It’s hard to believe we are already in February and have the first quarterly meeting of the year under our belt. I want to thank the membership for sticking with us to finish the meeting and formally adopt the Post-2028 GRI and initial negotiating positions with BPA. This is a crucial work stream as we continue to assess the best path forward for the Post-2028 era. We are already planning for our next meeting and look forward to serving your advocacy and energy needs in 2021.
Update on Simpson Proposal
Following our meeting on Wednesday where Lindsay Slater, Congressman Simpson’s Chief of Staff, shared the overarching concept of the Congressman’s proposal to address the long running dams versus anadromous fish with us, we learned that the proposal is very likely to be shared in some detail with the general public. Chatter around the proverbial water cooler indicates that several media outlets will be running articles this weekend to create awareness of the Congressman’s effort. We have heard that the Seattle Times, Idaho Statesman, Spokesman Review and Lewiston Tribune will be running articles in their Sunday editions, a professionally produced video will be released through social media on Saturday and it’s fair to assume Clearing Up will expand on their breaking story published Wednesday of this week. NRU was contacted for comment earlier in the week, but we chose not to comment.
NRU will scan the periodicals listed above and do some general searching for articles on this proposal to see how it is characterized and will share any information we find with the membership through this update. If you have any questions or comments on the Simpson proposal, please contact John Francisco directly at firstname.lastname@example.org.
NRU Responds to BPA’s NT Business Practice
NRU is teaming up with PNGC, WPAG, and Clatskanie PUD to submit comments to BPA regarding the agency’s draft NT Business Practice. As the name would suggest, the NT Business Practice is a key document for NT customers and sets the “rules of the road” for many aspects to use NT service such as forecasting loads and resources and encumbering capacity on BPA’s transmission system.
Unfortunately, the draft NT Business Practice has a long way to go before it can be used and relied upon by customers. The issues and questions we have identified are too long to list here, but we have attached our comments and draft NT Business Practice redline document for your review. Here are the general themes:
The draft BP provides literally no guidance on the load forecasts and offers little to no direction to NT customer’s when submitting forecasts that are out of BPA’s normal forecast cycle.
BPA has included new sections in the draft NT Business Practice that have yet to be vetted with NT customers in any formal settings such as the Network Operating Committee.
We are requesting that BPA suspend the current business practice timeline and present the draft for further review by the Network Operating Committee.
We will keep you posted regarding BPA’s response to our proposed changes and procedural requests. If you have questions or comments please contact Blake Weathers at email@example.com.
NRU and Other Parties Submit Direct Case Testimony in the Bonneville Rate Cases
As discussed at this week’s NRU Board meeting, NRU and other rate case parties have submitted direct case testimony in both the TC-22 and BP-22 rate case proceedings. Blake’s testimony submitted in TC-22 and Megan’s testimony submitted in BP-22 are attached to this update. Their testimony addressed the following topics:
TC-22: Seller’s Choice
Blake opposed BPA’s proposal to eliminate Seller’s Choice from the agency’s Open Access Transmission Tariff, rebutted BPA’s arguments for eliminating Seller’s Choice, and, in the alternative, proposed modifications if BPA insists it could not retain Seller’s Choice as is.
BP-22: Revenue financing
Real power loss returns
Energy Imbalance Market (“EIM”) secondary credit forecast
Utility Delivery Charge (“UDC”)
Megan opposed BPA staff’s proposal to include revenue financing in its BP-22 Power rates without a related financial policy in place, supported, but expressed concerns, in response to certain aspects of the proposed treatment of real power loss returns, addressed the need for an appropriate and accurate EIM secondary credit forecast, and opposed BPA staff’s proposal for a 29% increase in the UDC.
Staff is currently analyzing filings from other parties and planning NRU’s rebuttal testimony. We will schedule a webinar in the coming weeks to get Board feedback on and approval for NRU’s rebuttal plans. If you have questions or comments please contact Blake Weathers at firstname.lastname@example.org, Megan Stratman at email@example.com or Zabyn Towner at firstname.lastname@example.org.
NRU Submits Comments on the Western Energy Imbalance Market Governance Review Committee Revised Straw Proposal
On February 3 (after the deadline was extended) NRU submitted comments to the California ISO on the Western EIM Governance Review Committee’s (“GRC’s”) Revised Straw Proposal for changes to the governance structure of the EIM. The comments are attached to this update. The Straw Proposal attempts to increase the EIM Governing Body’s control over the EIM but does so within the framework of the California ISO Board retaining ultimate control over the EIM. NRU’s comments make two main points:
· The Revised Straw Proposal would create a strong, viable and improved means of governing the EIM within the legal and political constraints of being ultimately controlled by the California ISO Board.
· NRU would strongly prefer a western EIM that is a multi-state, independent entity not under the control of the state of California.
If you have questions or comments on this topic, please contact Zabyn Towner at email@example.com.