Document Type: Filings

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

NIPPC’s final comments in AR 631, the OPUC case on proposed rules for standard PPA contract terms and conditions, 2/16/23

NIPPC letter to BPA Administrator, John Hairston requesting BPA to launch an initiative focused on reforming transmission planning and project execution to accelerate capacity upgrades, 2/9/23

Test Date

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

NIPPC comments to BPA on its proposed business practice change to curtailments on 1:1 paths, 2/8/23

NIPPC’s Answer to PacifiCorp’s Replacement Generation Interconnection proposal in FERC docket ER23-408, 12/30/22

NIPPC’s Protest and Comments to WPP’s Response to Deficiency Letter in proceeding ER22-2762 on the WRAP tariff submission to FERC, 12/30/22

NIPPC’s supplemental comments in MPSC docket 2021.01.007, the implementation of HB 597 regarding utility competitive procurement and resource planning practices, 11/28/22

Reply from NIPPC, to WPP’s answer, to NIPPC’s protest of the WRAP tariff filing at FERC, 11/15/22

NIPPC, REC and CREA’s joint comments on the amendments to the proposed rules, in AR 631, the OPUC’s rulemaking on standard QF contract terms, 12/16/22

NIPPC comments on the preferential curtailment of Direct Access customers in AR 651, the OPUC’s informal rulemaking for direct access regulations, 11/18/22

NIPPC comments on the EDAM draft final proposal, using the CAISO
comment template, 11/22/22

NIPPC comments to the Washington UTC in UE-210795, Puget Sound Energy’s 2021 Clean Energy Implementation Plan (CEIP), 3/2/22

NIPPC’s comments in MPSC docket 2022.09.087, the Montana commission’s resource adequacy investigation, 10/14/22

Henry Tilghman’s summary statement on behalf of NIPPC at FERC’s technical conference on regional transmission planning, AD22-8-000, 10/4/22

NIPPC’s comments and protest in docket ER22-2762-000, The Western Power Pool’s proposed tariff for the WRAP before FERC, 9/30/22

NIPPC’s motion to intervene before FERC in the Western Power Pool’s proposed tariff for the Western Resource Adequacy Program, 9/27/22

NIPPC submits comments in FERC’s Interconnection NOPR, 9/14/22

NIPPC comments on the Southwest Power Pool’s draft proposal for Western Day-Ahead market and related services, 10/28/22

NIPPC’s comments on SPP’s Markets+ design document, 9/15/22

NIPPC, REC and CREA’s joint reply comments in AR 631, the OPUC’s rulemaking on standard QF contract terms, 10/7/22

NIPPC, REC and CREA’s joint comments on Group 2 rules in AR 631, the OPUC’s rulemaking on standard contract terms for qualifying facilities, 9/16/22

NIPPC comments on staff’s straw proposal for Division 38 rule language in AR 651, the OPUC’s informal rulemaking for Direct Access regulations, 9/15/22

NIPPC, REC and CREA submit post hearing reply brief in UM 2032, the OPUC’s docket on network upgrade cost allocation and interconnection service, 9/2/22

NIPPC comments on the CAISO EDAM revised straw proposal, following the Q&A format requested from stakeholders by CAISO, 9/26/22

NIPPC’s pre-hearing comments in the Montana PSC’s RFP rulemaking docket 2021.01.007, 8/10/22

NIPPC comments on FERC’s transmission planning NOPR, RM21-17-000, 8/17/22

NIPPC comments to the Department of Ecology on its draft Cap & Invest program rules, 7/15/22

NIPPC comments to SPP on the draft governance straw proposal for the Markets+ program, 7/15/22

NIPPC’s response to PacifiCorp’s Motion to Dismiss before the Deschutes County Court in NewSun’s objection to PacifiCorp’s RFP, UM 2193, 8/25/22

NIPPC’s motion to intervene in PacifiCorp’s RFP appeal, before the Deschutes County Court in UM 2193, 8/23/22

NIPPC’s reply testimony on PacifiCorp’s proposed new green tariff for large customers in OPUC docket UE 399, 8/11/22

NIPPC, REC and CREA submit comments in UM 2032, the OPUC’s investigation into network upgrade costs for qualifying facilities, 8/5/22

NIPPC comments on the BP-24 / TC-24 rate case workshops, July 29 & 30, addressing generation inputs, 8/10/22