04/17/2020 Portland Update

NRU Submits Comments to BPA Proposing Revised Rate Case Workshop Schedule Change

As described in last week’s Portland Update, BPA proposed to modify the rate case workshop schedule by cancelling the planned May and June workshops and using that time to internally develop a “comprehensive straw proposal” for BP-22/TC-22/EIM rate case issues, including redline changes to the rate schedules and tariff. Customer engagement would resume in late July through October, right up to the release of the Initial Proposal in November.

As proposed in last week’s Portland Update and supported by members, NRU submitted comments today recommending an alternative approach. We expressed concern with BPA “going dark” for such a long stretch and feared that the proposals and redlines released in late July would be “fully baked” and hard to change. Instead, we proposed a modified approach that forgoes the May workshop in order to provide BPA staff 8 weeks to internally develop a conceptual framework with examples on how its participation in the EIM would be incorporated into rates and the tariff. Public workshops would resume in June, giving customers the chance to comment on and help shape BPA’s proposal until early fall.

NRU shared this alternative approach within public power, where it was widely supported. We expect others in public power, including the Public Power Council and Powerex, to submit comments in support of this alternative, representing a strong showing of alignment.

Our comments are attached.

CRSO Comment Period Closes – What Happens Next?

The comment period for the Draft Environmental Impact Statement (DEIS) closed according to schedule at midnight on Monday April 13. Many stakeholders had pressured the lead agencies to extend the comment period citing concerns over the overall truncated process timeline and other time constraints related to COVID-19.

NRU submitted our comments as proposed in this update last week with minor tweaks to account for member feedback; over 8,000 comments were submitted in total. the majority of the highly detailed comments from tribes and states were submitted in the last hours prior to the deadline. The agencies were anticipating in excess of 100,000 comments but the Army Corp. of Engineers blocked submission of robot or automated comments to avoid overwhelming the submission portal on the internet.

The agencies and their contractors are now sorting, and synthesizing comments received. Responses to comments will be prepared and compiled in Appendix T of the Final Environmental Impact Statement (FEIS). Any changes to the draft in response to comments will be integrated into the FEIS. The FEIS is scheduled for release at the end of July.

The action agencies, NOAA and Fish and Wildlife, are preparing their Biological Opinions, or BiOps, concurrent with the schedule the lead agencies have for the FEIS. The BiOp processes won’t have any public exposure so we don’t have any information to share regarding details of the BiOps, but we do know the action agencies are working on the Preferred Alternative for them.

We will report out as soon as we hear anything substantive regarding the FEIS or the BiOps.

NRU comments_proposed schedule change_FI
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