COMMENT FOR 20-Year Extended Planning Horizon Pre-Scoping Comments

Submitted Sept. 26, 2022, 10:11 p.m.





Do You Have Any Recommendations On How The Study Should Evaluate Various Solutions (new transmission, new resources, non-wires, etc.)?

No response submitted.

What Load Forecasting Questions and Recommendations Do You Have?

No response submitted.

What Modeling and Data Questions and Recommendations Do You Have?

We recommend consulting with the Northwest Power and Conservation Council to fold in climate change assumptions into the river flow and load forecast modeling for the 20-year Extended Planning Horizon scenarios. Using primarily historical data for river flows to project the next 20 years might not represent the system we will see going forward. On the other hand, the projections used by the Power Council for the 2021 Power Plan on temperatures and precipitation "are not intended to be used as what the expected weather will be in any individual future year, rather they illustrate the types of temperatures that can be expected and the data are designed so that the range of weather over each decade represents an estimate of the range of conditions driven by climate change (2021 Power Plan)". The Council selected three out of nineteen RMJOC climate scenarios (developed by Bureau of Reclamation) to analyze the boundary conditions of potential regional climate change impacts. As mentioned in the 2021 Power Plan, from analysis of the temperature and streamflow data of the three RMJOC climate scenarios, the Council projected increasing winter hydropower generation due to increasing fall and winter streamflows from having more precipitation and in contrast, decreasing summer hydropower generation from decreasing summer streamflows caused by a shrinking snowpack and less summer precipitation. Based on these data, the Council also forecasts a trend of less frequent extremely cold winter temperatures and more frequent extremely warm summer temperatures. These climate impacts put downward pressure on winter electricity prices and align regional needs in the summer with the predominant electricity. Thus, it will be important to consider the climate change adjusted river flows and load forecast datasets in this long-term study. The datasets can also be accessed here: https://www.usbr.gov/pn/climate/planning/reports/index.html

What Resource Forecast Questions and Recommendations Do You Have?

Please see our comment on Modeling and Data Questions and Recommendations. 

General Comment

Renewable Northwest recommends consulting with the Northwest Power and Conservation Council to fold in climate change adjusted datasets into the river flow and load forecast modeling for the 20-year Extended Planning Horizon scenarios. Using primarily historical data for river flows to project the next 20 years might not represent the system we will see going forward. An option could be studying the impacts of these datasets as a sensitivity. Please see our more detailed comment in Modeling and Data Questions and Recommendations section. Thank you for considering these comments. 

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