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04/02/2021 Portland Update

Updated: Apr 26

Reminder: NRU Rate Cases Webinar on April 6 at 1 PM Pacific/2 PM Mountain NRU will hold a webinar on April 6 at 1pm PDT/2pm MDT to discuss latest developments and NRU strategy for the TC-22 transmission tariff proceeding and the BP-22 power and transmission rates proceeding. In this webinar, we will seek guidance from the NRU Board of Directors on next steps in the proceedings, including guidance on whether NRU should support recent settlement proposals. Our discussion will center on the five primary issues that NRU has focused on in these proceedings:

  1. Bonneville’s proposal to eliminate the “Seller’s Choice” provision in its transmission tariff.

  2. The proposed 29% increase to the Utility Delivery Charge and NRU’s proposal to eliminate the Delivery Segment;

  3. Correct charges for capacity used in transmission losses;

  4. Bonneville’s calculation of financial benefits of joining the EIM in the BP-22 rate period; and

  5. The inclusion and level of revenue financing to be included in Power rates, and the possibility of settling this issue as part of either a comprehensive or narrow rate case settlement;

You can access the webinar with this link or phone number:

Tue, Apr 6, 2021 1:00 PM - 2:30 PM (PDT) Please join my meeting from your computer, tablet or smartphone. https://global.gotomeeting.com/join/485484421 You can also dial in using your phone. United States: +1 (571) 317-3122 Access Code: 485-484-421

Feedback Requested – Proposed Post-2028 Comments to BPA

On March 18th, BPA met with public power via PPC’s Rates and Contracts forum to begin conversations about post-2028 and shared initial staff leanings on timeline, foundational interests and tenets. This week, the NRU Post-2028 Working Group met to develop comments to submit in response to BPA’s staff proposals. The outline below shows comments recommended by the Working Group to submit to BPA, due April 8th. Please provide any feedback or concerns to Megan (mstratman@nru-nw.com) by noon on Wednesday, April 7th.


  • NRU supports engagement with BPA and within public power on post-2028 issues.

  • We will share (again) the post-2028 principles and policy positions adopted by the NRU Board and advocate that these be used to direct our work over the next year.

  • BPA staff’s proposed “interests” and “foundational tenets” are generally consistent with NRU’s principles and policy positions. Based on discussions with the Working Group, we will propose specific comments in response to some of the interests, such as BPA’s recent “financial health” policies undermine the goal of rate “durability and stability” and emphasize the importance of low carbon emissions.



  • We will emphasize that using terms like “TRM” or “tiered rates” does not mean a rollover of today’s contracts and that we want to explore potential changes to key components of the rates, such as how the Tier 1 system size is set, how non-federal resources are integrated, how the demand charge functions, etc.

  • We believe there is general consensus within public power around BPA’s high-level interests and foundational tenets. Instead of spending more time discussing these, we should instead invest our time analyzing critical areas for change. In other words, let’s get out of the starting gates and start working on how to integrate NRU’s principles and policy positions into the post-2028 construct.

  • Topics such as transfer service, transmission access, and energy efficiency are critical to the post-2028 construct and must be included in the post-2028 discussions and not punted to a separate process (as seemingly proposed by BPA).

  • BPA’s 2018-2023 Strategic Plan has helped guide the agency and customers towards common goals and understandings. While it may be premature to have a Strategic Plan for post-2028, it will be critical for BPA to demonstrate to customers the linkages and touch points between the 2018-2023 Strategic Plan and the Post-2028 effort.


NRU Submits Comments on EIM Issues Consistent with our proposed comments sent via a previous Portland Update, NRU submitted comments this week to BPA regarding a two Energy Imbalance Market (EIM) issues: impact of greenhouse gas (GHG) accounting and the significantly truncated Phase V decision process. Our comments (attached) make the following points:

  • Since EIM purchases are considered “unspecified” when it comes to tracking GHG, any EIM purchases BPA makes will increase BPA’s carbon emissions for its system mix, all else equal. Because the extremely low carbon content of BPA’s system is highly valuable, any action taken that increases emissions must be made carefully. Therefore, we request this issue be addressed in the Phase V process and that BPA commit to keep customers regularly updated on how its carbon emissions are impacted should it join the EIM.

  • BPA’s process to consider joining the EIM ends with Phase V, where BPA issues a close-out letter documenting its decision. Public power and BPA worked to develop a timeline so Phase V would occur after the BP-22 rate case concluded so we could use all known information to consider whether BPA should join the EIM. Accordingly, Phase V was originally planned to occur from October to December of this year. BPA has since changed Phase V to begin immediately after the conclusion of the BP-22 rate case (literally two business days!) and provide only 19 calendar days to submit comments. This condensed timeline is to allow for FERC filings in order to BPA to achieve the Go-Live date of March 2022. However, the condensed timeline provides no opportunity for BPA and public power to consider all the information we now know and to have an earnest dialogue about how BPA should proceed. NRU’s comments urged the agency to revert to the original Phase V timeline.


It seems unlikely that BPA can lengthen its Phase V process given the need to file at FERC and get systems ready for Go-Live in March 2022. However, NRU believes it is essential for BPA and customers to have a legitimate Phase V process to consider new information, such as the application of the E3 cost/benefits study, the reliability events that happened last summer, the potential SPP Market+ option, etc.

Therefore, NRU proposes to submit a letter to the BPA Administrator requesting that the Go-Live date be delayed by one year to provide sufficient time for BPA and customers to consider all information at hand and make an informed and thoughtful decision on how to best proceed. Please let us know if you have any feedback, questions or concerns with this.

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