grid. This is very odd since salmon listed under the ESA could benefit enormously from water spilled from the system at this time of potential oversupply. BPA claims that there is no way to rely on non-hydro generators for power production and spill water from the dams to benefit fish without incurring excess nitrogen saturation, which would harm fish. But it is far from clear that BPA has explored its options to spill and benefit fish without incurring excess nitrogen saturation. I recommend that BPA open discussions with fisheries agencies on how to spill and benefit fish and withdraw its proposal to pay non-hydro producers to shut down.
- OMP12 0011 -
EagonFirst, very seldom do I get agitated enough to take time from my busy day to comment on any policy of any kind. This subject, however, has provoked me to do just that. I find it truly incredible that we, in Washington State, are subsidizing wind energy development not only with our tax dollars, but also with our energy rates. Despite EPA’s obvious political and totally stupid decision to designate hydro-power as non-renewable energy, anyone with an ounce of common sense knows that it is just that-a wonderful renewable energy resource. We are blessed in this area to have enough hydro-power to not only feed our area, but enough to send elsewhere. Putting up windmills that are ugly to the eye, restricting on our land use and generate unneeded power is CRAZY. If wind energy can not make it on its own merit, then it needs to dry up like any other business. With my electrical rates climbing since last year, and knowing that BPA will ultimately give in on this issue-basically having NO guts to stand up to wind energy, you should know that my neighbors and I are seeking to convert to gas as our primary source of energy.
- OMP12 0012 -
GerkI strongly object to the proposal that BPA pay (any amount) wind energy producers when they reduce their output (for any reason). I am a residential customer of the Benton PUD, which forecasts there is abundant hydroelectric power to meet demand until ~2023. My electric rate has already increased to cover the costs for purchasing wind energy that the PUD had to purchase because of Washington State’s Initiative 937, which disallowed hydropower as “renewable.” The consumer should not be forced to subsidize the wind energy industry for power that is not needed in the first place. The BPA should continue to maximize the delivery of low-cost, environmentally friendly, “renewable” hydropower; the wind energy industry should bear ALL of the cost if their higher-cost energy is not needed; the consumer should not be responsible for the cost of excess power generation. This situation will only get worse if BPA (ultimately the consumer) agrees to make ANY payment for excess energy production that is not needed.
- OMP12 0013 -
FeekesI would like to comment on the totally idiotic ideal of paying the wind farms to not produce energy during high run off periods. We as tax payer's are already susidizing this industry that can not and would not survive on it's own merits, how can it be justified to pay them to be shut off from the grid during times BPA is fallowing mandates to help fish. Is there some kind of gauranty to the wind companys of profit? The rate payers of BPA should not be accountable for a industry surviving on goverment hand outs. Please fight the wind company's in court. I am well aware that the legal system is in no way fair or just, but sometimes, the stupidity of corperations and government need to be brought to the light of day. I can think of no other way to shine a bright light on this issuie, and however remote, bring some resemblance of fairnas and sensability to issuie.
- OMP12 0014 -
BlackAs a tax paper and former Lineman for PP&L, I know there has to be more transparency and facts of the “net” KW that actually reaches the grid at the end of the year, instead of what we get in the media (enough KW to power 100,000 homes) which has never happened. I know PSE and PP&L had no way to get it to the grid until late in 2011 and I don't know if they still can. Solutions: Be factual 1. When there is abundance of water in rivers, pump water with wind back up to head waters of creeks, streams, holding areas and aquifers that are receding. I'm sure the Corp has all kinds of information on irrigation for the whole Touchet Valley. At one time there was a plan to put a canal system along the Snake River for fish and irrigation. A project like this could come together with all entities involved, (fish, hydro, wind for pumps, and barges) Besides it would put people back to work and create more irrigation for food crops. 2. No subsides – Green royalties where wind is built. County tax payers should receive a green royalty check once a year, like the oil royalties in Alaska. A. It would be easier for tax payers to vote for schools bonds, etc. B. It would also be easier for companies that are coming into the county for wind to get permitting if all taxpayers benefited instead of just a few, which divides the community. We have to work with what we have already (rich resources) classify Hydro Renewable.
- OMP12 0015 -
Brickey/NoneI do not feel BPA should be reimbursing the wind companies for power sales lost because they cannot ship their power on BPA lines. I do not know what sort of contract was signed with them, but this problem should have been addressed before contracts were signed. I can't believe no one realized it would come up. Why are we in the northwest expected to pay for lost sales experienced, in some cases, by eastern companies who built wind towers in the west? We are essentially subsidizing the wind industry. I do not like this at all, and feel if they want continuous ability to ship their power they should build their own transmission lines!
- OMP12 0016 -
RAHN/SELFI don't belive wind power should be accepted on BPA transmission lines when BPA is putting the lines to full use for the power they are producing. I don't like paying for high priced wind power.
- OMP12 0017 -
BallardI am writing a comment concerning the request by the wind energy companies for compensation for their lost revenue due to the amount of electricity produced by dams during the high run off periods. I do not think we as consumers of the electricity owe these wind energy companies compensation for "imagined" lost revenue. The water running through the dams decreased the amount of energy needed in the grid from the wind energy sources. Such is the economic law of supply and demand. The wind energy companies have overbuilt the need and have been a boondoggle since day one. They need to compete in the world of supply and demand. Their days of a free lunch should be over! Tell them that!
- OMP12 0018 -
Richardson/Springfield Utility Board
- OMP12 0019 -
HerbertPlease do NOT compensate the wind energy industry for generating electricity that they cannot use! As a user of your electricity, I am opposed to this. I have chosen to not subsidize this industry and do not want to, through my current or future electric bill. Wind energy is viable in some areas but historically this source has been subsidized by the government and cannot survive on it's revenue, alone. I do not want to be part of this and do not want BPA to pay anything to the wind industry.
- OMP12 0020 -
Jolly/Blue Mountain AllianceBPA should be fighting this so that the Pacific Northwest is not paying higher rates for the rest of the country's power. The wind companies are already getting subsidized enough from the state and the federal government. It does not make sense that BPA is forced to pay wind companies millions of dollars when BPA is trying to do the right thing by saving the fish during times of excess runoff. I don't see how wind tower companies that are supposed to be environmentally friendly are suing BPA because BPA is doing what they can to manage the excess water flows issue and saving the fish. It seems to me that the wind companies are after as much money as possible whether it is though tax subsidies or by suing. Seems like a lot of greed by the wind companies and all the citizens are paying for this disaster that we created by allowing to many wind towers. The dams should be considered green power anyways since water is a renewable resource.
- OMP12 0021 -
Johnson/NAAs a concerned citizen and BPA customer I am officially protesting expantion of existing BPA facilities and/or incorporation of energy from wind power to the existing hydro-electric system that would result in an increase in costs to any users (large companies or us residential customers)of hydro-electric power. All costs associatate with the developement and delivery of wind generated power should be totally absorbed by those companies developing, building and delivering this wind power. In addition the operation and delivery of hydro-electric power should not be curtailed or interupted to acomadate wind power if it would result in increased power rates for any customers (large or small). For the most part these wind power enterprizes are private companies that should be totally responsible for their own operations just like any other busness. They should have engineered and planned for the delivery system necesary to get the wind power to potential customers before they moved one shovel of soil. They should also be responsible for selling this more expensive power to customers that want to pay more for this kind of power. We all know that any increase in rates to any large company will ultimatley be paid for by us small power users or citizens through increase costs of other consumer products or services. It is BPA's responsibility to keep costs to its existing customers as low as possible, not to increase our rates to allow new businesses better start up opertunities. It is totally iresponsible for the government to provide subsidies to private companies to construct wind farms with out a plan to deliver the resultant power to the grid system. The construction of these wind farms with no logical delivery system, and no plan to pay for it, is one of the worst environmental nightmares of all time! I refuse to pay any rate increase or fee that is a result of wind power. Forcing private company costs on citizens in the name of environmentalism is illegal and I urge you not to become a part of it. BPA has done an outstanding job of manageing its part of our hydro-electric system, along with the Army Corps of Engineers, while balancing the complex fisheries and water resource issues in the Snake and Columbia river system. I urge you to protect those efforts and acomplishments by rejecting the incoporation of wind power through expantion, hydro-electric shut downs and/or rate increases at any level. Thank you for your consideration and the opertunity to comment. Please forgive the poor spelling.
- OMP12 0022 -
severeI believe that asking the rate payer to foot even a small portion of our power bill so the wind turbines can keep on turning is ridiculous and wasteful! When we have an abundant supply of hydro power it should be used. Wind companies should not take president over hydro and I believe that the FERC ruling should be over turned. It is wrong- plain and simple!
- OMP12 0023 -
PhillipsThe only reason we have to put up with wind power in the first place is that our politicians have decided that they can capture a lot of “green votes” by promoting it. It’s inefficient, undependable and uneconomical. Were it not for tax payer subsidies companies such as Florida Power, GE and Duke would not be putting up all the wind turbines we see despoiling our country side. Now the companies that bet on wind power to garner all the lucrative government subsidies want even more from the taxpayers to feather their nests. But this time they want to enhance their profits not from the tax payers at large, but from a select group of taxpayers, namely, those of us that live here in the Pacific Northwest. Now, in addition to the lucrative federal subsides they’re getting, they want to jack up our rates to compensate them when the grid is overloaded with hydroelectric power. I have a better idea, why don’t they reimburse us for the taxes we have to pay for all this nonsense when the wind ain’t blowing? The whole green energy craze is nothing but a cynical, crony capitalist, ploy to enrich a few politically favored big companies and line the pockets of environmental hucksters like Al Gore and other leftist politicians, who have all their constituents whipped into a frenzy thinking the world will come to an end if we don’t spend more taxpayer money on more inefficient, wasteful, uneconomical, green nonsense. It’s disgusting. Tell the wind power companies that want to jack up our rates to take a hike.
- OMP12 0024 -
GallantAs an owner of multiple businesses in the Northwest, I am truly shocked to hear of BPA's consideration to pay the owners of the wind farms a subsidy during times of high power output and low demand. These are the most subsidized entities in the "private sector" Are you telling me they didn't know that the rivers run high in the spring and the resultant high power generation would obviate the need for the wind input? Give me a break. They, the Wind Farms entered into an industry that is spotty in delivery and high in maintenance, and now they want, or better put you are proposing the rate payers further subsidize them. When are you going to lower my electric bill, because I need more energy in the summer to run the air conditioners in my stores? This makes me furious, I am calling my congressional delegation tomorrow to express my outrage. Simply put DO NOT do this.
- OMP12 0025 -
von BorstelIn regards to paying wind energy producers for electricity NOT generated. Since the land I'm farming has had two seperated wind farms installed, I am probably a bit more informed about the farce known as wind energy. Given that wind generated electricity is the most expensive of the mass produced power, no invester in there right mind would invest in a wind project unless government subsidies made profit possible. So we subsidize there construction, then subsidize to make they're kilowatt/hour rate competitive, we destroy farm land, and construct a blight upon the land and now we are going to pay them NOT to produce what they do such a poor job of doing in the first place. Only in America! I appreciate how BPA has found itself between a rock and a hard spot on this issue but please do not make the mistake of of pouring more money into "the rat hole". I must admit being a bit confused by BPA's proposal to the wind energy producers. In conversations with a retired BPA engineer, I was left with the impression that the hole of BPA understood what a boondoggle wind energy was and still is. So who is responsible for this proposal and for what reason? Just for accuracy, the Engineer I speak of is Bill Johnson and he is my first cousin! In closing, you must appreciate my position on this matter. I'm taxed to double subsidize wind energy, I have to put up with the noise they generate, the inconvenience of farming around the towers and roads, all the while knowing how this hole idea is not economically viable. Now I will get to "contribute" even more with higher electrical rates. Thanks for your time, Brian von Borstel
- OMP12 0026 -
ThornA nearly continuous history of wind speed is available on BPA's website, for most sites of wind farms in BPA's balancing authority. The efficiency graphs showing how each windmill model converts wind speed into energy, are available from the turbine manufacturers. It is clear, from these two data sources, that averaged annually, windmills in BPA's authority are producing little, if any, electricity. Specifically, it is blatantly obvious that no wind energy production opportunities were lost during last June's high-runoff period, since BPA carefully chose those rare shutdown hours to be times of calm wind. In fact, last June, in general, was so calm that most of the area's windmills were using more electricity than they were producing, shutdown or not. The fact that wind developers are now demanding payment from BPA for lost income during a time when no windmills were generating electricity, is irrefutable proof that wind developers do not get their income by selling electricity. Wind developers get their income, instead, by forcing BPA to sell BPA's own electricity at higher prices. Of course, BPA knows this; after all, the data are from BPA's own website. BPA, when it decided to appease the wind developers, must have mistakenly thought that we, the public, regard windmills as motherhood-and-apple-pie, to be encouraged at all cost. Perhaps we should disabuse them by our cries of outrage.
- OMP12 0027 -
severeThe FERC ruling needs to be over turned. It is high time that wind energy stands on it's own. It shouldn't be propped up by tax payer dollars or BPA rate hikes to customers.
- OMP12 0028 -
DoddI am apposed to BPA becoming the nurse maid to the Wind Power Company (Companies). If Wind Power Company (Companies) did not do their home work before installing wind towers they should not expect BPA, or other electrical agencies (producing and/or using) to cover the costs for their lack of appropriate planning.
- OMP12 0029 -
Stamper/nonePLEASE DO NOT COMPENSTATE THE WIND FARM CO,s. for there claimed loss of income during our Dams peak power season. They new full well what they would be up against during this period, when they ERECTED there Wind Generators. All they are doing is looking for a free handout, that will eventually come from the TAX payer & Pacific power customer's
- OMP12 0030 -
Price/NATo pay the wind mill industry to do nothing is not only absurd but irresponsible to the people of the North West that you are supposed to serve.This will not only raise power rates but will make the Northwest unattractive to industry and small business's.They will simply go to areas where rates are more competitive.To spill the excess water through the Dams will create a serious impact to the Smolt that will be traveling down the river During Spring run off.With increased nitrogen levels in the spilled water,the smolt run will experience serious losses.We ,the taxpayer have spent a large sum of money in the last 20 years to bring the runs back to record levels,and now we are to risk , for the wind mills?So the Alternative is to pay the wind Industry to do nothing so the water can be used to generate power and avoid spilling water,which will cause even higher power rates than we have already experienced?This is insane!Make the right decision,Shut down the wind mills if necessary,but don't degrade the fish runs that we have worked so hard for at a great expense to everyone,and Don't place us in a situation of higher rates and a further declining economy.Are you going to the right thing?Do whats right for the Northwest.
- OMP12 0031 -
LockardIt appears the wind power industry would like us rate payers to guarantee they get paid whether we need the sporadic energy they produce or don't have a need for it. Maybe the best procedure would be a trade off between the BPA and the wind farm owners. When the wind farms guarantee they will supply an agreed upon amount of energy 24 hours a day 365 days a year even when it's 100 degrees and there is not a whisper of a breeze and when it's zero degrees and we are under an inversion. If they will agree to this then their request to be paid for energy they can't sell at times would be more reasonable. If they are called upon for the energy but can't produce it then they will be obligated to purchase it from our other longstanding reliable sources. Isn't that fair? We expect this from hydro,coal,gas,and nuclear energy don't we?
- OMP12 0032 -
HobkirkI strongly object to the consideration of BPA or any other entity compensating windfarm produced electric power that is excess of need. The windfarm projects are heavily subsidized by our tax dollars already and for us to pay them for power we don't need further taxes the consumer. Landowners hosting the windmills, the developers and manufactuers and contractors are all well compensated without regard for forward planning of what the need for the wind generated power will be & how to provide for consistency and delivery. It is not yours nor we the consumers job to ante up more dollars to further susidize greed and lack of planning. Spring and early summer The rivers run full and the need to use that water is great to control reservoir levels, provide for fish passage and generate low cost hydroelectric power that we all know is RENEWABLE ENERGY. The rates are high enough, are taxes are high enough, Say No to further susidization of Wind generated electricity.
- OMP12 0033 -
Sandford III/SelfI don't think the Wind turbine companies should get special treatment. They should have their own transmission lines & shouldn't be runnning on BPA's. It's time they start finding out what the real cost is of operating these turbines instead of other getting to ride on the backs of the American people with subsides & low tax & no trying to get their expensive power out there for free thru BPA'S transmissions lines. Time to grow up!!! What about the high nitrogen levels that will be introduced into the water that will kill thousands of fish down river from spilling over the water. What about the killing of the imoprtant smolt? What about the higher electricity rates that will be placed on the consumer? The BPA needs to stand their ground with the wind turbine companies & tell them if they don't like how BPA regulates them on BPA's line then they need to get off of it & get there own transmission lines, period... WIND TURBINE POWER IS THE BIGGEST WASTE OF TAXPAYERS MONEY EVER!!! ALL BECAUSE BIG GOVERNMENT MANDATED IT!!! Time to start shutting them down & tare them down...... Again I hope BPA stand up to them & says "NO".......
- OMP12 0034 -
DeWitt/FarmerHaving read the comments posted so far,I find little to add, except to say I agree. Wind power should stand on it's own. We taxpayers are already suybsidizing these investors, and it's past time to stop this nonsense. That new projects continue to be built with no plans to transport the power to where it is needed or to provide storage of some sort is idiotic. Please do not pay these developers one penny. They have bilked us enough already.
- OMP12 0035 -
Reddemann/Energy NorthwestMark Reddemann and Sid Morrison
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- OMP12 0036 -
Kralman/Blue Mountain AllianceIt is my peronal opinion that the wind industry like all private business has to find a way to stand on it own. How may businesses except government favorites get kick backs and subisidies when ever something does not come out the way they would have like it to be. The Northwest and the rest of this country has received and will continue to receive a bounty of cheap energy..oh yes it is still subsidized a small amount but would be able to stand on its own if the government would keep out of the way. The wind industry is feathering only a few nests and because of that they have received a very critical eye that is about to become blacked! You will add to the cancer if you feed the monsters that have short life and will never pay their own ways. Regards, Norm Kralman
- OMP12 0037 -
NealBPA should not be paying the wind generators to not produce power. The problem is the structure of the tax credits. They encourage the wind parties to locate in the area's they can produce the most power, with no consideration of whether or not it is useful to anyone. We have already seen the results of this. In high flow periods energy becomes so cheap they can't give it away, but must pay someone to take it, thus negative prices. BPA needs to address the base problem, which is the structure of the tax credits. Paying the wind generators, especially to not generate energy, most of which would have been going to California anyway, isn't fair to PNW ratepayers & bad policy. I also have to question how BPA is able to continue to allow increasing amounts of wind generation to be added to the system, to the obvious detriment of endangered salmon, without anyone apparently having done an Environmental Impact Statement addressing this issue. Is this even legal???
- OMP12 0038 -
GriffithIt looks to me like the wind turbines were a big mistake. The public had no vote in it and homework wasn't done to foresee problems such as the inefficiency of the windmills, damage to the environment and the exhorbant amount of money poured into them, from the time they are installed to maintenance to keep them operating. The only thing worse than having to use our tax dollars to fund this ridiculous project is having to pay increased power bills because the wind power is such a "productive, efficient, economic way to produce electricity"----NOT!
- OMP12 0039 -
Branchcomb/Sierra Pacific IndustriesView attachment
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- OMP12 0040 -
Dohrman/Klickitat PUDBonneville Power Administration (BPA) has been involved in discussion to find an equitable solution to seasonal energy oversupply. The Oversupply Management Protocol has been proposed to mitigate total dissolved gas levels (TDG) while compensating the displaced generators. This solution was developed to comply with the Federal Energy Regulatory Commission (FERC) order to provide comparable transmission service. Production Tax Credits (PTCs) are Federal incentives offered to developers of renewable generation projects. These incentives are not available to Public Utilities. Even so, Publics have stepped up and built renewable generation projects. In BPA’s attempt to develop an equitable solution to the oversupply issue it would appear that Public Utilities with renewable projects will receive unequal treatment. The calculation used to determine compensation includes any PTCs a generator is entitled to, the value of the Renewable Energy Credits (RECs) (if unbundled from the energy) or the power sales price (if bundled with the RECs). Generation will be displaced in order of cost from the least-cost to highest-cost resource. Based on this calculation, Public Utility renewable projects who are not eligible to receive PTCs will always be displaced prior to private projects who are eligible since their cost calculation will be lower than generation projects receiving PTCs. This solution seems to us as a significant dis-incentive for Public Utilities to engage in renewable energy projects. Not only do we not receive Federal incentives to build renewable projects as private utilities do, but we would be curtailed FIRST by a Federally mandated solution to the over-supply issue. That would be counter-productive to the intent of Federal renewable energy incentives. As such, we ask that BPA include a proxy PTC cost for Public renewable generation projects. We are not asking that this be paid to these projects, just add a proxy, as there is a proxy cost for RECs. This would level the playing field and not cause any increased costs for BPA or any of the parties.
- OMP12 0041 -
Groce/Avista CorporationView attachment
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- OMP12 0042 -
Reinhardt/Windy Flats Partners LLCView attachment
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- OMP12 0043 -
lyon/homehello. it seems strange to say its unfortunate we have an over supply of power. in this case its true, this extra power is going to cost people money. in a capitalist economy you over supply an item you drive the price and often demand down. fossil fuel prices drop with over supply and raise with under supply. we had these wind turbins thrown at us and now the expensive power they produce is not in demand. the answer seems to be build more turbins and bonneville cut them a check for the unwanted power. just the opposite of anything that you would expect from the private sector anyway. its sad we as a nation have come to this. our government has grown to the state it cannot efficiently govern. actually i am just upset i did not think of this, its pure genius! build something the majority of the public did not ask for with public subsidies. then turn around and sue the public for not purchasing your expensive product. only in a land or time like this filled with so much dishonesty could one get away with the above mentioned. if bonneville pays these wind power generators than bonneville and/or the judges involved are as dishonest as the plaintifs themselves. all this in the name of saving our planet!
- OMP12 0044 -
Towner/PNGC PowerComments of PNGC Power attached. Thank you.
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- OMP12 0045 -
Kahn/NIPPCView attachment
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- OMP12 0046 -
Lobdell/Portland General ElectricView attachment
View Attachment
- OMP12 0047 -
Mathai-Jackson/Pacific Gas and Electric CompanyPlease find attached a comment letter from Pacific Gas and Electric Company on the Proposed Oversupply Management Protocol.
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- OMP12 0048 -
Mayo/PPL Energy PlusPPL EnergyPlus, LLC (“PPL”) appreciates the opportunity to submit the attached comments concerning the proposed Bonneville Power Administration (“BPA”) Oversupply Management Protocol (“Protocol”).
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- OMP12 0049 -
Sanger/ICNUView attachment
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- OMP12 0050 -
Hullett/Alcoa Intalco WorksView attachment
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- OMP12 0051 -
Neale/WPAGView attachment
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- OMP12 0052 -
Farrar/Turlock Irrigation DistrictAttached are the TID comments.
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- OMP12 0053 -
Baker/Public Power CouncilView attachment
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- OMP12 0054 -
Grant/Caithness Shepherds FlatPlease see attached, submitted at the request of Derrel Grant on behalf of the Shepherds Flat Wind Farm.
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- OMP12 0055 -
PaceView attachment
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- OMP12 0056 -
Yourkowski/Renewable Northwest ProjectPlease see attached RNP's comments on the proposed oversupply management protocol. Thank you.
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- OMP12 0057 -
Salyer/Modesto Irrigation DistrictView attachment
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- OMP12 0058 -
Lincoln/TransAlta Energy Marketing U.S. Inc.TransAlta comments on the proposed OMP are attached.
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- OMP12 0059 -
Nordt/Public Utility District No.2 of Grant CountyPlease see attched comments.
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- OMP12 0060 -
Nocella/National Hydropower AssociatioView attachment
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- OMP12 0061 -
Huhman/Morgan Stanley Capital GroupView attachment
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- OMP12 0062 -
Scanlan/Sacramento Municipal Utility District1) BPA needs to be more cognizant of the ‘downstream’ counterparty impacts resulting from the Proposed Oversupply Management Protocol. The tariff language and proposed method for managing oversupply and allocating costs largely only addresses the generator considerations without addressing the significant replacement costs and opportunity costs which the proposed tariff causes with downstream counterparties under long-term agreements. BPA has proposed affected parties make amendments to affected agreements to account for this Oversupply Management Protocol, but that does not acknowledge the fact that different parties in a transaction are impacted differently by the proposed tariff language, and BPA’s proposed oversupply protocol misaligns the inherent financial incentives of the parties to a transaction. 2) It remains unclear why BPA does not simply curtail the NERC E-Tag for the generators which need to be curtailed during an oversupply condition and then re-issue new tags for the re-supply of federal power for the curtailed schedules. BPA’s past and proposed method of substituting one product/source for a completely different product/source on a forward and ongoing basis with large volumes of energy involved without having that substitution reflected in the NERC E-Tag is a significant and going concern.
- OMP12 0063 -
Carr/NRUView document
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- OMP12 0064 -
Dubson/Northwest Wind GroupView attachment
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- OMP12 0065 -
Skidmore/Troutman Sanders LLPView attachment
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- OMP12 0066 -
Carrasco/Seattle City LightPlease see attached letter.
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- OMP12 0067 -
Nelson/Southern California EdisonPlease also see our second attachment with redlines.
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- OMP12 0068 -
Nelson/Southern California EdisonAttachment 2/2. Please also see our first attachment with comments.
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- OMP12 0069 -
Conger/N Wasco Co PUDThe attached comments are submitted by Northern Wasco County People's Utility District by Kurt Conger for Dwight Langer, General Manager.
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- OMP12 0070 -
Heutte/NW Energy CoalitionView attachment
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- OMP12 0071 -
Brost/Franklin PUDView attachment
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- OMP12 0072 -
Hedges/White Creek WindDATE: February 16, 2012 ATTN: Eric Taylor BPAT AE RE: White Creek Wind I – Response to February 14th Presentation – Oversupply Management Protocol In response to BPA’s February 14th presentation on “Oversupply Management Protocol”, White Creek Wind I, LLC and Harvest Wind Project have the following comments. These comments will also be forwarded to the provided link on BPA’s Public Involvement Page. 1. Will Sites be allowed to make changes to the value provided to BPA on displacement costs? Will there be any restrictions on time frames or frequencies for updating displacement cost values provided? 2. There were several significant items to the Oversupply Management Protocol that were not yet definite. For example, it is unclear as to how BPA will address the Rate Case for reimbursing displaced costs. Will this be based simply on a pro-rata share of a site’s nameplate capacity versus the entire B.A. wind fleet, or will this be based upon a Site’s historical usage of the Oversupply Management Protocol? Another unclear issue is how displaced energy would be accounted. For example, would this be based upon Scheduled Energy? Why not Potential Energy (Scheduled Energy +/- Imbalance)? How close will Scheduled Energy need to be to a Site’s Potential Energy? What if they are not close? Will this ever be checked? These are two examples of significant items that were not yet settled. As such, White Creek Wind I and Harvest Wind Project request another opportunity to provide comment to this Protocol, when the overall requirements are more clearly defined. Thank you for the efforts BPA is making to address Spring Runoff Curtailments and for the opportunity to be a part of the decision making process. Sincerely Bjorn Hedges White Creek Wind I, Plant Manager
- OMP12 0073 -
Toulson/Snohomish PUD
- OMP12 0074 -
Lawrence/Save Our Wild Salmon Coalition
- OMP12 0075 -
MacDougall/Powerex Corp.
- OMP12 0076 -
Faulkner/Puget Sound Energy
- OMP12 0078 -
Hale/Oregon Dept of Energy
- OMP12 0079 -
Patton/Idaho Water Resource Board
- OMP12 0080 -
Fisher/Legal and Consulting Servicescomments from M-S-R attached
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- OMP12 0081 -
Wilson/Washington PUD Associationview attachment
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- OMP12 0082 -
Garcia/Tacoma Powerview attachment
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- OMP12 0083 -
Herrera/Los Angeles Department of Water and PowerPlease see the attached letter.
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- OMP12 0084 -
Norris/Eugene Water and Electric BoardView attachment
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- OMP12 0085 -
Moore/Clark Public UtilitiesView attachment
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- OMP12 0086 -
Erb/PacifiCorpView attachment
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- OMP12 0087 -
Grace/American Wind Energy AssociationView attachment
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- OMP12 0088 -
Beard/SelfThe BPA should be allowed to curtail wind generated oversupply of electricity without economic penalty. It is unconscionable that taxpayers and ratepayers should have to pay wealthy, often foreign owned, corporations for unneeded, expensive electricity which is already highly subsidized. Additionally, further expansion of wind facilities will exacerbate the oversupply problem plus cause extra expense to build additional transmission infrastructure to accomodate the unreliable wind production. The obstinate, greedy position of industrial wind facility owners demanding to continue to produce electricity during oversupply situations jeopardizes long established measures to protect Columbia River salmon runs. Failure to honor salmon recovery agreements would jeopardize important power generation, irrigation, and transportation activities linked to the Columbia River. The wind industry's position is not fair to conventional power producers who utilize the BPA's distribution grid. It is not fair to rate payers and the owners of conventional power generating facilities that they cannot market their reliable, affordable power to accomodate the unreliable, subsidized wind generated electricity. In addition to the economic injustice of paying industrial wind facilities for their unreliable, overpriced electricity when it is not needed, the variability of the output jeopardizes the sability of BPA's regional grid. The instability of the grid could lead to a system failure with enormous public safety economic consequences. Thank you for your consideration. Casey Beard
- OMP12 0089 -
Blackview comment letter
View Attachment
- OMP12 0090 -
Reiten/Pacific PowerSee attached Letter of Clarification.
View Attachment
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Finance & Rates
