Some appropriate header and then an introduction goes here. Need also to check the Head and Meta statements, get text a good size, create good CSS styles, etc.


February 2022


Revealed here is the proposed list of Department of Energy ("DOE") experts, along with their email addresses, that will participate in critique -- and possible oversight -- of the Lower Snake River ("LSR") Power Replacement Study.
(I)f the BPA/EFI Lower Snake River analysis proceeds, EERE-WPTO is prepared to offer strategic support to BPA.
. . .
Presuming that the study does proceed, we should find a way to introduce the BPA group to this DOE-Lab team.

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-- internal Department of Energy email from Ryan Wiser
to DOE's Emily Hammond,
   Patricia Hoffman,
   Whitney Muse,
   Jeremiah Baumann,
   Steve Capanna,
   Jennifer Garson,
   Kathryn Jackson,
   Paul Spitsen &
   Samuel Bockenhauer

February 3, 2022, 2:01PM


A Title Page slide incorrectly addresses Bonneville Power Authority revealing Energy + Environmental Economics ("E3") inexperience with reporting to/for BPA.

E3 works with clients from all sectors of the electricity industry across the U.S., we provide a 360-degree understanding of markets, planning, policy, regulation, and environmental factors. Just as important, we are committed to delivering clear, unbiased analyses that help clients make informed decisions often in complex and multi-stakeholder contexts.
. . .
with exceptional attention to detail.
. . .
Our integrity and reputation for providing high-quality, unbiased work, earned over may years of successful projects, especially in the Pacific Northwest...

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-- E3 introductory presentation to Bonneville Power Authority
February 7, 2022


E3 promotes its reputation for providing unbiased analyses.

(W)e are committed to delivering clear, unbiased analyses that help clients make informed decisions often in complex and multi-stakeholder contexts.
. . .
Our integrity and reputation for providing high-quality, unbiased work, earned over many years of successful projects, especially in the Pacific Northwest has enabled us to occupy a unique niche in the energy industry: ... This breadth, which we believe is unmatched by our competitors, speaks to the enthusiasm and dedication of our staff and the respect clients have for E3's high-quality, unbiased analysis.

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-- Bonneville Power Authority: The Role the Lower Snake River Projects
February 7, 2022


March 2022


While it is true that Washington & Oregon state law allows "Hydropower (a)s an eligible source of GHG-free energy", studies from Pacific Northwest National Lab ("PNNL") informs us that reservoirs impounded by Lower Snake River dams produce methane gas, a potent greenhouse gas ("GHG").
Study design calculates resource replacement costs of Lower Snake River dams, assuming from the beginning that there will be a net cost.

Hydropower is an eligible source of GHG-free energy for all existing state clean energy goals
. . .
Each scenario will be run in RESOLVE twice (see figure).

The study's initial assumption is that a future electrical grid without LSR dams will be more expensive than one without. This turns out not to be the case when the model is allowed batteries as a replacement resource.

Afterall, storing relatively low cost electricity when it is abundant (e.g. midday solar energy from CA, NV, NM, AZ) is far less expensive than operating and maintaining an aging hydropower system.

Moreover, the LSR dams have never been reported to have provided more benefit than cost. Never.

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-- BPA Value of Lower Snake River Dams: Kickoff Meeting
March 9, 2022


E3 is surprised to see that there are times when LSR dams are not producing any power at all.

E3 email to BPA:
Quick question: we are doing some data quality checks on our historical hydro hourly data. Do you have a sense of the minimum generation for the 4 lower snake river dams? Clearly we'll remove a few 0 MW values we found, but am seeking your input on what a reasonable lower bound is for the 4 dams min gen, e.g. would they ever operate at a combined output of 50 MW or is that too small? 100 MW? 200 MW? Etc.
. . .
BPA's James Eve responds:
The lower Snake projects are able to operate to 0 generation by choice (not outage related) in Dec -- Feb so do not remove the 0 MW data during those months as they are likely correct to optimize reservoir content to generate during peak load periods.

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-- E3 email from Aaron Burdick to BPA's Robert Diffely, Eve James, Birgit Koehler
March 18, 2022, 11:42AM


"... we will let E3 perform the study independently. We do not plan to be engaged in their work as the aim was to have an independent 3rd party perform this study."
. . .
Based on the email below, it sounds like knowledge of the E3 analysis is now public. Is that right? Just wondering what NWPCC as well as various other NW stakeholders know, or do not know, about the study's existence, scope and timing.

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-- DOE email from Ryan Wiser to BPA's Brigit Koehler
March 23, 2022 5:06PM
Missing file


April 2022


From the start, Bonneville Power Administration ("BPA") misleads E3 into believing that the value of the LSR dams are far greater than the amount that should actually be modeled. This was done in at least two ways: via "White Book" and via "PNUCC methodology" (below).

BPA's White Book
Purposefully misleading, BPA chose to provide E3 with the "Nameplate Capacity" of 3,483MW reported in their "White Book" that also states 438 aMW of "firm energy" can be expected from the LSR dams. It is the latter number that would be pertinent to a Resource Adequacy assessment, not the overload capacity that the turbines could muster in a flood situation.

The lower snake river dams provide relatively low-cost and flexible carbon free power (and) are ~10% of the Northwest regional hydropower capacity.
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-- Lower Snake River Dams Replacement Draft Results prepared for BPA Executive Meeting
April 27, 2022


BPA proposes that hydropower provides "unique system benefits" that -- as E3 eventually reports back -- is not true at all. For example, PNNL(?, if so not acronym yet) studies reported that battery storage provide the system benefits of BPA purport to be "unique" to hydropower (see slide 5). . At the project's outset, it is assumed that resource needs and costs will be greater without the LSR dams than with. This turns out not to be the case (and to be revealed below), if/when batteries are recognized as a replacement resource for LSR hydropower. Notably, batteries do not need a large labor force to keep them running 24 hours at 7 days a week. Moreover, consider that LSR dams are soon in need of turbine replacement, that same investment would be better placed in a brand-new battery resource as a replacement.

As will become apparent in the below, BPA does not want anyone to realize the truth of the matter. Is this a proper means of "marketing" from a government agency? That's a good question to ask oneself. Hydropower resources provide unique system benefits to support system needs in the region

Hydropower resources provide unique system benefits to support system needs in the region

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-- Lower Snake River Dams Replacement Draft Results prepared for BPA Executive Meeting
April 27, 2022

DELETE PAGE 6 and this Show/Hide

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-- Lower Snake River Dams Replacement Draft Results prepared for BPA Executive Meeting
April 27, 2022


In the foreseen resource builds of E3's RESOLVE model, ranging from a need for 23,000 - 210,000 MW of new resources for maintaining system adequacy, the LSR 483aMW is vanishingly small in comparison. When E3's final report (page 41) admits a reasonable ELCC curve for storage, the grid benefits of storage being a worthwhile solution for LSR replacement, the benefit is downplayed as being small; " the replacement resources for the dam are not significantly changed and there is little impact on the replacement costs." But the changes are small because the LSR dams are small relative to the buildout that is foreseen.

In E3's April 27 slide deck, batteries are available for consideration by the RESOLVE model.

Summary of No LSR Dam Resolve Analysis: (see years 2045 and 2035 on slide 18) LSR Replacement Needs: (see red rectangle highlighting on slide 19)

2035 replacement is driven by resource adequacy needs

2045 replacement is driven by both resource adequacy and clean energy needs
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-- Lower Snake River Dams Replacement Draft Results prepared for BPA Executive Meeting
April 27, 2022


SPLIT THE FOLLOWING INTO APPROPRIATE, WELL-PLACED BITS.

Whereas a Effective Load Carrying Capacity ("ELCC") for LSR dams is given a fixed number (initially 65% of 3,483MW), other resources see "saturation" effects as more and more of the same resource is added to the grid. This is much the same as the law of diminishing returns common in economic theory.

Notably, for both 6-hour and 12-hour storage, the ELCC curves drop steeply to below 10% after the first 3GW of storage are installed. A footnote describes the ELCC as being the "firm contribution to system peak load." In other words, additional storage will require a nameplate capacity of 10x it's actual need (e.g. 438aMW of LSR firm energy would require 4,380MW of battery storage). In the following, you will see that the experts from US Department of Energy ("DOE") took notice of this apparent oversight.

Oddly, E3's final presentation did not appear to take the DOE feedback to heart. BPA's chosen need to "market" hydropower was apparently a more necessary objective, and an honest objective study was not the end product for the general public to consume.

Storage has yet to arrive in the NW, yet E3's assume a steeply declining Storage ELCC curve due to satuartion effects. (get an exact quote). But when storage is replacing storage, it would be odd if an ELCC curve is necessary. Replacing like for like should be on a one-for-one basis. Would it not?

(for an appropriate place, but writing it here to get it down
as of April, 2022
Emerging Tech: baseline + gas w/ carbon capture and storage, offshore wind, and nuclear SMR"
in May 7, 2022

Final report Embargoed until 6am July 12, 2022 with images overlain upon the watermark! (p147 of 214) "BPA E3 Study Records -- Fourth Release Part 3.pdf"
Scenario 2a - Deep Decarbonization (LSR breached)
2.0GW of Energy replacement via dual fuel NG/H2 CGGT
Peaking replacement
0.6GW wind
0.1GW storage (with 1MW/16acres 100MW is 1600 acres, or disbursed among Bonneville's 212 substations for optimum resilience and greatly replacing LSR capabilities)

DOE experts further asked E3 to check the assumption that 3.4 GW of LSR hydro removed, (see page 23 of this PPT presentation file:///Users/scottlevy/Desktop/GOB_v_BPA/DraftFinalResults_May2022.pdf).

The experts likely assumed that their feedback would be taken to heart, in full, not merely the parts that were acceptable the Save Our Dams "stakeholders".

Stated another way, siting NW solar projects in the desert Southwest, storing the excess midday for demand peaks at sunrise and sunset (preferably near the demand centers, beyond transmission bottleneck locations), and the "High ELCC" curve would necessarily then apply.


For BPA's Executive Briefing, decisionmakers are reminded that storage shows "limited value in the Northwest with the large hydro fleet." But this is misleading and inappropriate for a LSR Replacement of Resource Study. It is precisely this incorrect assumption that leads to the critique published in Clearing-Up following the final report's release.

Replacement is not the same as addition.
The LSR dams storage benefit, if lost, would be replaced in a one-for-one fashion. The final analysis from E3, however, does not recognize this fact. Instead, the RESOLVE model downgrades the battery replacement resource as though it were not a replacement, but as an addition to a system with "saturation" of storage resources.

Mature Technologies

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-- Lower Snake River Dams Replacement Draft Results prepared for BPA Executive Meeting
April 27, 2022


Excerpt from July 2022  BPA Lower Snake River Dams Power Replacement Study: 'Hydro firm capacity contribution for both LSR dams is assumed to be 65% of nameplate, per PNUCC' (Pacific Northwest Utility Conference Committee). While BPA is looking for E3's report to confirm the CRSO EIS record of decision, E3 is provided a starting assumption much higher (2,284MW = 65% of 3,483MW Nameplate) than the CRSO EIS finding (1,120 for Multi-Objective 3 and only 760MW is attributable to LSR breaching). Why would BPA be overstating?

I just looked up our EIS result for MO3 (dam breaching and other measures). With least-cost replacements (combined cycle gas), we identified 1,120 MW need for 2022. Comparing that to S0, No policy, the E3 results have around 2,500 MW for 2035. That's a pretty dramatic difference...

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-- BPA email from Birgit Koehler to E3's Aaron Burdick, Arne Olson & BPA's Robert Diffely, Eve James
April 28, 2022, 11:45AM


While this is an outlier case -- not included in the final reporting -- an increase in energy exports from the region, is mentioned alongside "frequent over-supply conditions".

S2a1: Deep Decarbonization - Limited Tech w/ No New Combustion
Without new natural gas or H2 combustion turbines to meet growing resource adequacy needs, a large overbuild of onshore wind, offshore wind, and battery storage are selected . . . Exports from the region increase due to more frequent over-supply conditions, curtailment reaches -60% in 2045

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-- Lower Snake River Dams Replacement Draft Results prepared for BPA Executive Meeting
April 27, 2022


May 2022


Q. Why state 3.5 cents/kWh instead of $35/MWh?
A. Confusing the units makes it harder for the reader to understand the comparison that would otherwise be simple.

Current BPA Generation Rate 3.5 cents/kWh

. . .

LSR Dam all-in Generation costs (2022 $/MWh)
$13/MWh without LSRCP
$17/MWh with LSRCP

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-- BPA email from Eve James to Aaron Burdick
May 4, 2022 9:55AM


Three weeks after the April 15 report (above) comes the May 4 Draft Final Results and battery storage has decreased (slide 42).

S2: Deep Decarbonization (2035)
2.0 GW NG/H2 CCGT
0.1 GW li-ion battery (was 0.2 GW by 2035)
0.6 GW wind

S2: Deep Decarbonization (2045)
2.0 GW NG/H2 CCGT
0.3 GW li-ion battery (was 1.5 GW)
0.4 GW wind
0.05 GW energy efficiency
1.2 TWh H2 generation

. . .

E3's May 4 slide deck includes Additional LSR Dam Qualitative Benefits as requested by the initital contract with BPA (slides 48 - 52). When E3 informs BPA that these "qualitative benefits" are replacable (see bold text below and visit link to two PNNL reports, one YouTube video perhaps) subsequent slide decks drop the topic from the reporting.

Hydro is a Key Regional Source of Reactive Power (slide 48)

Hydro is a Key Regional Source of Reactive Power (slide 49) Voltage Ride-Through and Frequency Response (slide 50) Inertia Buffers the Grid Against Instability (slide 51) Additional Grid Resilience Benefits (slide 52)
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-- BPA Lower Snake River Dams Project Draft Final Results"
May 4, 2022

NOTE for SCOTT: I see an April 27 report at bottom of BPA E3 Study Records -- Third Release Part 1.pdf)

Until very recently, hydropower has been the primary source of electricity generation and energy storage. But installations of wind and solar, oftentimes coupled with battery storage, are the new kids on the block.

Hydropower dominates historical generation, followed by coal and natural gas

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-- BPA Lower Snake River Dams Project: Draft Final Results
May 6, 2022


Adding to longstanding long-term contracts, newly created day-ahead, 1-hour and 15 minute markets have greatly improved reliability of the Western Electrical Coordinating Committee ("WECC") grid. With these markets, BPA regularly purchases from the abundant supply of day time solar energy (from CA, NV, AZ, NW). Then as sunset arrives, hydropower is sold back through these same market mechanisms.

Utility IRP expectations of firm capacity in the form of market purchases pose reliability risks due to regional resource adequacy trends (slide 52)

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-- BPA email from Who to Whom
May 6, 2022


DOE-National Lab comments are expected May 18. Comments then follow.

these are looking at some of BPA's replies, so not merely the Comments so this should accompany that page, not this one

is misleading
35 year replacement timeline
overly dramatic and inconsistent.
seems somewhat offbase
in a one-sided fashion
most contentious relates... disagree on capacity of LSR
ELCC assumptions of the LSR dams, storage, wind, solar, etc are truly comparable.
low marginall ELCC of 12-hour storage
Avista assumes .. much higher than what E3 assumes
I am frustrated - BPA(?) comment to the comment
overly off-putting to regional stakeholders

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-- internal BPA email from Eve James to E3's Aaron Burdick & Arne Olson
May 12, 2002 7:18AM


"Finally, are such low ELCC values for storage, even 12-hour storage, consistent with the 65% ELCC assumption made for the LSR dams?"
"opportunity for imports and exports of all electricity services"
"The capacity credit of storage seems to be substantially lower than what has been calculated in other regions, particularly for the 12 - hr storage duration, after the first few GW of storage is deployed."

Note that some of this feedback, if addressed, would require substantive new work, and time. This is especially true for our comments on the scenarios, and on ELCC treatment and assumptions. We encourage discussions in the near term to determine whether and how to address those comments.
. . .
ELCC Values and Influence on Overall Results Deserve Attention: The capacity credit assumptions and results are likely extremely important in estimating the costs of having to replace the LSR dams' grid benefits.
. . .
  • Cost Reporting: Can the fraction of the 'cost of LSR replacement' that comes from capacity needs be calculated? Based on the low raw LCOE costs of wind and solar, it seems logical that the capacity credit costs might make up half or even more of the total cost. If true, then all capacity-credit related assumptions and results are extremely important.
  • Capacity Credit of LSR Dams Should be Investigated, and Possibly Revised: The analysis assumes that the LSR dams have, in effect, a 65% ELCC and so a resource adequacy value of 2.2 GW. Since the estimated replacement costs is driven in large measure by resource adequacy, confidence is needed on the capacity credit assigned to the LSR dams. As well, given the importance of resource adequacy to the analysis, it is important that ELCC estimates employed for the LSR dams use similar methods to those used for other resources. Some advocates in the Northwest have presented data and analysis suggesting that a much lower capacity credit is warranted, maybe half that assumed in the E3 study, see: Addressing-the-LSR-Peaking-Capacity.pdf (nwenergy.org). DOE has not independently assessed the linked paper, or the capacity credit of the Lower Snake River dams. But given the critical nature of this single input parameter, we recommend that E3 evaluate the linked paper and LSR output data during periods of system stress to either validate or revise the assumed 65% capacity credit. If a proper ELCC-type study for these facilities has not been conducted, then a review of historical output during periods of peak historical winter and summer (net) load could be used as an approximation. Under the decarbonization scenarios, a focus on the winter period or maybe the early fall (lower PV, so potentially high net load) may be relevant. Overall, more work is needed to validate these assumptions.
  • Storage ELCC: The capacity credit of storage seems to be substantially lower than what has been calculated in other regions, particularly for the 12 - hr storage duration, after the first few GW of storage is deployed. We did not review the referenced study, but details on how these assumptions were created would be important within this slide deck. Information that would be helpful would include: (1) What does the winter peak look like? (time of day, duration, etc.); (2) What do resource profiles look like on that day, such that a combination of wind, solar, and 12-hour storage cannot contribute significantly? (3) Are interactions between wind, solar, and storage considered at all? (4) Are the scenarios in the referenced study similar enough to the scenarios in the LSR study to apply the same parameterization? Finally, are such low ELCC values for storage, even 12-hour storage, consistent with the 65% ELCC assumption made for the LSR dams?
  • . . .
  • Transmission Representation: Are the system-wide benefits of transmission (assumed to be needed for out of region wind and solar) considered? Is there any assumed resource adequacy contribution from this transmission, which could be provided from external "clean firm" resources? Also unclear more broadly how opportunity for imports and exports of all electricity services (energy, capacity, ancillary services) are being treated.

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-- BPA email from Who to Whom
circa May 18, 2022, (undated)


BPA's Environmental Communications Team shows frustration that E3 is not holding to, becoming suspect of, the overstated value of the LSR hydropower. Apparently, the Communication Team has yet to understand that reliability issues arise when power is scarce, not when it is plentiful.

As for the ELCC of the lower Snake projects, it is a little frustrating to hear them ask if the max capacity isn't just 1,000 MW like NWEC says. We have data to show that the peak capacity in the winter can be over 2,000 MW. (The average generation is 1,000 MW, so the peak will be higher anyhow.)

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-- BPA email from Birgit Koehler to Eve James along with E3's Arne Olson & Aaron Burdick
May 19, 2022 12:21PM


By mid-May 2022, peer review from Department of Energy ("DOE") and the White House Council on Environmental Quality had called into question the ELCC assumptions. The details of their concern are unpublished but it is seems likely they were directed at the oddly shaped ELCC curve for Energy Storage. Afterall, it sort of jumps out at you that Energy Storage looks so much different than ELCC curves for Solar and Wind.

This is also in the file called FrustratingAskIfMaxCapacity1000MW, a 12(?) page document
so maybe should be linking it instead, with several quotes from it.

e.g. I agree they don't point to any clear flaws, but they do point to key assumptions that drive the results but have a lot of uncertainty.

The 65% ELCC assumption we make is a clear driver of results, driven by the capacity need replacement. We're digging into some past work and the 2001 LSR output data provided by BPA to do some gut checks on that value. At the least, I could see us running a lower firm capacity % sensitivity as we discussed awhile back. We'll have a better opinion on a recommended approach once we've dug into that data a bit more.

next is the (R)egarding the comments.... (alredy included below)

(R)egarding the comments about ELCC assumptions, I can't tell if those are important to address or just note the source or logic behind the assumption ...

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-- Draft Final Report
May 19, 2022

Oh boy. Non-technical clearly is not E3's strong suit.

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-- internal BPA email from Birgit Koehler to Kathryn Pruder Scruggs, Eve James & VP Fish & Wildlife Scott Armentrout
May 20, 2022 4:38 PM


With these markets, BPA regularly purchases from the abundant supply of day time solar energy (from CA, NV, AZ, NW). Then as sunset arrives, hydropower is sold back through these same market mechanisms.

(perhaps) Mention that according to the CRSO EIS findings, sale price should be above cost of production it that is to 'sound business practices". For LSR dams, that sale price would thereby need to be ~$54/MWh, seldom achieved, and typically sold at a lower price, at a loss.

During average or high water years, Bonneville sells the surplus on the secondary market to help keep public power rates low.

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-- slide
May 20, 2022 4:38 PM


The text of the "High ELCC" (page 41 of Final Report) finding downplays the result, stating that the savings is "relatively small". When one considers the LSR dams represent less than 2% of the future grid, and their removal has a 2% benefit, then one notices the savings are commensurate with their size.

BPA's "Environmental Communications" team was on task to show that LSR power replacement with wind and solar would cover large tracts of land.

Can we make a map like this?

. . .

Katie is working to improve the E3 non-technical version of the ppt. We're hoping to get that done very quickly because it is urgent that we get back to CEO and DOE as quickly as possible.

In fact, we should discuss with E3 (and amongst ourselves) if we are far enough along that we can schedule that meeting. Many people would be happy if we could do it next week.

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-- Internal BPA email from Kathryn Pruder Scruggs (Environmental Communications Specialist) to Robert Diffely
May 23, 2022


BPA's Environmental Communication Team has yet to understand that reliability issues arise when power generation is scarce, not when it is plentiful. Maybe they do not understand E3 is to perform a Reliability Assessment, not just another BPA propaganda campaign (e.g. extolling benefits of a 3,458MW engine that seldom has the fuel to produce anywhere near that amount of energy).

I'm not quite sure what to make of the E3 slides that show that replacement resources are less MW than the 3,500 MW of the LSN. Maybe it's OK, because we can still say that it seems odd to get rid of perfectly good generation.

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-- internal BPA email from Birgit Koehler to Eve James & Kathryn Pruder Scruggs
May 23, 2022 7:53 AM


Some discussion goes here.


discussion here

Bottom line, we are suddenly under extreme pressure to get this done.

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-- internal BPA email from Birgit Koehler to Kathyrn Pruder Scruggs
May 23, 2022 3:15PM

E3's model, reveals a path towards "Deep Decarbonization" combined with salmon recovery would bring the removal LSR dams as soon as possible. Confusingly, their draft verbiage suggests those two are in conflict -- as BPA aims for the public to believe -- but E3's model proves the two are complementary.

With bluefish digging into 3,700 pages of BPA's FOIA-exempt deliberative documents (uncovered thanks to a lawsuit brought to Federal Courts by the Great Old Broads for the Wilderness) the public gets an important behind the scences look at BPA's shenanigans.


BPA Independence is suspect from the get go.
Note the document title "Bottom-Line Up Front" (is pun intended?).
Doug Johnson is introduced as being "very good at messaging most of our LSR dam capability public reports."

I received from feedback that the "Bottom-Line Up Front" and Conclusion slides need some more work
. . .

Attached are some "notes" for you to consider in the presentation. You can copy and paste into your template slides for the suggestions you like- feel free to edit and reword as needed. lam also sending a copy to Doug in our communications staff to see if he has any additional thoughts or comments since he is very good at messaging most of our lower Snake River dam capability public reports.

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-- BPA email from Eve James to E3's Aaron Burdick & Arne Olson
May 25, 2022, 8:46AM

Sparing Idaho's salmon of near certain extinction AND lowering BPA customer's cost at the same time is the solution: Remove LSR dams is E3's finding, and that is also what the CRSO EIS process found.

BPA's "Bottom Line" objective must therefore be to obfuscate the reality: Bury the fact that LSR dam removal is fast, cheap and easy.

This policy issue is looking for numbers: How much? How long?
Yes there are details, but put those after. So if you are looking
for how much -- its buried, or too complex.
And "How long?" is not in there specifically.

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-- Skype transcript of VP Fish & Wildlife Scott Armentrout
May 25, 2022


Some discussion goes here.

We can also plug in a couple of bullets from our news releases about the LSRD contribution to keeping the lights on during the cold snap and severe weather in winter 2021 and the June 2021 heat dome event.

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-- BPA email from Doug Johnson to BPA's Birgit Koehler & Eve James along with E3's Arne Olson & Aaron Burdick
May 25, 2022 9:06 AM

What are we losing?
. . .
(feedback re: 2,000MW of peaking capability) are exaggerating by only putting out the nameplate. Others are saying 1,000 -- we need to put our sustained capacity number up front to counter that narrative accurately
. . .

How long would it take to replace the services from breaching the lower Snake River dams?

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-- BPA notes of feedback upon an early E3 slide deck
undated

State EXACTLY what we are replacing. It's not 2,000 aMW, it's 3,483 of nameplate capacity.

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-- internal BPA email from Kathryn Pruder Scruggs to Eve James, Birgit Koehler and VP Scott Armentrout
May 25, 2022


Something "Ugh" goes here

I know this is a tough project - but maybe not as tough as doing CRSO over again - ugh

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-- transcribed Skype of VP Scott Armentrout
May 25, 2022


Regardless of the contracted consultants' modeling results, the "bottom line" mission given to the BPA "Environmental Communication" team is that E3's study and modeling results must validate the CRSO EIS Record of Decision. That is the unenviable task assigned. How will that challenge be tackled?

... E3 results compare with the results in the CRSO EIS to show they wouldn't change our decision on the alternative that was selected. Jill thinks that is important to include in the materials.

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-- Internal BPA email from Eve James to Kathryn Pruder Scruggs and Birgit Koehler
May 27, 2022 7:30AM

Here is some draft language to consider for the "E3 analysis not changing the decision" key message for the E3 study PPT. (8AM)
. . .
Yes, I guess not changing the decision is the bottom line. I can help with writing the message for the slide, if you like. (7:30AM)

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-- Internal BPA email from Kathryn Pruder Scruggs (Environmental Communications Specialist) to Eve James and Birgit Koehler
May 27, 2022 7:30AM & 8AM

Troubling for BPA's "Environmental Communications" team, E3's modeling reveals a more reliable electrical grid that is less expensive when LSR dams are removed; and the sooner the better.

This aligns with the findings of the CRSO EIS that LSR dams are not economic, but the Record of Decision (of October 2022) oddly kept the LSR dams in place. Now, for BPA's "environmental Communications" team, the "Bottom Line" is for that Record of Decision to be substantiated when publicly released.

In keeping with our strategy of non - defensive objectivity, could we just in a matter of fact manner point out that the emerging technology scenario by definition relies on technologies that do not exist yet a scale and that the timing and availapility of those tecnnologies in the future is uncertain.

Or something like that -- pretty sure you had a good bullet on that somewhere already.

. . .

(on slide)
While it is conceivable to replace power beneftis of the lower Snake River dams, it is expensive, lengthy and complex.

Expensive
... $100 per year per househole without economy-wide decarbonization policies and with maturation of emerging technology or up to $850 per year for each public power household

Lengthy:
-- 15 to 30 years total
for replacement resources -- it is unknown where replacement resources will be located and how much transmission infrastructure would be needed.

Complex: ... Breaching the four lower Snake River dams significantly adds to this deficit of resources in the region.

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-- Internal BPA email from Benjamin Zelinsky to Birgit Koehler, Eve James & Kathryn Pruder Scruggs (Environmental Communications Specialist)
May 27, 2022 7:30AM & 8AM

The E3 Resolve model finds that under "Scenario 2a, Deep Decarbonization", LSR dam breaching provides a more reliable grid for 2% less than a grid that keeps LSR dams intact. (E3's "Deep Decarbonization" scenario requires that all electricity generated or imported from other regions emits no carbon emissions, and forsees sizeable demand increase due to the electrification of buildings, transportation, and industry )

Interestingly, E3's "Baseline" scenario also shows a cost savings of 2% when LSR dams are breached. Either way you go (E3 only reported these two results when assuming a "High ELCC" for battery storage), LSR dams are not providing "power benefits" but make a future power grid more expensive.. To the dam supporter's dismay, that is what the DOE-commissioned, "independent" study from E3 reveals (see page 41 of Final Report).

Years earliery, the CRSO EIS came to much the same conclusion, but the accompanying Record of Decision kept the dams intact, irrespectively. The task at hand for BPA's "Envrionmental Communications Team" is to repeat that maneuvering.


some discussion here

Updated deck is attached.
We noted 700-900 aMW for now on slide 3, pending any further data/guidance on this (though we've still modeled 706 aMW in our RESOLVE cases).
. . .
The average annual generation with the updated CRSO EIS assumptions on the LSN projects is 862 aMW for the 90 year streamflow set.
. . .
Some white book data I was looking at had the LSN gen -940 aMW but I want to make sure it has the correct spill operation.
. . .
...we could also just add a note that says 700-900 aMW* (* E3's RESOLVE model uses 2001, 2005, and 2011 hydro years, which resulted in ~700 aMW of lower snake river dams generation, making it a conservative estimate of the dams' GHG-free energy value).
. . .
We're nearing a second draft. Can we meet briefly after lunch to discuss how we've integrated the BPA feedback and confirm any open questions?

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-- E3 email from Aaron Burdick to BPA's Eve James & Birgit Koehler
May 27, 2022, 5:25PM

Then Birgit's husband realized that batteries could readily be a LSR power replacement, and that solution would occupy a mere 3 to 6 acres and online in 3 to 6 months. That's fast. And easy.

Using Megapack, Tesla can deploy an emissions-free 250 MW, 1 GWh power plant in less than three months on a three-acre footprint - four times faster than a traditional fossil fuel power plant of that size.

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-- from Birgit's Husband
not dated


June 2022



some discussion here

Joel Cook will be hugely pleased to see these high numbers in the powerpoint. Very cool!
. . .
Interesting that these were all 1982. Clearly no spill, and some are 3 hours. We can find a way to say that we have generated over 3,400 MW somewhere in our presentations.
. . .
Maybe once fish operations happened on the projects so 1990 - 2021? I have some look back data that has a high value of 2955 MW

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-- BPA email from Who to Whom
May 31, 2022, 4:42PM


Some discussion goes here.

Some of the statements we had in our notes suggestions they weren't comfortable putting in since the study wasn't about that topic specifically and they want to keep the slides clean and independent from BPA messaging

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-- Transcript of Skype between Birgit Koehler and Eve James
May 31, 2022


In May 2022, Battery Storage may have been "Mature Technologies" though it was not selected.

Scenario 1: 100% Clean Retail Sales
  • 100% of retail sales met with clean energy by 2045, ~85% carbon reduction
  • Business-as-usual load growth
  • Can be achieved using existing mature technologies

Scenario 2: Deep Decarbonization

  • Zero carbon emissions remain in 2045
  • High electrification load growth consistent with economy-wide carbon abatement scenarios.
  • Emerging technologies are key to meeting higher winter reliability needs with carbon-free power

. . .

Replacing the Lower Snake River Dams
Scenario 1: 100% Clean Retail Sales

  • Capacity replaced with dual fuel natural gas + hydrogen turbines
  • Energy replaced by wind and net imports

Replacing the Lower Snake River Dams
Scenario 2: Deep Decarbonization

  • Capacity replaced with dual fuel natural gas + hydrogen turbines
  • Energy replaced by wind and net imports

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-- BPA Lower Snake River Dams Project Draft Final Results
May 2022


Using Megapack, Tesla can deploy an emissions-free 250 MW, 1 GWh power plant in less than three months on a three-acre footprint -- four times faster than a traditional fossil fuel power plant of that size.

-- Note from Mark, possibly Birgit's husband
May 23, 2022 10:26 AM

Show/Hide


Maybe not overlay on the LSN reservoirs, because they are a large area themselves.

-- BPA internal email, Birgit Koehler to Kathryn Pruder Scruggs
Subject: RE: can we make a map like this?
May 23, 2022 10:26 AM

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Maybe include the bit that technical language, is non-layman, and slips by the gatekeeper.

During the December 2021 'Cold Snap', the Northwest was exporting 3000 to 4000 MW every hour of the day, December 24-30, while Lower Snake River was providing around one-quarter of this energy surplus.

We can also plug in a couple of bullets from our news releases about the LSRD contribution to keeping the lights on during the cold snap and severe weather in winter 2021 and the June 2021 heat dome event.

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-- BPA email from Doug Johnson to Eve James and E3's Aaron Burdick & Arne Olsen
May 25, 2022

Graphic: During the December 2021 'Cold Snap', the Northwest was exporting 3000 to 4000 MW every hour of the day, December 24-30, while Lower Snake River was providing around one-quarter of this energy surplus.

Graphic: Lower Snake River hydropower's highest generation in any hour of the year, understandably sloping downwards since 1980 due to wear and tear of machinery.


Within the BPA executive suite, it has been a long-held assertion that the four LSR dams provide a benefit to the electric grid worthy of their cost. But model after model fails to support that false claim, and each and every "Executive Summary" strives to hide that very fact.

In the opinion of bluefish, BPA executives have long been less-than-honest in reporting LSR power benefits, and this has unpacks a raft of supporting evidence.

Consider BPA's interpretation of its foundational legal directive; to "market this power in such a manner as to encourage the most widespread use thereof at the lowest possible rates to consumers consistent with sound business principles". Are they complying with their mandate? How does this depend on the meaning of "market"? Tobacco companies being emblematic.

More to the point, is everyone in BPA's executive suite always in full agreement on interpreting their foundational legal directive?

Revealing is a transcribed Skype (5/25/22) wherein Vice President Fish and Wildlife, Scott Armentrout, makes a proposal to BPA Executives. Shouldn't there exist a trigger to inform leadership as to when a hydropower project (e.g. salmon-killing LSR dams) is worth the cost or not. Fish mitigation costs on LSR projects are exorbitant, and this thereby is reasonable proposal to consider.

Recently in the news, "public power" has been seeking to be relieved of the economic burden placed upon them by high-cost federal dams in Willamette Valley, Oregon. A similar argument could be laid upon the LSR projects. Importantly, both sets of dams were Congressionally authorized for purpose of "commercial navigation" (check that SCOTT, logs I recall), with hydropower production playing an auxilary, seconday role.

With their "commerical navigation" declining over the years, and maintenance costs remaining high, at some point their obsolescence is assured. Is it not? The "power benefits" then become important metrics for decision makers to consider.

Early in the E3 study process, VP Armentrout asks for such a trigger; what would tip the scale towards river restoration and dam breaching? BPA's VP of Fish & Wildlife deserves such an answer.

I heard (P)ower (a division of BPA separate from Transmission) say that power generation at the Willamette's was no longer beneficial at a certain number. ... While not relevant with this E3 study, it is a concept I still think leadership could use -- what are we watching for as triggers to make a conclusion that a cost is worth it or not worth it.

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-- Skype transcript of Scott Armentrout relayed by Birgit Koehler to Kathryn Pruder Scruggs (Environmental Communications Specialist) and Eve James,
May 25, 2022 9:49AM

In searching through the available record, it seems that no reply was then provided to BPA's VP Armentrout. To ask leadership for some preset condition from which "to make a conclusion that a cost is worth it or not worth it" is reasonable, especially when coming from the Vice President of Fish and Wildlife. As well, it seems to comply pefectly with the "sound business practices" that BPA is legal obliged to follow.

Breaching the Lower Snake River dams, the primary component of Multiple Objective 3 (MO3) bings the greatest cost savings of all alternatives considered in a 2020 NEPA report.

See also Tri-City Herald by Annette Cary
and
bluefish dueling with the CRSO EIS process in which nobody wins.


Something here.

Joel Cook will be hugely pleased to see these high numbers in the powerpoint. Very cool!

...

Thanks- could you look at the top hour from more recent data. Maybe once fish operations happened on the projects so 1990 -- 2021? I have some look back data that has a high value of 2955 MW- is there any data higher than that for that date range?

...

Interesting that these were all 1982. Clearly no spill, and some are 3 hours. We can find a way to say that we have generated over 3,400 MW somewhere in our presentations.

...

No problem! Narrowing down the data to what we need is best!

The Max Hour Gen in 2014 (2962 MW) happened in the month of March, just as you suspected... If only looking at months of Dec to Feb, here are the top 5 Max Hour gen for 2006 -- 2021:

Top 5 Single- hr Gen MWh
Jan - 2011 2838
Feb - 2015 2438
Feb - 2006 2419
Jan - 2006 2299
Feb - 2017 2299

Show/Hide

-- internal BPA emails between Birgit Koehler, Eve James, Steve Bellcoff, Esther Neuls & Ryan Egerdahl
May 31 - June 1, 2022


Pricing for Tesla Megapacks as of March 2025

Tesla can deploy an emissions-free 250 MW, 1 GWh power plant in less than three months on a three-acre footprint ...

-- BPA internal email, Birgit Koehler to Robert Diffely, Subject: RE: can we make a map like this?
June 1, 2022 7:30 PM


Second slide already shows intended result of the E3 study, yet to be completed.

"Would conclusions in the E3 study change the decision for the Columbia Rivei System EnvironmentaLImpact Statement ?

No. In fact, the E3 study confirms the decision."
In these early slides, we are watching misinformation in development early in the "study".