PNGC Power   711 NE Halsey • Portland, Oregon 97232-1268 • 503.288.1234
River
Northwest RTO/ISO
It’s time for the Northwest to move to a well-designed RTO/ISO. Most of the country operates under this organized transmission market structure and the nation’s largest RTO/ISO originated in 1927. BPA owns and operates about 75% of the Northwest’s high voltage electrical transmission system. Therefore, policy discussions regarding the region’s successful evolution toward a Northwest RTO/ISO that provides fair and open transmission access and an efficient market structure and ability to build physical infrastructure to provide clean, affordable and reliable power for the entire region, requires strong stakeholder engagement with BPA. But PNGC is looking to engage with a broader “coalition of the willing” to review options that best meet the needs of Northwest electric utility customers.  
 
We are encouraged by The Northwest Power Pool (NWPP)-led effort to establish a Resource Adequacy (RA) program. Given the closures of coal, nuclear, and gas generation plants around the west it is in everyone’s interest to make sure a RA program adequately addresses emerging reliability issues. However, RA cannot stand-alone as a set of standards and requirements unless it is supported by fair and open transmission access and effective markets that allow everyone to meet those standards under reasonable terms and conditions. 
 
PNGC does not support further steps towards the CAISO. While the CAISO EIM, for example, is an innovative tool and limited market structure, we remain concerned that the CAISO has multiple problems and fundamentally does not serve the Northwest’s interests. It is important to understand that the western US and Canada are physically and economically interconnected when it comes to electricity. We therefore, do not support any market structure where a single state (or province) can dictate rules and take actions that adversely impact other states or provinces. That is why we favor a multi-state/province RTO/ISO that logically starts with the Northwest US, with possible extension into the Southwest US, Rocky Mountain States and Western Canada.