Proposed Change to BPA’s Rate Case Workshop Schedule – NRU Board Feedback Requested
This week, BPA staff proposed a change to the BP-22/TC-22/EIM rate case workshop schedule and are asking for comments by next Wednesday, April 15th. Below is a summary of BPA’s proposal and NRU staff’s proposed comments in response. Please review and provide any feedback to Megan (email@example.com) by noon on Wednesday, April 15th.
Summary: Pause the current rate case workshop schedule to allow BPA staff time to internally develop a comprehensive straw proposal to share for public review and feedback starting in late July
The current rate case workshop schedule calls for two days of meetings every month until September, when BPA traditionally “goes dark” to run its rate case models and write testimony for the rate case which usually begins in early/mid-November.
BPA’s plan is to join the Energy Imbalance Market (EIM) in the middle of the next rate period, BP-22 (FY 2022-2023). Joining the EIM requires interrelated changes to BPA’s current Power and Transmission rates and Transmission tariff.
NRU and others in public power have repeatedly encouraged BPA to address these issues comprehensively, given their intricate interrelationships.
BPA staff wants time to put together a comprehensive straw proposal, including proposed redline changes to rate schedules and the tariff. These would be shared publicly mid/late July and public workshops would resume until the end of October.
NRU Staff Thoughts
We agree that integrating changes due to EIM participation into Transmission and Power rates and tariff is a challenging proposition but needs to happen ASAP.
We want to ensure sufficient public feedback and involvement in shaping the proposals. We are concerned that the straw proposal and proposed redlines will represent a “fully baked” proposal that will be challenging to change.
We are also concerned about the condensed public workshop schedule and backloading it into August-October. It seems less likely we can make real changes to the straw proposal the closer we are to the release of the Initial Proposal in November.
NRU Staff Proposed Comments
Given the need for BPA staff to integrate numerous rate designs and tariff issues to get BPA ready to participate in the EIM, NRU supports pausing the rate case workshop schedule for the month of May only.
BPA staff would have from now until mid-June to develop staff proposals related to EIM-related power and transmission rates issues and tariff modification.
The proposals should be presented as concepts with examples to enhance understanding. Redlines to rate schedules and the tariff should not be developed at this time.
We would resume public workshops starting with the currently scheduled meeting on June 23. BPA staff would share their straw proposals one week prior.
The monthly cadence of rate case workshops would continue through the summer, allowing customers to comment and propose modifications to BPA staff proposals, providing time for BPA staff to respond to and incorporate customer feedback, etc., leading to the development of the Initial Proposal.
Other rate case issues, such as potential modifications to the NR rate, would be discussed in the rate case workshops starting in June.
NRU Proposed CRSO Comments - Deadline Monday April 13
The deadline for submission of comments on the CRSO Draft Environmental Impact Statement (DEIS) is Monday April 13. Comments can be submitted online using this link. Many stakeholders requested the lead agencies extend the comment period, but the agencies have not taken any action to revise the deadline. Instead, issuing a news release yesterday confirming the Monday deadline for submission. The news release can be found here.
Our proposed comments are attached to this update for review. The tenor of the comments is generally in support of the Preferred Alternative (PA) presented in the DEIS. We still wanted to articulate our concern with the proposed spill level and the ability for the agencies to modify river operations quickly in response to harmful consequences from the proposed spill levels. With that concern, we stressed that any additional costs created by adoption of the PA must be allocated equitably and not placed solely on public power. We also stressed the value of the four lower Snake River dams to the region in terms of energy, capacity and reliability, and what the dams mean to the economic stability of rural communities served with electricity from the dams and irrigation water provided by the dams. Please send any feedback regarding the comments directly to John at firstname.lastname@example.org by mid-afternoon on Monday April 13.
Monday’s BPA/Public Power Carbon Forum
The next BPA/public power carbon forum will be held this upcoming Monday, April 13, 2:30-4:30pm Pacific. Webinar and conference call information is below. The meeting will begin with a recap and discussion of recent happenings with Washington State’s CETA, including Monday’s meeting on small utility reporting requirements, and Oregon’s executive order. The rest of the meeting will dig into the technical details of GHG reporting in the CAISO Energy Imbalance Market.
BPA/Public Power Carbon Forum: Monday, April 13, 2:30-4:30pm Pacific
Phone bridge: 415-527-5035, code 905 021 368
Meeting password: XKzGWcJS778
The next carbon forum will be May 11, 2:30-4:30pm Pacific, and will include a panel of trading floor personnel from different utilities sharing their experiences in buying/selling carbon-free power. Webinar/bridge information will again be distributed in advance via the Portland Update.