General Comment

The proposed study scope appropriately will seek to identify reliability issues at peak summer, peak winter and light load conditions. The underlying rationale is that if the system is reliable during conditions that put stress on the grid, then the system will also be reliable under average or normal conditions.

As the assumptions (or forecasts) for load and generation are developed for the study, I recommend that the planners ensure that the underlying assumptions they use for load forecasts and generation additions result in a stressed system for the study year. Such a future study year would consist of high load growth (from electrification of transportation and heating and lack of opportunities for energy efficiency) and higher reliance on location constrained generation resources. A study year with these characteristics will stress the system and idenfity deficiencies more effectively thatn a study year that assumes lower load growth that could be met with distributed energy resources or demand resonse.  

Because the proposed study is merely informational, there is no downside to focusing on a hypothetical future that puts more stress on the system.  At the same time, there is no real value in conducting a study based on assumptions that do not actually stress the grid in 2042.  Accordingly, I recommend that the team assume higher rates of load growth, lower levels of energy efficiency, lower levels of distributed generation, more location constrained generation resources (with onsite storage), higher natural gas costs, and lower hydro availability than might be predicted by the baseline assumptions for 2042.