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Supporting Attachment No. 8
To Comments made by Richard Lauckhart dated December 11, 2017
Comments I made to ColumbiaGrid pointing out the error in their System
Assessment write-up regarding the need to deliver 1,350 MW of Treaty power to
the Canadian border
Copy of Lauckhart Oral Comments made at ColumbiaGrid/WUTC Special Presentation July 31, 2017
1:30 PM to 3:30 PM
1) Did ColumbiaGrid perform load flow studies that show the need for Energize Eastside? We
don’t thinks so. But the ColumbiaGrid 2017 System Assessment suggests that ColumbiaGrid ran
load flow studies that show the need for Energize Eastside. If so, we would very much like to
see those studies to see how ColumbiaGrid might have shown the need for Energize Eastside
without using bad modeling assumptions. I have provided comments/questions to
ColumbiaGrid that address that and related questions. I look forward to seeing
ColumbiaGrid’s responses to the comments/questions I sent them. Those
comments/questions have been provided for the record in this WUTC proceeding Docket No.
170791. [It is clear to us that the PSE/Quanta load flow study allegedly showing the need for
Energize Eastside was done with bad modeling assumptions.]
2) One of the big questions relates to whether or not there is a Firm Requirement for BPA or some
US Entity to deliver 1,350 MW of Treaty Entitlement Power to the Canada border.
a. PSE has stated that ColumbiaGrid requires PSE to include a delivery of 1,350 MW of
Entitlement Power to the Canadian border when PSE studies the local area transmission
needs on the PSE system. Of course, ColumbiaGrid does not have the authority to
require PSE to build local transmission to cause increased capability to deliver Treaty
power to the Canada Border.
b. The ColumbiaGrid Draft 2017 System Assessment states that there is a 1,350 MW
Canadian Entitlement South to North commitment to deliver power at Blaine and
Nelway. But ColumbiaGrid has provided no evidence that such a commitment exists.
c. I have also written ColumbiaGrid providing evidence that demonstrates from Treaty
documents that such a Firm Commitment does not exist. That writing has been
provided for the record in this WUTC proceeding Docket No. 170791. ColumbiaGrid
needs to correct its erroneous statement in the ColumbiaGrid 2017 System Assessment
(and anywhere else it makes the statement) that there is a 1,350 MW Canadian
Entitlement South to North commitment to deliver power to the Canadian Border. I
look forward to those corrections being made.
3) It is one thing for ColumbiaGrid to test to assure that Energize Eastside (a purely local project)
does not adversely impact another utility. It is quite another thing for ColumbiaGrid to tell
PSE that their Energize Eastside project needs to help BPA increase its ability to deliver
Canadian Entitlement power to the Canadian border. Note:
a. ColumbiaGrid does not have that kind of authority
b. There is no Firm Commitment for PSE to deliver Canadian Entitlement power to the
Canadian border. Why would PSE customers need to pay to help BPA meet an
obligation to deliver Canadian Entitlement power to the Canadian border?
c. Even more telling…there is no Firm Commitment that BPA (or any other United States
Entity) has to deliver Canadian Entitlement power to the Canadian border.
d. And even further telling…We know that the grid cannot deliver 1,350 MW to the
Canadian border under heavy winter conditions in 2017…before Energize Eastside is
built (or after Energize Eastside is built for that matter)..
4) I have indicated a willingness to meet with ColumbiaGrid to go over my several
comments/questions and evidence. ColumbiaGrid has not yet accepted my invitation.