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Home My WebLink AboutC_Public_Comment_47.f_180614.email_attch3of7Supporting Attachment No. 13 To Comments made by Richard Lauckhart dated December 11, 2017 Document providing further evidence that the ColumbiaGrid System Assessment write-up stating there exists a Firm Commitment to deliver 1,350 MW of Treaty Power to the Canadian Border is not correct. Includes an email from ColumbiaGrid stating that BPA was the one that told them that such a Firm Commitment exists [even though BPA responded in a Public Record Act request that no such Firm Commitment exists]. ColumbiaGrid explains that it makes no check on what BPA tells them when they write their System Assessment document. They just include the BPA un-validated allegation in their System Assessment write-up. This allegation has subsequently been refuted by BPA in their response to the Public Records Act request From: Richard To: UTC DL Re0ords! • R ndahl An Danner— T Cc: D n M II Borgmanno Uill Pascoel Cehulko. Bradley • Brign-mever m ni iCarla AT h rliBlack.. "Charlie Gr'g": Court Mow " Ion II"k M, Mitchentrce` D r n AnclQUon- NESCO oroun7 DavidBrDavid LowreyLlNiQhtinciale. David ! Devin MQG-reaL DonMr Hwl "; Snyder. Jennifer (UTC)s John Fazio: Kelly Hall., Ken Nichols; Franklewich, Kyle (iTr)a Lea Fjgher "Liz Thomas"• "Mannett. John"i Mark Sellers-Vauabn7 Michael Subject: 0"Rflen: Milos Stefanovmc�]�e Ljcke�: Mcols Matz, Norm Hanseri7 "Popoff. PhMop"l ftaee Gasfimau�—"Saldivar. MaW` Scott Rmcharc&- Shauna Jensen! Johnson, Steven UE-160918 Further evidence there is no Firm Commitment to deliver 1350 MW of Entitlement Power to the Canada Border Date: Tuesday, August 22, 2017 3:08:31 PM Attachments: _imaoe001.ona -RichardLauckhaLt cpa3ments made at the ColumbiaGrid Boardectors meetino.odf Dear Records and WUTC Commissioners: Please include this email alorg with the forwarded email below and the attachment to this email in the Documents filed for the PSE IRP Docket No, UE-160918. The information provided here is further evidence that there is no Firm Cornmitment by anyone -to transmLt- 1,350 MW of Entitlement Canada PSE load flows attempting to justify Energize Eastside need to be redone to remove this assumption in their load flow modeling of transmission needs in the greater Bellevue area. Attached are comments I made at the August 16, 2017 ColumbiaGrid Board meeting. The email from Patrick Damiano of ColumbiaGrid to me today responds to those comments. These comments are enlightening for the following reasons: 1) 1 had commented to the ColumbiaGrid Board that the writing in the ColumbiaGrid System Assessments were wrong when they stated that there is a 1,350 MW Firm Commitment to deliver Entitlement Power to the Canadian Border. In his response Patrick Damiano stated "the Board of Directors does not adopt ColumbiaGrid's annual system assessments." In other words, the ColumbiaGrid independent board does not verify the accuracy of statements in these ColumbiaGrid System Assessment documents. 2) 1 had commented that ColumbiaGrid was losing credibility when it did not respond to stakeholder questions posed in their Open Comment periods. In his response Patrick Damiano stated "ColumbiaGrid is not obligated to address or respond to individual comments on the Draft System Assessment." 3) 1 had asked ColumbiaGrid to provide evidence that they were correct in writing that there is a 1,350 MW Firm Commitment to deliver Entitlement Power to the Canadian Border. Patrick Damiano stated: "We note that ColumbiaGrid does not have the authority under its planning process to mandate or otherwise compel a party to substantiate the details of their submittals or obligations. For further information, we suggest that you direct your inquiries to the Bonneville Power Administration or the U.S. Army Corps of Engineers, which are the U.S. federal entities responsible for administering the Canadian Entitlement pursuant to the Columbia River Treaty of 1964." In other words ColumbiaGrid is stating that it was BPA that told them to write that there is a 1,350 MW Firm Commitment to deliver Entitlement Power to the Canadian Border. 4) Pgint number 3 above gets us into a circle The COLUMBIA RIVER TREATY ENTITY AGREEMENT on ASPECTS OF THE DELIVERY OF THE CANADIAN ENTITLEMENT for APRIL 1, 1998 THROUGH SEPTEMBER 15,2024 BETWEEN THE CANADIAN ENTITY AND THE UNITED STATES ENTITY DATED MARCH 29,1999 made it clear that Canada was supposed to have requested such a Firm Commitment if it decided it wanted one. We have already asked BPA C r asked them to promide Firm ComMitment to deliver Entitlement Power to the Canada border,,., BPA responded that they had never received such a request. Canada prefers to have its share of Treaty power delivered to entities in the United States in exchange for those entities sending money to Canada. Once again, it is clear that PSE is improperly blaming ColumiaGrid for its decision to include large flows to Canada in their Eastside Needs Assessment. ColumbiaGrid says it is only passing on information provided them by BPA. But BPA has told us that they have no such commitment. Rich Lauckhart Energy Consultant Davis, California On behalf of a large number of citizens concerned about transmission plans in the Puget Sound Area From: Patrick Damiano <Damiano@ColumbiaGrid.org> Sent: Tuesday, August 22, 2017 12:06 PM To: Richard Lauckhart (lauckjr@hotmail.com) Cc: Kris Mikkeisen; Jim Miller; Ed Sienkiewicz Subject: August 5, 2017 Comments to Board Members or ColumbiaGrid's Draft 2017 System Assessment RE: August 5, 2017 Counts to Board Members on ColumbiaGrid's Draft 2017 System Assessment Mr. Lauckhart: Thank you for your participation in ColumbiaGrid's transmission planning process. The Directors have requested that I respond to your e-mails to the ColumbiaGrid Board Members, dated August 5, 2017, regarding certain inputs to ColumbiaGrid's Draft 2017 System Assessment ("Draft System Assessment"). Specifically, you inquired about the details of an existing transmission service obligation that is referenced in the Draft System Assessment (the "Canadian Entitlement," e.g. Draft System Assessment at 21-22). Pursuant to ColumbiaGrid's planning process, the Board of Directors does not adopt ColumbiaGrid's annual system assessments. The Board of Directors does, however, adopt ColumbiaGrid's biennial transmission expansion plans ("Plan") and updates to the Plan. The Draft System Assessment is an integral component of the ColumbiaGrid planning process. Pursuant to that planning process, ColumbiaGrid's staff, in coordination with the relevant parties and stakeholders, conducts a system assessment to determine the ability of each party to serve its network load, native load obligations and long-term firm obligations over the planning horizon. During the planning process, ColumbiaGrid conducts numerous planning meetings that are open to the public for stakeholder involvement and input. Based on your earlier submittals and your emails to the Board Members, we understand that you are requesting additional details regarding the Canadian Entitlement. While ColumbiaGrid endeavors to implement the planning process as transparently as possible, ColumbiaGrid is not obligated to address or respond to individual comments on the Draft System Assessment, Instead, ColumbiaGrid carefully considers all comments it receives from planning parties, interested persons, and other stakeholders to understand the applicability of such comments to the finalization of the Draft System Assessment. Thus, ColumbiaGrid had considered your earlier submittals during the comment window consistent with its planning process. The Canadian Entitlement was identified as an obligation previously submitted in ColumbiaGrid's planning process. As such, it is subject to analysis and inclusion in the Draft System Assessment. We note that ColumbiaGrid does not have the authority under its planning process to mandate or otherwise compel a party to substantiate the details of their submittals or obligations. For further information, we suggest that you direct your inquiries to the Bonneville Power Administration or the U.S. Army Corps of Engineers, which are the U.S. federal entities responsible for administering the Canadian Entitlement pursuant to the Columbia River Treaty of 1964. We also refer you to answers and responses regarding the Canadian Entitlement within FERC Docket No. EL15-74-000. Moreover, some information that you requested may not be appropriate for disclosure or dissemination. ColumbiaGrid has an obligation to protect any information it receives during the planning process that qualifies as Confidential Information and Critical Energy Infrastructure Information ("CEII"). Therefore, ColumbiaGrid cannot satisfy your earlier requests submitted during the comment window for the Draft 2017 System Assessment. For further information regarding Puget Sound Energy's ("PSE") Energize Eastside Project, we suggest that you direct your inquiries to PSE, Thank you again for your input and involvement in ColumbiaGrid's planning process. The success of ColumbiaGrid's mission to improve the reliability and efficient use of the Northwest's transmission grid is dependent on the solicitation of diverse viewpoints, which is only possible through broad participation in the planning process. Sincerely, Patrick Damiano President & CEO 503-943-4933 8338 NE Alderwood, STE-140; Portland, OR 97220 ColumbiaGrid's mission is to improve the planning, expansion, and efficient use of the Northwest Transmission Grid. www.rnlumbiagrid.oro