05/01/2020 Portland Update

I hope this update finds readers and their loved ones safe and sane as we complete another week of restrictions. We are looking forward to our first all-digital quarterly meeting on Wednesday next week. We are confident our call solution will accommodate all who are planning to listen in and participate. Meeting materials were distributed on Wednesday of this week. Please review and don’t hesitate to ask any questions you have.

BP-22/TC-22/EIM Workshop

During this week’s rate case workshop, BPA staff shared their initial thinking on how to allocate EIM charge codes. In a nutshell, EIM charge codes are the billing mechanism that BPA will use to pass through EIM market costs and credits to BPA’s customers. BPA’s decision on how to apply EIM charge codes will determine which costs or credits are directly assigned to specific customers or allocated by customer class.

This is likely the most complex issue in the EIM and rates workshops. There are numerous EIM charge codes and several different billing determinants at play. Some charge codes are even intended to potentially offset others, so there is further interconnectedness. BPA is trying to decide which of the EIM charge codes should be allocated to individual Transmission customers (or Power Services on behalf of Load Following customers). EIM charge codes that are not allocated directly to customers will need to be included in other BPA rates, which is challenging to take a position on since BPA is staggering the process so the rates structure will not be discussed until after the EIM charge code allocation method is selected. Note that these decisions are what will form the base of the initial rate case proposal. We will still have an opportunity to further discuss or advocate changes as part of the formal rate proceeding. However, it is often challenging to advance significant changes in the rate proceeding – it is best to do so in this informal workshop process.

NRU staff is still analyzing BPA staff’s proposal and discussing with others in public power. Comments on this issue are due May 12th. We will share our proposed feedback via a Portland Update for your review and guidance.

Small Utilities and CETA

NRU is working with other representatives of small COUs that have customers located in Washington to develop simplified reporting and planning requirements to comply with Washington’s Clean Energy Transformation Act (CETA).

NRU is involved with CETA implementation both from the WA utility perspective and the broader BPA customer perspective. Any carbon regulation may impact BPA’s products and services so it’s important to stay involved to try and avoid unintended consequences that could have broader implications across the entire region. It is also important to try and establish a compliance structure that is feasible for utilities as other states in the region look to regulate greenhouse gas emissions while watching how Washington implements CETA.

NRU and PNGC took the lead in developing a proposal to streamline CETA reporting and planning requirements for small or full requirements utilities in Washington. We shared these ideas informally with the Washington Department of Commerce last Friday, where they were well received. We are currently refining our proposal based on Commerce’s feedback.

This week, Commerce released its first draft of proposed rules. There is a lot to digest in the proposed rulemaking such as planning requirements and compliance reporting for non-small utilities (the “small utilities” requirements discussed above are currently being addressed in a different workstream). NRU is working with others in public power and BPA to analyze the proposals from the perspective of how they will (or will not) impact WA utilities and BPA/non-WA utilities more broadly.

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