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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

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sort of working through the content today.

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It's clear from the comments a great deal of content

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where I anticipate we'll go until 12 today.

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And we'll hear from Renewable Northwest first.

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They've provided a slide deck and then after they've presented,

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I'll invite the company up with any response they'd like to have.

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

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as topics that I would love you to speak to.

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We'll raise hands and sort of have a dialogue, workshop, style around each of those.

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And I'll ask folks to keep their comments sort of crisp given the scale of content

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and how fast noon will arrive.

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And I'll add that at 10-16 the great

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to shake out Oregon's great shake out

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will happen.

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And I anticipate everyone's phones

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to sort of lose their minds for a minute.

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And so we'll pause then.

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We won't try to talk through it and let that play out.

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And then come back.

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I'll just encourage you.

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It's a good opportunity to stop and think about

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whether you have a safety plan with your loved ones and how you would evacuate

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and so on and so forth. These drills are important opportunities to check in on

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whether we are as prepared as we could be and what actions we might take this

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weekend or over the fall to get better prepared. So with that, let me turn to my

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colleagues if you have any opening comments around the content what you'd like to hear from

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stakeholders today?

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I can jump in. So I just want to thank everybody for being here today and

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

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gone into this process by the company, staff, and stakeholders.

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But I do come into today very concerned about the value coming out of this IRP, not in

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terms of the analysis and input from parties, but from the lack of usable information for

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the commission, staff, stakeholders, and most importantly, the company.

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And IRP should help us all see the ways the future might unfold, and how the company intends

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to respond.

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The scenarios modeled and considered should give us insights that help to mitigate risk to

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both the company and the customers.

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

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to me as a regulator, but should be even more frightening to the company.

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I find it very hard to believe the company would put itself at risk in so many ways by

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leaving itself blind as to how the six-state system operates as a whole.

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I fully recognize the complexity and inherent difficulty in modeling the specific course system

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in the very policy landscape within that system.

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But that is what large and sophisticated companies do every day in order to be successful

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in the landscape within which they operate.

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So my hope for today is that we can find a way

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to drop the posturing and positioning around the politics

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dividing the states that the company serves,

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and find ways to salvage this IRP

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by making clear requests for information from the company

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that can be achieved in the time we have,

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so that we can actually see how Oregon fits

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into a specific course entire system

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and stop pretending that Oregon functions in isolation.

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To come away with anything less,

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we'd create massive risk for the company and customers.

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Thank you.

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appreciate that clarity. Commissioner Power. Thanks,

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Tritani. This is one of my first IRP sitting in this driver's seat. And

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understanding it represents a pretty significant departure in a few ways from

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previous assumptions. I think I'm hoping are meeting this morning pressure tests

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those assumptions with feedback from stakeholders. And if this is a building block upon which we build

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our future work, as I hope to serve on this commission for some time, does it provide our staff

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in the public with a level of interconnected transparency and recognition of past investments

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

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So those are the items I'm looking forward to discussing today.

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Thank you.

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I have been through several IRPs and this one I can attest is different.

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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.

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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.

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

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It's the core of what we need out of an IRP.

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

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and offered a slide deck to take us through their concerns.

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And so, Kristie, if you could bring that up.

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Thanks.

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All right.

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I'm happy to get us started.

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Good morning, Chair Tawny, Commissioner Perkins, and Commissioner Power.

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My name is Katie Chamberlain, and I'm the Regulatory Manager with Renewable Northwest,

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a Regional Clean Energy Advocacy Organization.

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I have with me Mike Getz, our Regulatory Affairs Director,

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Max Green with Sanger Green Law and formerly staff with Renewable Northwest and our team

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of technical consultants who will introduce themselves as we get into the presentation.

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First I want to thank the Commission for the opportunity to present at this workshop

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on Pacific Wars Integrated Resource Plan and Clean Energy Plan. Renewable Northwest has

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been engaged in Pacific Wars IRP development process and in the Commission review process

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

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access to their modeling file, which has allowed us to better understand how the company sets

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up its modeling ecosystem, the inputs and assumptions that are driving outcomes, and the challenges

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that are unique to planning for a six-state system with diverging policy priorities.

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next slide please. Our presentation will focus on our concerns coming out of the 2025 IRP

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and our recommendations for how to move forward in a complex planning environment as we've acknowledged.

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And with that, I will pass it to one of our consultants, Nick Popus. Thank you.

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Thank you so much Katie. Good morning Chair and commissioners, really appreciate the opportunity

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be here and present on our perspectives today. I've been involved as a technical consultant

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through Noble Northwest for I think three cycles if we count the 23IRP update and want to

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bring some historical context as we work through some of our recommendations, some of which flow

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

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and probably much more ground than we can cover today, really appreciate the comments from the

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this morning, which I think will influence where we emphasize our discussion today,

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and I think resonates strongly with some of the concerns that we're going to bring forward.

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We're going to kick things off with an overview and landscape for where the IRP is coming

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from, from a market and policy landscape, transition into a discussion of technical concerns

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around the modeling ecosystem, and then bring those back to some of our policy recommendations

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and link how the analysis informs the policy considerations and vice versa.

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I am going to breeze through quite a few of these slides.

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We wanted to be comprehensive in case there's questions or discussion,

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but we're going to really just try to emphasize some of the key points as we go forward.

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Let's transition to the next slide, please.

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Just to provide a little bit of context, the 25-IRP presents a landscape

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which has tremendous resource needs across the Pacific Warp system, certainly in PAC West,

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but that's true across PAC West and PAC East.

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As we're going to get into that need which is identified here while substantial is not

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a complete picture given the exclusion of large load customers from the IRP which we see

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as a critical missing data point for the commission to be able to make an informed decision about

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needs for organ customers.

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We're also in a landscape where the region as a whole is in a shifting supply demand balance

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we see rising scarcity in the West and the longstanding strategy for PAC West and organ which

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

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

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That alone drives a tremendous reliability need which we're going to get into in coming slides

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But in combination with organs state energy policies in age between 2021

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One, we have a really aggressive procurement landscape on our path to 2030.

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Much of the need was identified in the 23IRP and previously, but following the 22RFP cancellation

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and other delayed and deferred procurement, we're really starting a little bit behind

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the eight ball in terms of launching our way to 2030 and a lot of our recommendations are

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going to discuss how we can make sure that this IRP leads to more successful procurement

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as we go forward.

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I'm going to keep us moving and just jump into our policy recommendations on the next slide

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before we pivot into modeling. We're going to come back to these throughout the presentations,

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but to give you a sort of general sense of the advocacy perspective we have in the 2025 IRP,

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

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with the RFP, but also building in some guardrails so that the RFP can be successful and actually

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get sufficient resources to meet Oregon's resource needs both for current and expected

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future loads, which are not currently in the plan.

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And there's also some significant urgency to go out and pursue contracts that may be

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eligible for the expiring IRA tax credits.

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Wordment to Hemingway is a key asset for Oregon customers.

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

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in the east, which is currently constrained at 1600 megawatts, B2H would increase that

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by 50%.

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We're going to talk about how to keep that in the portfolio and keep that moving forward

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to achieve the massive benefits intended for organ customers.

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And then we want to spend a little bit of time on a witty, but important issue, which is a

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new framework specifically introduced in the 25IRP related to allocations between resources,

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which we see as conflating reliability and clean energy policies and allocating a tremendous

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this reliability need exclusively to Oregon's state energy policy requirements, which we

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view as both very problematic from a policy precedent standpoint, as well as from a cost

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allocation standpoint, the actual impact to Oregon customers, we think, would be quite

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severe.

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So let's jump into the next slide.

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I'm going to pass it off to my colleague Jim to talk through some modeling concerns from

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his review of the IRB.

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Thanks, Nick. Good morning, Chair and fellow commissioners. My name is Jim Heimlich.

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I'm a consultant with Renewable North West. I have almost 20 years of experience in

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modeling and over 10 years of experience with the energy exemplar pluso software that Pacific

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Core uses for the IRP planning process. Next slide.

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I want to start by just acknowledging

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that Pacific Core faces one of the most challenging planning problems in the West, arguably the most challenging.

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And I also want to credit Pacific Core for their engagement in this IRP cycle.

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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.

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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.

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

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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.

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These practices make it hard to leverage the full capabilities of the underlying software,

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to A, implement needed functionality, and B, reflect industry best practice.

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Some of our recommendations have been adopted by PAC, which we greatly appreciate.

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However, others have been dismissed and present opportunities for continued progress.

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Pacificoors IRP presents a complex problem

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Next slide.

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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.

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year for all the years in the planning horizon. This can also consist of sample

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chronology where we can take a subset of days or weeks to represent the full year

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for modeling computational tractability trade-offs. Why is this important? It's

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important because with the increasing roles of renewable and storage chronology is

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essential to capture the hour-by-hour changes in solar and wind profiles as well as

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state-of-charge of the battery fleet throughout the day. Lack of proper chronological

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sequencing drives heavy reliance on manual adjustments and is likely cause of the poor

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model convergence that PAC continues to grapple with. Just as a quick update, as of the first

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pelvic input meeting for the 2027 IRP PAC did enforce stakeholders that they are actively

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

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right direction. Next, moving on to the constraints and the complex interplay between jurisdictional

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firm capacity obligations alongside state policy requirements.

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Our view is that the current configuration in the model is incomplete and inaccurate

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and warns a change.

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We'll explore this further in upcoming slides.

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And finally, we have methodological errors.

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R&W has flagged approximately two dozen instances of modeling mistakes or questionable practices

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ranging from minor to moderate.

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it. Collectively, these issues limit the confidence R&W has and packs final results.

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For those interested in more detail, I point you to the appendix as well as our round

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one and round two comments which go further in depth.

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Next slide.

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Similar to our previous slide, I don't have time today to walk through each

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one of these recommendations, but I do want to highlight two which book in the range of complexity

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of these changes in compass. Let's first discuss changes that are a bit more straightforward

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forward in nature. For the 2025 IRP update, we recommend Pacific Core

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model the full retail load to capture the complete set of generation and transmission resources the portfolio will require.

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If a separate offtake agreement is under active negotiation to serve this large load with dedicated resources,

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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.

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Now onto the more complex side of things.

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

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However, we also recommend the Commission Direct Staff to develop its own independent modeling capabilities.

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

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open source solutions now exists that would allow for the ingestion of the same input values used in

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pacifical or pxos model and significantly reduce the dual model problem. Outside parties have

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expressive willingness to fund the effort and provide the required personnel and we see today's

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

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take us through the next topic. Thanks Jim. These are really meaty topics. We want to make sure

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we can bring these back to some headlines for the commission and how this informs some

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

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We really appreciate the depth of engagement we've had with Pacificorp. But I think

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

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inform what Oregon needs going forward. I'm going to really quickly breeze through some

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of the policy recommendations. I want to save time for allocations discussion, which

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I think is the most complex and probably least developed.

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So why don't we go to the next slide

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and I'm just gonna go very quickly

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through a couple of our other recommendations.

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I think we'd really like to be in a place where we could say

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we could just lean on the analysis provided in the IRP

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to inform Pacific Corps needs and organs needs.

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I don't think that we're gonna see that now

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or potentially even in the 25 update or 27 IRP.

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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.

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

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concerns with transmission, and the Gemini are going to take us through the allocation protocol discussion

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or the allocation framework in IRP.

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Next slide, please.

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Actually, we can jump ahead to 12.

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Thank you.

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So, just to provide some more context on the resource gap,

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this is a graphic showing Pacific corpse existing resources in the loads and resources table.

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This is across the system.

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We'll get into some of the east-west dynamics and later slides.

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

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This is net of large load customers, which are not included in the IRP.

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I just want to emphasize, and as we included in around two comments,

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

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That's a separate conversation we're happy to get into.

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

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

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Let's go ahead to the next slide

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So a number of our procurement recommendations really emphasize guardrails

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We know there's a substantial need we know from the IRP analysis. There's a substantial need

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we know with large load customers that's going to be even greater, perhaps some of those customers

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

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

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the RFP in a way that ensures specific or procures minimum resources to actually keep the lights on

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in Pack West. This is not a theoretical or compliance framework. This is with Pack West have sufficient

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reliability resources to keep the lights on in a regional scare city moment. So bringing this back

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to the 23 IRP and 23 update, we identified major resource needs, I should say, a specific

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or identified major resource needs in the 23 IRP presented a plan that was going to

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develop substantial, primarily clean energy and storage to build their way out of that gap,

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and then we largely didn't see that layout.

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

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this to the missed opportunity, which as the IRA tax credits go away, assuming we can only capture

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a small percentage of that or a small percentage of forward-looking resources can capture that,

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

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

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really important context as the commission thinks about how to structure and build guard rails around

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

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

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Let's go to the next slide please. And actually let's in the interest of time let's just continue

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on to slide 15 and we'll transition into a very very brief discussion on Boardman to Hemingway.

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Go to the next slide actually. I think folks are fairly familiar with Boardman to Hemingway

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at this point, but I just want to emphasize a couple key points.

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From an analytical framework perspective, increasing transfer capacity between East and West

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is one of the best tools Oregon has in its portfolio to improve Oregon energy policy

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goals, whether the reliability, cost, clean energy, all of these benefit tremendously from

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Boardman to Hemingway.

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This is a line that in that context has been in the works for nearly 20 years and had a billion

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dollars in projected customer benefits.

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I think it is very fair to say that that number is likely much higher in the current

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planning environment than that one billion and this is just I can't emphasize enough how important

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it is to increase transfer capacity between the regions. We understand based on discussions

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of recent public input meetings that Board Meta Hemingway will be completed physically. However,

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the final, the last mile of transfer capacity through BPA from the Umatilla County Longhorn

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and substation to urban load centers in the West, that's where the question mark is.

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And that's, frankly, where a lot of the benefits are for PAC-West customers.

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We understand from Pacific Corp that they plan to utilize this line for bundled load in eastern

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Oregon, bundled load that's not in the portfolio, because we've excluded new large loads, but

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that's our understanding.

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I think rather than get into a long discussion of all the questions I have around this strategy,

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I'll just emphasize keeping this moving towards PAC-West customers existing PAC-West customers

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is critical in achieving those benefits for Pacificorps existing load in Oregon.

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And let's go to the next slide. I'm just going to briefly touch on our recommendations.

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You're the primary action item, I think, for the Commission is to decline to accept B2H

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getting pulled from the preferred portfolio and direct Pacificorps to keep working towards

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getting this redirect and completing the last mile with the transmission redirect from BPA to

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organs, urban loads, load centers. Let's continue moving into the allocations discussion if we can

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

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into the detailed framework and mechanics of how this works. To set a little bit of the historical

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

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system where the costs and benefits of energy and reliability are shared across the six states.

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Under that framework for many many years organ customers have paid for assets in the east

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which do not directly benefit them because they are transmission constrained behind the east west

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transfer constraint and in parallel customers in the east have paid for market purchases that sort

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of Pac-West that fill the gap left by the lack of resources in Pac-West owned by Pacific

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Orb to serve those customers.

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This is just longstanding practice and precedent and is what has enabled the economies of scale

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and efficiencies of that integrated system.

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So that's the context.

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In the 25IRP, we see a new analytical framework for allocation which effectively would keep

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organ customers on the hook for those shared system resources while tagging all of the resource

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need all of the resource costs needed to build Pac-West out of its reliability gap to Pac-West

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customers. In Oregon and Washington, under the guise of framing those resources as policy driven,

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state policy driven, as opposed to reliability resources. I think it's important to acknowledge

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that these resources, which are necessary to improve their reliability situation in Pac-West,

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will likely be clean resources. They will likely contribute HB2021. But as we're going to go into

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

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the massive reliability gap in Pac-West that needs to be filled and under this long standing

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precedent should be filled in a way where the reliability costs are shared across all customers.

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I want to just emphasize we're at a moment where organ customers have financed physical assets

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in the east for many many many many years and in this moment where the reliability costs are

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coming due essentially through RAP and other regional dynamics pack is proposing a framework

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that would leave organ customers essentially out to dry after that longstanding practice

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of sharing these energy and reliability costs.

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So, I'm going to kick it over to Jim to take us through the specifics on the mechanics

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of this framework, which knowledge are complicated, but Jim, I appreciate you distilling these

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in a simple, available way as we can.

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Thanks, Nick.

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Next slide.

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So, just before warning, this conversation is a bit heady from a technical standpoint,

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but I'll do my best to try to walk through it step-by-step.

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So let's start where Renewable Northwest and Pacific Corrigory.

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First, reliability is a system-wide issue, thus resources required to maintain reliability

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should be system allocated.

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In each of the three jurisdictional models, PACCAS and the Plexaos database, they implement

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and then a set of local wrap constraints

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to drive reliability related procurement.

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This constraint is based on that jurisdiction share

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of system coincident peak load.

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It's also important to keep in mind

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that these set of jurisdictional constraints

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assume a copper sheet handling of PACS transmission network.

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What this means is that all intra

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and interregional transmission limits are ignored

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by these constraints.

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To address this oversimplified handling

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of deliverability, PAC also enforces an additional generic constraint that we will refer to as the

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RAP West constraint. This constraint is activated only in the Washington and Oregon jurisdictional model,

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but critically honors the East or West transfer limit of 1600 MW between PAC East and PAC West,

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thereby ensuring a minimum amount of bill takes place in PAC West to maintain reliability.

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The problem emerges with the introduction of the site's allocation framework that PAC

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introduced in the 2025 IRP, because it effectively bifurcates the portfolio into PAC use and

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PAC West, but fails to separate reliability costs from policy costs.

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This abandons the long-standing practice of uniform cost sharing for system reliability

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because of three critical flaws that we've identified.

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First we have what we're calling the geographic trap.

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The rap-west constraint forces bill to occur exclusively in Pac-West.

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Why does this matter?

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

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

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

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Tax West allocated share of resources under the MSP protocol. The result is we have reliability

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driven resources, our automatically side is allocated to Oregon and Washington under the

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current framework. This leads us to our second issue, the missing reliability baseline.

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We now know resources elected by the model are used to satisfy the rap West constraint, in

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In addition to other constraints associated with state policies, however, because PACS framework

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lacks a reliability only counterfactual study where all physical constraints of the system

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are recognized, we can't distinguish what portion of a selected proxy resource is needed

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for system reliability versus what's needed to satisfy regional environmental policies

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like HB2021, which leads us to the third issue, the conflation of cost and benefits.

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Without the ability to separate what drives resource selection in the model, the reliability

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benefits of proxy resources are conflated with their clean energy benefits.

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But PAC-Sitis allocates all PAC-West resources, treating them as if they are solely required

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for state-level policies, where in reality, a portion of these resources do address system-wide

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reliability and hence should be system-allocated, not-sitis-allocated.

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In case I lost you with all this modeling jargon, let's just summarize.

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Resources in Pac-West serve two distinct purposes, one, serve system reliability.

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The 1600 MW transmission bottleneck means Pac-West needs local resources to maintain reliability,

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which should be system-allocated.

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Two, is compliance with state-energy policies like HB2021.

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Premiums associated with this procurement should be side-as-allocated.

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

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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.

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Nick?

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Great, let's go ahead in the next slide please.

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So, I want to recognize we're approaching our time limit here, so I'm going to just very

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quickly hit this slide in the next slide, and then we'll wrap things up.

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But I just want to come back to the conclusion here in the takeaway.

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What we have on the right hand side of this slide is the west side physical reliability position

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and the east side physical reliability position.

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This is assessed using the RAP analysis provided by Pacific Warp in the IRP.

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And you can just very easily visualize how dramatically different these positions are.

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Pack West is not in balance, and this is a result of many years of policy and planning

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decisions that led to Pack West being reliant on both transfers and market purchases.

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This is a longstanding issue.

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It is not new as a result of state policies.

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It is just a function of how policy and planning decisions have occurred over many years.

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I just want to re-emphasize this, this is a really dramatic departure from

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precedent. So all of these resources we see in the bottom right, many of those

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have been allocated or either system allocated or costs have been shared

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with PAC-West customers for many years. And in a moment where PAC-West is in

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dramatic need of reliability build, we think it's just fundamentally unfair to tag

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the cost of building out of that hole exclusively to PAC-West customers in that

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historical context. I want to just quickly hit the next slide before we wrap up. I want to make

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

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both in public input meetings and in our comments. And I think we feel somewhat frustrated that the

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

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think we would disagree that the IRP does not directly allocate costs. However, the IRP

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ecosystem, both as a model and as an upstream procedural input, is really critical in future

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proceedings where costs are allocated. The Plexus modeling ecosystem, which is primarily

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reviewed and litigated in the IRP, is the basis for the CEP. It's also the basis for how

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Pacificorper views resources in the RFP. And certainly, as we understand it, is a critical

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upstream input to discussions around state allocation protocol and future rate cases.

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To quote a colleague, it's not directly a cost allocation exercise, but it's an important step

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on the way to prudence. I think we'd really like to see some discussion around this. We'd like

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to see one of the key items coming out of this IRP, a direction from the Commission, to

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Pacificoor to work with staff and stakeholders on resolution to this. It's really critical,

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And I think it's one of the most foundational issues for Oregon's outcomes in state allocation

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processes and how we think about moving this multi-state system forward.

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So I'm going to conclude there.

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I'm just going to call out two slides for reference for folks.

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If we could go ahead to slides, slide 24, we'll bring us back to our three recommendations

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

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attempted to break out these recommendations across

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procedurally where we might start to see some resolution.

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We know some of these are longer-term issues.

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Obviously, we'd love to see them solve now,

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but we're still digesting changes from the 23 IRP,

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for instance, ELCC implementation that we're hoping to move forward.

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So we're cognizant that the pathway is long

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and trying to provide some recommendations

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where the commission can take some near-term action

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and also tee up some future work in these future cycles.

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So we really appreciate the opportunity

431
00:35:46,800 --> 00:35:52,900
to talk through these issues today and welcome any questions, clarifications, discussion. Thank you.

432
00:35:54,500 --> 00:36:05,020
Thank you. I really appreciate how concrete and forward-looking you are being and it makes the

433
00:36:05,020 --> 00:36:12,200
challenge much more tractable, so I appreciate the thought you've given to not just sort of

434
00:36:13,240 --> 00:36:21,780
explaining the issues as you see them but also suggesting solutions. Questions? Colleagues,

435
00:36:21,880 --> 00:36:26,580
any questions or conversation you want to have with Renewable North West?

436
00:36:31,530 --> 00:36:35,930
Well, I'll just say I to appreciate the fact that it's not just pointing out issues, concerns,

437
00:36:35,930 --> 00:36:41,510
but giving some potential concrete actions that can be taken in both short term and the long term.

438
00:36:41,510 --> 00:36:42,730
so thank you.

439
00:36:47,410 --> 00:36:56,230
Okay. I appreciate you walking through all of this and it helps to put for me to wrap

440
00:36:56,230 --> 00:37:01,750
my head more around your more detailed comments. So thank you for taking the time and thank you

441
00:37:01,750 --> 00:37:08,510
for sticking to your time. When I saw the number of slides, I was worried. So I appreciate you

442
00:37:08,510 --> 00:37:15,170
respect in that. I'd like to invite the company out to respond. It looks like a

443
00:37:15,170 --> 00:37:19,530
Randy Baker, maybe that's a year who will respond for the company.

444
00:37:21,940 --> 00:37:22,520
Yes, I'm

445
00:37:22,520 --> 00:37:22,640
here.

446
00:37:25,260 --> 00:37:33,560
Great. Please go ahead. Alright, so a lot of material there. You know, the

447
00:37:33,560 --> 00:37:39,300
organization of it clearly took a lot of thinking and time. We do appreciate the

448
00:37:39,300 --> 00:37:45,800
consulting that we've done with Renewable Northwest in particular, I guess I'd like

449
00:37:45,800 --> 00:37:53,980
to start with what I think is the highest level concern which really results to a question

450
00:37:53,980 --> 00:37:55,800
regarding our NWs analysis.

451
00:37:56,880 --> 00:38:03,740
One of the most recent statements that we just heard is that PAC West is not in balance

452
00:38:03,740 --> 00:38:07,640
and that imbalance is not based on state policy.

453
00:38:08,020 --> 00:38:10,120
And this is one of two primary elements

454
00:38:10,520 --> 00:38:15,420
that we've recognized in what R&W has communicated to us.

455
00:38:16,020 --> 00:38:18,980
And there's a fundamental disagreement here.

456
00:38:19,300 --> 00:38:24,080
And I want to be as clear as I can and underscoring it.

457
00:38:24,800 --> 00:38:27,180
First of all, there's a correction to statements

458
00:38:27,180 --> 00:38:30,300
that were made existing resources are still allocated

459
00:38:30,300 --> 00:38:52,480
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.

460
00:38:53,560 --> 00:38:55,920
And that there is a cost to that.

461
00:38:57,400 --> 00:39:00,980
And so in R&W's framework, you know,

462
00:39:01,160 --> 00:39:04,380
this first area that I'm highlighting is that

463
00:39:04,380 --> 00:39:07,500
there's steps one and two depend upon a baseline

464
00:39:07,500 --> 00:39:11,180
that attempts to completely separate reliability from policy.

465
00:39:11,460 --> 00:39:13,080
We believe that that cannot be done.

466
00:39:13,640 --> 00:39:16,100
The conversations we've had leading to this point

467
00:39:16,100 --> 00:39:17,780
have been extremely valuable

468
00:39:19,080 --> 00:39:22,420
because it's allowed us to get that clarity

469
00:39:22,420 --> 00:39:34,140
around the issue. But what it boils down to is that SB 1547 by 2030 has Oregon withdrawing

470
00:39:34,140 --> 00:39:42,560
from otherwise existing system allocated resources in a way that has impacts on all parts

471
00:39:42,560 --> 00:39:53,860
of the system. And given the additional influence of House Bill 2021, really the only despatchable,

472
00:39:54,140 --> 00:40:03,960
qualified resource to replace the loss and reliability on the West is a battery. And those

473
00:40:03,960 --> 00:40:11,420
batteries while often a good deal economically are still expensive and would not have been

474
00:40:11,420 --> 00:40:19,640
needed but for Oregon policy. So I think that's the first thing that should be very clear.

475
00:40:20,480 --> 00:40:24,800
The second item that I want to call out that may seem a little out of order but I think

476
00:40:24,800 --> 00:40:33,020
it's critical to R&W's proposed framework is the idea in step three of their framework where

477
00:40:33,020 --> 00:40:39,640
they're saying let's run a fully optimized system-wide solution and I'm assuming they

478
00:40:39,640 --> 00:40:46,600
mean that also meets all criteria that need to be met for that model run and that includes

479
00:40:47,200 --> 00:40:52,660
that it has to be efficacious. It's got to be efficient in other words it has to run in a reasonable

480
00:40:52,660 --> 00:41:00,440
amount of time. It has to meet all state requirements and it has to produce a result that is competitive

481
00:41:00,440 --> 00:41:05,040
or better than the results that we're producing under a current system.

482
00:41:05,920 --> 00:41:11,920
In contrast to statements made about a pacific course,

483
00:41:12,920 --> 00:41:19,860
change in strategy for allocations, resource development, and selection,

484
00:41:20,700 --> 00:41:26,420
I'd just like to say that, you know, we appreciate that this has been a long evolution.

485
00:41:26,420 --> 00:41:29,840
We've been working these problems for four years now.

486
00:41:31,020 --> 00:41:36,840
And with regard to that all-in system optimization that is in step three of our NW's framework,

487
00:41:37,820 --> 00:41:40,180
you know, we've been working on the problem for four years.

488
00:41:40,520 --> 00:41:43,120
We've been working directly with our NW for several months.

489
00:41:43,720 --> 00:41:51,560
We have not seen a solution that meets those criteria and that achieves the result

490
00:41:51,560 --> 00:41:55,420
that, frankly, everybody, including Pacificoor, would love to have.

491
00:41:55,760 --> 00:42:00,080
It would be great if we could run a single model that would do everything and be compliant,

492
00:42:00,460 --> 00:42:04,120
but there are conflicts in state policies that prevent this.

493
00:42:04,840 --> 00:42:08,640
Pacificoor's approach is not an extreme approach.

494
00:42:08,780 --> 00:42:12,800
I would rather say that it's a very well-balanced approach.

495
00:42:13,340 --> 00:42:21,100
It's balancing the fact that there are conflicts among state policies that are new in developing

496
00:42:23,840 --> 00:42:31,480
And at the same time, trying to maintain parity amongst the different jurisdictions.

497
00:42:32,420 --> 00:42:38,340
For example, you know, going back and I'll try to go through this very quickly.

498
00:42:38,540 --> 00:42:44,900
In the 2021 IRP is where we really started working on this in earnest with CEDA coming in to the fold.

499
00:42:44,900 --> 00:42:53,320
In the 2023 IRP, we introduced a methodology that began with a system-wide preferred portfolio

500
00:42:53,320 --> 00:42:57,900
and then layered in jurisdictional resource selections.

501
00:42:58,380 --> 00:43:00,120
That was not very popular.

502
00:43:00,500 --> 00:43:03,660
It had the potential for over-build in that methodology.

503
00:43:04,080 --> 00:43:05,900
We don't believe that it did over-build.

504
00:43:06,480 --> 00:43:13,640
In the 2023 IRP update, responsive to stakeholder and staff feedback, we developed a different

505
00:43:13,640 --> 00:43:22,320
methodology which is the jurisdictional methodology that we then used in the 2025 IRP, that methodology is

506
00:43:22,320 --> 00:43:29,820
precisely seeking balance. It's not an extreme one way or another. It doesn't abandon

507
00:43:30,240 --> 00:43:34,920
the system-wide solution which we still perform. In fact, every one of the jurisdictional studies

508
00:43:34,920 --> 00:43:41,740
is a system-wide study and then we integrate those according to a methodology that is mathematical

509
00:43:41,740 --> 00:43:50,340
radical and reproducible and you know it keeps in mind facts such as for this

510
00:43:50,340 --> 00:43:53,980
state of Washington we must select resources under the social cost to

511
00:43:53,980 --> 00:43:59,120
greenhouse gases rule that's you know there's no way around that there's no

512
00:43:59,120 --> 00:44:04,240
circumvention of that also we did not want to reduce it to an order of

513
00:44:04,240 --> 00:44:08,140
operations question in other words who do we start with do we optimize for

514
00:44:08,140 --> 00:44:13,500
Oregon first, then Washington, then Wyoming, or do we start with Wyoming, and then move

515
00:44:13,500 --> 00:44:16,640
on to Oregon, and then move on to Washington?

516
00:44:17,600 --> 00:44:24,680
There's no way to do an order of operations approach that is not recursive, cyclical,

517
00:44:24,940 --> 00:44:28,840
and ultimately extremely difficult to defend.

518
00:44:29,420 --> 00:44:35,820
So we select an approach by which we examine each jurisdiction's needs independently, and

519
00:44:35,820 --> 00:44:38,440
And then bring them together into an integrated portfolio.

520
00:44:39,600 --> 00:44:44,180
And then we have, you know, many steps that we take to ensure that we're not overbuilding,

521
00:44:44,380 --> 00:44:45,360
that we're not underbuilding.

522
00:44:45,580 --> 00:44:46,780
We check for all compliance.

523
00:44:47,200 --> 00:44:51,220
We try to ensure that every state gets the resources that it wants.

524
00:44:51,840 --> 00:44:53,440
And then that's the final outcome.

525
00:44:54,200 --> 00:44:55,120
Is it perfect?

526
00:44:55,560 --> 00:44:55,720
No.

527
00:44:56,440 --> 00:44:58,020
But it's an evolution.

528
00:44:58,020 --> 00:44:59,980
And I believe that

529
00:45:00,000 --> 00:45:28,540
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.

530
00:45:28,540 --> 00:45:34,900
And, um, anyway, those are the significant points and, you know, and a question that

531
00:45:34,900 --> 00:45:43,160
I have for R&W as a consequence is, you know, we've revisited, revisited, um,

532
00:45:45,640 --> 00:45:46,420
actually,

533
00:45:46,540 --> 00:45:47,420
let me start over with that.

534
00:45:47,660 --> 00:45:51,540
Can I pause you there just before you move into that?

535
00:45:51,720 --> 00:45:51,820
Sure.

536
00:45:52,220 --> 00:45:59,360
I hear you saying, there's a, I'm hearing you lay out a really paradigm level dispute.

537
00:45:59,360 --> 00:46:28,740
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.

538
00:46:28,740 --> 00:46:37,260
And am I sort of catching, but where Renewable Northwest seems to really, and many of the

539
00:46:37,260 --> 00:46:40,600
stakeholders seem to really hunger for that sort of counterfactual.

540
00:46:41,940 --> 00:46:44,560
Yeah, thank you, Chair Tony, and that is an excellent point.

541
00:46:44,860 --> 00:46:51,720
And frankly, running that step one of their framework, I don't see it as being particularly

542
00:46:51,720 --> 00:46:52,360
problematic.

543
00:46:53,010 --> 00:46:57,360
The difficulty is that you can't get to their step two of the framework because the very

544
00:46:57,360 --> 00:47:01,880
next thing that you would be forced to do is to take into account the effects of state

545
00:47:01,880 --> 00:47:09,580
policy on reliability. And the baseline that they've selected, we see as being an appropriate

546
00:47:09,580 --> 00:47:16,440
because it does not take into account that effect. Our position is that Oregon has ambitious

547
00:47:16,440 --> 00:47:23,980
and laudable policy goals and those have effects on the system. Reliability is one of the more

548
00:47:23,980 --> 00:47:29,920
significant effects, I believe. And that has to be accounted for. So running it is not problematic.

549
00:47:31,000 --> 00:47:38,260
But what you then do with it is immediately apply the reliability impacts to establish a baseline

550
00:47:38,260 --> 00:47:42,860
that is more sensible and more workable in our opinion.

551
00:47:45,200 --> 00:47:47,900
But is there no value in

552
00:47:47,900 --> 00:48:00,100
And demonstrating to stakeholders the delta between the, let's call it the old way of

553
00:48:00,100 --> 00:48:06,700
doing it before Utah's requirements that Hunter and Huntington stay online till 2042

554
00:48:06,700 --> 00:48:11,200
before CEDA's deliverability requirements are in play.

555
00:48:12,060 --> 00:48:16,480
There's a host of policy across the region at this point that you're grappling with.

556
00:48:17,640 --> 00:48:25,900
Is there no value to laying out that counterfactual in the cost cap discussion, which of course

557
00:48:25,900 --> 00:48:28,060
is a contest case that we won't go into detail?

558
00:48:28,640 --> 00:48:31,900
There is a whole construct around counterfactual.

559
00:48:33,100 --> 00:48:41,560
Yeah, and I'll let others on my team chime in, but yeah, I believe that that can have heuristic

560
00:48:41,560 --> 00:48:46,400
value, but in order to do it cleanly, you'd have to back out all state policy, including

561
00:48:46,400 --> 00:48:53,900
SB 1547, and then the comparison when you include SB 1547, that would be the first impact

562
00:48:53,900 --> 00:48:59,720
that you would see is those reliability capacity generation emissions impacts.

563
00:49:01,700 --> 00:49:08,900
And you don't, you know, you gain something interesting to look at, I grant, and we're

564
00:49:08,900 --> 00:49:10,940
perfectly willing and able to run such a study.

565
00:49:10,940 --> 00:49:16,720
It just didn't seem necessary in order to get to the result, to get to the outcomes.

566
00:49:17,680 --> 00:49:26,820
I think perhaps you are missing a piece where you're bringing the stakeholders along in your process.

567
00:49:27,280 --> 00:49:33,440
I think you're hearing from them that they disagree with sort of how you solved the problem.

568
00:49:35,400 --> 00:49:40,480
And I think maybe it's something interesting to look at because you have a sense of how

569
00:49:40,480 --> 00:49:41,480
you want to solve the problem.

570
00:49:41,480 --> 00:49:43,460
I think there's a trust gap there.

571
00:49:44,420 --> 00:49:49,720
But I'll pause, Commissioner Perkins, it looks like you might have questions as well.

572
00:49:50,080 --> 00:49:52,100
Well, I mean, I'm going down the same path that you are.

573
00:49:52,220 --> 00:49:58,280
And my brain is wondering how A, you could not think it was an important thing to do when

574
00:49:58,280 --> 00:49:59,900
all of the stakeholders are asking for it.

575
00:49:59,900 --> 00:50:05,960
It may not in your mind be something that has value, but the stakeholders are all clearly

576
00:50:05,960 --> 00:50:11,380
saying and has value. Our staff is saying it has value. I think it has value. I don't understand

577
00:50:11,380 --> 00:50:16,760
how you can determine the impacts of state policy if you don't understand how the system

578
00:50:16,760 --> 00:50:23,100
is operating without those in place. How can you come to that conclusion if you can't see

579
00:50:23,100 --> 00:50:26,820
that delta and everybody else can't see that delta? I guess that's what I'm struggling with.

580
00:50:26,820 --> 00:50:29,280
And if you say it's definitely easy for you to do,

581
00:50:29,520 --> 00:50:31,340
why wouldn't you have just done it and provided it

582
00:50:31,340 --> 00:50:33,020
when everybody was asking for it in the first place?

583
00:50:33,460 --> 00:50:34,480
And I build on that.

584
00:50:34,480 --> 00:50:34,780
Yes.

585
00:50:35,080 --> 00:50:38,240
Brandy, before you respond, to Commissioner Perkins,

586
00:50:38,480 --> 00:50:41,520
I think, and I was curious because my recollection

587
00:50:41,520 --> 00:50:44,580
is that the company was very supportive of House Bill 2021

588
00:50:45,040 --> 00:50:45,840
in 2021.

589
00:50:46,740 --> 00:50:51,300
So I pulled up corporate testimony on the record

590
00:50:51,300 --> 00:50:55,680
to better remember how the company was positioning itself

591
00:50:55,680 --> 00:51:02,800
And I think what I'm curious about here in this conversation is when state policies

592
00:51:02,800 --> 00:51:11,000
were up for discussion here in the state, Pacificore said House Bill 2021 recognizes that

593
00:51:11,000 --> 00:51:15,580
the grid is regional in nature, and that Oregon's participation in regional electricity markets

594
00:51:15,580 --> 00:51:20,560
is the key component to ensuring affordable integration of renewable resources and ensuring

595
00:51:20,560 --> 00:51:25,760
our reliability. Later, we're going on to discuss that pacificor, one of the benefits of being a

596
00:51:25,760 --> 00:51:31,580
regional multi-state electricity provider, is that we can share costs at scale and leverage geographic

597
00:51:31,580 --> 00:51:38,140
diversity to provide the best solutions to all our customers. And so I'm curious what changed.

598
00:51:39,540 --> 00:51:45,680
Yeah, all of that is true. And all of that, I think, remains true. And pacificor is not opposed

599
00:51:45,680 --> 00:51:47,500
to House Bill 2021.

600
00:51:48,440 --> 00:51:50,700
What has changed is a number of things.

601
00:51:51,380 --> 00:51:55,140
Federal legislation being paramount amongst them.

602
00:51:55,220 --> 00:52:01,980
The resolution of how state policies are interpreted

603
00:52:01,980 --> 00:52:03,220
and must be implemented.

604
00:52:03,560 --> 00:52:04,920
That's also a change.

605
00:52:07,740 --> 00:52:09,880
And it's a different world.

606
00:52:10,240 --> 00:52:11,820
When we talk about a paradigm shift,

607
00:52:12,080 --> 00:52:15,620
we believe that there is indeed clearly a paradigm shift.

608
00:52:16,380 --> 00:52:45,560
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.

609
00:52:45,560 --> 00:52:54,120
study did not come up in our 18-month, 15-month public input meeting series. There was a lot of

610
00:52:54,120 --> 00:53:01,840
discussion about establishing the proper basis for determining what the reliability needs are and

611
00:53:01,840 --> 00:53:08,240
how that differential would have to be measured, you know, of the preferred portfolio as the expected

612
00:53:08,240 --> 00:53:16,840
a case against other cases. There was a lot of discussion that zeroes in on the issues of

613
00:53:16,840 --> 00:53:21,840
measures and approaches and modeling, but this was not brought up in the Public Input

614
00:53:21,840 --> 00:53:28,880
Meeting Series, and it's not in our stakeholder feedback form. So, yeah, there's a huge amount

615
00:53:28,880 --> 00:53:36,800
of interest in it now, and I think that huge amount of interest is probably being incentivized

616
00:53:36,800 --> 00:53:43,440
by the fact that the removal of federal policy and the rejiggering, if you will, of the planning

617
00:53:43,440 --> 00:53:53,040
environment has made Oregon's ambitious policies more expensive, because there's not this underlying

618
00:53:53,040 --> 00:53:59,320
bed of federal tax-supported resources filling up the system.

619
00:54:07,900 --> 00:54:14,840
I think that there is no question, a pipeline of renewables is very different, and the cost

620
00:54:14,840 --> 00:54:16,640
environment for renewables is very different.

621
00:54:16,900 --> 00:54:29,140
But I am observing a host of constraints that are confusing, and so I'd love to ask

622
00:54:29,140 --> 00:54:30,040
you about two of them.

623
00:54:31,480 --> 00:54:41,220
Can you describe to me whether B2H serving a large customer is B2H ending in a cul-de-sac?

624
00:54:42,580 --> 00:54:49,180
Or by serving that large customer, does B2H get a connected across to Pac-West functionally?

625
00:54:49,760 --> 00:54:58,320
And once it's all in EDAM, Pac-West essentially has access to the transfer capability of B2H.

626
00:54:58,320 --> 00:55:01,040
or is it just really just a cul-de-sac?

627
00:55:01,260 --> 00:55:02,380
It's going to the large customer,

628
00:55:02,780 --> 00:55:04,120
it's the end of the conversation.

629
00:55:05,380 --> 00:55:07,260
Yeah, thank you for the question, Chertani.

630
00:55:07,500 --> 00:55:09,640
If I may, I'd like to defer to Rick Link

631
00:55:09,640 --> 00:55:10,400
on this question.

632
00:55:11,140 --> 00:55:12,060
Rick, can you hop on?

633
00:55:15,690 --> 00:55:16,450
You're muted, Rick.

634
00:55:24,000 --> 00:55:24,900
No, you're still muted.

635
00:55:28,110 --> 00:55:28,710
Double muted.

636
00:55:28,830 --> 00:55:31,170
I have to hit all three mute buttons.

637
00:55:31,350 --> 00:55:32,290
Not a way I've hit star six.

638
00:55:33,270 --> 00:55:33,610
You're good.

639
00:55:34,990 --> 00:55:36,950
We can hear you, or we heard you just a moment ago.

640
00:55:39,360 --> 00:55:39,960
There you go.

641
00:55:40,540 --> 00:55:40,840
All right.

642
00:55:43,840 --> 00:55:52,160
So, yes, B2H would in and of itself longhorn does it connect to our PAC-West BAA, but the

643
00:55:52,160 --> 00:55:59,020
longhorn substation is in very close geographic proximity to elements of our transmission

644
00:55:59,020 --> 00:56:04,580
system in the PAC-West balancing authority area with some minor, you know, have the

645
00:56:04,580 --> 00:56:10,680
mileage off top of my head somewhere between 15 to 30 miles, I think, of local, I'll call

646
00:56:10,680 --> 00:56:16,500
All that transmission infrastructure would be added in this plan to be added in that part

647
00:56:16,500 --> 00:56:18,680
of the system to ultimately connect it to PacWest.

648
00:56:19,240 --> 00:56:26,860
That being said, just as a reminder, our West Balancing Authority area has a lot of low

649
00:56:26,860 --> 00:56:30,340
pockets that connect it and we serve some of that through transmission rights that we have

650
00:56:30,340 --> 00:56:35,020
with Bonneville across our system as well, so it's not a contiguous system on our PacWest

651
00:56:36,440 --> 00:56:58,320
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?

652
00:56:59,990 --> 00:57:11,810
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.

653
00:57:12,610 --> 00:57:21,270
But like I said, when it does connect to our transmission assets that make up our Western VA, that is connected.

654
00:57:21,270 --> 00:57:35,170
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.

655
00:57:35,730 --> 00:57:48,010
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.

656
00:57:49,230 --> 00:57:55,690
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.

657
00:57:56,190 --> 00:57:58,350
Be really clear. We're not giving up on that.

658
00:57:58,910 --> 00:58:02,350
That pathway, right? We're keeping all of our options open. We're playing.

659
00:58:02,930 --> 00:58:14,230
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.

660
00:58:14,230 --> 00:58:17,350
in Bonneville's queue, they're not removed,

661
00:58:17,930 --> 00:58:19,870
and they will ultimately, at some point,

662
00:58:19,990 --> 00:58:21,610
I believe, be studied and we'll find out

663
00:58:21,610 --> 00:58:24,230
what that study tells us at that point in time

664
00:58:24,230 --> 00:58:25,730
and we'll make the appropriate decisions

665
00:58:25,730 --> 00:58:27,670
based on what that information tells us.

666
00:58:28,990 --> 00:58:31,310
But we do have a need for it.

667
00:58:31,430 --> 00:58:33,850
The way I think of it, another way to think of this,

668
00:58:34,470 --> 00:58:38,710
Chertani is when we were working through the term sheet process

669
00:58:38,710 --> 00:58:42,350
and getting the basic concepts in place

670
00:58:42,350 --> 00:58:43,430
between the three parties,

671
00:58:43,430 --> 00:58:44,930
responsible Idaho and Pacific Corps.

672
00:58:45,910 --> 00:58:48,430
It became increasingly apparent that

673
00:58:48,430 --> 00:58:52,370
I don't criticize them for this,

674
00:58:52,510 --> 00:58:54,590
but they wanted us to get the redirect request

675
00:58:54,590 --> 00:58:56,310
that we've been talking about, you know,

676
00:58:56,450 --> 00:58:58,450
achieved through their normal business practices

677
00:58:58,450 --> 00:59:02,170
that they couldn't commit to offering those redirects

678
00:59:02,170 --> 00:59:04,530
as part of the agreement itself, right?

679
00:59:04,710 --> 00:59:06,090
They committed that if you submit it,

680
00:59:06,170 --> 00:59:08,530
we will follow our process and let you know how that pans out.

681
00:59:09,390 --> 00:59:11,310
When we became aware of that,

682
00:59:11,310 --> 00:59:16,590
we had to, you know, kind of assess, well, if what if Bonneville never offers those

683
00:59:16,590 --> 00:59:22,790
weeks, or what if Bonneville offers them, but at a time frame and a cost that's not acceptable,

684
00:59:23,070 --> 00:59:29,370
right? That's crazy high cost in 10 years down the road. Would we still have to use for B2H?

685
00:59:30,130 --> 00:59:33,290
And the answer to that question was yes, right? Because we did have

686
00:59:34,350 --> 00:59:39,110
load and very close proximity to pH, so that we got, that's how we got comfortable

687
00:59:39,730 --> 00:59:43,730
moving forward and ultimately executing the term sheet and moving on to

688
00:59:43,730 --> 00:59:47,430
definitive agreements after that term sheet was signed among the parties.

689
00:59:48,090 --> 00:59:53,390
Recognize because I'll have to say that accent that is I wouldn't expressly state

690
00:59:53,390 --> 00:59:56,830
that we may not have signed the term sheet. It would have been a much riskier

691
00:59:56,830 --> 00:59:59,910
endeavor for us to consider moving forward with a

692
01:00:00,000 --> 01:00:25,040
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.

693
01:00:25,920 --> 01:00:32,880
I appreciate you raising the term sheet because that was my second question around B2H.

694
01:00:35,540 --> 01:00:37,940
I'm conscious of time, it's 10.30.

695
01:00:39,680 --> 01:00:44,080
We need to move to the rest of the agenda.

696
01:00:46,760 --> 01:00:52,780
Colleagues, do you want to ask the Pacific Corps anything further in relationship to sort

697
01:00:52,780 --> 01:01:00,800
what renewable northwest is raised so far. These issues are all intertwined and so hopefully by the

698
01:01:00,800 --> 01:01:07,080
end of the morning we have more clarity on all of them but just to keep us moving along.

699
01:01:21,150 --> 01:01:21,590
This is

700
01:01:23,250 --> 01:01:32,010
challenging. This happens in IRPs and in other dockets where we really struggle with stakeholders

701
01:01:32,010 --> 01:01:38,170
is talking past each other. And I think these workshops can be helpful for trying to help

702
01:01:39,010 --> 01:01:45,370
parties hear each other. And so I appreciate the clear engagement.

703
01:01:46,810 --> 01:01:52,710
Let's turn to item three, the jurisdictional modeling assumptions and impacts.

704
01:01:53,770 --> 01:02:00,750
So Renewable Northwest has teed a bunch of this up. But I'd love to see a show of hands on

705
01:02:00,750 --> 01:02:08,790
who would like to sort of raise something additional or unique as opposed to what

706
01:02:08,790 --> 01:02:12,050
Renewable Northwest has already raised on these topics.

707
01:02:14,330 --> 01:02:15,190
Recognizing that we

708
01:02:15,190 --> 01:02:19,370
have your written comments, I'll pause.

709
01:02:25,680 --> 01:02:28,220
Let people find the razor hand button. We

710
01:02:37,120 --> 01:02:40,040
have a lot of written comments. I

711
01:02:50,280 --> 01:02:53,440
have a question on this topic. Colleagues, you

712
01:02:53,440 --> 01:02:58,880
might not have questions for the company on this topic. So let me ask the company and

713
01:02:58,880 --> 01:03:08,000
then colleagues, you please follow on. So I am very curious as I engage with these constraints

714
01:03:08,000 --> 01:03:23,020
It's a specific or about the way you seem to be saying how HB2021 is interpreted is deeply

715
01:03:23,020 --> 01:03:35,740
impacting access to market purchases and sort of choking, putting Oregon on an

716
01:03:35,740 --> 01:03:45,720
Island and I'd really love you to unpack that given the extensive work in the EDM process

717
01:03:45,720 --> 01:03:52,760
around trying to address GHG constraints and so on.

718
01:03:53,040 --> 01:03:53,620
Rohini.

719
01:03:58,020 --> 01:04:00,580
Hopefully, I'm hooked up and you can hear me.

720
01:04:01,120 --> 01:04:01,260
Yes.

721
01:04:02,200 --> 01:04:02,460
Awesome.

722
01:04:03,080 --> 01:04:05,220
Thank you, Chair Tony, for the question.

723
01:04:05,220 --> 01:04:08,720
and I'll try to answer your question directly,

724
01:04:08,760 --> 01:04:11,040
but I might add a little bit of context as well.

725
01:04:11,720 --> 01:04:14,960
I think there are a few kind of points to make here.

726
01:04:15,540 --> 01:04:19,460
So as far as just modeling towards House Bill 2021 compliance,

727
01:04:20,260 --> 01:04:24,020
as you're well aware, having seen the results we've presented,

728
01:04:24,640 --> 01:04:30,300
there's definitely kind of a narrow amount of emissions

729
01:04:30,300 --> 01:04:33,120
that a Pacific Corp can plan to rely on,

730
01:04:33,120 --> 01:04:40,200
whether it comes from emitting gas units or unspecified market purchases as far as what room

731
01:04:40,200 --> 01:04:47,200
would we have under an 80% or 90% reduction in emissions in 2030 or 2035? Not even thinking

732
01:04:47,200 --> 01:04:53,580
about maybe the limitations in 2040. And so under that paradigm, we've tried to set up our modeling

733
01:04:53,580 --> 01:05:01,140
in a way that allows us to endogenously plan to those requirements for Oregon, which does require

734
01:05:01,140 --> 01:05:07,800
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.

735
01:05:08,420 --> 01:05:16,080
And a large part of that comes from the amount that we typically might rely on front office transactions for FOTs and the model,

736
01:05:16,440 --> 01:05:26,140
which are again unspecified market purchases that do come with a significant unspecified market emissions rate under the DEQ methodology.

737
01:05:26,640 --> 01:05:30,840
And so, you know, just, I won't pull it up, but, you know,

738
01:05:30,940 --> 01:05:34,000
harkening back to the presentation I gave shortly after we filed this

739
01:05:34,000 --> 01:05:37,960
E.P., you can look at our Oregon retail sales on an annual basis

740
01:05:37,960 --> 01:05:44,760
in 2030, what's forecasted, and it's, you know, somewhere around 14,000

741
01:05:44,760 --> 01:05:48,580
gigawatt hours, and you can look at, you know, what the existing

742
01:05:48,580 --> 01:05:52,420
generation is that we have to serve Oregon in 2030, which no longer

743
01:05:52,420 --> 01:05:54,940
and include school generation for obvious reasons,

744
01:05:55,460 --> 01:05:58,000
does include some amount of gas trend that we have to,

745
01:05:58,180 --> 01:06:00,960
and I think in 2030, we don't really need to restrain it

746
01:06:00,960 --> 01:06:03,020
at adding enough resources helps us meet it.

747
01:06:03,520 --> 01:06:05,140
And there is some market reliance.

748
01:06:06,000 --> 01:06:08,360
One thing that I'll comment on is there's nothing

749
01:06:08,360 --> 01:06:10,240
in our models that's necessarily accounting

750
01:06:10,240 --> 01:06:12,440
for how things might change under EDAM.

751
01:06:13,020 --> 01:06:16,360
I can let Randy speak to whether or not we see that changing

752
01:06:16,360 --> 01:06:19,420
and whether or not we see how market participation

753
01:06:19,420 --> 01:06:25,700
or settlements in EDM might change kind of what that view looks like from a long-term modeling perspective, I can't say

754
01:06:26,180 --> 01:06:30,400
But you know, we kind of model our various markets

755
01:06:30,940 --> 01:06:34,000
Typically, we're looking at probably mid-sea in this region

756
01:06:34,520 --> 01:06:40,360
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

757
01:06:40,360 --> 01:06:46,580
Oregon allocated generation might not be enough, but as you know, we're not typically modeling that on an hourly basis

758
01:06:46,580 --> 01:06:51,460
we're kind of looking at annually. And so we, you know, just purely on an energy basis,

759
01:06:51,740 --> 01:06:57,900
there is a very large need for resources that can generate to serve. And that might become

760
01:06:57,900 --> 01:07:02,200
more efficient when we're in EDAM, and maybe that leads to less curtailment of renewables,

761
01:07:02,200 --> 01:07:07,200
and maybe that leads to a change in how we model. But I think from a compliance with House Bill 2021

762
01:07:07,200 --> 01:07:13,000
perspective, we're really focused on what is the energy that can serve Oregon customers,

763
01:07:13,860 --> 01:07:23,120
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?

764
01:07:23,920 --> 01:07:26,780
Did I answer your question if I didn't please, please ask me again,

765
01:07:30,260 --> 01:07:31,520
Cheritani, you're muted.

766
01:07:31,520 --> 01:07:44,000
I appreciate that, and I think what I, the fall, you know, the piece that the stakeholder

767
01:07:44,000 --> 01:07:50,640
community and the regulatory community that needs to grapple with is, how do we maximize

768
01:07:50,640 --> 01:07:59,220
when we know we are getting lower cost? Lower emissions resources out of the market, solar

769
01:07:59,220 --> 01:08:04,600
out of California, for example, how do we account for that effectively?

770
01:08:05,040 --> 01:08:12,160
So I guess that's what I'm not seeing that this is a constraint and it is not permanent.

771
01:08:12,680 --> 01:08:19,280
The here is how we might resolve it, sort of a pointer from the companies. So.

772
01:08:19,720 --> 01:08:25,100
And to that point, my understanding, I am not a part of the EDM implementation in any way,

773
01:08:25,100 --> 01:08:34,000
But my understanding has been that going into EDAM doesn't necessarily change like what generation of the specific corpus claimant, right?

774
01:08:34,480 --> 01:08:42,540
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.

775
01:08:43,060 --> 01:08:51,980
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.

776
01:08:51,980 --> 01:08:58,180
We are still going to see from Pacific Corkside all of our generation that generated on annual

777
01:08:58,180 --> 01:09:04,000
bases monthly intervals and that's going to account for what served kind of on a cost

778
01:09:04,000 --> 01:09:05,860
allocated basis for organ customers.

779
01:09:06,640 --> 01:09:11,320
And there's currently the way we do it is we just kind of take a share of these market purchases

780
01:09:11,320 --> 01:09:15,600
that happen in the markets and we kind of cost allocate that to Oregon.

781
01:09:16,260 --> 01:09:21,520
And we also might impute an additional shortfall market, which I don't think is typically

782
01:09:21,520 --> 01:09:24,760
happening, but we could impute, you know, an additional market shortfall if

783
01:09:24,760 --> 01:09:28,740
Oregon allocated resources were stacked up and they weren't enough to meet

784
01:09:28,740 --> 01:09:33,160
Oregon retail sales on an annual basis. And so to my understanding what

785
01:09:33,160 --> 01:09:38,140
settles in EDM is it necessarily directly changing that from a specific

786
01:09:38,140 --> 01:09:41,820
quarter perspective, it just might make it more efficient and a benefit could be

787
01:09:41,820 --> 01:09:45,380
like perhaps less curtailment in the markets. And again, does that change how we

788
01:09:45,380 --> 01:09:50,600
model? I can't say. But my understanding is what we bit into the market really

789
01:09:50,600 --> 01:09:55,600
shouldn't change kind of the claim that we have on our own energy.

790
01:09:56,160 --> 01:10:00,260
So the converse is that we don't necessarily get to claim others clean energy coming

791
01:10:00,260 --> 01:10:00,980
back to us.

792
01:10:01,200 --> 01:10:04,480
And so if that, so we are still seeing unspecified in that sense.

793
01:10:04,640 --> 01:10:07,040
So if that were to change, that would be wonderful.

794
01:10:07,140 --> 01:10:07,920
We'd love to see it.

795
01:10:08,040 --> 01:10:15,380
I just currently am not aware of something that gives me kind of a specified market purchase.

796
01:10:15,380 --> 01:10:17,740
That's at a lower rate, if that makes sense.

797
01:10:17,740 --> 01:10:19,300
It does. It does.

798
01:10:21,860 --> 01:10:28,880
Questions, colleagues, and also stakeholders open to hearing from folks on these issues.

799
01:10:31,680 --> 01:10:36,340
Let me just check and see if my colleagues have questions for a specific core and then I'll go to you.

800
01:10:37,320 --> 01:10:45,800
Well, I guess my question would be wouldn't including that potential future option of changing how those purchases are.

801
01:10:47,560 --> 01:10:52,140
looked at and credited, wouldn't modeling that be part of looking at future scenarios,

802
01:10:52,920 --> 01:10:55,120
so you can have an idea of how that might play out.

803
01:10:56,180 --> 01:10:57,580
Yeah, that's a great question.

804
01:10:57,740 --> 01:11:01,660
And I just am really not an expert by any means on how that will change.

805
01:11:01,960 --> 01:11:05,780
Again, I think from a long-term planning perspective, noting that,

806
01:11:05,920 --> 01:11:09,720
you know, we're never going to purposely, perfectly forecast what, like,

807
01:11:09,960 --> 01:11:13,040
hour to hour, month to month kind of market settlements are.

808
01:11:13,040 --> 01:11:17,820
I do think we are contemplating it right I think it's a conversation we're having internally you know

809
01:11:17,820 --> 01:11:24,060
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

810
01:11:24,060 --> 01:11:26,680
We'll have a better idea but again

811
01:11:26,680 --> 01:11:31,880
I think from a long-term planning perspective as far as compliance you know

812
01:11:31,880 --> 01:11:37,160
I still see it as we have kind of the claim over all of our own generation

813
01:11:37,940 --> 01:11:41,160
Maybe the forecast of that generation changes because of EDAM

814
01:11:41,160 --> 01:11:45,940
But we have a fairly optimistic forecast as it is for our renewables based on really

815
01:11:45,940 --> 01:11:47,700
just transmission constraints in the system.

816
01:11:48,420 --> 01:11:53,440
And we are kind of claiming, quote unquote, the clean credit, which there's no wrecks

817
01:11:53,440 --> 01:11:53,860
or anything.

818
01:11:54,280 --> 01:11:57,420
But we are claiming that as energy that can serve and is compliant.

819
01:11:57,900 --> 01:12:00,940
And we're looking at, does that reduce our perceived market position?

820
01:12:01,260 --> 01:12:01,880
Yes, great.

821
01:12:02,100 --> 01:12:03,180
We think there'll be less emissions.

822
01:12:04,040 --> 01:12:10,520
I don't have anything to my knowledge that will change significantly what the market dynamics

823
01:12:10,520 --> 01:12:15,340
are to change the generation, like if it's going to change dispatch order or market or something,

824
01:12:15,560 --> 01:12:20,160
but yeah, I'm absolutely would love to see it. I know that there are tons of folks,

825
01:12:20,480 --> 01:12:24,960
you know, at the company and other parties that are talking about in EDAM, thinking about things

826
01:12:24,960 --> 01:12:31,280
like residual energy and all of that, and maybe having a measure on a monthly basis or whatever

827
01:12:31,280 --> 01:12:37,120
scale that says, well, all of that kind of market energy that came to you, you know, because we were

828
01:12:37,120 --> 01:12:39,260
shorter in that period could actually be

829
01:12:39,260 --> 01:12:40,140
to lower emissions rate.

830
01:12:40,480 --> 01:12:43,400
But again, I don't know how likely that is.

831
01:12:43,600 --> 01:12:45,700
I don't know what the stack of resources looks like.

832
01:12:46,420 --> 01:12:48,880
So I think I wouldn't know what to model.

833
01:12:49,520 --> 01:12:52,560
But again, I totally welcome anyone from Pacific Corp

834
01:12:52,560 --> 01:12:54,580
to chime in if they have better intel than me.

835
01:12:55,900 --> 01:12:58,380
But yeah, we're just focused on what

836
01:12:58,380 --> 01:13:01,840
can Pacific Corp's resources generate reasonably based

837
01:13:01,840 --> 01:13:03,920
on constraints in the system and trying

838
01:13:03,920 --> 01:13:06,900
to offset that market reliance as much as we can.

839
01:13:10,930 --> 01:13:11,090
Really?

840
01:13:12,270 --> 01:13:16,530
Yeah, I mean, I just wanted to add, we're definitely looking at this internally

841
01:13:17,090 --> 01:13:21,610
and as a, from a forecasting scenario perspective,

842
01:13:22,150 --> 01:13:24,870
it doesn't even necessarily require a model run.

843
01:13:24,990 --> 01:13:29,690
There are perhaps calculations that could be done to book in potential impacts.

844
01:13:30,250 --> 01:13:32,130
But, yeah, we're looking at it.

845
01:13:32,190 --> 01:13:36,090
We're interested in, you know, any feedback or suggestions.

846
01:13:36,090 --> 01:13:37,610
I think you're welcome.

847
01:13:38,310 --> 01:13:42,430
I mean, I guess I would say that if that's something you can do,

848
01:13:42,570 --> 01:13:48,030
that's information I think would be useful in kind of looking at how changes

849
01:13:48,030 --> 01:13:55,650
within the market and how transactions are handled and credited.

850
01:13:56,230 --> 01:13:59,450
It would give us, I think it would give everybody insight into the value

851
01:14:00,090 --> 01:14:04,190
and look how things could be done to optimize the system for customers

852
01:14:04,190 --> 01:14:04,830
and for the company.

853
01:14:04,830 --> 01:14:05,830
thank

854
01:14:07,840 --> 01:14:14,160
you. I think I'll add to that having worked really extensively in that process with

855
01:14:14,160 --> 01:14:21,140
Oregon DEQ and the OPUC team. There's a huge amount of work going on and I would really

856
01:14:21,780 --> 01:14:27,760
end to my mind. It makes a really big difference in terms of both how much you build and what you

857
01:14:27,760 --> 01:14:36,240
build, whether how you're going to compete with California and Washington in E Dam to draw clean

858
01:14:36,240 --> 01:14:45,620
energy resources to Oregon as a GHG constraint state. It really impacts the purchasing decision

859
01:14:45,620 --> 01:14:51,260
and the relative competitiveness of different resources, I think. So I think it's really important.

860
01:14:51,700 --> 01:14:59,800
But I'll put a pin there and pivot to Fred, your perspective on these modeling assumptions and

861
01:15:00,000 --> 01:15:06,520
So, on this juicy question, narrowly, perhaps. Yeah, if it's a good morning, chair, Tony, and

862
01:15:06,520 --> 01:15:12,880
commissioners, Perkins, and hour, Fred Huitt, representing the Northwest Energy Coalition.

863
01:15:13,780 --> 01:15:18,600
Topical, I want to focus on is under item three is resource adequacy, and specifically

864
01:15:19,180 --> 01:15:23,260
the Western resource adequacy program. So if it's okay for me to address that right now,

865
01:15:23,260 --> 01:15:24,480
I can do that, or I can wait.

866
01:15:26,080 --> 01:15:32,300
So RAA resource adequacy is obviously a key part of the IRP process and many other

867
01:15:32,300 --> 01:15:32,740
things.

868
01:15:33,520 --> 01:15:39,340
The question arises about the relationship between the IRP and the Western resource adequacy

869
01:15:39,340 --> 01:15:39,820
program.

870
01:15:40,120 --> 01:15:45,740
I will not get into all of the details on that, but clearly major decision point coming at

871
01:15:45,740 --> 01:15:52,260
the end of this month on October 31st for Pacific or in other participants to decide whether

872
01:15:52,260 --> 01:15:55,780
they want to participate in the binding program that starts in a couple of years.

873
01:15:56,880 --> 01:16:01,120
And at the same time, and I'm speaking here also as a member of the RAP program review

874
01:16:01,120 --> 01:16:06,300
committee, there's a substantial amount of work going on to revise the RAP program design,

875
01:16:06,840 --> 01:16:12,980
including in the areas that are relevant here, especially the planning review margin, and

876
01:16:12,980 --> 01:16:19,360
the way that RAP is moving forward in the operating phase and both, you know, forward showing

877
01:16:19,360 --> 01:16:25,100
and the operating phase on the zonal approach within the overall RAP program, which currently

878
01:16:25,100 --> 01:16:29,780
right now is a geographic split between basically the northwest and the west, rest of the

879
01:16:29,780 --> 01:16:35,000
west, with informally called the SWEED as southwest, I'm never sure what the acronym

880
01:16:35,000 --> 01:16:42,280
is anyway. There's a proposal on the table right now to, there's subgroups under the program

881
01:16:42,280 --> 01:16:47,900
review committee or under that process at RAP to review both the planning reserve margin where

882
01:16:47,900 --> 01:16:51,960
there's a lot of concern, I think, rightly about the variability that we've already seen with

883
01:16:51,960 --> 01:16:58,320
a year to year, and also on this kind of zonal approach, both of which are directly relevant to

884
01:16:58,320 --> 01:17:06,260
what happens with PAC-RP planning going forward, and just to note, we both support and thank PAC

885
01:17:06,260 --> 01:17:13,060
for being very responsive to all of the input that we provided in questions that, especially technical

886
01:17:13,060 --> 01:17:17,960
questions and the analysis that Renewable North West and Sierra Club have sponsored that's been

887
01:17:17,960 --> 01:17:24,780
really, really good. We also support the call by many of us to revamp the planning approach

888
01:17:24,780 --> 01:17:30,800
in the IRP update, which is coming fairly soon. The issue with that is the RAP review process,

889
01:17:31,160 --> 01:17:36,200
and what's happening with the IRP update, you know, there might be a bit of a alignment issue

890
01:17:36,200 --> 01:17:42,220
with all of that, so we may not know, as the RAP update proceeds, how much change the

891
01:17:42,220 --> 01:17:44,420
RAP process will be undergoing.

892
01:17:45,100 --> 01:17:51,780
So I just wanted to point that out, the issue with, especially with the Zonal approach

893
01:17:52,160 --> 01:17:56,040
is directly relevant in that, the proposal we have just seen.

894
01:17:57,160 --> 01:18:02,020
We've got the Materials in Tuesday and discussed them in the program review committee yesterday.

895
01:18:02,020 --> 01:18:07,580
day, the materials coming from the subgroup suggest a change to a market-aligned approach

896
01:18:07,580 --> 01:18:13,960
for RAP rather than a geographic basis for doing the zone approach, which probably means

897
01:18:13,960 --> 01:18:18,980
if that goes forward, that specific or if they participate in the binding program would

898
01:18:18,980 --> 01:18:23,620
be in a single zone in the EDAM side, if you want to call it that.

899
01:18:23,620 --> 01:18:30,560
But as opposed to now where the SWEED, the Northwest SWEED division happens basically

900
01:18:30,560 --> 01:18:36,860
between PACK East and PACK West, that's directly relevant to the information that you've got

901
01:18:36,860 --> 01:18:39,920
to put into the modeling and the perspective that we have.

902
01:18:40,580 --> 01:18:43,720
And also connects to, for example, matters, other matters.

903
01:18:43,980 --> 01:18:49,680
So for example, UM-24 or for currently before the Commission with Oregon's or the Commission's

904
01:18:49,680 --> 01:18:52,800
own kind of backstop resource adequacy program.

905
01:18:52,800 --> 01:18:58,280
This is a very complicated thing to deal with, so I wanted to point that these timing issues

906
01:18:58,280 --> 01:19:05,900
and the content issues out for your consideration because I would finally say our view at the

907
01:19:05,900 --> 01:19:11,940
Northwest Energy Coalition is we want to keep as intact a wrap as we can, but we have to

908
01:19:11,940 --> 01:19:17,420
recognize that there are legitimate issues that are being raised by Pacific or others about

909
01:19:17,420 --> 01:19:20,420
the program design currently, that will take time to work out.

910
01:19:23,240 --> 01:19:37,820
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.

911
01:19:39,380 --> 01:19:39,920
Okay,

912
01:19:42,400 --> 01:19:48,620
you know, Fred, I think as you think about, I know Pacific Corps is doing another round

913
01:19:48,620 --> 01:19:53,440
of reply comments, and that might be the last set of comments in the process, it's never

914
01:19:53,440 --> 01:20:00,080
the last set of comments, but you know, as you work with the RAP, really articulating how

915
01:20:00,080 --> 01:20:03,760
this shift in footprints impacts the IRP is helpful.

916
01:20:03,760 --> 01:20:08,200
So I appreciate how you cover that in your comments.

917
01:20:09,520 --> 01:20:12,040
Okay, yeah, it's 10 to 11.

918
01:20:12,880 --> 01:20:17,480
I would like to take a break recess until 11 o'clock,

919
01:20:17,480 --> 01:20:22,800
and then take up items four and five and six if we have time.

920
01:20:23,660 --> 01:20:29,380
But colleagues, this is really intended for us to get our arms around the challenges.

921
01:20:29,780 --> 01:20:31,520
And these are all interrelated challenges.

922
01:20:31,520 --> 01:20:42,920
So I want you to feel free to pursue your curiosity as you need to, don't feel constrained by the agenda topics.

923
01:20:44,140 --> 01:20:48,100
So Christie, let's recess until 11 o'clock.

924
01:20:52,740 --> 01:20:53,060
All right.

925
01:20:54,600 --> 01:21:00,620
I'd love to move on to item four on the agenda.

926
01:21:00,620 --> 01:21:10,220
We've discussed this some with questions that we were posing around V2H, but I think there's much more to unpack there.

927
01:21:11,700 --> 01:21:14,800
I see Zach, you have your hand up.

928
01:21:15,820 --> 01:21:25,240
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.

929
01:21:31,980 --> 01:21:38,500
Great. Thanks, Chair Donnie. We actually have just one more point we'd like to make on the

930
01:21:38,500 --> 01:21:40,280
jurisdictional modeling if that's possible.

931
01:21:42,980 --> 01:21:43,540
Yeah,

932
01:21:46,380 --> 01:21:49,700
so understanding I'm not a modeler,

933
01:21:49,980 --> 01:22:02,000
right? I don't have subject matter expertise, but I have been working with our IRP team and our

934
01:22:02,000 --> 01:22:03,160
point to get lost in the weeds.

935
01:22:06,430 --> 01:22:11,850
A lot of the commenters are quite concerned that our

936
01:22:11,850 --> 01:22:17,450
jurisdictional modeling approach is going to result in increased costs for organ customers

937
01:22:18,230 --> 01:22:28,930
that it could result in substantial over-build of resources. And it kind of obscures system

938
01:22:28,930 --> 01:22:29,970
need, right?

939
01:22:32,310 --> 01:22:40,450
I actually think renewable north-west's proposal actually exacerbates all of those

940
01:22:40,450 --> 01:22:48,890
issues except for cost. So their method actually points in the wrong direction for the conclusions

941
01:22:49,430 --> 01:22:55,070
that they're trying to draw. And I'd like to hear folks perspective on this, but let me unpack

942
01:22:55,070 --> 01:22:55,910
pack this a little bit.

943
01:22:57,080 --> 01:22:58,270
So let's start with costs.

944
01:22:59,230 --> 01:23:03,570
So since A3201 is an emissions reduction mandate, right?

945
01:23:04,730 --> 01:23:07,150
Oregon has the same emissions it needs to reduce,

946
01:23:07,330 --> 01:23:09,870
regardless where those resources come from.

947
01:23:10,630 --> 01:23:14,550
So either Oregon gets by Rohingy's back

948
01:23:14,550 --> 01:23:15,390
of the envelope math.

949
01:23:15,670 --> 01:23:20,430
Either Oregon gets three gigawatts of cytos resources

950
01:23:20,430 --> 01:23:31,150
by 2035 or Oregon gets, you know, 26, 27 percent, whatever current allocation factor is of 10

951
01:23:31,150 --> 01:23:38,770
gigawatts of system resources, right? But it's the same amount of resources, regardless if it's

952
01:23:38,770 --> 01:23:49,810
shared with the system or site is. And so the costs aren't going to be impacted by whether we

953
01:23:50,750 --> 01:23:57,110
move forward with an R&W type modeling approach because Oregon still has the

954
01:23:57,110 --> 01:24:03,930
same need. Regardless where those resources are cited or system. But what

955
01:24:03,930 --> 01:24:09,370
it's important about Renewal Northwest's approach here is that for each

956
01:24:09,370 --> 01:24:17,490
resource that Renewal Northwest model would have come from system resources, that

957
01:24:17,490 --> 01:24:20,890
results in more over build than

958
01:24:20,890 --> 01:24:25,590
pacificors, right? So every resource that

959
01:24:25,590 --> 01:24:27,850
is no longer supported by a

960
01:24:27,850 --> 01:24:32,530
CITIS decision in an IRP framework

961
01:24:32,530 --> 01:24:36,850
that has to become a system resource

962
01:24:36,850 --> 01:24:39,030
and as soon as it becomes a system

963
01:24:39,030 --> 01:24:41,510
resource we have to procure four times

964
01:24:41,510 --> 01:24:44,910
more to meet the same need for

965
01:24:44,910 --> 01:24:53,590
Oregon, right? So, taking to the extreme, let's just say all about our HB 2021 resources should

966
01:24:53,590 --> 01:25:01,170
instead be system resources, right? So, Renewable Northwest methodology is saying that, hey,

967
01:25:01,490 --> 01:25:07,790
pack, you know, instead of the three gigs you need, you actually need to procure 10 gigawatts

968
01:25:07,790 --> 01:25:16,570
by 2035. And Oregon gets, you know, the 27-28% of that, right? So the point here is to show

969
01:25:16,570 --> 01:25:23,870
that every time a site is resource becomes a system resource, that is necessarily more

970
01:25:23,870 --> 01:25:32,170
overbilled than Pacificoors approach. And, you know, the third issue here, I think

971
01:25:32,170 --> 01:25:33,810
think I hope really brings it home.

972
01:25:35,510 --> 01:25:43,270
Even if, you know, CIVCOR's approach has some, you know, flaws with our liability assessments

973
01:25:43,270 --> 01:25:48,070
or there's some modeling errors that we need to address or there's some EDAM implications

974
01:25:48,070 --> 01:25:52,470
that, you know, could impact our results.

975
01:25:52,830 --> 01:26:02,350
Even if like we add those fixes, I don't think there's a colorable argument that the

976
01:26:02,350 --> 01:26:11,610
system needs seven gigawatts of resources by 2035, right? And so if that's the conclusion,

977
01:26:12,520 --> 01:26:20,890
every time a site is resource for Oregon that's needed to meet HB2021 requirements, every time

978
01:26:21,400 --> 01:26:30,870
that resource has to be shared with the system, that creates an obligation for PAC to try and seek

979
01:26:30,870 --> 01:26:41,090
recovery of those resources from other states, and I just don't see the world where we have to

980
01:26:41,930 --> 01:26:51,010
seek recovery in our other states for a material volume of resources necessary to comply with

981
01:26:51,010 --> 01:26:58,670
HP 2021, where there isn't a need identified. So I'm really curious. I see Jim's got his hand up,

982
01:26:58,670 --> 01:27:01,130
But this is my kind of-

983
01:27:01,130 --> 01:27:05,590
I appreciate you sort of laying this out

984
01:27:05,590 --> 01:27:07,310
because I think this is we have, we have,

985
01:27:07,850 --> 01:27:11,450
I would diagnose, we have a very much

986
01:27:11,450 --> 01:27:13,310
a talking past each other's situation.

987
01:27:14,190 --> 01:27:19,510
I am not hearing stakeholders have articulate

988
01:27:19,510 --> 01:27:22,150
the sort of all or nothing approach

989
01:27:22,150 --> 01:27:24,830
that you are arguing.

990
01:27:25,030 --> 01:27:25,810
So I hear you.

991
01:27:25,810 --> 01:27:35,450
So I understand what you are saying around DEQ compliance is via MSP cost allocation

992
01:27:36,340 --> 01:27:44,790
if a resource's system cost allocated only 27% or a third or whatever the right allocation

993
01:27:44,790 --> 01:27:50,770
factor is in the moment can be accounted for DEQ compliance.

994
01:27:50,770 --> 01:27:59,650
And thus, for example, all of the wind that we have procured over the last several years

995
01:27:59,650 --> 01:28:03,310
Oregon only gets to claim 30% roughly.

996
01:28:04,030 --> 01:28:14,010
Sort of is the challenge and you're pointing to, I think, the reality of 1547

997
01:28:14,010 --> 01:28:18,450
and taking the thermal fleet out of Oregon's cost allocation.

998
01:28:19,270 --> 01:28:46,850
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.

999
01:28:47,550 --> 01:28:49,870
Can you speak a little bit to that?

1000
01:28:50,030 --> 01:28:53,570
Can you hear that nuance or that stacking up?

1001
01:28:54,150 --> 01:28:55,350
Is that not valid?

1002
01:28:56,250 --> 01:29:01,470
Yeah, so I think I can have one thing of value to say here,

1003
01:29:01,770 --> 01:29:05,330
but then I think I'm out of my depth, right?

1004
01:29:09,280 --> 01:29:11,460
Where I think, or Northwest,

1005
01:29:13,800 --> 01:29:18,020
the discussion on reliability where we diverge

1006
01:29:18,020 --> 01:29:31,160
is specific core things that Oregon's requirement to get out of coal by 2030, that is a state-specific

1007
01:29:31,160 --> 01:29:40,280
policy that creates state-specific reliability problems. Because when Oregon exits coal,

1008
01:29:41,080 --> 01:29:47,780
those resources don't necessarily retire. They will keep serving states that keep that energy

1009
01:29:48,020 --> 01:29:56,960
in their allocation of resources, so when Oregon loses a gigawatt of, you know,

1010
01:29:56,960 --> 01:29:59,440
based load resources.

1011
01:30:00,000 --> 01:30:29,080
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.

1012
01:30:29,080 --> 01:30:37,260
But again, I'm, you know, that's just my takeaway, but I really need Randy to come on and

1013
01:30:37,260 --> 01:30:42,920
do his thing because, yeah, happy to be corrected where, you know, I'm a spoke on something.

1014
01:30:43,140 --> 01:30:46,660
So we go back to, we have a very fundamental difference of view.

1015
01:30:47,020 --> 01:30:57,040
Pack believes it has a reliable portfolio right now and it is Oregon's choices about resources

1016
01:30:57,040 --> 01:30:58,960
that are making it unreliable.

1017
01:30:59,820 --> 01:31:05,200
And I can't speak to where we're at on system reliability.

1018
01:31:05,800 --> 01:31:09,900
I was just thinking of the specific Oregon policy

1019
01:31:09,900 --> 01:31:12,780
for 2030. Can I see Randy's here?

1020
01:31:13,000 --> 01:31:13,760
So I'll...

1021
01:31:13,760 --> 01:31:15,540
Yeah, can you answer the system?

1022
01:31:15,700 --> 01:31:18,980
Your perspective on the system reliability issue.

1023
01:31:19,880 --> 01:31:21,380
High load hours.

1024
01:31:22,480 --> 01:31:24,640
You know, what we don't have in this IRP

1025
01:31:24,640 --> 01:31:32,740
He is any analysis of any heat map about where you are under duress in South Africa.

1026
01:31:33,100 --> 01:31:33,260
Yeah.

1027
01:31:33,560 --> 01:31:35,120
Thank you, Chair Tyne.

1028
01:31:36,340 --> 01:31:43,800
What we do have is what the IRP traditionally carries, which is a description of what proxy

1029
01:31:43,800 --> 01:31:50,440
resources are needed where and when and what we see is that the East needs about 300 megawatts.

1030
01:31:51,840 --> 01:31:54,220
And so there is potential there.

1031
01:31:54,220 --> 01:32:01,260
There's no doubt if you entangle that with questions or concerns about

1032
01:32:01,260 --> 01:32:07,240
deliverability, about Eastside interest and the kinds of resources that would be

1033
01:32:07,240 --> 01:32:14,340
dictated by HB2021, there are a lot of complications. And if you take 300

1034
01:32:14,340 --> 01:32:21,640
megawatts out of a need of three gigawatts, I'm not sure that you're looking at a

1035
01:32:21,640 --> 01:32:28,520
problem that is of the magnitude that that I've heard being expressed or the urgency that I've

1036
01:32:28,520 --> 01:32:36,640
seen in, you know, comments or conversations. And one thing that we did not talk about yet,

1037
01:32:36,640 --> 01:32:46,920
that I'll mention in that vein, just to be sure that we don't get caught up in this is the

1038
01:32:46,920 --> 01:32:55,020
presence of proxy energy efficiency in the load and resource balance, and I'm only

1039
01:32:55,020 --> 01:33:00,160
mentioning it, we're not open that can worms, but I just want to say that that's not

1040
01:33:00,160 --> 01:33:06,340
an error or mistake, as R&W called it out, it's intentional, and it's included for good reason,

1041
01:33:06,480 --> 01:33:15,780
based on expectation. We include in that view of the system anything that is committed or

1042
01:33:15,780 --> 01:33:20,840
are definitively anticipated as well as resources that are actually currently in operation.

1043
01:33:21,060 --> 01:33:26,820
And we have full expectation that the east is going to get a share of energy efficiency

1044
01:33:26,820 --> 01:33:29,360
that's very similar to what we have forecasted.

1045
01:33:29,420 --> 01:33:30,520
And so it's not missing.

1046
01:33:30,720 --> 01:33:34,800
There's not additional need on the east because we included it in that view.

1047
01:33:35,480 --> 01:33:37,560
It's intentionally included in that view.

1048
01:33:38,000 --> 01:33:42,380
So again, about 300 megawatts on the east is what they need.

1049
01:33:42,380 --> 01:33:43,320
Okay.

1050
01:33:47,490 --> 01:33:54,570
I'm going to invite Jim, you to respond. I think this is helpful looking to my colleagues.

1051
01:33:55,030 --> 01:34:00,310
Is this a helpful sort of unpacking of the issues for you or is it leaving you with?

1052
01:34:01,650 --> 01:34:08,990
Go ahead. Go ahead. Yes, I'm not hearing overlap in agreement about sort of basic assumptions of

1053
01:34:08,990 --> 01:34:12,910
how Oregon and the entire system are integrated.

1054
01:34:15,150 --> 01:34:16,470
Yeah, I agree with that.

1055
01:34:17,870 --> 01:34:22,310
Yeah, I mean, I, my goal is I stand for us

1056
01:34:22,310 --> 01:34:23,650
to try to get useful information

1057
01:34:23,650 --> 01:34:26,250
to get us to a successful conclusion with this IRP.

1058
01:34:27,650 --> 01:34:29,630
I still feel like there's this lack of,

1059
01:34:30,290 --> 01:34:31,830
like you said, talking past each other

1060
01:34:32,270 --> 01:34:33,850
in terms of what's needed to get there.

1061
01:34:34,150 --> 01:34:38,010
And I still, it feels to me like what's being fed to us

1062
01:34:38,010 --> 01:34:44,110
is trust us. We've looked at it. It's not important to understand that underlying how the system

1063
01:34:44,110 --> 01:34:50,650
would function. And I think what's repeated to be saying, being said back is, no, it's really

1064
01:34:50,650 --> 01:34:56,550
important. And yeah, we may not like the outcome of it. It may not come out exactly, but it's important

1065
01:34:56,550 --> 01:35:02,370
information to be able to understand going forward and to unpack in a lot of different ways

1066
01:35:02,370 --> 01:35:06,890
in dockets that are going to be coming before us. Like it's important information to have as a baseline.

1067
01:35:08,630 --> 01:35:17,630
I appreciate that Commissioner Perkins, I feel like we don't have a common base of understanding

1068
01:35:19,210 --> 01:35:28,690
yet around system need, organ need and that you are correct. Well, this is not a cost allocation

1069
01:35:28,690 --> 01:35:37,670
docket, this will be, this is the opportunity to build a common understanding of that need.

1070
01:35:38,930 --> 01:35:45,130
With that, Jim, you're welcome to pitch in.

1071
01:35:46,150 --> 01:35:51,450
Yeah, thanks, Chair Tony. So there's a lot there, maybe just to kind of break this out into

1072
01:35:51,450 --> 01:35:58,310
sections here starting with Randy's original comments and again I appreciate

1073
01:35:58,310 --> 01:36:05,050
Pacificoors input on these very complicated matters but but but I I agree with

1074
01:36:05,050 --> 01:36:09,970
with the dyes in terms I think we are returning to this talking past each other

1075
01:36:09,970 --> 01:36:19,260
so for example R&W is not implying or arguing that policies like SB1547 has

1076
01:36:19,260 --> 01:36:20,560
no impact on system reliability.

1077
01:36:21,240 --> 01:36:22,580
We agree with that statement.

1078
01:36:24,220 --> 01:36:27,400
What we're saying is, because of this lack

1079
01:36:27,400 --> 01:36:30,280
of this counterfactual, where we ignore all environmental

1080
01:36:30,280 --> 01:36:32,420
policies, regardless of the location,

1081
01:36:32,740 --> 01:36:34,740
and just look to see what the system would need.

1082
01:36:35,480 --> 01:36:39,460
Both PACIs and PAC West were purely reliability only reasons.

1083
01:36:40,280 --> 01:36:42,660
Without that, we don't understand what those cost

1084
01:36:42,660 --> 01:36:45,220
differentials are, or those resource differentials are.

1085
01:36:45,220 --> 01:36:53,980
And so we can't have a baseline to then understand these incremental impacts of these jurisdictional

1086
01:36:53,980 --> 01:36:57,580
policies that are not reliability related.

1087
01:36:58,380 --> 01:37:07,440
So a framework that would allow for this layering on of state policies would provide that information

1088
01:37:07,440 --> 01:37:13,980
to parse out what amount of resources are going to be needed regardless for reliability.

1089
01:37:13,980 --> 01:37:20,000
And then what's that incremental resource that's going to be needed just for the state-led

1090
01:37:20,000 --> 01:37:21,160
environmental policies?

1091
01:37:21,800 --> 01:37:23,980
So I think that's our first point of disagreement there.

1092
01:37:24,840 --> 01:37:25,940
Second point of disagreement.

1093
01:37:26,220 --> 01:37:32,640
Randy had mentioned that Renewable Northwest along with many other stakeholders are advocating

1094
01:37:32,640 --> 01:37:37,520
for the system-wide approach, but that system-wide approach is impossible to conduct given these

1095
01:37:37,520 --> 01:37:42,240
diametrically opposed constraints that they would need to implement in the model.

1096
01:37:42,240 --> 01:37:50,600
While we agree that this is a very difficult and complex process, we disagree with the premise

1097
01:37:50,600 --> 01:37:55,480
that that's not feasible to do these system-wide runs and to incorporate this system-wide

1098
01:37:55,480 --> 01:38:02,860
run into a framework to identify if any savings are on the table to be distributed across

1099
01:38:02,860 --> 01:38:09,760
all specific core customers when you do a system planning on a holistic basis compared to

1100
01:38:09,760 --> 01:38:14,180
And what the cost would be when you have to do this siloed approach as you layer on these

1101
01:38:14,180 --> 01:38:15,360
individual state policies.

1102
01:38:16,280 --> 01:38:20,780
So again, there's a talking past one another here in terms of we're not saying the system

1103
01:38:20,780 --> 01:38:28,280
wide approach is going to be necessarily the most opt or present a large bucket of savings.

1104
01:38:28,280 --> 01:38:28,920
It may not.

1105
01:38:29,280 --> 01:38:35,680
But at least we have the information to see is there any synergies across the system to where

1106
01:38:35,680 --> 01:38:42,420
we can then distribute those savings accordingly so that Oregon is still paying for its specific

1107
01:38:42,980 --> 01:38:50,160
cost premiums associated with these environmental policies, like SB 1547 and HB 2021, but there

1108
01:38:50,160 --> 01:38:54,820
might not be as much of a cost penalty due to the system-wide savings that we could identify

1109
01:38:54,820 --> 01:38:55,780
with such a run.

1110
01:38:56,340 --> 01:39:01,440
So that's the second point of contention there, and I do think it's possible to evaluate

1111
01:39:01,440 --> 01:39:05,260
the feasibility of implementing some sort of framework that would accomplish this.

1112
01:39:06,060 --> 01:39:10,020
So just for clarification, R&W hasn't proposed the framework.

1113
01:39:10,220 --> 01:39:13,980
We have a framework in our heads of what we think could work.

1114
01:39:14,160 --> 01:39:19,920
What we're asking for is specific or work with state holders to essentially evaluate this

1115
01:39:19,920 --> 01:39:20,560
sort of framework.

1116
01:39:20,780 --> 01:39:22,200
To see, like, is this feasible?

1117
01:39:22,720 --> 01:39:27,860
And if not, what is the actual thing preventing this sort of framework from being implemented?

1118
01:39:27,860 --> 01:39:29,680
It could be from a practical standpoint.

1119
01:39:30,260 --> 01:39:33,480
Jim, these requires a significant number of additional runs.

1120
01:39:34,100 --> 01:39:36,760
These runs, each one of these runs will take x number of hours

1121
01:39:37,240 --> 01:39:40,520
just from a kind of to operationalize this sort of approach

1122
01:39:41,000 --> 01:39:42,360
with all the portfolio variants.

1123
01:39:42,740 --> 01:39:43,680
It's not feasible.

1124
01:39:43,840 --> 01:39:46,520
We would be running studies for six months out of the year.

1125
01:39:47,800 --> 01:39:50,800
We won't know where we fall on some of these things

1126
01:39:50,800 --> 01:39:53,300
until we at least have that conversation

1127
01:39:53,300 --> 01:39:55,400
of what we think would be a more complete,

1128
01:39:55,400 --> 01:40:03,000
more fair framework until we can work with Pacific or another stakeholders to propose such

1129
01:40:03,000 --> 01:40:08,280
frameworks to identify the strengths and minds of each approach because everything has a trade-off.

1130
01:40:09,700 --> 01:40:13,420
And then the last point that Randy had mentioned was none of the stakeholders had brought these

1131
01:40:13,420 --> 01:40:17,400
concerns during the public input meetings. I don't feel I have to fail at the fair comment.

1132
01:40:18,180 --> 01:40:23,480
One, primarily because we were actually trying to understand this problem during the public input

1133
01:40:23,480 --> 01:40:24,280
with stakeholder meeting.

1134
01:40:24,780 --> 01:40:27,380
Getting access to the Plexus file really helped us

1135
01:40:27,380 --> 01:40:29,520
diving to the details to understand

1136
01:40:29,980 --> 01:40:32,680
how these constraints are set up because it's really crucial.

1137
01:40:33,580 --> 01:40:35,620
And until we could get into that file,

1138
01:40:36,480 --> 01:40:39,000
we didn't have, I personally didn't have

1139
01:40:39,000 --> 01:40:40,780
a complete understanding of what was going on.

1140
01:40:41,160 --> 01:40:44,100
We submitted multiple public stakeholder feedback forms

1141
01:40:44,100 --> 01:40:45,080
to try to get at it.

1142
01:40:45,440 --> 01:40:46,680
And some of those were helpful,

1143
01:40:46,900 --> 01:40:48,660
the response that we received from Pacificoor,

1144
01:40:48,960 --> 01:40:51,400
but it was still incomplete responses.

1145
01:40:51,400 --> 01:40:57,300
And we never could get a true accurate and complete understanding of how the model was

1146
01:40:57,300 --> 01:40:59,680
actually set up until we got access to the file.

1147
01:41:00,340 --> 01:41:05,960
So rather than just try to put comments out there that may or may not be modically

1148
01:41:06,500 --> 01:41:11,600
valid from modeling standpoint, R&W really wants to understand the problem first and then move

1149
01:41:11,600 --> 01:41:12,520
forward with our comments.

1150
01:41:14,580 --> 01:41:20,580
Transitioning to the comments made by Zachary, I believe it was, I'm going to sound like a

1151
01:41:20,580 --> 01:41:24,980
broken record here but again we're talking past each other. I think Zachary with all

1152
01:41:24,980 --> 01:41:28,880
the respect fundamentally misunderstand the points that we're trying to argue here.

1153
01:41:29,640 --> 01:41:35,400
In these counterfactual studies we're not saying that a resource identified as a system

1154
01:41:35,400 --> 01:41:40,080
need would be physically built. We're just trying to identify what the cost associated with

1155
01:41:40,080 --> 01:41:45,020
that counterfactual study would be to be going to understand the cost premium once we layer

1156
01:41:45,020 --> 01:41:49,720
in the actual resource build with the environmental constraints activated.

1157
01:41:50,340 --> 01:41:55,840
So we're not saying goal build stuff that you would otherwise if Oregon wasn't implementing

1158
01:41:55,840 --> 01:41:59,700
these policies, and then we're going to build stuff on top of that, we're not advocating

1159
01:41:59,700 --> 01:42:00,340
for that at all.

1160
01:42:00,340 --> 01:42:05,240
We're just trying to identify where the overlap is, so we don't have to commit any over

1161
01:42:05,240 --> 01:42:05,600
build.

1162
01:42:06,180 --> 01:42:10,940
And if there is some benefits here, all stakeholders can share in those cost savings.

1163
01:42:10,940 --> 01:42:16,740
And then the last item around the energy efficiency, that's great to know in terms of clarity.

1164
01:42:17,160 --> 01:42:24,080
But again, this is just another example in which pacificor presents confusing and sometimes

1165
01:42:24,080 --> 01:42:29,680
incomplete information in their IRP or another official proceeding of documents.

1166
01:42:30,200 --> 01:42:36,640
And until we actually comment on those, then we get additional clarifying information.

1167
01:42:36,640 --> 01:42:42,760
And, you know, one can reasonably assume that if we're looking at just a existing resource

1168
01:42:42,760 --> 01:42:46,940
only load and resource balance, you would not expect to see a significant increase

1169
01:42:46,940 --> 01:42:51,400
in energy efficiency unless there's some specific reason why that would occur.

1170
01:42:52,320 --> 01:42:56,600
Otherwise, it's fair to assume that the model would be selecting that to occur, which again

1171
01:42:56,600 --> 01:42:58,120
would then fall into that proxy resource.

1172
01:42:58,700 --> 01:43:04,360
So just another example of how it can be very confusing and difficult to truly understand

1173
01:43:04,360 --> 01:43:09,060
what's going on the Pacific or side offense and that trust issue there that you guys had mentioned,

1174
01:43:09,060 --> 01:43:15,700
I think is very much in a perceptive comment and until we can continue to work through these

1175
01:43:15,700 --> 01:43:20,960
problems, we're going to I'm afraid continue to talk past one another. So I was a lot and I'll stop

1176
01:43:20,960 --> 01:43:21,200
there.

1177
01:43:23,350 --> 01:43:27,990
Thank you. Any follow-ups colleagues with with Jim?

1178
01:43:32,570 --> 01:43:37,970
I appreciate the comments and Randy

1179
01:43:37,970 --> 01:43:58,830
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

1180
01:43:59,870 --> 01:44:04,650
because I want to make sure we have time for that for folks to raise issues there.

1181
01:44:05,370 --> 01:44:05,890
Randy.

1182
01:44:08,320 --> 01:44:15,520
Thank you, Chertani. Let me get my hand down out of the way. Yeah, Jim,

1183
01:44:15,640 --> 01:44:20,500
I appreciate your comments and I think that our conversations, consultations,

1184
01:44:20,500 --> 01:44:27,400
had been very fruitful. I agree that access to the database has been critical to

1185
01:44:27,400 --> 01:44:34,260
moving the conversation forward. But I would like to point out that this too is a new paradigm.

1186
01:44:34,840 --> 01:44:40,040
The complexities in the planning environment that we currently live in has been driving

1187
01:44:41,000 --> 01:44:50,880
Pacificoors IRP in certain directions for a long time. In the 2023 IRP, we made a huge drive

1188
01:44:50,880 --> 01:44:56,380
for transparency in our workpapers and made more of them public than we ever had before. We continued

1189
01:44:56,380 --> 01:44:59,900
that the 2025 IRP we

1190
01:45:00,000 --> 01:45:29,560
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,

1191
01:45:29,560 --> 01:45:38,780
But, you know, this is a new area in terms of the need for all of these steps and efforts

1192
01:45:38,780 --> 01:45:44,140
and increasing the transparency of the IRP document and all the data that goes along with

1193
01:45:44,140 --> 01:45:44,480
it.

1194
01:45:45,060 --> 01:45:48,360
You know, supplying the database, that's a pretty new thing.

1195
01:45:49,200 --> 01:45:53,560
You know, we've been working with Washington on that for a while, we've had some struggles

1196
01:45:53,560 --> 01:45:59,320
and some challenges, I'm not sure what use everyone gets when we supply the database,

1197
01:45:59,320 --> 01:46:06,180
which we've done several times now, I think Jim has made more use of it and his folks at R&W

1198
01:46:06,180 --> 01:46:11,140
than anyone that we've ever seen. And that's fantastic, but I want to point out that

1199
01:46:11,140 --> 01:46:19,680
that in and of itself is a new paradigm that we're now existing in to share and discuss and move

1200
01:46:19,680 --> 01:46:20,720
through this information.

1201
01:46:22,500 --> 01:46:27,980
You know, if the database had been, you know,

1202
01:46:28,100 --> 01:46:30,800
if it was available at the beginning of the public input process,

1203
01:46:30,800 --> 01:46:33,480
we would be in a whole different world right now.

1204
01:46:33,960 --> 01:46:39,620
I'm not so sure that from the perspective of specific course attempts

1205
01:46:39,620 --> 01:46:44,760
to be open and transparent, I'm not so sure that we are passing

1206
01:46:44,760 --> 01:46:47,080
each other as much as it might appear.

1207
01:46:47,080 --> 01:46:50,960
I think really we're reaching clarity about where our fundamental differences lay.

1208
01:46:51,880 --> 01:46:54,360
And we're certainly happy to have those discussions.

1209
01:46:54,760 --> 01:47:04,000
We were recently invited to have a conversation with various stakeholders on the 2025 IRP

1210
01:47:04,000 --> 01:47:08,880
update and what might be done looking forward to address issues with the modeling.

1211
01:47:09,500 --> 01:47:13,000
We're open to hearing those ideas and we're open to working with those ideas.

1212
01:47:13,000 --> 01:47:16,900
So I just wanted to make it clear that that's the case.

1213
01:47:18,800 --> 01:47:36,200
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.

1214
01:47:36,880 --> 01:47:46,000
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.

1215
01:47:46,460 --> 01:47:53,040
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.

1216
01:47:54,340 --> 01:48:05,420
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.

1217
01:48:05,420 --> 01:48:13,540
You know, I've not seen any, all of the evidence on being able to run the real holy grail

1218
01:48:14,060 --> 01:48:20,320
of a modeling attempt that integrates everything simultaneously, all of the evidence so far

1219
01:48:20,320 --> 01:48:23,920
has been negative and have not seen anything to the contrary.

1220
01:48:24,260 --> 01:48:29,520
That's not Randy, and I don't think I'm not for when seeking that holy grail.

1221
01:48:29,520 --> 01:48:37,780
Well, I think I am always looking from an IRP, for an adaptive decision-making process

1222
01:48:37,780 --> 01:48:43,400
with that tells us directionally important information.

1223
01:48:44,480 --> 01:48:48,640
And so I, for one, in terms of engaging with the IRP over the years,

1224
01:48:50,680 --> 01:48:52,000
have not been very

1225
01:48:52,000 --> 01:48:55,900
interested in, is it, you know, is it 10 megawatts this way or 10 megawatts that way?

1226
01:48:55,900 --> 01:49:03,200
this is all directional from my perspective. I'm curious, I am, so we've had some

1227
01:49:03,200 --> 01:49:15,160
conversation about system-wide, East Side being reliable. If we stripped back 1547

1228
01:49:15,160 --> 01:49:22,660
and 2021, would the West Side be reliable? I can't tell, and I think that's part

1229
01:49:22,660 --> 01:49:34,660
of sort of not knowing whether we're headed into a physical operational problem or whether

1230
01:49:34,660 --> 01:49:44,140
we're headed into a policy compliance problem. I can't tell which I'm headed into and I, as a

1231
01:49:44,140 --> 01:49:53,560
regulator would address those differently, right? Is there a way you can help us? Maybe

1232
01:49:53,560 --> 01:50:00,080
and maybe this is a request for reply comments. In your reply comments, clarify for us whether

1233
01:50:00,080 --> 01:50:07,560
we're headed into an operational problem or a cost allocation policy compliance problem.

1234
01:50:08,960 --> 01:50:14,240
Right. And that's an excellent point. It really is. And, you know, often when we start the IRP,

1235
01:50:15,060 --> 01:50:19,100
you know, we're looking at it from a perspective of what does it look like all in

1236
01:50:19,620 --> 01:50:25,140
under different sets of circumstances? Sure, of course. Yeah, yeah. So, I mean, I appreciate your

1237
01:50:25,140 --> 01:50:32,060
understanding of that. And, you know, to the extent that we didn't run a study that would be very

1238
01:50:32,060 --> 01:50:40,160
informative for the purposes that you're describing? Yeah, I can't all by myself sitting

1239
01:50:40,160 --> 01:50:45,240
here make a commitment for the team, the company and our priorities, but I'm very interested

1240
01:50:45,240 --> 01:50:48,420
in that. I would certainly like to do that. And I think we're going to take a serious

1241
01:50:48,420 --> 01:50:54,080
look at, you know, how we reply to those comments and see if there's anything that we can

1242
01:50:54,080 --> 01:50:59,960
add. And it, you know, what kind of analysis that might be, you know, I also can't commit

1243
01:50:59,960 --> 01:51:07,020
to sitting here at the moment, but we're considering it. Certainly, our focus has been on

1244
01:51:07,020 --> 01:51:14,120
our newly initiated public input meeting series for the 2027 IRP and planning for the

1245
01:51:14,120 --> 01:51:21,240
2025 IRP update and what we can accomplish ahead of that. But in the more immediate sense,

1246
01:51:21,600 --> 01:51:28,140
certainly, there might be something that we can do that would help give confidence and comfort.

1247
01:51:30,240 --> 01:51:44,240
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?

1248
01:51:44,980 --> 01:51:46,660
Haven't talked as much about transmission.

1249
01:51:46,660 --> 01:51:59,200
I just want to echo your distillation, I think, of the complexity right here, and support

1250
01:51:59,200 --> 01:52:00,520
that request that you made.

1251
01:52:03,740 --> 01:52:10,000
Yeah, I would agree fully, and when I think about the six-date system that you serve, I

1252
01:52:12,140 --> 01:52:17,820
can't imagine that this wouldn't be useful information for all states and regulators and

1253
01:52:17,820 --> 01:52:25,780
policy makers, just being able to understand kind of the underlying impacts of how the system

1254
01:52:25,780 --> 01:52:30,940
would operate without constraints, how the system operates with constraints. I think

1255
01:52:30,940 --> 01:52:36,840
that baseline information is so helpful for everybody to understand the reality of the

1256
01:52:36,840 --> 01:52:43,800
world and to look forward as new changes and new policies are considered and, you know, fuel

1257
01:52:43,800 --> 01:52:47,960
prices change and all the different pieces change. But I just think it's really important

1258
01:52:47,960 --> 01:52:52,080
for policymakers and for regulators across the statistic whether you're in Utah or you're

1259
01:52:52,080 --> 01:52:54,000
in Oregon. I think it's important.

1260
01:52:56,190 --> 01:53:01,550
Yeah, I really agree, I think, colleagues across

1261
01:53:01,550 --> 01:53:08,090
the West are really curious what the cost of Utah's decisions on Huntington are. Those are

1262
01:53:08,090 --> 01:53:13,990
plants that aren't, you know, maybe, maybe you're necessary for reliability

1263
01:53:13,990 --> 01:53:23,650
perspective, maybe art, who can tell? And so it creates a real challenge. Okay. Let's pivot

1264
01:53:23,650 --> 01:53:32,610
to the CEP discussion. That has not come up as much. It's a Renewal Northwest slide deck didn't

1265
01:53:33,270 --> 01:53:41,690
raise it as centrally. I'd love to see a show of hands on anyone who'd like to talk about the challenge there.

1266
01:53:45,880 --> 01:53:49,600
You know, I think in particular as we, while we have not

1267
01:53:51,240 --> 01:53:59,540
crystallized how we're going to handle a cost cat proceeding, having so little agreement around

1268
01:53:59,540 --> 01:54:07,800
And what is being driven by policy versus driven by simple load growth and reliability is

1269
01:54:11,160 --> 01:54:13,260
port 10's real challenge.

1270
01:54:15,000 --> 01:54:19,700
Okay, I'm not seeing hands, I'm a little bit surprised no one wants to talk about the

1271
01:54:19,700 --> 01:54:20,040
CEP.

1272
01:54:22,310 --> 01:54:22,590
Fred?

1273
01:54:24,330 --> 01:54:25,550
Well, thanks, Chair.

1274
01:54:25,670 --> 01:54:28,530
Tommy, I'll venture to dive in on this.

1275
01:54:28,530 --> 01:54:36,550
I think there's a complex overlap, like everything's complex, between the quantitative aspects

1276
01:54:36,550 --> 01:54:42,110
we've been focusing on, the qualitative aspects of the CEP in terms of continual progress

1277
01:54:42,770 --> 01:54:47,610
and a lot of the other issues that are addressed in the comments that we signed on, along

1278
01:54:47,610 --> 01:54:48,590
with the advocates.

1279
01:54:49,190 --> 01:54:54,550
So I won't try to cover everything, but I just want to give some basic impressions from

1280
01:54:54,550 --> 01:54:55,730
what we've been saying.

1281
01:54:55,730 --> 01:55:05,270
The first thing is that the continual progress issue has been impeded by PACS decision to cancel the 2022 RFP.

1282
01:55:06,610 --> 01:55:09,150
And there are lots of aspects to that.

1283
01:55:09,370 --> 01:55:10,170
You know, here we are.

1284
01:55:11,490 --> 01:55:13,990
I don't want to say it's what are under the bridge.

1285
01:55:14,130 --> 01:55:15,770
There are some things we can do about that.

1286
01:55:16,250 --> 01:55:21,670
But there's no question this is created a real crunch in where we are now at.

1287
01:55:21,670 --> 01:55:39,190
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.

1288
01:55:39,190 --> 01:55:46,230
And the current issue I think a lot is how much of the expiring

1289
01:55:46,230 --> 01:55:51,130
wind and solar tax credits can be captured for projects that will be built

1290
01:55:51,130 --> 01:55:55,590
or should be built no matter what, even under what we consider to be an

1291
01:55:55,590 --> 01:55:58,730
underpowered 2025 IRPS it now stands.

1292
01:55:59,670 --> 01:56:02,890
And that's got a ticking clock eye for sure.

1293
01:56:03,810 --> 01:56:11,390
What efforts can be made for Oregon under the Oregon Cytus RFP and for the other Washington

1294
01:56:11,390 --> 01:56:20,530
Cytus RFP and for potential action by Pacificoor in the East UIUC area where our colleagues

1295
01:56:20,530 --> 01:56:24,550
at Utah clean energy and others have really pushed forward that idea.

1296
01:56:25,030 --> 01:56:29,590
I think there's a lot more that can still be done and shall I also mention the governor's

1297
01:56:29,590 --> 01:56:30,370
executive order.

1298
01:56:30,370 --> 01:56:39,830
So those are all in this world here around this planning prospect that has a kind of current action component right at this moment.

1299
01:56:40,470 --> 01:56:45,870
So we want to reflect that we're not going to be able to solve everything but we still have some opportunities.

1300
01:56:48,850 --> 01:56:57,310
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.

1301
01:56:57,310 --> 01:57:04,530
to help guide things more directly so that we don't end up in this kind of situation again.

1302
01:57:05,270 --> 01:57:12,310
So those are broad comments on the kind of overview and the continual progress issue.

1303
01:57:12,750 --> 01:57:18,030
I do want to mention a couple more things from our detailed comments just to put this in the record.

1304
01:57:18,030 --> 01:57:25,190
First, in the area we discussed is that the CBRE effort is looking like a very important

1305
01:57:25,190 --> 01:57:30,210
thing that we can do going forward, but we believe that the company's effort there

1306
01:57:30,210 --> 01:57:31,170
should be more robust.

1307
01:57:32,370 --> 01:57:38,230
Secondly, there is additional refinements that we detailed in our comments and in support

1308
01:57:38,230 --> 01:57:42,250
of the CBI as a community benefit indicators.

1309
01:57:43,030 --> 01:57:47,510
And finally, and I think this is again practice and broad issues facing the commission and

1310
01:57:47,510 --> 01:57:53,770
all of us as well as the company additional modeling to help and survey work and so forth

1311
01:57:53,770 --> 01:58:00,430
to help inform and deepen our view, our understanding of affordability and energy burden

1312
01:58:01,170 --> 01:58:06,430
faced literally right now by Oregonians and by Pacificor customers. So there's kind of

1313
01:58:06,430 --> 01:58:08,050
general comments. I hope that's helpful.

1314
01:58:11,050 --> 01:58:15,450
Thanks, Fred. I appreciate it. Nick.

1315
01:58:19,580 --> 01:58:20,040
Thanks.

1316
01:58:20,040 --> 01:58:22,580
Sure, Tony, let me just see if I can come on video here.

1317
01:58:24,200 --> 01:58:27,480
Oh, it doesn't look like it. Well, anyway, um, yeah, I just

1318
01:58:27,480 --> 01:58:31,380
might be able to turn you on. I think she had to turn you off earlier. So

1319
01:58:31,380 --> 01:58:34,500
Oh, thank you. Okay. Um, well, maybe just to kick it off, I

1320
01:58:34,500 --> 01:58:39,020
appreciate you raising the CEP issue and I do acknowledge this is not been the

1321
01:58:39,020 --> 01:58:43,140
focus for R&W in this cycle, given how deeply we've been engaged with the

1322
01:58:43,140 --> 01:58:47,000
IRP and just the sort of nature of the CEP coming out later in the process

1323
01:58:47,000 --> 01:58:54,200
with somewhat limited time. Our focus is really been on making sure, just like in the 23-a-RP,

1324
01:58:54,360 --> 01:58:59,100
we have the need identified. I think we'd like to see action in the form of procurement

1325
01:58:59,100 --> 01:59:05,220
to actually get us on track there. So we know from the IRP and the CEP,

1326
01:59:05,580 --> 01:59:09,700
their substantial need for nuclear energy resources, we know that that's likely under-accounted,

1327
01:59:09,780 --> 01:59:14,760
given the exclusion of large loads, which tend to have high utilization, high capacity factors.

1328
01:59:14,760 --> 01:59:18,920
so that's going to drive more energy requirements and higher HB 2021 requirements.

1329
01:59:19,820 --> 01:59:24,800
We're interested in getting a better understanding of the analytical framework used in the CEP

1330
01:59:25,740 --> 01:59:31,740
to be candid in both the stakeholder meeting and in our follow-up review of the documents provided.

1331
01:59:31,900 --> 01:59:36,060
I think we've struggled with just understanding some of the basic elements of the analysis,

1332
01:59:36,420 --> 01:59:40,160
some things where costs seem to be sort of inverted in magnitude.

1333
01:59:40,160 --> 01:59:48,660
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.

1334
01:59:48,940 --> 01:59:59,960
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.

1335
02:00:00,000 --> 02:00:02,000
Just to keep those projects moving forward.

1336
02:00:04,470 --> 02:00:31,630
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

1337
02:00:31,630 --> 02:00:37,330
as a process isn't important on its own, but just to triage our engagement with the limited time

1338
02:00:37,330 --> 02:00:40,910
and the issues we've identified in the IRP, we've just not spent as much time there,

1339
02:00:41,570 --> 02:00:47,010
and I think while we should collectively get that to a place where it is really meaningful,

1340
02:00:47,610 --> 02:00:54,570
I don't think we're going to do that in time for action or action item review in the commission's

1341
02:00:54,570 --> 02:00:56,250
therapy process. Okay.

1342
02:01:00,720 --> 02:01:07,120
Other perspectives or anything else as we come up towards 12,

1343
02:01:07,120 --> 02:01:10,920
anything else folks would like to highlight for us

1344
02:01:13,190 --> 02:01:15,990
and colleagues I'll turn to you for

1345
02:01:15,990 --> 02:01:22,490
some closing thoughts as you for folks to take away as they continue with this process.

1346
02:01:22,490 --> 02:01:28,010
else. Anything anyone else wants to highlight to us or raise other issues?

1347
02:01:39,340 --> 02:01:40,140
I want to recognize

1348
02:01:40,140 --> 02:01:45,980
staff has been quiet, but I know that's because this is an unknown and other than contested

1349
02:01:45,980 --> 02:01:53,280
case and we can consult with staff and hear their thoughts, so I appreciate that they've

1350
02:01:53,280 --> 02:01:59,400
been making space for other folks in this conversation. Rose, Sierra Club, good to see you.

1351
02:02:02,080 --> 02:02:06,960
I know I've been quiet during this proceeding. I haven't wanted to be repetitive. I guess

1352
02:02:06,960 --> 02:02:13,220
I will just say for the record that we agree with Renault-Wenoros-Quest analysis and raise

1353
02:02:13,220 --> 02:02:18,380
a lot of our own concerns and comments that I don't want to repeat here. I think the one piece

1354
02:02:18,380 --> 02:02:23,420
that I did want to lift up on the CEP and continual progress, which we did put into comments

1355
02:02:23,420 --> 02:02:35,260
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.

1356
02:02:36,360 --> 02:02:49,000
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.

1357
02:02:49,840 --> 02:02:56,320
just the reality is that at this point to get resources online to reduce admissions, that's what it looks like.

1358
02:02:57,740 --> 02:03:01,240
But HP 2021 requires continual progress.

1359
02:03:01,640 --> 02:03:08,160
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.

1360
02:03:08,480 --> 02:03:18,980
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

1361
02:03:18,980 --> 02:03:26,140
expectations. You know, we listed out a number of actions that the Civil Court might take between

1362
02:03:26,660 --> 02:03:33,980
now and 2030 in addition to their 2025 RFP and just to highlight a few. I mean, we don't have

1363
02:03:33,980 --> 02:03:43,140
any update on plans for a 2026 RFP that has been required as a phase two. PGE issued an open call

1364
02:03:43,140 --> 02:03:48,040
for proposals for resources. We could see the Civil Court do that. And then we also highlighted

1365
02:03:48,980 --> 02:03:54,200
leaning into demand side resources, potentially issuing an RFP for a virtual power plant.

1366
02:03:55,100 --> 02:04:00,260
So I think all solutions need to be on the table and we would like to see a lot more from

1367
02:04:00,260 --> 02:04:06,880
the company than just a single RFP that if it's not successful, really puts compliance in high

1368
02:04:06,880 --> 02:04:16,220
risk of debris. So thank you. Thanks for that. I'm curious how you think about the intersection of

1369
02:04:16,220 --> 02:04:29,040
1547, right, taking as a given, the DEQ compliance is measured on a cost allocation basis.

1370
02:04:29,660 --> 02:04:36,520
And 1547 drives a very particular shape around cost allocation on the coal fleet,

1371
02:04:36,520 --> 02:04:42,920
given that we haven't actually ended up setting up any early exits and so on,

1372
02:04:44,020 --> 02:04:50,040
which I think is probably good because we're at least engaged in the coal plants' discussions.

1373
02:04:50,800 --> 02:04:57,080
I don't know that early exits would have actually served the decarbonization conversation very, very well.

1374
02:04:57,540 --> 02:05:12,660
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.

1375
02:05:12,660 --> 02:05:15,280
How should I, how should I think about that interplay?

1376
02:05:16,880 --> 02:05:19,180
Yeah, I think that's a tough question.

1377
02:05:20,520 --> 02:05:25,180
You know, what we play into comments is there is an exit from the coal plants,

1378
02:05:25,240 --> 02:05:29,940
and that's under one law, and then HB2021 obviously has the continuum of progress requirements.

1379
02:05:30,340 --> 02:05:34,920
And when you're only considering, okay, in 2030, we have to immediately exit.

1380
02:05:35,220 --> 02:05:37,500
That does create that step system.

1381
02:05:38,180 --> 02:05:51,440
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.

1382
02:05:51,920 --> 02:06:02,880
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.

1383
02:06:05,420 --> 02:06:12,200
There's been a discussion today about, you know, where does Oregon sit within a multi-state

1384
02:06:12,810 --> 02:06:13,140
system?

1385
02:06:13,680 --> 02:06:16,360
And this is a very tricky issue.

1386
02:06:16,620 --> 02:06:22,620
I think that it's very valuable, not only for Oregon, but also for the East Side States

1387
02:06:22,620 --> 02:06:29,160
to see what a portfolio looks like when HP 2021 is incorporated into full system modeling.

1388
02:06:29,160 --> 02:06:34,520
And I know that there's a lot of conversation about other states don't want their resource

1389
02:06:34,520 --> 02:06:37,440
decisions to be driven by Oregon's policy.

1390
02:06:37,880 --> 02:06:42,460
But I think if you see that full system, there's going to be a lot of synergy that we know

1391
02:06:42,460 --> 02:06:44,020
one of our first was talking about earlier.

1392
02:06:44,560 --> 02:06:49,140
And then you can sort of pull out what are the changes in the resources that would have

1393
02:06:49,140 --> 02:06:52,520
been used and assign those excess costs to Oregon.

1394
02:06:53,380 --> 02:06:58,140
But to, you know, be very direct on this when I am saying is that the full system,

1395
02:06:58,140 --> 02:07:06,040
So portfolio should allow Oregon's state policies to drive co-plant retirements across

1396
02:07:06,040 --> 02:07:10,080
the system, so that we can see what that looks like for the whole system.

1397
02:07:12,890 --> 02:07:13,910
I appreciate that.

1398
02:07:14,550 --> 02:07:22,610
I would agree that our Idaho colleagues might want to see what the Utah Colessee is costing

1399
02:07:22,610 --> 02:07:27,270
them, for example, but I appreciate that.

1400
02:07:27,270 --> 02:07:29,290
Any questions for Rose?

1401
02:07:32,920 --> 02:07:33,040
No.

1402
02:07:33,480 --> 02:07:33,600
Okay.

1403
02:07:34,500 --> 02:07:35,180
Thanks so much.

1404
02:07:35,720 --> 02:07:42,180
I appreciate the rigor you all bring to the Thermal Fleet conversation and half over

1405
02:07:42,180 --> 02:07:43,280
the IRP years.

1406
02:07:44,420 --> 02:07:45,020
Randy.

1407
02:07:49,270 --> 02:07:50,050
Thank you, Chair.

1408
02:07:50,150 --> 02:07:55,490
I just wanted to say, at this time, in case the opportunity doesn't come up later,

1409
02:07:56,170 --> 02:08:01,190
that staff has been pretty quiet and Rose has been fairly quiet up to this point.

1410
02:08:01,190 --> 02:08:04,270
But I just wanted to express appreciation for two things.

1411
02:08:04,770 --> 02:08:09,010
One is that we've had some very candid conversations with staff

1412
02:08:09,010 --> 02:08:11,850
that have been helpful and logical

1413
02:08:11,850 --> 02:08:16,490
and help to clarify matters, not just RMW,

1414
02:08:16,650 --> 02:08:18,190
but I wanted to acknowledge that as well.

1415
02:08:18,790 --> 02:08:23,390
And also, Rose, we do appreciate the outreach

1416
02:08:23,990 --> 02:08:28,250
to have more discussion and hopefully greater clarity

1417
02:08:28,250 --> 02:08:34,930
around what happens for the 2025 IRP update, which of course, you know, is a platform moving toward

1418
02:08:34,930 --> 02:08:41,630
the 2027 IRP. So, just wanted to say that. Thank you. Thank you, Randy. I appreciate that.

1419
02:08:42,830 --> 02:08:50,370
And I do appreciate that Pacific Corps is investing time in this stakeholder dialogue.

1420
02:08:53,670 --> 02:08:59,250
We're still struggling to hear each other, but I appreciate the time that your team is investing in that.

1421
02:09:01,370 --> 02:09:05,190
Well, with that, colleagues, I think we've heard from the stakeholders.

1422
02:09:05,830 --> 02:09:12,450
I'm curious or would open the floor to anything you'd like to wrap the morning up with.

1423
02:09:12,450 --> 02:09:18,090
Marching orders to send our stakeholders off with, perhaps,

1424
02:09:21,790 --> 02:09:23,050
Commissioner Perkins?

1425
02:09:25,330 --> 02:09:27,610
Yeah, I think we're going to take away from today.

1426
02:09:28,050 --> 02:09:34,290
I've got to figure out how to stop talking past each other and come to a place where we can

1427
02:09:34,290 --> 02:09:40,830
derive some information fairly quickly that allows people to get comfortable with

1428
02:09:41,930 --> 02:09:46,070
or at least better understand the basis of this IRP

1429
02:09:46,070 --> 02:09:48,110
and what sort of course is putting forward.

1430
02:09:49,250 --> 02:09:52,110
What I don't wanna have happen is that we have this long process

1431
02:09:52,110 --> 02:09:59,330
that ends in an outcome, it isn't good for anybody.

1432
02:10:00,490 --> 02:10:04,810
This needs to be a process that allows us

1433
02:10:04,810 --> 02:10:06,610
to better understand what our future might be

1434
02:10:06,610 --> 02:10:07,990
and the decisions that we can make.

1435
02:10:07,990 --> 02:10:18,070
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.

1436
02:10:21,460 --> 02:10:23,460
Thanks commissioner power.

1437
02:10:26,230 --> 02:10:35,970
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.

1438
02:10:37,370 --> 02:10:42,450
previous plans. And on top of that sort of a siloed approach to build upon that in out years,

1439
02:10:43,470 --> 02:10:47,190
we'll leave us with less and less information about whether

1440
02:10:48,150 --> 02:10:53,790
procurements are strategically and the best interests of our customers here. So do hope that

1441
02:10:53,790 --> 02:11:02,110
parties are able to get to new dialogue about coming to some common scenarios so that we have more

1442
02:11:02,110 --> 02:11:08,090
information before us as we continue to evaluate this planning document.

1443
02:11:11,720 --> 02:11:12,540
Appreciate that.

1444
02:11:14,940 --> 02:11:30,700
I would add to those important points, the cancellation of the RFP is what

1445
02:11:30,700 --> 02:11:34,940
it is. It is gone to Fred's point. It is water

1446
02:11:34,940 --> 02:11:41,840
enter the bridge at this point. The company made a set of traces, business decisions that it felt

1447
02:11:41,840 --> 02:11:47,400
were right in the moment and we have not had a venue to sort of adjudicate the prudence of those

1448
02:11:47,400 --> 02:12:00,900
decisions per se and I, you know, there's a range of perspectives on why we got where we ended up.

1449
02:12:00,900 --> 02:12:09,820
I think from my perspective, the really important question is, what do we do from here?

1450
02:12:13,280 --> 02:12:25,200
And in that sense, I have very practical questions, am I facing an operational problem

1451
02:12:25,200 --> 02:12:34,620
on-packed in-packed West, if I am, what constraints are driving that? And what is the procurement

1452
02:12:34,620 --> 02:12:35,660
that solves that?

1453
02:12:38,540 --> 02:12:45,720
Am I facing, then on top of that, a different gap driven by state

1454
02:12:45,720 --> 02:12:55,080
policies, some of which have pacing elements like the cost cap or the reliability

1455
02:12:55,080 --> 02:13:04,280
pos that I will that I will need to have some foundation for the three of us to

1456
02:13:04,280 --> 02:13:14,860
adjudicate and so while the company I understand why you want the

1457
02:13:14,860 --> 02:13:16,080
all in solution.

1458
02:13:19,020 --> 02:13:26,640
Those we have learned, for example, in 2019, when you did so much extensive work,

1459
02:13:28,740 --> 02:13:33,400
demonstrating where and when the cold plants had value, and where and when they didn't,

1460
02:13:33,900 --> 02:13:39,940
you learned a lot. We learned a lot. There was a host of cold plants. We could all stop arguing about

1461
02:13:39,940 --> 02:13:44,660
and some co-plants we could have a much more informed argument about.

1462
02:13:46,320 --> 02:13:55,870
So I'd really encourage you to listen for the underlying

1463
02:13:57,570 --> 02:14:03,310
difference of perspective and try to speak to that from the stakeholders

1464
02:14:04,110 --> 02:14:08,670
because if we can't build that common foundation, that common understanding

1465
02:14:08,670 --> 02:14:17,670
of our position operationally from a policy perspective and from a cost allocation perspective,

1466
02:14:17,710 --> 02:14:25,570
we're going to continue to just really struggle to take decisions that are constructive

1467
02:14:25,570 --> 02:14:31,090
and feel good about them and be able to justify them to the larger world.

1468
02:14:33,010 --> 02:14:43,470
and so I'd encourage you to really take an approach as you did in 2019 around those coal

1469
02:14:43,470 --> 02:14:53,990
plant analyses where you really lean in and you learned a lot about the economics of

1470
02:14:53,990 --> 02:14:59,910
your cold, cold fleet and really capture a lot of value.

1471
02:15:00,000 --> 02:15:29,940
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

1472
02:15:29,940 --> 02:15:34,220
the institutional capability to do it. I have a lot of confidence you can do it.

1473
02:15:35,460 --> 02:15:40,460
And so I look forward to seeing that in the reply comments. And I really appreciate stakeholders

1474
02:15:40,460 --> 02:15:50,500
willingness to be pragmatic, triage, focus on what's achievable, and while holding out the

1475
02:15:50,500 --> 02:15:56,940
aspiration and holding us accountable to the aspiration in the state policies

1476
02:15:58,120 --> 02:16:03,300
being very pragmatic about what's in front of us right now. I really appreciate

1477
02:16:03,300 --> 02:16:09,200
that. It makes the conversation much more productive than it could otherwise be.

1478
02:16:10,220 --> 02:16:16,680
So with all of that, I want to appreciate everyone's time this morning and the

1479
02:16:16,680 --> 02:16:22,180
comments you've provided so far and the comments that I know will get as we head

1480
02:16:22,180 --> 02:16:31,120
into the final phase of looking through this IRP and dealing with it so that we can deal

1481
02:16:31,120 --> 02:16:34,260
with the update, which will come hot on its heels.

1482
02:16:35,300 --> 02:16:40,760
So is there anything else to come before us this morning, anything else that we need to

1483
02:16:40,760 --> 02:16:41,200
address?

1484
02:16:44,130 --> 02:16:44,610
Okay.

1485
02:16:44,930 --> 02:16:45,610
Seeing nothing.

1486
02:16:46,210 --> 02:16:53,070
I send everybody off to catch a little bit of a walk in the sunshine before we take up

1487
02:16:53,070 --> 02:16:57,030
For our next business in the afternoon, all the best, we're adjourned.