In support of comments made by the Public Power Council (PPC), the American Public Power Association recently stressed the importance of ensuring that any new costs resulting from the Columbia River System Operations draft Environmental Impact Statement (DEIS) are “equitably aligned with the regional benefits of the federal hydropower system.”
PPC is a trade association representing the interests of the non-profit, consumer-owned utilities of the Pacific Northwest. PPC’s utility membership purchases much or all of their wholesale power and transmission service from the Bonneville Power Administration (BPA).
On April 13, PPC submitted comments with the co-lead federal agencies leading the Columbia River System Operations DEIS.
PPC said that it appreciates the effort that the federal agencies have put into creating a comprehensive analysis of alternatives for management and operation of the Columbia River System. Overall, the DEIS represents a comprehensive and robust analysis regarding the potential impacts of the alternatives, PPC said in its comments.
“While the co-lead federal agencies present a well-defined preferred alternative, PPC remains concerned about the additional costs and biological uncertainty that this preferred alternative may engender,” PPC said.
“Northwest public power has a long-standing commitment to science-based, cost-effective mitigation for the environmental impacts of operating the federal hydro system,” said Scott Simms, PPC’s Executive Director. “As we said in our written comments, with these costs comprising 25 percent or more of BPA’s wholesale power rates, we have reached the point where solutions must be found to ensure that preference customers do not solely bear incremental costs that provide broader social and environmental benefits.”
With the DEIS squarely proposing to change river operations toward new, largely untested procedures, PPC – with APPA’s support – is advocating for federal resources dedicated to monitoring these new operations and making changes as necessary.
“Going forward, close monitoring and adaptive management will be required. We will need certainty and clarity about co-lead agency mileposts and transparency regarding actual performance of the preferred alternative against co-lead agency stated objectives. Solutions will have to be found to ensure that preference customers do not solely bear incremental costs that provide broader social and environmental benefits.”
Overall principles
PPC said that in evaluating the DEIS, it is guided by the following set of four principles.
First, the primary focus of Northwest public power is assuring that any new costs resulting from the government’s process are equitably allocated and not borne exclusively by BPA’s public power customers.
“To the extent the preferred alternative results in additional costs allocated entirely to public power, it is time to find ways to build on existing federal law to more broadly share these regional costs,” PPC said. “Not only is it appropriate to equitably align cost responsibility with public benefits but doing so also recognizes the region’s shared stake in both fish recovery and the financial health of BPA.”
Second, the economic, environmental, and operational benefits of the Federal Columbia River Power System (FCRPS) as it exists today should be properly considered and accounted for.
Hydropower is a 24/7 clean renewable source that is vital to meeting the region’s carbon goals, which continue to strengthen as society’s concerns about carbon intensify, PPC noted.
“FCRPS hydropower is also a flexible resource that enables the region to meet future sustainability goals by integrating intermittent renewable resources like wind and solar onto the grid. The flexible capacity that the FCRPS provides will only increase in demand and value as state legislation, policies and economic or other factors drive the retirement of fossil-fueled base load resources and replace them with intermittent renewable generation.”
The FCRPS projects “are a key part of reliable and affordable grid operations and cannot be replaced at low cost by intermittent renewable resources. The value of capacity and reliability of the power produced by these projects has to be properly accounted for.”
Third, as community-owned, non-profit entities, public power utilities are particularly mindful of their public service mission and obligations to all people they serve. Public power utilities “serve many individuals and communities that are struggling. In both urban and rural locations, public power utilities fund substantial low-income assistance programs,” PPC said. “We need to be mindful that policy changes that adversely impact the hydro system will result in higher costs for the region’s ratepayers, which puts some urban and rural ratepayers at a higher risk that they won’t have access to this essential public service.”
Fourth, Northwest public power is aligned on the goal of ensuring all fish mitigation costs are properly allocated and do not unduly burden BPA customers, and there are also a number of other community perspectives beyond the cost component.
In addition to the costs concerns, individual community perspectives of public power utilities include electricity supply and grid reliability, local jobs and community commerce, river commerce and navigation, recreation, municipal water supplies and water quality, irrigation water for agriculture, flood control, environmental impacts, and many more, PPC said.
PPC argues for follow-on public process
PPC said that with the completion of the final EIS, a follow-on public process should be established by BPA or the co-lead agencies, as appropriate, to periodically share specific performance outcomes of the preferred alternative.
“If necessary, from that process, BPA or the co-lead agencies should create engagement opportunities for any significant adaptive management steps that are needed to better align system performance to the preferred alternative objectives,” PPC said.
APPA sends letter in support of PPC comments
In an April 13 letter to the federal agencies leading the DEIS, APPA said it strongly supports and endorses the comments submitted by PPC.
“APPA wishes to reinforce the importance of federal hydropower to the nation and the Pacific Northwest,” it said.
“Bonneville and the federal hydropower it markets have been a cornerstone of the Pacific Northwest’s economy since 1937. We appreciate the valuable multi-purposes served by the federal hydropower system, including the Columbia River System, and the difficulty of balancing sometimes competing interests and functions.”
However, as the rest of the U.S. “grapples with how to ensure an affordable and reliable transition to a clean economy, the Pacific Northwest is leaps and bounds ahead. Innate to hydropower are attributes – low cost, non-emitting, and reliable – that are highly desirable energy policy goals that energy markets are moving toward appropriately valuing.”
APPA went on to say that with BPA power contracts set to expire in 2028, “it is imperative” that any new costs resulting from the DEIS process are equitably aligned with the regional benefits of the federal hydropower system.
“BPA’s power customers cannot continue to shoulder those costs alone – aligning cost responsibilities with public benefits recognizes the region’s shared stake in both fish recovery and the economic, operational, and other environmental benefits of the Federal Columbia River Power System,” APPA said.
Though this DEIS is a matter of intense interest to public power in the Pacific Northwest, many of the issues around allocations of costs to public power versus other parties, the value of investments in environmental stewardship and other related themes have relevance in other processes impacting public power across the country, Simms said.
“We value APPA’s support and collaboration in our efforts to secure a reliable, economic, and clean power supply for public power customers in the Northwest,” Simms said. “At the end of the day, our member utilities – and the small and large communities they represent – are depending on our national and regional public power associations to speak in a strong and unified voice in order to get our important perspectives heard in processes such as this one.”
