NIPPC’s comments in Montana PSC docket 2022.09.087 regarding data center loads and resource adequacy in Montana
NIPPC and WPTF joint comments protesting PGE’s EDAM implementation filing before FERC in docket no. ER25-1868-000
NIPPC comments on Avista’s amended 2025 RFP, in UE 250155 at the Washington UTC
NIPPC submits comments for the UTC to review in Avista’s draft 2025 RFP, UE 250155
NIPPC comments on the commission’s proposed rules in its IRP/RFP modernization docket, AR 669, focusing on utility access to confidential bidder information,
NIPPC continues to push for PGE to make its transmission available to all bidders in UM 2371, Portland General Electric’s 2025 All-Source RFP
NIPPC’s Opening Testimony, drafted by expert witness, Ali Al-Jabir, in the Oregon PUC investigation into direct access, UM 2024
NIPPC comments on EDAM Congestion Revenue Allocation draft final proposal, using the Q&A form provided by the CAISO
NIPPC and RNW comments to BPA in response to topics raised at its April 21st Transmission Planning Reform Workshop
NIPPC comments on BPA’s Day-Ahead Market Draft Policy
NIPPC and WPTF file joint comments before FERC in PacifiCorp’s EDAM proceeding, RE-25-951-000
NIPPC submits comments to the UTC on the independent evaluator’s final report in Puget Sound Energy’s 2021 All-source RFP, UE 210220
NIPPC comments on staff’s draft report in the OPUC’s IRP/RFP modernization docket, UM 2348
NIPPC comments on staff’s recommendations in UM 2371, Portland General Electric’s 2025 RFP
NIPPC comments to BPA on its proposed interim solutions for Network Integration Transmission Service (NITS), following its March 7workshop presentation on Access to Transmission Capacity Initial Alternatives
NIPPC and WPTF joint filing to protest PacifiCorp’s EDAM filing at FERC, in PacifiCorp’s EDAM implementation docket, ER25-951-000
NIPPC’s final workshop comments in UM2348, the OPUC’s IRP and RFP modernization investigation
NIPPC’s comments to the CAISO as part of its annual policy initiatives roadmap on congestion allocation costs, highlighted by PacifiCorp’s EDAM implementation filing
NIPPC comments following the January 30 BPA workshop to evaluate its Day-Ahead Market decision
NIPPC comments to BPA on its transmission planning reform process, including NIPPC / RNW recommendations from their White Paper
NIPPC comments on BPA’s proposed business practice of “requesting transmission service”
NIPPC and Renewable Northwest’s joint direct testimony in the BPA BP-26 Rate Proceeding for the 2026-2029 rate period
NIPPC’s comments on the draft rules on the implementation of CETA, and the ongoing dispute over the word ‘use’ in Washington UTC docket UE-210183
NIPPC comments to Portland General Electric on its proposed tariff changes to implement EDAM
NIPPC’s response brief to the OPUC regarding PacifiCorp’s HB 2021 compliance investigation, UM 2345
NIPPC comments on OPUC staff’s report on the final shortlist for Portland General Electric’s 2023 All-Source RFP, UM 2274, including its request for a partial waiver of the competitive bidding rules
NIPPC’s initial brief in UM 2345, the OPUC case looking at PacifiCorp’s continual progress towards HB 2021 compliance
NIPPC comments to BPA on its November 5th day-ahead market workshop, recommending BPA delays its timeline for making a day-ahead market decision until the end of 2025
NIPPC and Renewable Northwest’s comments to BPA on staff’s preliminary proposal on transmission RDC (reserves distribution clause) use in FY 2024, urging the BPA Administrator to return the accumulated surplus reserves to transmission customers as a credit
NIPPC comments to the Washington State Department of Ecology on its Cap-and-Invest Linkage Rulemaking
NIPPC comments to PGE on its proposed acreage requirements in its proposed business practice related to site control requirements for interconnection
NIPPC’s petition to intervene in UM 2345, the OPUC case on PacifiCorp’s compliance with HB-2021
NIPPC and Renewable Northwest comment to BPA on its BP/TC 26 September 25-26 workshop
NIPPC and Renewable Northwest comment to BPA on its BP/TC 26 August 27/28 workshops
NIPPC comments in case IPC-E-24-12, Idaho Power’s application for approval of a market purchase agreement focusing on competitive procurement rules in Idaho, 8/6/24
NIPPC’s comments on Puget Sound Energy’s voluntary RPF docket UE 240532, 7/31/24
NIPPC comments on the OPUC staff report reviewing RA rules in Oregon for ESS providers, UM 2337, 8/27/24
NIPPC and Renewable Northwest submit response to the OPUC in UE-427, the case considering whether access should be granted to highly confidential bidder information from PGE’s 2021 RFP, 8/9/24
NIPPC comments on OPUC staff’s report on Idaho Power’s draft RFP, UM 2317, 8/9/24
NIPPC comments to BPA on its BP/TC 26 July 30 workshop, 8/14/24
NIPPC’s updated comments on BPA’s revised notice to enforce TSR data exhibit requirements, 7/16/24
NIPPC and Renewable Northwest comments to BPA on its BP/TC 26 June 26 workshop on generator interconnection withdrawal penalties, non-EIM balancing, affected system studies, and attachment and transmission planning, 7/10/24
NIPPC comments on BPA’s June 3rd day-ahead market evaluation workshop, including outstanding NIPPC questions to the agency, 7/4/24
NIPPC joint comments to the UTC, urging the commission to revisit their interpretation of the term “use” in CETA rulemaking UE 210183, 6/21/24
NIPPC submits comments to the UTC in UE 210183, the commission’s docket to clarify the interpretation of CETA, the Clean Energy Transformation Act, 5/10/24
NIPPC’s comments to the OPUC on Idaho Power’s 2028 RFP, in docket UM 2317, 6/3/24
NIPPC, REC and CREA’s joint comments in UM 2000, the OPUC’s examination of the policies governing avoided cost rates for QFs in Oregon, 5/15/24
NIPPC comments to BPA in response to the BPA Tech Forum announcement that it will strictly enforce its Transmission Service Request data exhibit requirements, 6/4/24
NIPPC and Renewable Northwest comments to BPA on its BP/TC 26 May 22 workshop, 6/4/24
NIPPC and Renewable Northwest comments to BPA on its BP/TC 26 April 24 workshop, 5/8/24
NIPPC comments to BPA on staff’s day-ahead market recommendation leaning towards Markets+, 5/3/24
NIPPC submits comments to the UTC on PSE’s request for a rate of return on PPAs, 3/1/24
NIPPC responses to PGE in the OPUC’s direct access investigation, UM 2024, 4/5/24
NIPPC comments on planning for NITS loads and resources, 4/22/24
NIPPC’s second set of informal comments in the Washington Department of Ecology’s rulemaking on markets, 2/15/24
NIPPC’s pre-workshop comments in the Washington UTC’s rulemaking UE-210183, to consider the adoption of markets and compliance requirements for CETA, 2/16/24
NIPPC’s straw proposal on direct access issues in UM 2024, the OPUC’s investigation into long-term direct access programs, 2/29/24
Joint reply comments from NIPPC, Calpine and Brookfield Renewable in AR 660, the OPUC’s docket on the adoption of rules relating to resource adequacy in Oregon, 2/13/24
NIPPC comments on the commission staff’s report recommending acknowledgement of Idaho Power’s 2026 RFP final shortlist in UM 2255, Idaho Power’s RFP, 2/8/24
NIPPC’s comments to the Department of Energy on its proposed NEPA rulemaking, 1/2/24
NIPPC’s West-Wide Governance Pathways Initiative comments, supporting a paired approach of a short-term and long-term solution, 1/12/24
NIPPC’s opening comments in AR 660, the OPUC’s rulemaking into resource adequacy, 8/1/24
NIPPC’s comments on the OPUC’s Notice of Proposed Rulemaking (NOPR) on direct access programs in Oregon, highlighting the ongoing lengthy process of over 5 years, in AR 651, 4/25/23
NIPPC, REC and CREA, jointly the QF trade associations, submit comments on staff’s straw proposal on standard solar-plus-storage rates in Oregon, as part of UM 2000, the OPUC’s investigation into PURPA implementation, 4/25/23
NIPPC comments to the OPUC in UM 2274, Portland General Electric’s request to waive certain competitive bidding guidelines from its 2023 All-Source RFP, 4/13/23
Joint comments filed by NIPPC, REC and CREA in response to the joint utilities’ motion for a rehearing or clarification of the commission order in UM 2032, the OPUC’s investigation into the treatment of network upgrade costs for qualifying facilities, 4/5/23
NIPPC’s comments to the OPUC in UM 2255, Idaho Power’s draft RFP to meet 2026 capacity needs, 3/17/23
NIPPC’s comments on staff’s updated straw proposal in UM 2143, the OPUC’s resource adequacy investigation, 3/13/23
NIPPC comments to BPA on the alternatives the agency identified for interconnection queue reform at its March 16/17 workshops, 3/29/23
NIPPC comments to BPA on the provider of choice process, supporting efforts to increase the size of the federal system, 3/21/23
NIPPC comments to BPA on generator interconnection queue reform as part of the kickoff to the TC-25 tariff revision process, 3/1/23
NIPPC’s final comments and issues matrix in UM 2274, PGE’s RFP docket, 12/21/23
NIPPC’s comments to the Montana PSC on Northwestern Energy’s 2023 IRP, docket 2022.11.102, 10/6/23
NIPPC comments to the Washington Department of Ecology on its Electricity Markets Rulemaking for importers, 10/30/23
NIPPC comments on the current draft rules in docket UE-210183 on CETA implementation with regard to the adoption of markets and compliance requirements, 11/27/23
NIPPC’s comments to NorthernGrid on its draft regional transmission plan, 10/11/23
NIPPC submits joint comments to SPP, as part of the independents sector, on potential governance changes for its Markets+ program, 10/10/23
NIPPC’s comments in UM 2274 on PGE’s supplemental filing related to its affiliate, Portland Renewable Resource Co. (PRP) bidding into its RFP, 11/17/23
NIPPC comments on BPA’s Day Ahead Market Process, following BPA’s September workshop, 10/15/23
NIPPC’s motion to intervene in ER23-2686, the CAISO’s proposed tariff amendment to implement its day-ahead market, 9/21/23
NIPPC’s response to PGE’s motion for clarification or reconsideration in UI 489, PGE’s refiled affiliate application, 9/27/23
NIPPC submits comments on staff’s report in UM 2143, the OPUC’s investigation into resource adequacy in Oregon, 9/18/23
NIPPC’s comments in UM 1631, PGE’s waiver request to provide limited load forecasting information for its Green Future Enterprise (GFE) program, 8/28/23
NIPPC comments on PacifiCorp’s Solar + Storage rate in UM 1729, 8/28/23
NIPPC comments in UI 489, PGE’s refiled affiliate application, 8/4/23
NIPPC comments on the EDAM tariff submitted to the CAISO, 7/7/23
NIPPC principles submitted in BPA’s stakeholder process in its consideration of participating in the day-ahead market, 8/15/23
NIPPC comments on the facilitation of a consumer led workshop series in U-230161, the UTC’s investigation on the impact of the Climate Commitment Act on IOUs in Washington state, 5/10/23
NIPPC comments opposing approval of PGE’s application to form an affiliate to bid in its RFP process, docket UI 489, 6/29/23
Expert report on imputed debt, authored by Michael Gorman for NIPPC, as part of the coalition’s filings in UM 2274, PGE’s RFP case, 6/21/23
NIPPC’s comments on PGE’s requests for acknowledgement of its draft RFP, and a partial waiver of the competitive bidding rules in UM 2274, 6/16/23
NIPPC’s comments on staff’s draft resource adequacy rules proposal in UM 2143, the OPUC’s investigation into resource adequacy in Oregon, 6/12/23
NIPPC’s comments and updated issues list filed in OPUC docket UM 2255, updating NIPPC’s position following staff’s report in Idaho Power’s RFP, 6/6/23
NIPPC submits comments on staff’s report in Idaho Power’s 2026 draft RFP, in UM 2255, 5/9/23
NIPPC’s comments on BPA’s May TC-25 workshop, 6/1/23
NIPPC and RNW Whitepaper on Reforms to BPA’s Transmission Planning and Business Case Policies, “‘Appropriate and Required’: BPA and Building the Grid the Northwest Needs”, 5/3/23
NIPPC comments on staff’s proposal for generator interconnection queue reform as part of the TC-25 process, 5/2/23
NIPPC Position Statement on Western Wholesale Market Reforms and RTOs, July 2023
NIPPC comments to the House Committee on Environment & Energy on the provision in HB 1589 for utility bias on procurement and ownership as part of Washington State’s decarbonization goals, 2/6/23
NIPPC comments to the House Committee on Environment & Energy on House Bill 1192, the Washington transmission reform bill supported by Gov. Jay Inslee, 1/19/23