Preliminary Analysis of Spill Test

1. Preliminary Analysis of Spill Test February 4, 2014

2. Preliminary Analysis • A Spill Test at 125% TDG from April 3 to June 20 for 24 hours a day has been submitted through a number of venues including NOAA’s draft FCRPS Biological Opinion, the federal Action Agencies draft 2014-2018 FCRPS Biological Opinion Implementation Plan and the Northwest Power and Conservation Council Fish & Wildlife Program Amendment process. • At the request of constituents, we have conducted a preliminary analysis of the more spill proposal as we understand it. The proposal contains caveats in a number of areas, but the details were not included.

3. Spill Test Would Reduce Average Annual Federal Generation by 600 aMW No BiOp Fish Operations Current Fish Operations Spill Test Proposal ~9,400 aMW per year ~8,400 aMW per year ~7,800 aMW per year About 1000 annual aMW About 600 annual aMW For perspective: City of Seattle uses about 1,171 aMW per year Columbia Generating Station (nuclear plant in Richland) produces about 1,030 aMW per year Centralia Coal Plant produces about 1,200 aMW per year Estimated annual average megawatts, based on an evaluation of the historical 80 year water supply record

4. Lost Generation Would be Concentrated in the Spring Current Fish Operations Spill Test Proposal Generation would be reduced – on average – every hour in the spring by 2,500 MW ~10,000 aMW produced in Spring ~7,500 aMW produced in Spring For perspective: It would take more than six typical 400 MW combined cycle gas plants to produce the amount of energy removed from the system in the spring. Energy efficiency cannot replace this magnitude of power in the spring in the NW. Estimated average megawatt hours, April 3 – June 20, based on an evaluation of the historical 80 year water supply record

5. 10-Year Test – Would Reduce Value of Hydro System by Over One Billion Dollars • $100 million per year in lost firm power (450 aMW per year) • $10 million per year in lost secondary power sales (150 aMW per year)

6. Total Rate Effect: Almost 8% Increase • Oregon’s spill proposal increases rates since it both reduces secondary energy sales revenue that offset BPA’s operating costs and and decreases the number of megawatt hours BPA has to sell – which means BPA’s cost per megawatt hour will be higher • In addition, customers will also have to replace the lost 450 annual aMW of lost firm power they can no longer get from the federal system • The overall wholesale rate effect to BPA’s customer utilities is estimated to be an increase of nearly 8 percent

7. Carbon Impacts of Replacement Energy • CO2 production increase: ~ 1.9 million metric tons (MT) • $55 million per year in social cost of carbon* • This estimate is based on a study prepared by the Northwest Power and Conservation Council in 2008 • In the Pacific Northwest, hydro, wind, and other renewables are used before combustion turbines and coal as they have lower costs to run. • For most of the year, natural gas fired power plants are the last resource brought online to supply power instantaneously and to respond to decreases in hydropower production • A typical combined cycle natural gas fired power plant emits 800 lbs. of C02 per megawatt hour • A one megawatt hour decrease in hydropower results in 800 lbs. of CO2production • The equivalent of about 440,000 cars or 28,000 tanker trucks of gasoline consumed * Based on data from the May 2013 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis – Under Executive Order 12866. Using $29.15 per metric ton of CO2 (the medium probability case)

8. Operations Impacts • The flexibility of the federal hydro system is used to balance changes in resources and loads on a second by second basis. • Proposed spill test would significantly reduce the flexibility of the FCRPS to respond to changes in loads or wind output.

9. Balancing Reserves • The hydro system has limits on what it can provide and still comply with all hydraulic objectives including current fish operations • Reduced flexibility could severely reduce quantity of balancing reserves that could be provided by the hydro system. • With the addition of a large wind fleet the need for balancing reserves has increased • With the spill proposal, new resources likely would be needed to provide balancing services for bothexisting and future variable renewable resources which would likely increase the cost to provide these resources

10. Oversupply of Generation • Spilling to 125% TDG for 11 weeks may reduce the implementation of oversupply management protocol (displacement of wind); • But the magnitude of more spill is on average 600 aMWs of hydropower, while our experience with oversupply situations has resulted in displacements of: 11 aMWs in 2011, 6 aMWs in 2012, and zero aMWs in 2013. • We forecast oversupply situations only in about 50% of the years; not every year. • Increased spill would also reduce hydropower supply in the hours when the federal power is needed to meet firm load requirements in the Northwest. • This potential reduction in oversupply may be offset by a change in resource mix in the region. Thermal plants that normally shut down in the spring may need to continue running to meet loads. This change may contribute to oversupply because of minimum generation and run-time requirements at the thermal plants. • Potential impacts to transmission interties may reduce access to markets outside the BPA Balancing Authority

11. Transmission Impacts • Initial assessments identified the following likely impacts of more spill: • Reduced intertie transfer capacity • Increased congestion on North of John Day and North of Hanford transmission paths • Would be a significant change from current operating paradigm and may cause operating issues that we do not currently face