General Comment

Some utilities' IRPs pre-date existing public policy requirements (for example PGE's 2019 IRP). How will the information related to future resource needs from those out-dated IRPs be adjusted for this study?

IRPs frequently only identify only "market purchases" (i.e PSE) or generic resources -- such as solar -- without a specified geographic region. How will the the study address these generic resources with regard to location and transmission availability? How will they study determine whether there is sufficient installed capacity to support all the "market purchases" identified in IRPs? How will the study determine where generic renewable resources are located for purposes of the study and whether there is sufficient transmission capacity to deliver those generic renewable resources from that location to the LSE?

Both the extreme heat and extreme cold scenarios seem to assume that there will be surplus renewable generation outside the study region for import to the NW to meet the extreme loads. What is the basis for the assumption that surplus generation will be available in nearby regions.

Both the extreme heat and extreme cold scenarios seem limited to exploring whether there is sufficient transmission to enable the NW to import its way out of an extreme weather event; and the only solutions considered will be transmission solutions.  I recommend expanding the study scope to determine whether transmission expansion to geographic zones within the NW with high potential for renewable energy development is more cost-effective than a transmission-only import solution. I understand the principle of "not picking winners and losers"; but 1) the study is already picking winners by limiting consideraton of generation to hypothetical surplus wind generation in adjoining regions, and 2) the results of the study that considers alternative generation portfolios will not "pick a winner", so much as provide LSEs and Public Utility Commissions with better data upon which to base their decisions regarding future generation resources.

At lines 134-6, the study states that preferred portfolio resources will initially be offline but may be included if needed; how will the study confirm that transmission is available for those preferred portfolio resources.

Line 145. The study seeks only transmission solutions. There seems to be no effort to consider alternative generation build outs within the region (and the associated transmission) as a more cost-effective solution to building transmission to increase imports from neighboring regions.

Will the study consider the requirements of the WPP Resource Adequacy program (both generation capacity requirements and transmission requirements)?  If so, how? If not, why not?