[0:03] Good morning, everyone. Today is October 16th, 2025, and this is a special public meeting of the Public Utility Commission of Oregon, and all commissioners are present. Today, we are taking up a workshop on LC-85-Pacific Cores 2025 IRP, and there's an agenda posted, so let me say a little bit about how I anticipate

[0:32] sort of working through the content today.

[0:38] It's clear from the comments a great deal of content

[0:43] where I anticipate we'll go until 12 today.

[0:48] And we'll hear from Renewable Northwest first.

[0:52] They've provided a slide deck and then after they've presented,

[0:56] I'll invite the company up with any response they'd like to have.

[1:00] And then for items 3, 4, 5, and 6, we'll take those as groups, sort of the sub-bullets

[1:11] as topics that I would love you to speak to.

[1:14] We'll raise hands and sort of have a dialogue, workshop, style around each of those.

[1:21] And I'll ask folks to keep their comments sort of crisp given the scale of content

[1:28] and how fast noon will arrive.

[1:32] And I'll add that at 10-16 the great

[1:36] to shake out Oregon's great shake out

[1:38] will happen.

[1:40] And I anticipate everyone's phones

[1:42] to sort of lose their minds for a minute.

[1:47] And so we'll pause then.

[1:48] We won't try to talk through it and let that play out.

[1:52] And then come back.

[1:53] I'll just encourage you.

[1:54] It's a good opportunity to stop and think about

[1:57] whether you have a safety plan with your loved ones and how you would evacuate

[2:03] and so on and so forth. These drills are important opportunities to check in on

[2:10] whether we are as prepared as we could be and what actions we might take this

[2:16] weekend or over the fall to get better prepared. So with that, let me turn to my

[2:26] colleagues if you have any opening comments around the content what you'd like to hear from

[2:34] stakeholders today?

[2:39] I can jump in. So I just want to thank everybody for being here today and

[2:45] for the last few months that folks have come together on this. And I recognize a lot of work has

[2:53] gone into this process by the company, staff, and stakeholders.

[2:57] But I do come into today very concerned about the value coming out of this IRP, not in

[3:03] terms of the analysis and input from parties, but from the lack of usable information for

[3:08] the commission, staff, stakeholders, and most importantly, the company.

[3:12] And IRP should help us all see the ways the future might unfold, and how the company intends

[3:16] to respond.

[3:17] The scenarios modeled and considered should give us insights that help to mitigate risk to

[3:21] both the company and the customers.

[3:23] At this point, I'm concerned we're left flying blind in many ways, and that's frightening

[3:27] to me as a regulator, but should be even more frightening to the company.

[3:31] I find it very hard to believe the company would put itself at risk in so many ways by

[3:34] leaving itself blind as to how the six-state system operates as a whole.

[3:39] I fully recognize the complexity and inherent difficulty in modeling the specific course system

[3:43] in the very policy landscape within that system.

[3:46] But that is what large and sophisticated companies do every day in order to be successful

[3:50] in the landscape within which they operate.

[3:52] So my hope for today is that we can find a way

[3:56] to drop the posturing and positioning around the politics

[3:58] dividing the states that the company serves,

[4:00] and find ways to salvage this IRP

[4:01] by making clear requests for information from the company

[4:04] that can be achieved in the time we have,

[4:06] so that we can actually see how Oregon fits

[4:08] into a specific course entire system

[4:09] and stop pretending that Oregon functions in isolation.

[4:12] To come away with anything less,

[4:13] we'd create massive risk for the company and customers.

[4:19] Thank you.

[4:19] appreciate that clarity. Commissioner Power. Thanks,

[4:25] Tritani. This is one of my first IRP sitting in this driver's seat. And

[4:34] understanding it represents a pretty significant departure in a few ways from

[4:38] previous assumptions. I think I'm hoping are meeting this morning pressure tests

[4:46] those assumptions with feedback from stakeholders. And if this is a building block upon which we build

[4:55] our future work, as I hope to serve on this commission for some time, does it provide our staff

[5:01] in the public with a level of interconnected transparency and recognition of past investments

[5:11] of work of time effort by many, many stakeholders to move our state ahead in our goals and collectively as a region.

[5:20] So those are the items I'm looking forward to discussing today.

[5:27] Thank you.

[5:30] I have been through several IRPs and this one I can attest is different.

[5:35] So, and presents, from my perspective, many of the same challenges that you articulated, Commissioner Perkins, I am struggling to understand how much reliability need we face, whether that's a physical reliability challenge or an allocation challenge only.

[6:00] how much gap remains in terms of policy goals, whether that is a physical challenge or an allocation challenge, and what the overall risk mitigation approach is as the landscape for procurement changes very, very quickly under our feet.

[6:27] So I look forward to hearing how folks are getting to those core guide posts around need and actions to fill that need.

[6:40] It's the core of what we need out of an IRP.

[6:45] And so with all that, let's turn to Renewable Northwest, which is provided through a very high level and over urging comments.

[6:56] and offered a slide deck to take us through their concerns.

[7:02] And so, Kristie, if you could bring that up.

[7:05] Thanks.

[7:11] All right.

[7:12] I'm happy to get us started.

[7:13] Good morning, Chair Tawny, Commissioner Perkins, and Commissioner Power.

[7:17] My name is Katie Chamberlain, and I'm the Regulatory Manager with Renewable Northwest,

[7:23] a Regional Clean Energy Advocacy Organization.

[7:26] I have with me Mike Getz, our Regulatory Affairs Director,

[7:29] Max Green with Sanger Green Law and formerly staff with Renewable Northwest and our team

[7:35] of technical consultants who will introduce themselves as we get into the presentation.

[7:40] First I want to thank the Commission for the opportunity to present at this workshop

[7:44] on Pacific Wars Integrated Resource Plan and Clean Energy Plan. Renewable Northwest has

[7:50] been engaged in Pacific Wars IRP development process and in the Commission review process

[7:56] us for many cycles. For this cycle in particular, we were able to work with the company to get

[8:02] access to their modeling file, which has allowed us to better understand how the company sets

[8:08] up its modeling ecosystem, the inputs and assumptions that are driving outcomes, and the challenges

[8:14] that are unique to planning for a six-state system with diverging policy priorities.

[8:19] next slide please. Our presentation will focus on our concerns coming out of the 2025 IRP

[8:27] and our recommendations for how to move forward in a complex planning environment as we've acknowledged.

[8:34] And with that, I will pass it to one of our consultants, Nick Popus. Thank you.

[8:39] Thank you so much Katie. Good morning Chair and commissioners, really appreciate the opportunity

[8:44] be here and present on our perspectives today. I've been involved as a technical consultant

[8:51] through Noble Northwest for I think three cycles if we count the 23IRP update and want to

[8:57] bring some historical context as we work through some of our recommendations, some of which flow

[9:02] through from the 23IRP and previous IRPs in some which are new. We've got a long suite of issues

[9:09] and probably much more ground than we can cover today, really appreciate the comments from the

[9:14] this morning, which I think will influence where we emphasize our discussion today,

[9:19] and I think resonates strongly with some of the concerns that we're going to bring forward.

[9:23] We're going to kick things off with an overview and landscape for where the IRP is coming

[9:27] from, from a market and policy landscape, transition into a discussion of technical concerns

[9:33] around the modeling ecosystem, and then bring those back to some of our policy recommendations

[9:38] and link how the analysis informs the policy considerations and vice versa.

[9:43] I am going to breeze through quite a few of these slides.

[9:46] We wanted to be comprehensive in case there's questions or discussion,

[9:49] but we're going to really just try to emphasize some of the key points as we go forward.

[9:54] Let's transition to the next slide, please.

[9:58] Just to provide a little bit of context, the 25-IRP presents a landscape

[10:03] which has tremendous resource needs across the Pacific Warp system, certainly in PAC West,

[10:09] but that's true across PAC West and PAC East.

[10:11] As we're going to get into that need which is identified here while substantial is not

[10:16] a complete picture given the exclusion of large load customers from the IRP which we see

[10:20] as a critical missing data point for the commission to be able to make an informed decision about

[10:25] needs for organ customers.

[10:27] We're also in a landscape where the region as a whole is in a shifting supply demand balance

[10:33] we see rising scarcity in the West and the longstanding strategy for PAC West and organ which

[10:38] Relied on market purchases or front office transactions. So essentially short-term transactions from the market is no longer viable both because those

[10:47] Resources are no longer available as other utilities take them for native load and this wrap becomes binding and excludes those from the portfolio

[10:55] That alone drives a tremendous reliability need which we're going to get into in coming slides

[11:00] But in combination with organs state energy policies in age between 2021

[11:04] One, we have a really aggressive procurement landscape on our path to 2030.

[11:08] Much of the need was identified in the 23IRP and previously, but following the 22RFP cancellation

[11:14] and other delayed and deferred procurement, we're really starting a little bit behind

[11:19] the eight ball in terms of launching our way to 2030 and a lot of our recommendations are

[11:24] going to discuss how we can make sure that this IRP leads to more successful procurement

[11:28] as we go forward.

[11:31] I'm going to keep us moving and just jump into our policy recommendations on the next slide

[11:36] before we pivot into modeling. We're going to come back to these throughout the presentations,

[11:41] but to give you a sort of general sense of the advocacy perspective we have in the 2025 IRP,

[11:48] we'll be discussing the near-term procurement gaps, both making sure those can move forward successfully

[11:53] with the RFP, but also building in some guardrails so that the RFP can be successful and actually

[11:57] get sufficient resources to meet Oregon's resource needs both for current and expected

[12:02] future loads, which are not currently in the plan.

[12:06] And there's also some significant urgency to go out and pursue contracts that may be

[12:10] eligible for the expiring IRA tax credits.

[12:14] Wordment to Hemingway is a key asset for Oregon customers.

[12:17] It's been in the works for nearly 20 years, and it is a critical linkage to resource supply

[12:22] in the east, which is currently constrained at 1600 megawatts, B2H would increase that

[12:27] by 50%.

[12:27] We're going to talk about how to keep that in the portfolio and keep that moving forward

[12:30] to achieve the massive benefits intended for organ customers.

[12:34] And then we want to spend a little bit of time on a witty, but important issue, which is a

[12:39] new framework specifically introduced in the 25IRP related to allocations between resources,

[12:44] which we see as conflating reliability and clean energy policies and allocating a tremendous

[12:49] this reliability need exclusively to Oregon's state energy policy requirements, which we

[12:54] view as both very problematic from a policy precedent standpoint, as well as from a cost

[13:02] allocation standpoint, the actual impact to Oregon customers, we think, would be quite

[13:05] severe.

[13:06] So let's jump into the next slide.

[13:08] I'm going to pass it off to my colleague Jim to talk through some modeling concerns from

[13:12] his review of the IRB.

[13:15] Thanks, Nick. Good morning, Chair and fellow commissioners. My name is Jim Heimlich.

[13:19] I'm a consultant with Renewable North West. I have almost 20 years of experience in

[13:26] modeling and over 10 years of experience with the energy exemplar pluso software that Pacific

[13:32] Core uses for the IRP planning process. Next slide.

[13:39] I want to start by just acknowledging

[13:40] that Pacific Core faces one of the most challenging planning problems in the West, arguably the most challenging.

[13:47] And I also want to credit Pacific Core for their engagement in this IRP cycle.

[13:51] Not only have they shared their Plexus XML file with R&W, but they participated in multiple technical calls to walk us through some of the more detailed modeling mechanics.

[14:01] This really gave us a much better understanding of what's happening under the hood and allowed us to provide more targeted and specific recommendations for model improvement.

[14:10] Our file comments are meant to serve as constructive feedback because Renewable Northwest believes a stronger modeling framework benefits everyone.

[14:18] With that said, as part of our review, we did discover some questionable modeling decisions made by the company, which includes items such as redundant or stale objects that are still active during model runs, as well as a heavy reliance on manual adjustments, which are prone to calculation errors.

[14:36] These practices make it hard to leverage the full capabilities of the underlying software,

[14:42] to A, implement needed functionality, and B, reflect industry best practice.

[14:48] Some of our recommendations have been adopted by PAC, which we greatly appreciate.

[14:52] However, others have been dismissed and present opportunities for continued progress.

[14:57] Pacificoors IRP presents a complex problem

[15:06] Next slide.

[15:10] Since the 2023 RRP, we've provided extensive technical feedback across multiple areas. For the sake of brevity, I'll highlight three today. First, we'll discuss chronology. Let's start with the definition. Chronology refers to the preservation of the sequence of time series data. It's important to know that this doesn't equate to having to model every hour in the year.

[15:32] year for all the years in the planning horizon. This can also consist of sample

[15:36] chronology where we can take a subset of days or weeks to represent the full year

[15:41] for modeling computational tractability trade-offs. Why is this important? It's

[15:47] important because with the increasing roles of renewable and storage chronology is

[15:50] essential to capture the hour-by-hour changes in solar and wind profiles as well as

[15:55] state-of-charge of the battery fleet throughout the day. Lack of proper chronological

[16:00] sequencing drives heavy reliance on manual adjustments and is likely cause of the poor

[16:05] model convergence that PAC continues to grapple with. Just as a quick update, as of the first

[16:10] pelvic input meeting for the 2027 IRP PAC did enforce stakeholders that they are actively

[16:16] investigating the user chronology in their Plexus LT setup and R&W views this as a step in the

[16:22] right direction. Next, moving on to the constraints and the complex interplay between jurisdictional

[16:28] firm capacity obligations alongside state policy requirements.

[16:33] Our view is that the current configuration in the model is incomplete and inaccurate

[16:37] and warns a change.

[16:38] We'll explore this further in upcoming slides.

[16:41] And finally, we have methodological errors.

[16:44] R&W has flagged approximately two dozen instances of modeling mistakes or questionable practices

[16:50] ranging from minor to moderate.

[16:51] it. Collectively, these issues limit the confidence R&W has and packs final results.

[16:58] For those interested in more detail, I point you to the appendix as well as our round

[17:03] one and round two comments which go further in depth.

[17:06] Next slide.

[17:09] Similar to our previous slide, I don't have time today to walk through each

[17:12] one of these recommendations, but I do want to highlight two which book in the range of complexity

[17:16] of these changes in compass. Let's first discuss changes that are a bit more straightforward

[17:21] forward in nature. For the 2025 IRP update, we recommend Pacific Core

[17:25] model the full retail load to capture the complete set of generation and transmission resources the portfolio will require.

[17:32] If a separate offtake agreement is under active negotiation to serve this large load with dedicated resources,

[17:38] Pacific Core must also demonstrate how the remaining retail customers will be kept whole in the event there's any reassignment of network transmission service.

[17:46] Now onto the more complex side of things.

[17:49] For the 2027 IRP, we look forward to continuing to work with Pacific Court on implementing these model improvements.

[17:55] However, we also recommend the Commission Direct Staff to develop its own independent modeling capabilities.

[18:02] Such an ability will empower staff to not just validate past modeling results, but produce key missing counterfactual studies and explore alternative allocation frameworks.

[18:12] open source solutions now exists that would allow for the ingestion of the same input values used in

[18:17] pacifical or pxos model and significantly reduce the dual model problem. Outside parties have

[18:23] expressive willingness to fund the effort and provide the required personnel and we see today's

[18:27] discussion as an opportunity to start those conversations. I'm going to pass this back on to Nick and he'll

[18:33] take us through the next topic. Thanks Jim. These are really meaty topics. We want to make sure

[18:41] we can bring these back to some headlines for the commission and how this informs some

[18:44] of the policy actions you all can do with this 25-IRP. But I just want to echo Jim's comments.

[18:51] We really appreciate the depth of engagement we've had with Pacificorp. But I think

[18:55] as discussed, there's a lot of work to do before we think this model is ready to really effectively

[19:00] inform what Oregon needs going forward. I'm going to really quickly breeze through some

[19:05] of the policy recommendations. I want to save time for allocations discussion, which

[19:08] I think is the most complex and probably least developed.

[19:13] So why don't we go to the next slide

[19:15] and I'm just gonna go very quickly

[19:16] through a couple of our other recommendations.

[19:21] I think we'd really like to be in a place where we could say

[19:23] we could just lean on the analysis provided in the IRP

[19:26] to inform Pacific Corps needs and organs needs.

[19:30] I don't think that we're gonna see that now

[19:33] or potentially even in the 25 update or 27 IRP.

[19:36] So we're really trying to bring some actionable things that the commission can do now to keep the state moving in the right direction while we continue to develop that model into something that that can achieve those goals or potentially find alternatives as Jim mentioned so the commission can have other ways to inform or in customer needs and move those forward.

[19:55] So in the next few slides, I'm just going to quickly talk about how we get our near term procurement moving forward.

[20:00] concerns with transmission, and the Gemini are going to take us through the allocation protocol discussion

[20:05] or the allocation framework in IRP.

[20:07] Next slide, please.

[20:09] Actually, we can jump ahead to 12.

[20:12] Thank you.

[20:13] So, just to provide some more context on the resource gap,

[20:17] this is a graphic showing Pacific corpse existing resources in the loads and resources table.

[20:22] This is across the system.

[20:23] We'll get into some of the east-west dynamics and later slides.

[20:26] Just to frame this, there is already a deficiency from a wrap perspective and one that we anticipate would grow substantially.

[20:34] This is net of large load customers, which are not included in the IRP.

[20:38] I just want to emphasize, and as we included in around two comments,

[20:42] we're really grappling with the legal framework that would exclude these bundled customers as specific or frames them from the IRP.

[20:49] That's a separate conversation we're happy to get into.

[20:51] But there's a massive gap and our concern is with as we're going to the allocation framework

[20:58] allocating all of this as though this is state policy driven. That's instead of reliability driven creates really severe inequities between the states

[21:06] Let's go ahead to the next slide

[21:10] So a number of our procurement recommendations really emphasize guardrails

[21:14] We know there's a substantial need we know from the IRP analysis. There's a substantial need

[21:18] we know with large load customers that's going to be even greater, perhaps some of those customers

[21:22] bringing their own generation, but we know it's going to be likely substantially higher. We also

[21:26] have HB 2021 needs layered on top of this. And we'd really like the commission to think about

[21:31] the RFP in a way that ensures specific or procures minimum resources to actually keep the lights on

[21:35] in Pack West. This is not a theoretical or compliance framework. This is with Pack West have sufficient

[21:41] reliability resources to keep the lights on in a regional scare city moment. So bringing this back

[21:46] to the 23 IRP and 23 update, we identified major resource needs, I should say, a specific

[21:53] or identified major resource needs in the 23 IRP presented a plan that was going to

[21:58] develop substantial, primarily clean energy and storage to build their way out of that gap,

[22:03] and then we largely didn't see that layout.

[22:05] We largely missed that opportunity with the cancellation of the 22 RFP, and I want to

[22:11] this to the missed opportunity, which as the IRA tax credits go away, assuming we can only capture

[22:17] a small percentage of that or a small percentage of forward-looking resources can capture that,

[22:22] we might be talking about $3.5 billion in tax credits that were missed for the portfolio that was

[22:29] presented by Pacific Orp and what their plans to procure were in the 23IRP. And I think this is

[22:34] really important context as the commission thinks about how to structure and build guard rails around

[22:38] actions coming out of the 25 IRP. If you identify a huge need initiate an RFP and then just don't

[22:44] follow through on it, you don't really get the outcomes that you were hoping for from the IRP.

[22:50] Let's go to the next slide please. And actually let's in the interest of time let's just continue

[22:55] on to slide 15 and we'll transition into a very very brief discussion on Boardman to Hemingway.

[23:01] Go to the next slide actually. I think folks are fairly familiar with Boardman to Hemingway

[23:08] at this point, but I just want to emphasize a couple key points.

[23:11] From an analytical framework perspective, increasing transfer capacity between East and West

[23:15] is one of the best tools Oregon has in its portfolio to improve Oregon energy policy

[23:20] goals, whether the reliability, cost, clean energy, all of these benefit tremendously from

[23:25] Boardman to Hemingway.

[23:26] This is a line that in that context has been in the works for nearly 20 years and had a billion

[23:32] dollars in projected customer benefits.

[23:34] I think it is very fair to say that that number is likely much higher in the current

[23:37] planning environment than that one billion and this is just I can't emphasize enough how important

[23:43] it is to increase transfer capacity between the regions. We understand based on discussions

[23:50] of recent public input meetings that Board Meta Hemingway will be completed physically. However,

[23:56] the final, the last mile of transfer capacity through BPA from the Umatilla County Longhorn

[24:04] and substation to urban load centers in the West, that's where the question mark is.

[24:10] And that's, frankly, where a lot of the benefits are for PAC-West customers.

[24:14] We understand from Pacific Corp that they plan to utilize this line for bundled load in eastern

[24:20] Oregon, bundled load that's not in the portfolio, because we've excluded new large loads, but

[24:25] that's our understanding.

[24:27] I think rather than get into a long discussion of all the questions I have around this strategy,

[24:32] I'll just emphasize keeping this moving towards PAC-West customers existing PAC-West customers

[24:38] is critical in achieving those benefits for Pacificorps existing load in Oregon.

[24:45] And let's go to the next slide. I'm just going to briefly touch on our recommendations.

[24:49] You're the primary action item, I think, for the Commission is to decline to accept B2H

[24:54] getting pulled from the preferred portfolio and direct Pacificorps to keep working towards

[24:59] getting this redirect and completing the last mile with the transmission redirect from BPA to

[25:05] organs, urban loads, load centers. Let's continue moving into the allocations discussion if we can

[25:12] go ahead to slide 19. I'm going to just briefly tee this up and then hand it over to Jim to get us

[25:18] into the detailed framework and mechanics of how this works. To set a little bit of the historical

[25:25] context packs process over decades has been to operate pack east and pack west as an integrated

[25:32] system where the costs and benefits of energy and reliability are shared across the six states.

[25:38] Under that framework for many many years organ customers have paid for assets in the east

[25:44] which do not directly benefit them because they are transmission constrained behind the east west

[25:48] transfer constraint and in parallel customers in the east have paid for market purchases that sort

[25:54] of Pac-West that fill the gap left by the lack of resources in Pac-West owned by Pacific

[25:58] Orb to serve those customers.

[26:00] This is just longstanding practice and precedent and is what has enabled the economies of scale

[26:05] and efficiencies of that integrated system.

[26:08] So that's the context.

[26:10] In the 25IRP, we see a new analytical framework for allocation which effectively would keep

[26:17] organ customers on the hook for those shared system resources while tagging all of the resource

[26:23] need all of the resource costs needed to build Pac-West out of its reliability gap to Pac-West

[26:28] customers. In Oregon and Washington, under the guise of framing those resources as policy driven,

[26:33] state policy driven, as opposed to reliability resources. I think it's important to acknowledge

[26:37] that these resources, which are necessary to improve their reliability situation in Pac-West,

[26:43] will likely be clean resources. They will likely contribute HB2021. But as we're going to go into

[26:48] in a couple of slides. It's far from fair to characterize these as state policy driven when we see

[26:53] the massive reliability gap in Pac-West that needs to be filled and under this long standing

[26:58] precedent should be filled in a way where the reliability costs are shared across all customers.

[27:04] I want to just emphasize we're at a moment where organ customers have financed physical assets

[27:09] in the east for many many many many years and in this moment where the reliability costs are

[27:15] coming due essentially through RAP and other regional dynamics pack is proposing a framework

[27:20] that would leave organ customers essentially out to dry after that longstanding practice

[27:25] of sharing these energy and reliability costs.

[27:28] So, I'm going to kick it over to Jim to take us through the specifics on the mechanics

[27:31] of this framework, which knowledge are complicated, but Jim, I appreciate you distilling these

[27:35] in a simple, available way as we can.

[27:38] Thanks, Nick.

[27:39] Next slide.

[27:41] So, just before warning, this conversation is a bit heady from a technical standpoint,

[27:47] but I'll do my best to try to walk through it step-by-step.

[27:51] So let's start where Renewable Northwest and Pacific Corrigory.

[27:55] First, reliability is a system-wide issue, thus resources required to maintain reliability

[28:00] should be system allocated.

[28:03] In each of the three jurisdictional models, PACCAS and the Plexaos database, they implement

[28:09] and then a set of local wrap constraints

[28:11] to drive reliability related procurement.

[28:14] This constraint is based on that jurisdiction share

[28:17] of system coincident peak load.

[28:20] It's also important to keep in mind

[28:21] that these set of jurisdictional constraints

[28:24] assume a copper sheet handling of PACS transmission network.

[28:27] What this means is that all intra

[28:29] and interregional transmission limits are ignored

[28:32] by these constraints.

[28:34] To address this oversimplified handling

[28:36] of deliverability, PAC also enforces an additional generic constraint that we will refer to as the

[28:43] RAP West constraint. This constraint is activated only in the Washington and Oregon jurisdictional model,

[28:50] but critically honors the East or West transfer limit of 1600 MW between PAC East and PAC West,

[28:57] thereby ensuring a minimum amount of bill takes place in PAC West to maintain reliability.

[29:03] The problem emerges with the introduction of the site's allocation framework that PAC

[29:07] introduced in the 2025 IRP, because it effectively bifurcates the portfolio into PAC use and

[29:14] PAC West, but fails to separate reliability costs from policy costs.

[29:18] This abandons the long-standing practice of uniform cost sharing for system reliability

[29:22] because of three critical flaws that we've identified.

[29:26] First we have what we're calling the geographic trap.

[29:29] The rap-west constraint forces bill to occur exclusively in Pac-West.

[29:34] Why does this matter?

[29:35] It matters because the required volume of this constraint is based on Pac-West's share of system quints in a peak.

[29:41] But only resources physically located in Pac-West, whether those are existing resources or proxy resources, can satisfy the constraint.

[29:49] Import from PAKES are eligible, but only after what's left over, PAKES has met its own obligations, which is less than PAKES.

[30:00] Tax West allocated share of resources under the MSP protocol. The result is we have reliability

[30:07] driven resources, our automatically side is allocated to Oregon and Washington under the

[30:12] current framework. This leads us to our second issue, the missing reliability baseline.

[30:19] We now know resources elected by the model are used to satisfy the rap West constraint, in

[30:24] In addition to other constraints associated with state policies, however, because PACS framework

[30:30] lacks a reliability only counterfactual study where all physical constraints of the system

[30:36] are recognized, we can't distinguish what portion of a selected proxy resource is needed

[30:42] for system reliability versus what's needed to satisfy regional environmental policies

[30:47] like HB2021, which leads us to the third issue, the conflation of cost and benefits.

[30:52] Without the ability to separate what drives resource selection in the model, the reliability

[30:57] benefits of proxy resources are conflated with their clean energy benefits.

[31:03] But PAC-Sitis allocates all PAC-West resources, treating them as if they are solely required

[31:08] for state-level policies, where in reality, a portion of these resources do address system-wide

[31:15] reliability and hence should be system-allocated, not-sitis-allocated.

[31:19] In case I lost you with all this modeling jargon, let's just summarize.

[31:24] Resources in Pac-West serve two distinct purposes, one, serve system reliability.

[31:30] The 1600 MW transmission bottleneck means Pac-West needs local resources to maintain reliability,

[31:36] which should be system-allocated.

[31:38] Two, is compliance with state-energy policies like HB2021.

[31:43] Premiums associated with this procurement should be side-as-allocated.

[31:47] Both of these drivers are real, the patch framework provides no mechanism to separate the two out from one another.

[31:54] As Nick will discuss momentarily, R&W advocates for a new framework that will address this critical issue to prevent the unfair allocation from continuing in the 2027 IRP.

[32:07] Nick?

[32:09] Great, let's go ahead in the next slide please.

[32:12] So, I want to recognize we're approaching our time limit here, so I'm going to just very

[32:16] quickly hit this slide in the next slide, and then we'll wrap things up.

[32:20] But I just want to come back to the conclusion here in the takeaway.

[32:25] What we have on the right hand side of this slide is the west side physical reliability position

[32:32] and the east side physical reliability position.

[32:34] This is assessed using the RAP analysis provided by Pacific Warp in the IRP.

[32:38] And you can just very easily visualize how dramatically different these positions are.

[32:43] Pack West is not in balance, and this is a result of many years of policy and planning

[32:49] decisions that led to Pack West being reliant on both transfers and market purchases.

[32:55] This is a longstanding issue.

[32:56] It is not new as a result of state policies.

[32:59] It is just a function of how policy and planning decisions have occurred over many years.

[33:03] I just want to re-emphasize this, this is a really dramatic departure from

[33:08] precedent. So all of these resources we see in the bottom right, many of those

[33:13] have been allocated or either system allocated or costs have been shared

[33:16] with PAC-West customers for many years. And in a moment where PAC-West is in

[33:21] dramatic need of reliability build, we think it's just fundamentally unfair to tag

[33:26] the cost of building out of that hole exclusively to PAC-West customers in that

[33:31] historical context. I want to just quickly hit the next slide before we wrap up. I want to make

[33:37] sure we save a couple minutes for questions. We've tried to engage with Pacific or on this item,

[33:44] both in public input meetings and in our comments. And I think we feel somewhat frustrated that the

[33:50] response largely hinges on this conclusion that the IRP is not a cost allocation exercise. I don't

[33:55] think we would disagree that the IRP does not directly allocate costs. However, the IRP

[34:01] ecosystem, both as a model and as an upstream procedural input, is really critical in future

[34:06] proceedings where costs are allocated. The Plexus modeling ecosystem, which is primarily

[34:11] reviewed and litigated in the IRP, is the basis for the CEP. It's also the basis for how

[34:17] Pacificorper views resources in the RFP. And certainly, as we understand it, is a critical

[34:22] upstream input to discussions around state allocation protocol and future rate cases.

[34:28] To quote a colleague, it's not directly a cost allocation exercise, but it's an important step

[34:33] on the way to prudence. I think we'd really like to see some discussion around this. We'd like

[34:38] to see one of the key items coming out of this IRP, a direction from the Commission, to

[34:44] Pacificoor to work with staff and stakeholders on resolution to this. It's really critical,

[34:49] And I think it's one of the most foundational issues for Oregon's outcomes in state allocation

[34:56] processes and how we think about moving this multi-state system forward.

[35:00] So I'm going to conclude there.

[35:03] I'm just going to call out two slides for reference for folks.

[35:06] If we could go ahead to slides, slide 24, we'll bring us back to our three recommendations

[35:13] which I'm not going to go back through, but I also want to call out slide 25 where we've

[35:17] attempted to break out these recommendations across

[35:21] procedurally where we might start to see some resolution.

[35:23] We know some of these are longer-term issues.

[35:26] Obviously, we'd love to see them solve now,

[35:28] but we're still digesting changes from the 23 IRP,

[35:32] for instance, ELCC implementation that we're hoping to move forward.

[35:36] So we're cognizant that the pathway is long

[35:38] and trying to provide some recommendations

[35:39] where the commission can take some near-term action

[35:41] and also tee up some future work in these future cycles.

[35:45] So we really appreciate the opportunity

[35:46] to talk through these issues today and welcome any questions, clarifications, discussion. Thank you.

[35:54] Thank you. I really appreciate how concrete and forward-looking you are being and it makes the

[36:05] challenge much more tractable, so I appreciate the thought you've given to not just sort of

[36:13] explaining the issues as you see them but also suggesting solutions. Questions? Colleagues,

[36:21] any questions or conversation you want to have with Renewable North West?

[36:31] Well, I'll just say I to appreciate the fact that it's not just pointing out issues, concerns,

[36:35] but giving some potential concrete actions that can be taken in both short term and the long term.

[36:41] so thank you.

[36:47] Okay. I appreciate you walking through all of this and it helps to put for me to wrap

[36:56] my head more around your more detailed comments. So thank you for taking the time and thank you

[37:01] for sticking to your time. When I saw the number of slides, I was worried. So I appreciate you

[37:08] respect in that. I'd like to invite the company out to respond. It looks like a

[37:15] Randy Baker, maybe that's a year who will respond for the company.

[37:21] Yes, I'm

[37:22] here.

[37:25] Great. Please go ahead. Alright, so a lot of material there. You know, the

[37:33] organization of it clearly took a lot of thinking and time. We do appreciate the

[37:39] consulting that we've done with Renewable Northwest in particular, I guess I'd like

[37:45] to start with what I think is the highest level concern which really results to a question

[37:53] regarding our NWs analysis.

[37:56] One of the most recent statements that we just heard is that PAC West is not in balance

[38:03] and that imbalance is not based on state policy.

[38:08] And this is one of two primary elements

[38:10] that we've recognized in what R&W has communicated to us.

[38:16] And there's a fundamental disagreement here.

[38:19] And I want to be as clear as I can and underscoring it.

[38:24] First of all, there's a correction to statements

[38:27] that were made existing resources are still allocated

[38:30] to Oregon, to the extent that Oregon is still participating in them, but that's directly tied to what we believe is fact, which is that state policy directly explicitly and significantly impacts reliability across the system, increasing it for the east and decreasing it for the west.

[38:53] And that there is a cost to that.

[38:57] And so in R&W's framework, you know,

[39:01] this first area that I'm highlighting is that

[39:04] there's steps one and two depend upon a baseline

[39:07] that attempts to completely separate reliability from policy.

[39:11] We believe that that cannot be done.

[39:13] The conversations we've had leading to this point

[39:16] have been extremely valuable

[39:19] because it's allowed us to get that clarity

[39:22] around the issue. But what it boils down to is that SB 1547 by 2030 has Oregon withdrawing

[39:34] from otherwise existing system allocated resources in a way that has impacts on all parts

[39:42] of the system. And given the additional influence of House Bill 2021, really the only despatchable,

[39:54] qualified resource to replace the loss and reliability on the West is a battery. And those

[40:03] batteries while often a good deal economically are still expensive and would not have been

[40:11] needed but for Oregon policy. So I think that's the first thing that should be very clear.

[40:20] The second item that I want to call out that may seem a little out of order but I think

[40:24] it's critical to R&W's proposed framework is the idea in step three of their framework where

[40:33] they're saying let's run a fully optimized system-wide solution and I'm assuming they

[40:39] mean that also meets all criteria that need to be met for that model run and that includes

[40:47] that it has to be efficacious. It's got to be efficient in other words it has to run in a reasonable

[40:52] amount of time. It has to meet all state requirements and it has to produce a result that is competitive

[41:00] or better than the results that we're producing under a current system.

[41:05] In contrast to statements made about a pacific course,

[41:12] change in strategy for allocations, resource development, and selection,

[41:20] I'd just like to say that, you know, we appreciate that this has been a long evolution.

[41:26] We've been working these problems for four years now.

[41:31] And with regard to that all-in system optimization that is in step three of our NW's framework,

[41:37] you know, we've been working on the problem for four years.

[41:40] We've been working directly with our NW for several months.

[41:43] We have not seen a solution that meets those criteria and that achieves the result

[41:51] that, frankly, everybody, including Pacificoor, would love to have.

[41:55] It would be great if we could run a single model that would do everything and be compliant,

[42:00] but there are conflicts in state policies that prevent this.

[42:04] Pacificoor's approach is not an extreme approach.

[42:08] I would rather say that it's a very well-balanced approach.

[42:13] It's balancing the fact that there are conflicts among state policies that are new in developing

[42:23] And at the same time, trying to maintain parity amongst the different jurisdictions.

[42:32] For example, you know, going back and I'll try to go through this very quickly.

[42:38] In the 2021 IRP is where we really started working on this in earnest with CEDA coming in to the fold.

[42:44] In the 2023 IRP, we introduced a methodology that began with a system-wide preferred portfolio

[42:53] and then layered in jurisdictional resource selections.

[42:58] That was not very popular.

[43:00] It had the potential for over-build in that methodology.

[43:04] We don't believe that it did over-build.

[43:06] In the 2023 IRP update, responsive to stakeholder and staff feedback, we developed a different

[43:13] methodology which is the jurisdictional methodology that we then used in the 2025 IRP, that methodology is

[43:22] precisely seeking balance. It's not an extreme one way or another. It doesn't abandon

[43:30] the system-wide solution which we still perform. In fact, every one of the jurisdictional studies

[43:34] is a system-wide study and then we integrate those according to a methodology that is mathematical

[43:41] radical and reproducible and you know it keeps in mind facts such as for this

[43:50] state of Washington we must select resources under the social cost to

[43:53] greenhouse gases rule that's you know there's no way around that there's no

[43:59] circumvention of that also we did not want to reduce it to an order of

[44:04] operations question in other words who do we start with do we optimize for

[44:08] Oregon first, then Washington, then Wyoming, or do we start with Wyoming, and then move

[44:13] on to Oregon, and then move on to Washington?

[44:17] There's no way to do an order of operations approach that is not recursive, cyclical,

[44:24] and ultimately extremely difficult to defend.

[44:29] So we select an approach by which we examine each jurisdiction's needs independently, and

[44:35] And then bring them together into an integrated portfolio.

[44:39] And then we have, you know, many steps that we take to ensure that we're not overbuilding,

[44:44] that we're not underbuilding.

[44:45] We check for all compliance.

[44:47] We try to ensure that every state gets the resources that it wants.

[44:51] And then that's the final outcome.

[44:54] Is it perfect?

[44:55] No.

[44:56] But it's an evolution.

[44:58] And I believe that

[45:00] But the CEP represents the very best preferred portfolio to address these problems that we've had so far. And we also have, you know, future plans that we're working on. These discussions are going to lead to fixing some errors in the model. They're going to lead to perhaps capping the resource selections that each state had selected in as jurisdictional runs in the integrated portfolio run.

[45:28] And, um, anyway, those are the significant points and, you know, and a question that

[45:34] I have for R&W as a consequence is, you know, we've revisited, revisited, um,

[45:45] actually,

[45:46] let me start over with that.

[45:47] Can I pause you there just before you move into that?

[45:51] Sure.

[45:52] I hear you saying, there's a, I'm hearing you lay out a really paradigm level dispute.

[45:59] But you don't feel that it is reasonable or feasible to or reasonable maybe is the right word model something that doesn't incorporate state policies in order to see the scale of reliability challenge created by the wrap rules and or the physics of scarcity in the in the grid.

[46:28] And am I sort of catching, but where Renewable Northwest seems to really, and many of the

[46:37] stakeholders seem to really hunger for that sort of counterfactual.

[46:41] Yeah, thank you, Chair Tony, and that is an excellent point.

[46:44] And frankly, running that step one of their framework, I don't see it as being particularly

[46:51] problematic.

[46:53] The difficulty is that you can't get to their step two of the framework because the very

[46:57] next thing that you would be forced to do is to take into account the effects of state

[47:01] policy on reliability. And the baseline that they've selected, we see as being an appropriate

[47:09] because it does not take into account that effect. Our position is that Oregon has ambitious

[47:16] and laudable policy goals and those have effects on the system. Reliability is one of the more

[47:23] significant effects, I believe. And that has to be accounted for. So running it is not problematic.

[47:31] But what you then do with it is immediately apply the reliability impacts to establish a baseline

[47:38] that is more sensible and more workable in our opinion.

[47:45] But is there no value in

[47:47] And demonstrating to stakeholders the delta between the, let's call it the old way of

[48:00] doing it before Utah's requirements that Hunter and Huntington stay online till 2042

[48:06] before CEDA's deliverability requirements are in play.

[48:12] There's a host of policy across the region at this point that you're grappling with.

[48:17] Is there no value to laying out that counterfactual in the cost cap discussion, which of course

[48:25] is a contest case that we won't go into detail?

[48:28] There is a whole construct around counterfactual.

[48:33] Yeah, and I'll let others on my team chime in, but yeah, I believe that that can have heuristic

[48:41] value, but in order to do it cleanly, you'd have to back out all state policy, including

[48:46] SB 1547, and then the comparison when you include SB 1547, that would be the first impact

[48:53] that you would see is those reliability capacity generation emissions impacts.

[49:01] And you don't, you know, you gain something interesting to look at, I grant, and we're

[49:08] perfectly willing and able to run such a study.

[49:10] It just didn't seem necessary in order to get to the result, to get to the outcomes.

[49:17] I think perhaps you are missing a piece where you're bringing the stakeholders along in your process.

[49:27] I think you're hearing from them that they disagree with sort of how you solved the problem.

[49:35] And I think maybe it's something interesting to look at because you have a sense of how

[49:40] you want to solve the problem.

[49:41] I think there's a trust gap there.

[49:44] But I'll pause, Commissioner Perkins, it looks like you might have questions as well.

[49:50] Well, I mean, I'm going down the same path that you are.

[49:52] And my brain is wondering how A, you could not think it was an important thing to do when

[49:58] all of the stakeholders are asking for it.

[49:59] It may not in your mind be something that has value, but the stakeholders are all clearly

[50:05] saying and has value. Our staff is saying it has value. I think it has value. I don't understand

[50:11] how you can determine the impacts of state policy if you don't understand how the system

[50:16] is operating without those in place. How can you come to that conclusion if you can't see

[50:23] that delta and everybody else can't see that delta? I guess that's what I'm struggling with.

[50:26] And if you say it's definitely easy for you to do,

[50:29] why wouldn't you have just done it and provided it

[50:31] when everybody was asking for it in the first place?

[50:33] And I build on that.

[50:34] Yes.

[50:35] Brandy, before you respond, to Commissioner Perkins,

[50:38] I think, and I was curious because my recollection

[50:41] is that the company was very supportive of House Bill 2021

[50:45] in 2021.

[50:46] So I pulled up corporate testimony on the record

[50:51] to better remember how the company was positioning itself

[50:55] And I think what I'm curious about here in this conversation is when state policies

[51:02] were up for discussion here in the state, Pacificore said House Bill 2021 recognizes that

[51:11] the grid is regional in nature, and that Oregon's participation in regional electricity markets

[51:15] is the key component to ensuring affordable integration of renewable resources and ensuring

[51:20] our reliability. Later, we're going on to discuss that pacificor, one of the benefits of being a

[51:25] regional multi-state electricity provider, is that we can share costs at scale and leverage geographic

[51:31] diversity to provide the best solutions to all our customers. And so I'm curious what changed.

[51:39] Yeah, all of that is true. And all of that, I think, remains true. And pacificor is not opposed

[51:45] to House Bill 2021.

[51:48] What has changed is a number of things.

[51:51] Federal legislation being paramount amongst them.

[51:55] The resolution of how state policies are interpreted

[52:01] and must be implemented.

[52:03] That's also a change.

[52:07] And it's a different world.

[52:10] When we talk about a paradigm shift,

[52:12] we believe that there is indeed clearly a paradigm shift.

[52:16] The requirements that we now have on the table with the federal laws that are now in place and the restrictions that we have to maintain the integrity of our modeling solution so is not to favor a particular jurisdiction one over another it requires balance and we've attempted to create that balance as best we can this this question of running that initial absolutely no state policy of any kind.

[52:45] study did not come up in our 18-month, 15-month public input meeting series. There was a lot of

[52:54] discussion about establishing the proper basis for determining what the reliability needs are and

[53:01] how that differential would have to be measured, you know, of the preferred portfolio as the expected

[53:08] a case against other cases. There was a lot of discussion that zeroes in on the issues of

[53:16] measures and approaches and modeling, but this was not brought up in the Public Input

[53:21] Meeting Series, and it's not in our stakeholder feedback form. So, yeah, there's a huge amount

[53:28] of interest in it now, and I think that huge amount of interest is probably being incentivized

[53:36] by the fact that the removal of federal policy and the rejiggering, if you will, of the planning

[53:43] environment has made Oregon's ambitious policies more expensive, because there's not this underlying

[53:53] bed of federal tax-supported resources filling up the system.

[54:07] I think that there is no question, a pipeline of renewables is very different, and the cost

[54:14] environment for renewables is very different.

[54:16] But I am observing a host of constraints that are confusing, and so I'd love to ask

[54:29] you about two of them.

[54:31] Can you describe to me whether B2H serving a large customer is B2H ending in a cul-de-sac?

[54:42] Or by serving that large customer, does B2H get a connected across to Pac-West functionally?

[54:49] And once it's all in EDAM, Pac-West essentially has access to the transfer capability of B2H.

[54:58] or is it just really just a cul-de-sac?

[55:01] It's going to the large customer,

[55:02] it's the end of the conversation.

[55:05] Yeah, thank you for the question, Chertani.

[55:07] If I may, I'd like to defer to Rick Link

[55:09] on this question.

[55:11] Rick, can you hop on?

[55:15] You're muted, Rick.

[55:24] No, you're still muted.

[55:28] Double muted.

[55:28] I have to hit all three mute buttons.

[55:31] Not a way I've hit star six.

[55:33] You're good.

[55:34] We can hear you, or we heard you just a moment ago.

[55:39] There you go.

[55:40] All right.

[55:43] So, yes, B2H would in and of itself longhorn does it connect to our PAC-West BAA, but the

[55:52] longhorn substation is in very close geographic proximity to elements of our transmission

[55:59] system in the PAC-West balancing authority area with some minor, you know, have the

[56:04] mileage off top of my head somewhere between 15 to 30 miles, I think, of local, I'll call

[56:10] All that transmission infrastructure would be added in this plan to be added in that part

[56:16] of the system to ultimately connect it to PacWest.

[56:19] That being said, just as a reminder, our West Balancing Authority area has a lot of low

[56:26] pockets that connect it and we serve some of that through transmission rights that we have

[56:30] with Bonneville across our system as well, so it's not a contiguous system on our PacWest

[56:36] But from a PAK West capabilities or PAK West import capabilities perspective is serving the large customer a cul-de-sac or does it by serving the large customer is B-2-H serving PAK West?

[56:59] It would be serving PAC-West. I mean, it is needed to help serve that customer. It's like a contingent facility or a required facility for load service in that particular part of the area.

[57:12] But like I said, when it does connect to our transmission assets that make up our Western VA, that is connected.

[57:21] If it's not a complete island in the boardman area where longhorn generally terminates geographically there are connections up into Washington and other parts of our system, particularly when we look at our third party rights on Bonneville.

[57:35] So it's one way to think of it is, it's just load and there happens to be a large amount of load growth there that can be used and that would require additional transmission infrastructure.

[57:49] And you know, just like there's load in other parts of our system as well, that could benefit if we could get it there, right? And we're not.

[57:56] Be really clear. We're not giving up on that.

[57:58] That pathway, right? We're keeping all of our options open. We're playing.

[58:02] Letting the story play itself out. It's not been written yet. The final chapters. You know blank pages at this stage. We have our redirect requests that have been much discussed in this process.

[58:14] in Bonneville's queue, they're not removed,

[58:17] and they will ultimately, at some point,

[58:19] I believe, be studied and we'll find out

[58:21] what that study tells us at that point in time

[58:24] and we'll make the appropriate decisions

[58:25] based on what that information tells us.

[58:28] But we do have a need for it.

[58:31] The way I think of it, another way to think of this,

[58:34] Chertani is when we were working through the term sheet process

[58:38] and getting the basic concepts in place

[58:42] between the three parties,

[58:43] responsible Idaho and Pacific Corps.

[58:45] It became increasingly apparent that

[58:48] I don't criticize them for this,

[58:52] but they wanted us to get the redirect request

[58:54] that we've been talking about, you know,

[58:56] achieved through their normal business practices

[58:58] that they couldn't commit to offering those redirects

[59:02] as part of the agreement itself, right?

[59:04] They committed that if you submit it,

[59:06] we will follow our process and let you know how that pans out.

[59:09] When we became aware of that,

[59:11] we had to, you know, kind of assess, well, if what if Bonneville never offers those

[59:16] weeks, or what if Bonneville offers them, but at a time frame and a cost that's not acceptable,

[59:23] right? That's crazy high cost in 10 years down the road. Would we still have to use for B2H?

[59:30] And the answer to that question was yes, right? Because we did have

[59:34] load and very close proximity to pH, so that we got, that's how we got comfortable

[59:39] moving forward and ultimately executing the term sheet and moving on to

[59:43] definitive agreements after that term sheet was signed among the parties.

[59:48] Recognize because I'll have to say that accent that is I wouldn't expressly state

[59:53] that we may not have signed the term sheet. It would have been a much riskier

[59:56] endeavor for us to consider moving forward with a

[1:00:00] That may not have a use for us, right? That wouldn't even meet the use and useful standard. Because it terminates, you know, at a place that is called a sac at Longhorn, at that point. But because we had this other load in the area, we got a full movie forward that we could have a use for this line, even if for some reason we never got the redirect request needed to bring the energy to our load or bring it home from Longhorn.

[1:00:25] I appreciate you raising the term sheet because that was my second question around B2H.

[1:00:35] I'm conscious of time, it's 10.30.

[1:00:39] We need to move to the rest of the agenda.

[1:00:46] Colleagues, do you want to ask the Pacific Corps anything further in relationship to sort

[1:00:52] what renewable northwest is raised so far. These issues are all intertwined and so hopefully by the

[1:01:00] end of the morning we have more clarity on all of them but just to keep us moving along.

[1:01:21] This is

[1:01:23] challenging. This happens in IRPs and in other dockets where we really struggle with stakeholders

[1:01:32] is talking past each other. And I think these workshops can be helpful for trying to help

[1:01:39] parties hear each other. And so I appreciate the clear engagement.

[1:01:46] Let's turn to item three, the jurisdictional modeling assumptions and impacts.

[1:01:53] So Renewable Northwest has teed a bunch of this up. But I'd love to see a show of hands on

[1:02:00] who would like to sort of raise something additional or unique as opposed to what

[1:02:08] Renewable Northwest has already raised on these topics.

[1:02:14] Recognizing that we

[1:02:15] have your written comments, I'll pause.

[1:02:25] Let people find the razor hand button. We

[1:02:37] have a lot of written comments. I

[1:02:50] have a question on this topic. Colleagues, you

[1:02:53] might not have questions for the company on this topic. So let me ask the company and

[1:02:58] then colleagues, you please follow on. So I am very curious as I engage with these constraints

[1:03:08] It's a specific or about the way you seem to be saying how HB2021 is interpreted is deeply

[1:03:23] impacting access to market purchases and sort of choking, putting Oregon on an

[1:03:35] Island and I'd really love you to unpack that given the extensive work in the EDM process

[1:03:45] around trying to address GHG constraints and so on.

[1:03:53] Rohini.

[1:03:58] Hopefully, I'm hooked up and you can hear me.

[1:04:01] Yes.

[1:04:02] Awesome.

[1:04:03] Thank you, Chair Tony, for the question.

[1:04:05] and I'll try to answer your question directly,

[1:04:08] but I might add a little bit of context as well.

[1:04:11] I think there are a few kind of points to make here.

[1:04:15] So as far as just modeling towards House Bill 2021 compliance,

[1:04:20] as you're well aware, having seen the results we've presented,

[1:04:24] there's definitely kind of a narrow amount of emissions

[1:04:30] that a Pacific Corp can plan to rely on,

[1:04:33] whether it comes from emitting gas units or unspecified market purchases as far as what room

[1:04:40] would we have under an 80% or 90% reduction in emissions in 2030 or 2035? Not even thinking

[1:04:47] about maybe the limitations in 2040. And so under that paradigm, we've tried to set up our modeling

[1:04:53] in a way that allows us to endogenously plan to those requirements for Oregon, which does require

[1:05:01] I think things to look a little bit different for how we would serve Oregon customers versus how we might serve customers on the rest of the system.

[1:05:08] And a large part of that comes from the amount that we typically might rely on front office transactions for FOTs and the model,

[1:05:16] which are again unspecified market purchases that do come with a significant unspecified market emissions rate under the DEQ methodology.

[1:05:26] And so, you know, just, I won't pull it up, but, you know,

[1:05:30] harkening back to the presentation I gave shortly after we filed this

[1:05:34] E.P., you can look at our Oregon retail sales on an annual basis

[1:05:37] in 2030, what's forecasted, and it's, you know, somewhere around 14,000

[1:05:44] gigawatt hours, and you can look at, you know, what the existing

[1:05:48] generation is that we have to serve Oregon in 2030, which no longer

[1:05:52] and include school generation for obvious reasons,

[1:05:55] does include some amount of gas trend that we have to,

[1:05:58] and I think in 2030, we don't really need to restrain it

[1:06:00] at adding enough resources helps us meet it.

[1:06:03] And there is some market reliance.

[1:06:06] One thing that I'll comment on is there's nothing

[1:06:08] in our models that's necessarily accounting

[1:06:10] for how things might change under EDAM.

[1:06:13] I can let Randy speak to whether or not we see that changing

[1:06:16] and whether or not we see how market participation

[1:06:19] or settlements in EDM might change kind of what that view looks like from a long-term modeling perspective, I can't say

[1:06:26] But you know, we kind of model our various markets

[1:06:30] Typically, we're looking at probably mid-sea in this region

[1:06:34] Not really, you can correct me if I'm wrong and we're relying on a certain amount of market purchases to meet those hours in which

[1:06:40] Oregon allocated generation might not be enough, but as you know, we're not typically modeling that on an hourly basis

[1:06:46] we're kind of looking at annually. And so we, you know, just purely on an energy basis,

[1:06:51] there is a very large need for resources that can generate to serve. And that might become

[1:06:57] more efficient when we're in EDAM, and maybe that leads to less curtailment of renewables,

[1:07:02] and maybe that leads to a change in how we model. But I think from a compliance with House Bill 2021

[1:07:07] perspective, we're really focused on what is the energy that can serve Oregon customers,

[1:07:13] where's it generating, how is it getting to them, and how much room does that leave us to rely on a market position, knowing that it has assigned missions right?

[1:07:23] Did I answer your question if I didn't please, please ask me again,

[1:07:30] Cheritani, you're muted.

[1:07:31] I appreciate that, and I think what I, the fall, you know, the piece that the stakeholder

[1:07:44] community and the regulatory community that needs to grapple with is, how do we maximize

[1:07:50] when we know we are getting lower cost? Lower emissions resources out of the market, solar

[1:07:59] out of California, for example, how do we account for that effectively?

[1:08:05] So I guess that's what I'm not seeing that this is a constraint and it is not permanent.

[1:08:12] The here is how we might resolve it, sort of a pointer from the companies. So.

[1:08:19] And to that point, my understanding, I am not a part of the EDM implementation in any way,

[1:08:25] But my understanding has been that going into EDAM doesn't necessarily change like what generation of the specific corpus claimant, right?

[1:08:34] All of the resources, and you think about our DEQ methodology, where essentially we're kind of stacking all the communications that are communicating it correct.

[1:08:43] And so my understanding is even if we are bidding in all of our resources into EDAM and in the day ahead it might reshuffle to make it more efficient for the system.

[1:08:51] We are still going to see from Pacific Corkside all of our generation that generated on annual

[1:08:58] bases monthly intervals and that's going to account for what served kind of on a cost

[1:09:04] allocated basis for organ customers.

[1:09:06] And there's currently the way we do it is we just kind of take a share of these market purchases

[1:09:11] that happen in the markets and we kind of cost allocate that to Oregon.

[1:09:16] And we also might impute an additional shortfall market, which I don't think is typically

[1:09:21] happening, but we could impute, you know, an additional market shortfall if

[1:09:24] Oregon allocated resources were stacked up and they weren't enough to meet

[1:09:28] Oregon retail sales on an annual basis. And so to my understanding what

[1:09:33] settles in EDM is it necessarily directly changing that from a specific

[1:09:38] quarter perspective, it just might make it more efficient and a benefit could be

[1:09:41] like perhaps less curtailment in the markets. And again, does that change how we

[1:09:45] model? I can't say. But my understanding is what we bit into the market really

[1:09:50] shouldn't change kind of the claim that we have on our own energy.

[1:09:56] So the converse is that we don't necessarily get to claim others clean energy coming

[1:10:00] back to us.

[1:10:01] And so if that, so we are still seeing unspecified in that sense.

[1:10:04] So if that were to change, that would be wonderful.

[1:10:07] We'd love to see it.

[1:10:08] I just currently am not aware of something that gives me kind of a specified market purchase.

[1:10:15] That's at a lower rate, if that makes sense.

[1:10:17] It does. It does.

[1:10:21] Questions, colleagues, and also stakeholders open to hearing from folks on these issues.

[1:10:31] Let me just check and see if my colleagues have questions for a specific core and then I'll go to you.

[1:10:37] Well, I guess my question would be wouldn't including that potential future option of changing how those purchases are.

[1:10:47] looked at and credited, wouldn't modeling that be part of looking at future scenarios,

[1:10:52] so you can have an idea of how that might play out.

[1:10:56] Yeah, that's a great question.

[1:10:57] And I just am really not an expert by any means on how that will change.

[1:11:01] Again, I think from a long-term planning perspective, noting that,

[1:11:05] you know, we're never going to purposely, perfectly forecast what, like,

[1:11:09] hour to hour, month to month kind of market settlements are.

[1:11:13] I do think we are contemplating it right I think it's a conversation we're having internally you know

[1:11:17] Is this something that's going to have an impact and and I think once we are able to go live in EDAM and actually see that in practice

[1:11:24] We'll have a better idea but again

[1:11:26] I think from a long-term planning perspective as far as compliance you know

[1:11:31] I still see it as we have kind of the claim over all of our own generation

[1:11:37] Maybe the forecast of that generation changes because of EDAM

[1:11:41] But we have a fairly optimistic forecast as it is for our renewables based on really

[1:11:45] just transmission constraints in the system.

[1:11:48] And we are kind of claiming, quote unquote, the clean credit, which there's no wrecks

[1:11:53] or anything.

[1:11:54] But we are claiming that as energy that can serve and is compliant.

[1:11:57] And we're looking at, does that reduce our perceived market position?

[1:12:01] Yes, great.

[1:12:02] We think there'll be less emissions.

[1:12:04] I don't have anything to my knowledge that will change significantly what the market dynamics

[1:12:10] are to change the generation, like if it's going to change dispatch order or market or something,

[1:12:15] but yeah, I'm absolutely would love to see it. I know that there are tons of folks,

[1:12:20] you know, at the company and other parties that are talking about in EDAM, thinking about things

[1:12:24] like residual energy and all of that, and maybe having a measure on a monthly basis or whatever

[1:12:31] scale that says, well, all of that kind of market energy that came to you, you know, because we were

[1:12:37] shorter in that period could actually be

[1:12:39] to lower emissions rate.

[1:12:40] But again, I don't know how likely that is.

[1:12:43] I don't know what the stack of resources looks like.

[1:12:46] So I think I wouldn't know what to model.

[1:12:49] But again, I totally welcome anyone from Pacific Corp

[1:12:52] to chime in if they have better intel than me.

[1:12:55] But yeah, we're just focused on what

[1:12:58] can Pacific Corp's resources generate reasonably based

[1:13:01] on constraints in the system and trying

[1:13:03] to offset that market reliance as much as we can.

[1:13:10] Really?

[1:13:12] Yeah, I mean, I just wanted to add, we're definitely looking at this internally

[1:13:17] and as a, from a forecasting scenario perspective,

[1:13:22] it doesn't even necessarily require a model run.

[1:13:24] There are perhaps calculations that could be done to book in potential impacts.

[1:13:30] But, yeah, we're looking at it.

[1:13:32] We're interested in, you know, any feedback or suggestions.

[1:13:36] I think you're welcome.

[1:13:38] I mean, I guess I would say that if that's something you can do,

[1:13:42] that's information I think would be useful in kind of looking at how changes

[1:13:48] within the market and how transactions are handled and credited.

[1:13:56] It would give us, I think it would give everybody insight into the value

[1:14:00] and look how things could be done to optimize the system for customers

[1:14:04] and for the company.

[1:14:04] thank

[1:14:07] you. I think I'll add to that having worked really extensively in that process with

[1:14:14] Oregon DEQ and the OPUC team. There's a huge amount of work going on and I would really

[1:14:21] end to my mind. It makes a really big difference in terms of both how much you build and what you

[1:14:27] build, whether how you're going to compete with California and Washington in E Dam to draw clean

[1:14:36] energy resources to Oregon as a GHG constraint state. It really impacts the purchasing decision

[1:14:45] and the relative competitiveness of different resources, I think. So I think it's really important.

[1:14:51] But I'll put a pin there and pivot to Fred, your perspective on these modeling assumptions and

[1:15:00] So, on this juicy question, narrowly, perhaps. Yeah, if it's a good morning, chair, Tony, and

[1:15:06] commissioners, Perkins, and hour, Fred Huitt, representing the Northwest Energy Coalition.

[1:15:13] Topical, I want to focus on is under item three is resource adequacy, and specifically

[1:15:19] the Western resource adequacy program. So if it's okay for me to address that right now,

[1:15:23] I can do that, or I can wait.

[1:15:26] So RAA resource adequacy is obviously a key part of the IRP process and many other

[1:15:32] things.

[1:15:33] The question arises about the relationship between the IRP and the Western resource adequacy

[1:15:39] program.

[1:15:40] I will not get into all of the details on that, but clearly major decision point coming at

[1:15:45] the end of this month on October 31st for Pacific or in other participants to decide whether

[1:15:52] they want to participate in the binding program that starts in a couple of years.

[1:15:56] And at the same time, and I'm speaking here also as a member of the RAP program review

[1:16:01] committee, there's a substantial amount of work going on to revise the RAP program design,

[1:16:06] including in the areas that are relevant here, especially the planning review margin, and

[1:16:12] the way that RAP is moving forward in the operating phase and both, you know, forward showing

[1:16:19] and the operating phase on the zonal approach within the overall RAP program, which currently

[1:16:25] right now is a geographic split between basically the northwest and the west, rest of the

[1:16:29] west, with informally called the SWEED as southwest, I'm never sure what the acronym

[1:16:35] is anyway. There's a proposal on the table right now to, there's subgroups under the program

[1:16:42] review committee or under that process at RAP to review both the planning reserve margin where

[1:16:47] there's a lot of concern, I think, rightly about the variability that we've already seen with

[1:16:51] a year to year, and also on this kind of zonal approach, both of which are directly relevant to

[1:16:58] what happens with PAC-RP planning going forward, and just to note, we both support and thank PAC

[1:17:06] for being very responsive to all of the input that we provided in questions that, especially technical

[1:17:13] questions and the analysis that Renewable North West and Sierra Club have sponsored that's been

[1:17:17] really, really good. We also support the call by many of us to revamp the planning approach

[1:17:24] in the IRP update, which is coming fairly soon. The issue with that is the RAP review process,

[1:17:31] and what's happening with the IRP update, you know, there might be a bit of a alignment issue

[1:17:36] with all of that, so we may not know, as the RAP update proceeds, how much change the

[1:17:42] RAP process will be undergoing.

[1:17:45] So I just wanted to point that out, the issue with, especially with the Zonal approach

[1:17:52] is directly relevant in that, the proposal we have just seen.

[1:17:57] We've got the Materials in Tuesday and discussed them in the program review committee yesterday.

[1:18:02] day, the materials coming from the subgroup suggest a change to a market-aligned approach

[1:18:07] for RAP rather than a geographic basis for doing the zone approach, which probably means

[1:18:13] if that goes forward, that specific or if they participate in the binding program would

[1:18:18] be in a single zone in the EDAM side, if you want to call it that.

[1:18:23] But as opposed to now where the SWEED, the Northwest SWEED division happens basically

[1:18:30] between PACK East and PACK West, that's directly relevant to the information that you've got

[1:18:36] to put into the modeling and the perspective that we have.

[1:18:40] And also connects to, for example, matters, other matters.

[1:18:43] So for example, UM-24 or for currently before the Commission with Oregon's or the Commission's

[1:18:49] own kind of backstop resource adequacy program.

[1:18:52] This is a very complicated thing to deal with, so I wanted to point that these timing issues

[1:18:58] and the content issues out for your consideration because I would finally say our view at the

[1:19:05] Northwest Energy Coalition is we want to keep as intact a wrap as we can, but we have to

[1:19:11] recognize that there are legitimate issues that are being raised by Pacific or others about

[1:19:17] the program design currently, that will take time to work out.

[1:19:23] Thanks, Fred. I think you highlight what a moving landscape we're coping with. Everyone is coping with questions for Fred on the issues he's raised.

[1:19:39] Okay,

[1:19:42] you know, Fred, I think as you think about, I know Pacific Corps is doing another round

[1:19:48] of reply comments, and that might be the last set of comments in the process, it's never

[1:19:53] the last set of comments, but you know, as you work with the RAP, really articulating how

[1:20:00] this shift in footprints impacts the IRP is helpful.

[1:20:03] So I appreciate how you cover that in your comments.

[1:20:09] Okay, yeah, it's 10 to 11.

[1:20:12] I would like to take a break recess until 11 o'clock,

[1:20:17] and then take up items four and five and six if we have time.

[1:20:23] But colleagues, this is really intended for us to get our arms around the challenges.

[1:20:29] And these are all interrelated challenges.

[1:20:31] So I want you to feel free to pursue your curiosity as you need to, don't feel constrained by the agenda topics.

[1:20:44] So Christie, let's recess until 11 o'clock.

[1:20:52] All right.

[1:20:54] I'd love to move on to item four on the agenda.

[1:21:00] We've discussed this some with questions that we were posing around V2H, but I think there's much more to unpack there.

[1:21:11] I see Zach, you have your hand up.

[1:21:15] If other folks would like to raise issues on this topic, please put your hands up and let's go ahead and start with you, Zach.

[1:21:31] Great. Thanks, Chair Donnie. We actually have just one more point we'd like to make on the

[1:21:38] jurisdictional modeling if that's possible.

[1:21:42] Yeah,

[1:21:46] so understanding I'm not a modeler,

[1:21:49] right? I don't have subject matter expertise, but I have been working with our IRP team and our

[1:22:02] point to get lost in the weeds.

[1:22:06] A lot of the commenters are quite concerned that our

[1:22:11] jurisdictional modeling approach is going to result in increased costs for organ customers

[1:22:18] that it could result in substantial over-build of resources. And it kind of obscures system

[1:22:28] need, right?

[1:22:32] I actually think renewable north-west's proposal actually exacerbates all of those

[1:22:40] issues except for cost. So their method actually points in the wrong direction for the conclusions

[1:22:49] that they're trying to draw. And I'd like to hear folks perspective on this, but let me unpack

[1:22:55] pack this a little bit.

[1:22:57] So let's start with costs.

[1:22:59] So since A3201 is an emissions reduction mandate, right?

[1:23:04] Oregon has the same emissions it needs to reduce,

[1:23:07] regardless where those resources come from.

[1:23:10] So either Oregon gets by Rohingy's back

[1:23:14] of the envelope math.

[1:23:15] Either Oregon gets three gigawatts of cytos resources

[1:23:20] by 2035 or Oregon gets, you know, 26, 27 percent, whatever current allocation factor is of 10

[1:23:31] gigawatts of system resources, right? But it's the same amount of resources, regardless if it's

[1:23:38] shared with the system or site is. And so the costs aren't going to be impacted by whether we

[1:23:50] move forward with an R&W type modeling approach because Oregon still has the

[1:23:57] same need. Regardless where those resources are cited or system. But what

[1:24:03] it's important about Renewal Northwest's approach here is that for each

[1:24:09] resource that Renewal Northwest model would have come from system resources, that

[1:24:17] results in more over build than

[1:24:20] pacificors, right? So every resource that

[1:24:25] is no longer supported by a

[1:24:27] CITIS decision in an IRP framework

[1:24:32] that has to become a system resource

[1:24:36] and as soon as it becomes a system

[1:24:39] resource we have to procure four times

[1:24:41] more to meet the same need for

[1:24:44] Oregon, right? So, taking to the extreme, let's just say all about our HB 2021 resources should

[1:24:53] instead be system resources, right? So, Renewable Northwest methodology is saying that, hey,

[1:25:01] pack, you know, instead of the three gigs you need, you actually need to procure 10 gigawatts

[1:25:07] by 2035. And Oregon gets, you know, the 27-28% of that, right? So the point here is to show

[1:25:16] that every time a site is resource becomes a system resource, that is necessarily more

[1:25:23] overbilled than Pacificoors approach. And, you know, the third issue here, I think

[1:25:32] think I hope really brings it home.

[1:25:35] Even if, you know, CIVCOR's approach has some, you know, flaws with our liability assessments

[1:25:43] or there's some modeling errors that we need to address or there's some EDAM implications

[1:25:48] that, you know, could impact our results.

[1:25:52] Even if like we add those fixes, I don't think there's a colorable argument that the

[1:26:02] system needs seven gigawatts of resources by 2035, right? And so if that's the conclusion,

[1:26:12] every time a site is resource for Oregon that's needed to meet HB2021 requirements, every time

[1:26:21] that resource has to be shared with the system, that creates an obligation for PAC to try and seek

[1:26:30] recovery of those resources from other states, and I just don't see the world where we have to

[1:26:41] seek recovery in our other states for a material volume of resources necessary to comply with

[1:26:51] HP 2021, where there isn't a need identified. So I'm really curious. I see Jim's got his hand up,

[1:26:58] But this is my kind of-

[1:27:01] I appreciate you sort of laying this out

[1:27:05] because I think this is we have, we have,

[1:27:07] I would diagnose, we have a very much

[1:27:11] a talking past each other's situation.

[1:27:14] I am not hearing stakeholders have articulate

[1:27:19] the sort of all or nothing approach

[1:27:22] that you are arguing.

[1:27:25] So I hear you.

[1:27:25] So I understand what you are saying around DEQ compliance is via MSP cost allocation

[1:27:36] if a resource's system cost allocated only 27% or a third or whatever the right allocation

[1:27:44] factor is in the moment can be accounted for DEQ compliance.

[1:27:50] And thus, for example, all of the wind that we have procured over the last several years

[1:27:59] Oregon only gets to claim 30% roughly.

[1:28:04] Sort of is the challenge and you're pointing to, I think, the reality of 1547

[1:28:14] and taking the thermal fleet out of Oregon's cost allocation.

[1:28:19] But I think I'm really hearing a differentiation between the reliability gap first and then what's left over in terms of back in the thermal fleet out of the cost allocation and replacing it with zero emitting backing the unspecified market purchases out of the cost allocation and replacing it was specified.

[1:28:47] Can you speak a little bit to that?

[1:28:50] Can you hear that nuance or that stacking up?

[1:28:54] Is that not valid?

[1:28:56] Yeah, so I think I can have one thing of value to say here,

[1:29:01] but then I think I'm out of my depth, right?

[1:29:09] Where I think, or Northwest,

[1:29:13] the discussion on reliability where we diverge

[1:29:18] is specific core things that Oregon's requirement to get out of coal by 2030, that is a state-specific

[1:29:31] policy that creates state-specific reliability problems. Because when Oregon exits coal,

[1:29:41] those resources don't necessarily retire. They will keep serving states that keep that energy

[1:29:48] in their allocation of resources, so when Oregon loses a gigawatt of, you know,

[1:29:56] based load resources.

[1:30:00] That reliability benefit will serve every state that keeps that electricity in their allocation of resources, an organ that has to bring on more resources to serve load and to meet reliability requirements that otherwise would not exist. And that's a state specific concern that other states shouldn't have to bear the weight on.

[1:30:29] But again, I'm, you know, that's just my takeaway, but I really need Randy to come on and

[1:30:37] do his thing because, yeah, happy to be corrected where, you know, I'm a spoke on something.

[1:30:43] So we go back to, we have a very fundamental difference of view.

[1:30:47] Pack believes it has a reliable portfolio right now and it is Oregon's choices about resources

[1:30:57] that are making it unreliable.

[1:30:59] And I can't speak to where we're at on system reliability.

[1:31:05] I was just thinking of the specific Oregon policy

[1:31:09] for 2030. Can I see Randy's here?

[1:31:13] So I'll...

[1:31:13] Yeah, can you answer the system?

[1:31:15] Your perspective on the system reliability issue.

[1:31:19] High load hours.

[1:31:22] You know, what we don't have in this IRP

[1:31:24] He is any analysis of any heat map about where you are under duress in South Africa.

[1:31:33] Yeah.

[1:31:33] Thank you, Chair Tyne.

[1:31:36] What we do have is what the IRP traditionally carries, which is a description of what proxy

[1:31:43] resources are needed where and when and what we see is that the East needs about 300 megawatts.

[1:31:51] And so there is potential there.

[1:31:54] There's no doubt if you entangle that with questions or concerns about

[1:32:01] deliverability, about Eastside interest and the kinds of resources that would be

[1:32:07] dictated by HB2021, there are a lot of complications. And if you take 300

[1:32:14] megawatts out of a need of three gigawatts, I'm not sure that you're looking at a

[1:32:21] problem that is of the magnitude that that I've heard being expressed or the urgency that I've

[1:32:28] seen in, you know, comments or conversations. And one thing that we did not talk about yet,

[1:32:36] that I'll mention in that vein, just to be sure that we don't get caught up in this is the

[1:32:46] presence of proxy energy efficiency in the load and resource balance, and I'm only

[1:32:55] mentioning it, we're not open that can worms, but I just want to say that that's not

[1:33:00] an error or mistake, as R&W called it out, it's intentional, and it's included for good reason,

[1:33:06] based on expectation. We include in that view of the system anything that is committed or

[1:33:15] are definitively anticipated as well as resources that are actually currently in operation.

[1:33:21] And we have full expectation that the east is going to get a share of energy efficiency

[1:33:26] that's very similar to what we have forecasted.

[1:33:29] And so it's not missing.

[1:33:30] There's not additional need on the east because we included it in that view.

[1:33:35] It's intentionally included in that view.

[1:33:38] So again, about 300 megawatts on the east is what they need.

[1:33:42] Okay.

[1:33:47] I'm going to invite Jim, you to respond. I think this is helpful looking to my colleagues.

[1:33:55] Is this a helpful sort of unpacking of the issues for you or is it leaving you with?

[1:34:01] Go ahead. Go ahead. Yes, I'm not hearing overlap in agreement about sort of basic assumptions of

[1:34:08] how Oregon and the entire system are integrated.

[1:34:15] Yeah, I agree with that.

[1:34:17] Yeah, I mean, I, my goal is I stand for us

[1:34:22] to try to get useful information

[1:34:23] to get us to a successful conclusion with this IRP.

[1:34:27] I still feel like there's this lack of,

[1:34:30] like you said, talking past each other

[1:34:32] in terms of what's needed to get there.

[1:34:34] And I still, it feels to me like what's being fed to us

[1:34:38] is trust us. We've looked at it. It's not important to understand that underlying how the system

[1:34:44] would function. And I think what's repeated to be saying, being said back is, no, it's really

[1:34:50] important. And yeah, we may not like the outcome of it. It may not come out exactly, but it's important

[1:34:56] information to be able to understand going forward and to unpack in a lot of different ways

[1:35:02] in dockets that are going to be coming before us. Like it's important information to have as a baseline.

[1:35:08] I appreciate that Commissioner Perkins, I feel like we don't have a common base of understanding

[1:35:19] yet around system need, organ need and that you are correct. Well, this is not a cost allocation

[1:35:28] docket, this will be, this is the opportunity to build a common understanding of that need.

[1:35:38] With that, Jim, you're welcome to pitch in.

[1:35:46] Yeah, thanks, Chair Tony. So there's a lot there, maybe just to kind of break this out into

[1:35:51] sections here starting with Randy's original comments and again I appreciate

[1:35:58] Pacificoors input on these very complicated matters but but but I I agree with

[1:36:05] with the dyes in terms I think we are returning to this talking past each other

[1:36:09] so for example R&W is not implying or arguing that policies like SB1547 has

[1:36:19] no impact on system reliability.

[1:36:21] We agree with that statement.

[1:36:24] What we're saying is, because of this lack

[1:36:27] of this counterfactual, where we ignore all environmental

[1:36:30] policies, regardless of the location,

[1:36:32] and just look to see what the system would need.

[1:36:35] Both PACIs and PAC West were purely reliability only reasons.

[1:36:40] Without that, we don't understand what those cost

[1:36:42] differentials are, or those resource differentials are.

[1:36:45] And so we can't have a baseline to then understand these incremental impacts of these jurisdictional

[1:36:53] policies that are not reliability related.

[1:36:58] So a framework that would allow for this layering on of state policies would provide that information

[1:37:07] to parse out what amount of resources are going to be needed regardless for reliability.

[1:37:13] And then what's that incremental resource that's going to be needed just for the state-led

[1:37:20] environmental policies?

[1:37:21] So I think that's our first point of disagreement there.

[1:37:24] Second point of disagreement.

[1:37:26] Randy had mentioned that Renewable Northwest along with many other stakeholders are advocating

[1:37:32] for the system-wide approach, but that system-wide approach is impossible to conduct given these

[1:37:37] diametrically opposed constraints that they would need to implement in the model.

[1:37:42] While we agree that this is a very difficult and complex process, we disagree with the premise

[1:37:50] that that's not feasible to do these system-wide runs and to incorporate this system-wide

[1:37:55] run into a framework to identify if any savings are on the table to be distributed across

[1:38:02] all specific core customers when you do a system planning on a holistic basis compared to

[1:38:09] And what the cost would be when you have to do this siloed approach as you layer on these

[1:38:14] individual state policies.

[1:38:16] So again, there's a talking past one another here in terms of we're not saying the system

[1:38:20] wide approach is going to be necessarily the most opt or present a large bucket of savings.

[1:38:28] It may not.

[1:38:29] But at least we have the information to see is there any synergies across the system to where

[1:38:35] we can then distribute those savings accordingly so that Oregon is still paying for its specific

[1:38:42] cost premiums associated with these environmental policies, like SB 1547 and HB 2021, but there

[1:38:50] might not be as much of a cost penalty due to the system-wide savings that we could identify

[1:38:54] with such a run.

[1:38:56] So that's the second point of contention there, and I do think it's possible to evaluate

[1:39:01] the feasibility of implementing some sort of framework that would accomplish this.

[1:39:06] So just for clarification, R&W hasn't proposed the framework.

[1:39:10] We have a framework in our heads of what we think could work.

[1:39:14] What we're asking for is specific or work with state holders to essentially evaluate this

[1:39:19] sort of framework.

[1:39:20] To see, like, is this feasible?

[1:39:22] And if not, what is the actual thing preventing this sort of framework from being implemented?

[1:39:27] It could be from a practical standpoint.

[1:39:30] Jim, these requires a significant number of additional runs.

[1:39:34] These runs, each one of these runs will take x number of hours

[1:39:37] just from a kind of to operationalize this sort of approach

[1:39:41] with all the portfolio variants.

[1:39:42] It's not feasible.

[1:39:43] We would be running studies for six months out of the year.

[1:39:47] We won't know where we fall on some of these things

[1:39:50] until we at least have that conversation

[1:39:53] of what we think would be a more complete,

[1:39:55] more fair framework until we can work with Pacific or another stakeholders to propose such

[1:40:03] frameworks to identify the strengths and minds of each approach because everything has a trade-off.

[1:40:09] And then the last point that Randy had mentioned was none of the stakeholders had brought these

[1:40:13] concerns during the public input meetings. I don't feel I have to fail at the fair comment.

[1:40:18] One, primarily because we were actually trying to understand this problem during the public input

[1:40:23] with stakeholder meeting.

[1:40:24] Getting access to the Plexus file really helped us

[1:40:27] diving to the details to understand

[1:40:29] how these constraints are set up because it's really crucial.

[1:40:33] And until we could get into that file,

[1:40:36] we didn't have, I personally didn't have

[1:40:39] a complete understanding of what was going on.

[1:40:41] We submitted multiple public stakeholder feedback forms

[1:40:44] to try to get at it.

[1:40:45] And some of those were helpful,

[1:40:46] the response that we received from Pacificoor,

[1:40:48] but it was still incomplete responses.

[1:40:51] And we never could get a true accurate and complete understanding of how the model was

[1:40:57] actually set up until we got access to the file.

[1:41:00] So rather than just try to put comments out there that may or may not be modically

[1:41:06] valid from modeling standpoint, R&W really wants to understand the problem first and then move

[1:41:11] forward with our comments.

[1:41:14] Transitioning to the comments made by Zachary, I believe it was, I'm going to sound like a

[1:41:20] broken record here but again we're talking past each other. I think Zachary with all

[1:41:24] the respect fundamentally misunderstand the points that we're trying to argue here.

[1:41:29] In these counterfactual studies we're not saying that a resource identified as a system

[1:41:35] need would be physically built. We're just trying to identify what the cost associated with

[1:41:40] that counterfactual study would be to be going to understand the cost premium once we layer

[1:41:45] in the actual resource build with the environmental constraints activated.

[1:41:50] So we're not saying goal build stuff that you would otherwise if Oregon wasn't implementing

[1:41:55] these policies, and then we're going to build stuff on top of that, we're not advocating

[1:41:59] for that at all.

[1:42:00] We're just trying to identify where the overlap is, so we don't have to commit any over

[1:42:05] build.

[1:42:06] And if there is some benefits here, all stakeholders can share in those cost savings.

[1:42:10] And then the last item around the energy efficiency, that's great to know in terms of clarity.

[1:42:17] But again, this is just another example in which pacificor presents confusing and sometimes

[1:42:24] incomplete information in their IRP or another official proceeding of documents.

[1:42:30] And until we actually comment on those, then we get additional clarifying information.

[1:42:36] And, you know, one can reasonably assume that if we're looking at just a existing resource

[1:42:42] only load and resource balance, you would not expect to see a significant increase

[1:42:46] in energy efficiency unless there's some specific reason why that would occur.

[1:42:52] Otherwise, it's fair to assume that the model would be selecting that to occur, which again

[1:42:56] would then fall into that proxy resource.

[1:42:58] So just another example of how it can be very confusing and difficult to truly understand

[1:43:04] what's going on the Pacific or side offense and that trust issue there that you guys had mentioned,

[1:43:09] I think is very much in a perceptive comment and until we can continue to work through these

[1:43:15] problems, we're going to I'm afraid continue to talk past one another. So I was a lot and I'll stop

[1:43:20] there.

[1:43:23] Thank you. Any follow-ups colleagues with with Jim?

[1:43:32] I appreciate the comments and Randy

[1:43:37] And folks, I'm going to just say if you want to comment on noting the time, if you want to comment on the issues on the agenda and for in particular put your hand up, I think we will pivot to the CEP conversation here because that's really important by sort of 1130

[1:43:59] because I want to make sure we have time for that for folks to raise issues there.

[1:44:05] Randy.

[1:44:08] Thank you, Chertani. Let me get my hand down out of the way. Yeah, Jim,

[1:44:15] I appreciate your comments and I think that our conversations, consultations,

[1:44:20] had been very fruitful. I agree that access to the database has been critical to

[1:44:27] moving the conversation forward. But I would like to point out that this too is a new paradigm.

[1:44:34] The complexities in the planning environment that we currently live in has been driving

[1:44:41] Pacificoors IRP in certain directions for a long time. In the 2023 IRP, we made a huge drive

[1:44:50] for transparency in our workpapers and made more of them public than we ever had before. We continued

[1:44:56] that the 2025 IRP we

[1:45:00] We have had increasingly complex modeling issues. We've made a concerted effort to talk about every single critical subject of the 800-page IRP document during the accelerated and expanded public input meeting series. And we incorporated all of our stakeholder feedback forms with links to various topics throughout the document in the 2025 IRP. And I just say that to point out that,

[1:45:29] But, you know, this is a new area in terms of the need for all of these steps and efforts

[1:45:38] and increasing the transparency of the IRP document and all the data that goes along with

[1:45:44] it.

[1:45:45] You know, supplying the database, that's a pretty new thing.

[1:45:49] You know, we've been working with Washington on that for a while, we've had some struggles

[1:45:53] and some challenges, I'm not sure what use everyone gets when we supply the database,

[1:45:59] which we've done several times now, I think Jim has made more use of it and his folks at R&W

[1:46:06] than anyone that we've ever seen. And that's fantastic, but I want to point out that

[1:46:11] that in and of itself is a new paradigm that we're now existing in to share and discuss and move

[1:46:19] through this information.

[1:46:22] You know, if the database had been, you know,

[1:46:28] if it was available at the beginning of the public input process,

[1:46:30] we would be in a whole different world right now.

[1:46:33] I'm not so sure that from the perspective of specific course attempts

[1:46:39] to be open and transparent, I'm not so sure that we are passing

[1:46:44] each other as much as it might appear.

[1:46:47] I think really we're reaching clarity about where our fundamental differences lay.

[1:46:51] And we're certainly happy to have those discussions.

[1:46:54] We were recently invited to have a conversation with various stakeholders on the 2025 IRP

[1:47:04] update and what might be done looking forward to address issues with the modeling.

[1:47:09] We're open to hearing those ideas and we're open to working with those ideas.

[1:47:13] So I just wanted to make it clear that that's the case.

[1:47:18] You know, there's no, there's no attempt here, frankly, to make the lives of myself, my team, or the company more difficult by not running analyses that could potentially be run.

[1:47:36] that's not what's going on. What's going on is, you know, we have a definite set of intentions and purposes in how we model and how we move forward.

[1:47:46] And we're being asked to do things that we have never been asked to do and we're accommodating them, frankly, as best we can.

[1:47:54] You know, so we do have some fundamental disagreements that if resolved one way or the other may give you a different result or an interestingly different result or may not that's yet to be seen.

[1:48:05] You know, I've not seen any, all of the evidence on being able to run the real holy grail

[1:48:14] of a modeling attempt that integrates everything simultaneously, all of the evidence so far

[1:48:20] has been negative and have not seen anything to the contrary.

[1:48:24] That's not Randy, and I don't think I'm not for when seeking that holy grail.

[1:48:29] Well, I think I am always looking from an IRP, for an adaptive decision-making process

[1:48:37] with that tells us directionally important information.

[1:48:44] And so I, for one, in terms of engaging with the IRP over the years,

[1:48:50] have not been very

[1:48:52] interested in, is it, you know, is it 10 megawatts this way or 10 megawatts that way?

[1:48:55] this is all directional from my perspective. I'm curious, I am, so we've had some

[1:49:03] conversation about system-wide, East Side being reliable. If we stripped back 1547

[1:49:15] and 2021, would the West Side be reliable? I can't tell, and I think that's part

[1:49:22] of sort of not knowing whether we're headed into a physical operational problem or whether

[1:49:34] we're headed into a policy compliance problem. I can't tell which I'm headed into and I, as a

[1:49:44] regulator would address those differently, right? Is there a way you can help us? Maybe

[1:49:53] and maybe this is a request for reply comments. In your reply comments, clarify for us whether

[1:50:00] we're headed into an operational problem or a cost allocation policy compliance problem.

[1:50:08] Right. And that's an excellent point. It really is. And, you know, often when we start the IRP,

[1:50:15] you know, we're looking at it from a perspective of what does it look like all in

[1:50:19] under different sets of circumstances? Sure, of course. Yeah, yeah. So, I mean, I appreciate your

[1:50:25] understanding of that. And, you know, to the extent that we didn't run a study that would be very

[1:50:32] informative for the purposes that you're describing? Yeah, I can't all by myself sitting

[1:50:40] here make a commitment for the team, the company and our priorities, but I'm very interested

[1:50:45] in that. I would certainly like to do that. And I think we're going to take a serious

[1:50:48] look at, you know, how we reply to those comments and see if there's anything that we can

[1:50:54] add. And it, you know, what kind of analysis that might be, you know, I also can't commit

[1:50:59] to sitting here at the moment, but we're considering it. Certainly, our focus has been on

[1:51:07] our newly initiated public input meeting series for the 2027 IRP and planning for the

[1:51:14] 2025 IRP update and what we can accomplish ahead of that. But in the more immediate sense,

[1:51:21] certainly, there might be something that we can do that would help give confidence and comfort.

[1:51:30] Um, I'd like to pivot to the CEP conversation, but colleagues, is there anything you want to put a pin on or say as we, as we sort of exit the constraints, jurisdictional modeling?

[1:51:44] Haven't talked as much about transmission.

[1:51:46] I just want to echo your distillation, I think, of the complexity right here, and support

[1:51:59] that request that you made.

[1:52:03] Yeah, I would agree fully, and when I think about the six-date system that you serve, I

[1:52:12] can't imagine that this wouldn't be useful information for all states and regulators and

[1:52:17] policy makers, just being able to understand kind of the underlying impacts of how the system

[1:52:25] would operate without constraints, how the system operates with constraints. I think

[1:52:30] that baseline information is so helpful for everybody to understand the reality of the

[1:52:36] world and to look forward as new changes and new policies are considered and, you know, fuel

[1:52:43] prices change and all the different pieces change. But I just think it's really important

[1:52:47] for policymakers and for regulators across the statistic whether you're in Utah or you're

[1:52:52] in Oregon. I think it's important.

[1:52:56] Yeah, I really agree, I think, colleagues across

[1:53:01] the West are really curious what the cost of Utah's decisions on Huntington are. Those are

[1:53:08] plants that aren't, you know, maybe, maybe you're necessary for reliability

[1:53:13] perspective, maybe art, who can tell? And so it creates a real challenge. Okay. Let's pivot

[1:53:23] to the CEP discussion. That has not come up as much. It's a Renewal Northwest slide deck didn't

[1:53:33] raise it as centrally. I'd love to see a show of hands on anyone who'd like to talk about the challenge there.

[1:53:45] You know, I think in particular as we, while we have not

[1:53:51] crystallized how we're going to handle a cost cat proceeding, having so little agreement around

[1:53:59] And what is being driven by policy versus driven by simple load growth and reliability is

[1:54:11] port 10's real challenge.

[1:54:15] Okay, I'm not seeing hands, I'm a little bit surprised no one wants to talk about the

[1:54:19] CEP.

[1:54:22] Fred?

[1:54:24] Well, thanks, Chair.

[1:54:25] Tommy, I'll venture to dive in on this.

[1:54:28] I think there's a complex overlap, like everything's complex, between the quantitative aspects

[1:54:36] we've been focusing on, the qualitative aspects of the CEP in terms of continual progress

[1:54:42] and a lot of the other issues that are addressed in the comments that we signed on, along

[1:54:47] with the advocates.

[1:54:49] So I won't try to cover everything, but I just want to give some basic impressions from

[1:54:54] what we've been saying.

[1:54:55] The first thing is that the continual progress issue has been impeded by PACS decision to cancel the 2022 RFP.

[1:55:06] And there are lots of aspects to that.

[1:55:09] You know, here we are.

[1:55:11] I don't want to say it's what are under the bridge.

[1:55:14] There are some things we can do about that.

[1:55:16] But there's no question this is created a real crunch in where we are now at.

[1:55:21] So the question of continual progress also then has other implications, for example, on the House Bill 2021 cost threshold, which is being discussed in other matters before you.

[1:55:39] And the current issue I think a lot is how much of the expiring

[1:55:46] wind and solar tax credits can be captured for projects that will be built

[1:55:51] or should be built no matter what, even under what we consider to be an

[1:55:55] underpowered 2025 IRPS it now stands.

[1:55:59] And that's got a ticking clock eye for sure.

[1:56:03] What efforts can be made for Oregon under the Oregon Cytus RFP and for the other Washington

[1:56:11] Cytus RFP and for potential action by Pacificoor in the East UIUC area where our colleagues

[1:56:20] at Utah clean energy and others have really pushed forward that idea.

[1:56:25] I think there's a lot more that can still be done and shall I also mention the governor's

[1:56:29] executive order.

[1:56:30] So those are all in this world here around this planning prospect that has a kind of current action component right at this moment.

[1:56:40] So we want to reflect that we're not going to be able to solve everything but we still have some opportunities.

[1:56:48] And the other point to make, I think to underscore with Renewable Northwest is brought forward on the need for stronger guardrails around the action plan.

[1:56:57] to help guide things more directly so that we don't end up in this kind of situation again.

[1:57:05] So those are broad comments on the kind of overview and the continual progress issue.

[1:57:12] I do want to mention a couple more things from our detailed comments just to put this in the record.

[1:57:18] First, in the area we discussed is that the CBRE effort is looking like a very important

[1:57:25] thing that we can do going forward, but we believe that the company's effort there

[1:57:30] should be more robust.

[1:57:32] Secondly, there is additional refinements that we detailed in our comments and in support

[1:57:38] of the CBI as a community benefit indicators.

[1:57:43] And finally, and I think this is again practice and broad issues facing the commission and

[1:57:47] all of us as well as the company additional modeling to help and survey work and so forth

[1:57:53] to help inform and deepen our view, our understanding of affordability and energy burden

[1:58:01] faced literally right now by Oregonians and by Pacificor customers. So there's kind of

[1:58:06] general comments. I hope that's helpful.

[1:58:11] Thanks, Fred. I appreciate it. Nick.

[1:58:19] Thanks.

[1:58:20] Sure, Tony, let me just see if I can come on video here.

[1:58:24] Oh, it doesn't look like it. Well, anyway, um, yeah, I just

[1:58:27] might be able to turn you on. I think she had to turn you off earlier. So

[1:58:31] Oh, thank you. Okay. Um, well, maybe just to kick it off, I

[1:58:34] appreciate you raising the CEP issue and I do acknowledge this is not been the

[1:58:39] focus for R&W in this cycle, given how deeply we've been engaged with the

[1:58:43] IRP and just the sort of nature of the CEP coming out later in the process

[1:58:47] with somewhat limited time. Our focus is really been on making sure, just like in the 23-a-RP,

[1:58:54] we have the need identified. I think we'd like to see action in the form of procurement

[1:58:59] to actually get us on track there. So we know from the IRP and the CEP,

[1:59:05] their substantial need for nuclear energy resources, we know that that's likely under-accounted,

[1:59:09] given the exclusion of large loads, which tend to have high utilization, high capacity factors.

[1:59:14] so that's going to drive more energy requirements and higher HB 2021 requirements.

[1:59:19] We're interested in getting a better understanding of the analytical framework used in the CEP

[1:59:25] to be candid in both the stakeholder meeting and in our follow-up review of the documents provided.

[1:59:31] I think we've struggled with just understanding some of the basic elements of the analysis,

[1:59:36] some things where costs seem to be sort of inverted in magnitude.

[1:59:40] So I think we look forward to diving deeper into this as we go forward, but our focus is really on getting movement on the substantial need identified.

[1:59:48] I think I don't anticipate in either the IRP or the CEP, we're going to get a precise value there, which is an issue in its own as we've discussed, but want to make sure we get movement and some guardrails.

[2:00:00] Just to keep those projects moving forward.

[2:00:04] So I'm hearing from you, sort of directionally, we have what the marching orders are clear. And so the value proposition of trying to really dial in the CEP is important, but somewhat lower than making sure that move forward momentum is accomplished. I think that's right. And not that the CEP

[2:00:31] as a process isn't important on its own, but just to triage our engagement with the limited time

[2:00:37] and the issues we've identified in the IRP, we've just not spent as much time there,

[2:00:41] and I think while we should collectively get that to a place where it is really meaningful,

[2:00:47] I don't think we're going to do that in time for action or action item review in the commission's

[2:00:54] therapy process. Okay.

[2:01:00] Other perspectives or anything else as we come up towards 12,

[2:01:07] anything else folks would like to highlight for us

[2:01:13] and colleagues I'll turn to you for

[2:01:15] some closing thoughts as you for folks to take away as they continue with this process.

[2:01:22] else. Anything anyone else wants to highlight to us or raise other issues?

[2:01:39] I want to recognize

[2:01:40] staff has been quiet, but I know that's because this is an unknown and other than contested

[2:01:45] case and we can consult with staff and hear their thoughts, so I appreciate that they've

[2:01:53] been making space for other folks in this conversation. Rose, Sierra Club, good to see you.

[2:02:02] I know I've been quiet during this proceeding. I haven't wanted to be repetitive. I guess

[2:02:06] I will just say for the record that we agree with Renault-Wenoros-Quest analysis and raise

[2:02:13] a lot of our own concerns and comments that I don't want to repeat here. I think the one piece

[2:02:18] that I did want to lift up on the CEP and continual progress, which we did put into comments

[2:02:23] is, you know, I think what we see in the emission reduction projections is this just in time strategy that, you know, all the stakeholders in the commissioners have spoken about before.

[2:02:36] You know, we see pretty steady emissions and then a really significant drop and that is a result primarily from Pacific Corps cancellation of the 2022 RFP and then not moving forward in 2024.

[2:02:49] just the reality is that at this point to get resources online to reduce admissions, that's what it looks like.

[2:02:57] But HP 2021 requires continual progress.

[2:03:01] And if you don't see any movement in the years up until 2030, I think it's harder to square that with the plain language of the statute.

[2:03:08] And so I think there are other things that civil corporate should be doing in one way for the commission to help ensure the continual progress is met is to provide some guidance on the

[2:03:18] expectations. You know, we listed out a number of actions that the Civil Court might take between

[2:03:26] now and 2030 in addition to their 2025 RFP and just to highlight a few. I mean, we don't have

[2:03:33] any update on plans for a 2026 RFP that has been required as a phase two. PGE issued an open call

[2:03:43] for proposals for resources. We could see the Civil Court do that. And then we also highlighted

[2:03:48] leaning into demand side resources, potentially issuing an RFP for a virtual power plant.

[2:03:55] So I think all solutions need to be on the table and we would like to see a lot more from

[2:04:00] the company than just a single RFP that if it's not successful, really puts compliance in high

[2:04:06] risk of debris. So thank you. Thanks for that. I'm curious how you think about the intersection of

[2:04:16] 1547, right, taking as a given, the DEQ compliance is measured on a cost allocation basis.

[2:04:29] And 1547 drives a very particular shape around cost allocation on the coal fleet,

[2:04:36] given that we haven't actually ended up setting up any early exits and so on,

[2:04:44] which I think is probably good because we're at least engaged in the coal plants' discussions.

[2:04:50] I don't know that early exits would have actually served the decarbonization conversation very, very well.

[2:04:57] But, you know, how much of that sort of step change is online dates versus sort of an art effect of how 1547 is changing cost allocation.

[2:05:12] How should I, how should I think about that interplay?

[2:05:16] Yeah, I think that's a tough question.

[2:05:20] You know, what we play into comments is there is an exit from the coal plants,

[2:05:25] and that's under one law, and then HB2021 obviously has the continuum of progress requirements.

[2:05:30] And when you're only considering, okay, in 2030, we have to immediately exit.

[2:05:35] That does create that step system.

[2:05:38] We and others have advocated that there needs to be an ongoing emission constraint included in the modeling that would drive a more steady exit from the remaining resources.

[2:05:51] And if that had been included in a portfolio that was looking at HB 2021 compliance, you would see what resources are needed to have a steady or smoother exit from the thermal resources.

[2:06:05] There's been a discussion today about, you know, where does Oregon sit within a multi-state

[2:06:12] system?

[2:06:13] And this is a very tricky issue.

[2:06:16] I think that it's very valuable, not only for Oregon, but also for the East Side States

[2:06:22] to see what a portfolio looks like when HP 2021 is incorporated into full system modeling.

[2:06:29] And I know that there's a lot of conversation about other states don't want their resource

[2:06:34] decisions to be driven by Oregon's policy.

[2:06:37] But I think if you see that full system, there's going to be a lot of synergy that we know

[2:06:42] one of our first was talking about earlier.

[2:06:44] And then you can sort of pull out what are the changes in the resources that would have

[2:06:49] been used and assign those excess costs to Oregon.

[2:06:53] But to, you know, be very direct on this when I am saying is that the full system,

[2:06:58] So portfolio should allow Oregon's state policies to drive co-plant retirements across

[2:07:06] the system, so that we can see what that looks like for the whole system.

[2:07:12] I appreciate that.

[2:07:14] I would agree that our Idaho colleagues might want to see what the Utah Colessee is costing

[2:07:22] them, for example, but I appreciate that.

[2:07:27] Any questions for Rose?

[2:07:32] No.

[2:07:33] Okay.

[2:07:34] Thanks so much.

[2:07:35] I appreciate the rigor you all bring to the Thermal Fleet conversation and half over

[2:07:42] the IRP years.

[2:07:44] Randy.

[2:07:49] Thank you, Chair.

[2:07:50] I just wanted to say, at this time, in case the opportunity doesn't come up later,

[2:07:56] that staff has been pretty quiet and Rose has been fairly quiet up to this point.

[2:08:01] But I just wanted to express appreciation for two things.

[2:08:04] One is that we've had some very candid conversations with staff

[2:08:09] that have been helpful and logical

[2:08:11] and help to clarify matters, not just RMW,

[2:08:16] but I wanted to acknowledge that as well.

[2:08:18] And also, Rose, we do appreciate the outreach

[2:08:23] to have more discussion and hopefully greater clarity

[2:08:28] around what happens for the 2025 IRP update, which of course, you know, is a platform moving toward

[2:08:34] the 2027 IRP. So, just wanted to say that. Thank you. Thank you, Randy. I appreciate that.

[2:08:42] And I do appreciate that Pacific Corps is investing time in this stakeholder dialogue.

[2:08:53] We're still struggling to hear each other, but I appreciate the time that your team is investing in that.

[2:09:01] Well, with that, colleagues, I think we've heard from the stakeholders.

[2:09:05] I'm curious or would open the floor to anything you'd like to wrap the morning up with.

[2:09:12] Marching orders to send our stakeholders off with, perhaps,

[2:09:21] Commissioner Perkins?

[2:09:25] Yeah, I think we're going to take away from today.

[2:09:28] I've got to figure out how to stop talking past each other and come to a place where we can

[2:09:34] derive some information fairly quickly that allows people to get comfortable with

[2:09:41] or at least better understand the basis of this IRP

[2:09:46] and what sort of course is putting forward.

[2:09:49] What I don't wanna have happen is that we have this long process

[2:09:52] that ends in an outcome, it isn't good for anybody.

[2:10:00] This needs to be a process that allows us

[2:10:04] to better understand what our future might be

[2:10:06] and the decisions that we can make.

[2:10:07] So I just hope we can come away from this and get some information on the table that helps us get there for both the CEP and the IRB.

[2:10:21] Thanks commissioner power.

[2:10:26] I think I'll echo Commissioner Perkins comments but also note I think for me this is a significant deviation as I understand it from.

[2:10:37] previous plans. And on top of that sort of a siloed approach to build upon that in out years,

[2:10:43] we'll leave us with less and less information about whether

[2:10:48] procurements are strategically and the best interests of our customers here. So do hope that

[2:10:53] parties are able to get to new dialogue about coming to some common scenarios so that we have more

[2:11:02] information before us as we continue to evaluate this planning document.

[2:11:11] Appreciate that.

[2:11:14] I would add to those important points, the cancellation of the RFP is what

[2:11:30] it is. It is gone to Fred's point. It is water

[2:11:34] enter the bridge at this point. The company made a set of traces, business decisions that it felt

[2:11:41] were right in the moment and we have not had a venue to sort of adjudicate the prudence of those

[2:11:47] decisions per se and I, you know, there's a range of perspectives on why we got where we ended up.

[2:12:00] I think from my perspective, the really important question is, what do we do from here?

[2:12:13] And in that sense, I have very practical questions, am I facing an operational problem

[2:12:25] on-packed in-packed West, if I am, what constraints are driving that? And what is the procurement

[2:12:34] that solves that?

[2:12:38] Am I facing, then on top of that, a different gap driven by state

[2:12:45] policies, some of which have pacing elements like the cost cap or the reliability

[2:12:55] pos that I will that I will need to have some foundation for the three of us to

[2:13:04] adjudicate and so while the company I understand why you want the

[2:13:14] all in solution.

[2:13:19] Those we have learned, for example, in 2019, when you did so much extensive work,

[2:13:28] demonstrating where and when the cold plants had value, and where and when they didn't,

[2:13:33] you learned a lot. We learned a lot. There was a host of cold plants. We could all stop arguing about

[2:13:39] and some co-plants we could have a much more informed argument about.

[2:13:46] So I'd really encourage you to listen for the underlying

[2:13:57] difference of perspective and try to speak to that from the stakeholders

[2:14:04] because if we can't build that common foundation, that common understanding

[2:14:08] of our position operationally from a policy perspective and from a cost allocation perspective,

[2:14:17] we're going to continue to just really struggle to take decisions that are constructive

[2:14:25] and feel good about them and be able to justify them to the larger world.

[2:14:33] and so I'd encourage you to really take an approach as you did in 2019 around those coal

[2:14:43] plant analyses where you really lean in and you learned a lot about the economics of

[2:14:53] your cold, cold fleet and really capture a lot of value.

[2:15:00] Thank you for customers. As opposed to how you dug in on the gateway south modeling, and we still have a dispute about the value of that line. I think this commission's really demonstrated an openness to learning and taking in new information and taking hard decisions when justified. But we need you to help us get to that place. And you've done it before. And so I know you have

[2:15:29] the institutional capability to do it. I have a lot of confidence you can do it.

[2:15:35] And so I look forward to seeing that in the reply comments. And I really appreciate stakeholders

[2:15:40] willingness to be pragmatic, triage, focus on what's achievable, and while holding out the

[2:15:50] aspiration and holding us accountable to the aspiration in the state policies

[2:15:58] being very pragmatic about what's in front of us right now. I really appreciate

[2:16:03] that. It makes the conversation much more productive than it could otherwise be.

[2:16:10] So with all of that, I want to appreciate everyone's time this morning and the

[2:16:16] comments you've provided so far and the comments that I know will get as we head

[2:16:22] into the final phase of looking through this IRP and dealing with it so that we can deal

[2:16:31] with the update, which will come hot on its heels.

[2:16:35] So is there anything else to come before us this morning, anything else that we need to

[2:16:40] address?

[2:16:44] Okay.

[2:16:44] Seeing nothing.

[2:16:46] I send everybody off to catch a little bit of a walk in the sunshine before we take up

[2:16:53] For our next business in the afternoon, all the best, we're adjourned.

Special Public Meeting LC 85 PAC 2025 Integrated Resource Plan

Agenda

Transcript