CGNP's Opposition to the WWGPI

PacifiCorp doesn't seem to get the hint from the California Legislature and Governor that the state does not want more coal-fired power.... Instead PacifiCorp goes to the Feds.

For about 8 years, CGNP has vigorously opposed PacifiCorp’s lobbying to export more coal-fired power into California via CAISO grid regionalization. The California legislature opposed AB 813 {Holden 2018) and AB 538 (Holden, 2023) California’s governors have signed executive orders calling for decreased power - sector emissions. So, Berkshire Hathaway Energy subsidiary PacifiCorp, which operates a fleet of mostly coal-fired power plants, principally in Wyoming, elected to quietly lobby a quasi-federal bureaucracy that you likely never heard of, The Western Interstate Energy Board. CGNP learned about this gambit and filed a 31-page long single-spaced Objection prior to the May 8, 2024 deadline. (Several past or present PacifiCorp employees are part of the proposed governance structure disclosed at the WWGPI website.)

Here’s what CGNP is protecting:

(Photo credit: CGNP) This is the sign at the entrance of PG&E’s Diablo Canyon Power Plant (DCPP.) While the sign reads “California’s Largest Clean Energy Producer” the plant is also “California’s Largest Energy Producer.” DCPP’s typical annual electricity production is equal to five Hoover Dams., or about 18 TWh, where a TWh is a billion kilowatt-hours.

The first two pages of CGNP’s 31-page-long filing are reproduced below. This serves as an introduction to this controversy.

Western Interstate Energy Board  Committee on Regional Electric Power Cooperation (WIEB-CREPC)

1600 Broadway, Suite 1020
Denver, Colorado 80202

(720) 897-4600

https://www.westernenergyboard.org/wwgpi/     website

Comments@WestWidePathwaysInitiative.org   email

May 8, 2024

OPPOSE the West-Wide Governance Pathways Initiative (WWGPI)

SUMMARY:

            The WWGPI is likely supported by vigorous lobbying by coal interests in states such as Wyoming with weak environmental protections. Independent nonprofit Californians for Green Nuclear Power (CGNP) believes the purpose of the WWGPI is to eventually implement a west-wide RTO or ISO to replace the California Independent System Operator (CAISO) for the state of California, despite a consistent rejection by the California legislature of CAISO grid regionalization plans. The California legislature rejected CAISO grid regionalization as a consequence of grid governance concerns and environmental concerns - this is a "state's rights" issue.  CAISO has a footprint covering a large part of California and a small portion of Nevada. CAISO is controlled by a board selected by the Governor of California, yielding state control. CAISO's mandates were changed as a consequence of ENRON's profiteering schemes which significantly harmed the economic interests of California electricity and natural gas ratepayers.

            California is vulnerable to out-of-state interests taking advantage of California's structural deficiency of a lack of in-state generation to serve all of the state's load coupled with high in-state demand. California imports roughly 1/3 of its annual power consumption of about 300 TWh / year, where a TWh is 1 billion kilowatt-hours. This is the largest amount of electricity imports of any state. California imports roughly 95% of the natural gas consumed in the state. In a videoconference about 3 years ago, CGNP observed a pair of WIEB-CREPC officials describing a plan where the west-wide RTO would be created with participation of the western states except California. Then, plan proponents would "circle back" to include California. The harms to California include the potential nullification of California environmental laws such as SB 1368 (Perata, 2006) as a consequence of the 2016 U.S. Supreme Court decision in   Hughes v. Talen Energy. In multistate RTOs or ISOs, state environmental laws regarding electricity generation policies are at risk for nullification as a consequence of federal preemption based on the U.S. Constitution's Commerce Clause. The ENRON saga also serves to illustrate how out-of-state firms took advantage of the essentially inelastic demand for electricity and natural gas to supply energy to California's industries and residences in our modern society. For the above reasons, the WWGPI should be rejected.

Table of Contents

SUMMARY: 1

A. PacifiCorp is primarily a coal-fired utility. 3

B. PacifiCorp expends millions annually lobbying California - CGNP Concerns with PacifiCorp lobbying disclosures  7

C. A Significant U.S. Supreme Court Case  Hughes v. Talen Energy (2016). 12

D. The California Legislature and CGNP Prefer CAISO Remain a California-based ISO.. 15

E.  The "Unspecified Sources" Loophole in California Power Source Disclosures. 15

F. California's  Need For DCPP's Dispatchable Power. 16

G. The German Economic Calamity called "Energiewende" is Cautionary for California. 17

H. Conclusion. 19

APPENDIX. 20

The Former Chancellor Who Became Putin’s Man in Germany. 20

Germany’s Greens embrace coal 22

Germans Are Getting Mugged by Reality of Green Energy. 24

"This is nonsense"-Ex-Eon supervisory board contradicts Habeck's reasons for phasing out nuclear power  ....27

Did the minister lie?-Nuclear power plant operators contradict Habeck's representation. 29

Voting intention in Germany 2021-2024. 30

The Ampel's woes continue in 2024. 31

CGNP's link to the entire 31-page WWGPI Opposition Comments is found inside a short article at the CGNP website. https://tinyurl.com/No-WWGPI      

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There are several relevant new articles found at CGNP's GreenNUKE Substack.  They are listed in chronological order.  The final number in the bold URLs are sequential.  More information is located at the CGNP website.

· Why is Grid Inertia Important? - Without sufficient synchronous grid inertia, the grid becomes unstable and a blackout occurs.    March 4, 2024     https://tinyurl.com/No-WWGPI-1

·  BHE is a Likely Opponent of DCPP Extended Operations - Part 1 -  The CPUC has been aggressively lobbied, likely by BHE subsidiary PacifiCorp to make a series of "coal-friendly" decisions   April 20, 2024  https://tinyurl.com/No-WWGPI-2

· BHE is a Likely Opponent of DCPP Extended Operations - Part 2  - BHE's 2020 coal-fired generation was about 174% of DCPP's typical annual power production. BHE's 2020 natural gas-fired generation adds 67% of DCPP's production for a total of 241%.  April 21, 2024    https://tinyurl.com/No-WWGPI-3

· Top German Greens officials accused of deception in nuclear phase-out advice - After months of obstructions, a German high court forces the German government to disclose key internal memoranda regarding a nuclear phase-out following the February, 2022 Russian attack of Ukraine   April 28, 2024   https://tinyurl.com/No-WWGPI-4

· How Did the CPUC Decide to Deny CGNP Intervenor Compensation? - Lavish Opposition Lobbying Likely Culprit   May 2, 2024     https://tinyurl.com/No-WWGPI-5

· 'Filing Error' (cough) in PacifiCorp's Most Recent California Lobbying Disclosure - PacifiCorp likely spent the greatest amount on California lobbying of any firm during 1Q 2024. PacifiCorp supplied a misleading amount of ZERO on the first page of their mandatory disclosure        May 10, 2024       https://tinyurl.com/No-WWGPI-6

P.S. In case you did not know, CGNP does not receive any funding from PG&E, DCPP’s owner.

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