NRU Rate Case Webinar – Next Steps After Direct Testimony in BP-22 and TC-22
Staff has had an opportunity to review direct testimony filed in the BP-22 and TC-22 rate cases and we are at a juncture where member feedback is crucial to our rebuttal testimony. We have scheduled a webinar to share other parties’ direct cases and gather input from members. The date, time and connection details for the webinar are listed below.
Please join us if your schedule allows. It’s important we hear from as many members as possible prior to determining and filing our rebuttal testimony. You can also reach out to us directly to share your feedback if you’re unable to participate in the webinar. Materials were distributed earlier this afternoon.
Tue, Feb 23, 2021 9:00 AM - 10:00 AM (PST)
Please join my meeting from your computer, tablet or smartphone.
You can also dial in using your phone. (For supported devices, tap a one-touch number below to join instantly.)
United States: +1 (872) 240-3212 - One-touch: tel:+18722403212,,626163373#
Access Code: 626-163-373
Post-2028 Meeting with BPA
This week, we had our monthly meeting with BPA staff on post-2028 issues. In addition to the core team from Power Services, representatives from Transmission Services are now joining our monthly meetings as we attempt to ensure a smoother integration between Power and Transmission post-2028.
We shared the Post-2028 policy positions adopted by the NRU Board earlier this month and emphasized that these are in addition to and build off the principles adopted last year. Attached is the handout we provided to BPA which shows both our policy positions and principles on a single page to emphasize these are all applicable.
BPA staff was very receptive to the positions advanced by NRU and asked thoughtful clarification questions. NRU staff emphasized that while we support allocating the Federal system post-2028, this needs to be interpreted broadly and is not merely a rollover of the existing structure. For example, we want to explore different methodologies for defining the Federal system (e.g., which water year to use?) and allocating to customers. Parlance can be tricky because when we say “allocating” or “tiering” that does not necessarily mean a continuation of our current approach; instead, it represents a “big box” in which there is room for exploration and modification about how the system is allocated.
Here is the latest on BPA’s plans for post-2028 discussions:
BPA expects to begin broader discussions with public power sometime this spring, likely late March, or April.
Initial conversations will be between only public power and BPA, using an informal forum like PPC’s Rates and Contracts group. This will enable more free flowing conversation between the primary parties: BPA and preference customers. Eventually, “big tent” meetings will be held to which all stakeholders will be invited, but this should allow us to advance public power initiatives with BPA in prior to those big tent meetings.
BPA is still working on developing “staff leanings” and a rollout and engagement plan, but here is BPA’s current thinking (you’ll note it looks quite similar to the process we just went through here at NRU over the last year!):
Discuss the applicability of the interests and principles from Regional Dialogue to the post-2028 world.
Discuss the “foundational tenets” of the post-2028 construct, such as:
Standardized contracts with the same term lengths (i.e., BPA does not seem interested in staggered term contracts where some customers have a contract term of “X” years while others have a contract term of “Y” years).
Having long-term contracts and rate structures.
Offering Load Following, Slice, Block products, with adjustments and improvements.
Allocation of the system and tiering rates.
BPA staff stressed that the information they gathered last year continues to influence BPA’s thinking.
Overall, NRU staff is pleased with BPA’s plan and think it will facilitate robust conversations between BPA and customers. Perhaps most importantly, since we just went through this process ourselves, we are positioned to be very active participants in advancing NRU’s positions. One thing BPA noted is their interest in a “Regional Dialogue-like” construct but emphasized this does not mean a full rollover of the current construct – this is where terminology can become tricky and we need to be intentional in our word choices.
The NRU Post-2028 Working Group meets March 2nd; work initiatives are based on the policy positions.
NRU staff is meeting with staff of other public power entities to share NRU’s policy positions and learn about their post-2028 priorities. This will allow us to find common ground, where differences may exist and identify potential compromise positions or where we may need to defend our interests.
We will continue to iterate with the Working Group, NRU Board, BPA and others in public power to make sure everyone is kept informed and ensure we are advancing the interests of the NRU membership.
Columbia Basin Collaborative (Formerly Four State Process)
From this writing forward we will only refer to the process convened by the four governors of the Northwest states by its now formal name of the Columbia Basin Collaborative (CBC). This name was chosen to be as inclusive of all interests as possible and demonstrate equity to all participants and stakeholders.
The CBC is starting to take some shape with a kickoff webinar that is being held next week. NRU was able to secure an invitation and staff will be attending the webinar. The webinar is slated for three hours on the morning of February 24th and is largely organizational in nature. The agenda includes significant time for introductions and remarks from tribal and state representatives, high-level overview of CBC purpose and proposed approach and opportunity for input and feedback. The key section will be the CBC purpose and proposed approach as that is where the structure of the plenary group along with opportunities for sovereign and stakeholder engagement will be discussed. If the webinar provides any substantive information, we will convey that information in a future update.
BPA Provides Updated Data For Transfer Service Study
Last year, NRU staff committed to updating the ICUA Transfer Cost Benefit Analysis that was last conducted in 2004. The purpose of the study is to demonstrate the cost savings that has resulted by Bonneville’s use of transfer service in lieu of building transmission facilities to the fringes of the Columbia River basin and areas that would result in duplication of facilities.
Most of the study inputs must come directly from Bonneville in order to ensure that we have all the updated transfer points of deliveries, facilities, and cost assumptions that have been changed or updated since 2004. We are happy to report that we were able to receive the necessary Point of Delivery information from Bonneville in December, and just this week, we received their updated capital and overhead cost assumptions. While we are still clarifying a few of the data points, this means that we are ready to get into the nitty gritty of the transfer study.