Expedited Rate Case to Suspend FRP Surcharge
In response to letters submitted by NRU and PPC, BPA is proposing an expedited rate case to suspend the Financial Reserves Policy (FRP) Surcharge due to the extraordinary economic challenges caused by the COVID-19 pandemic. The suspension would begin as soon as FERC approves the rate change through the remainder of the rate period (September 30, 2021).
Because the surcharge is in the rate schedule, BPA is required to hold a rate proceeding to modify the rate schedule and file that with FERC. Given the immediate need to provide rate relief, BPA has proposed the most expedited process available.
When parties submit their interventions to participate in the rate case, BPA will require parties to submit notice if they plan to object to the proposal to suspend the FRP Surcharge. If no objections are made, BPA will employ a condensed, uncontested schedule where the Record of Decision would be filed with FERC by the end of this month so the FRP Surcharge would be suspended by July 1st. If granted by FERC, this means you would see the rate reduction (no FRP Surcharge) starting on your July bill issued in August.
However, if any party submits notice of objection, an expedited rate proceeding will be necessary. The proceeding would conclude within 90 days. Some of the Transmission-only customers offered comments during the BPA workshop today that reiterated some of the points they have made historically, about the chances of a Reserves Distribution Clause being triggered for Transmission or the impact of the Leverage Policy on Transmission rates.
We hope the Transmission-only customers recognize that the suspension of the FRP Surcharge will provide immediate rate relief to power customers stricken by the economic crisis and that the FRP Surcharge only builds cash reserves, it does not impact BPA’s overall cost recovery. However, it is unclear whether one or more of the Transmission-only customers will file notice of objection, thus triggering the longer (though still expedited) 90-day rate proceeding.
Prior to the invention deadline of June 24, BPA is asking for customer comment by June 10. NRU staff proposes to submit comments strongly in support of the proposal to suspend the FRP Surcharge as quickly as possible and that we will not object to the proposal. Please let us know if you have any questions or concerns with our proposal by COB June 9.
NEMS Is Hiring!
NEMS is looking to fill a new Resource Analyst position to assist its members with their non-federal resource supply. This position is likely to support NRU in the future as well and will be a critical piece in NRU and NEMS service to members.
The job is posted on NWPPA’s job listing website and can be viewed at the link below:
Please forward to any qualified candidates that you may be aware of who are interested in joining the team!
Lots of stuff going on right now in the BPA rates sphere – we submitted several sets of comments this week alone. Below is a summary of our submitted comments; full copies are attached.
BP-22 RHWM Process
We asked for more information behind the -110 aMW decrease to the Tier 1 system due to “CRSO Preferred Alternative measures.” Note that this -110 aMW reduction is addition to the -160 aMW reduction due to changes in spill operations under the CRSO Preferred Alternative.
We asked for a crosswalk of changes to the size of the Tier 1 system due to changes in spill operations since FY 2016.
We expressed appreciation to BPA for allowing more flexibility in allowing customers to change their load forecasts for BP-22 due to COVID-19 impacts. If you have changes to your load forecasts, be sure to let BPA know ASAP.
BP-22/TC-22 Rate Case Topics and Schedule
We asked BPA to prioritize the most important and challenging rate case issues to ensure we have sufficient time to hear BPA staff’s proposal, respond to it, and for BPA staff to incorporate our feedback in the next round. This iterative process may take several cycles and BPA will need to “go dark” to write the Initial Proposal by September, which is not that far off.
The highest priority topics for us include: allocation of EIM charge codes, generation inputs, transmission losses, NR rate options and EIM requirements for small, non-participating resources.
In addition to the crosswalk of changes to the size of the Tier 1 system requested in the RHWM process, we asked for a crosswalk of the financial changes to the Tier 1 rate due to changes in spill operations since FY 2016.
We are submitting comments in the TC-22 process to advocate for continued use of BPA Transmission’s Seller’s Choice product.
Extension to Increase CHWMs for New Tribal Utilities
We supported BPA’s proposal from a policy perspective to extend the expiration of increases to CHWM for New Tribal Utilities through the end of FY 2028, subject to the existing cap of 40 aMW for New Tribal Utilities and the overall cap of 250 aMW for New Publics.
We asked BPA to work with customers to determine the appropriate next steps to implement this change to ensure that the requirements to change the TRM are sufficiently followed.
Cancelled – June’s Carbon Forum
Due to scheduling conflicts, we are cancelling the public power/BPA carbon forum that would normally be held on Monday.
The next Carbon Forum will be Monday, July 13th at 2:30-4:30pm Pacific time. The topics will include CETA updates and BPA’s single system mix.
August NIU/NRU Meetings Format
Many members of NIU and NRU are seeing their local areas reopen for regular business, but Oregon continues to proceed with extreme caution. Multnomah County, where our regular meeting venue is located, has yet to enter phase one of the Reopening Oregon plan. A quick check of the Multnomah County website shows that the county has reached only three of the five thresholds to allow the county to enter phase one. The website does not offer any projection for when the county will reach phase one or any subsequent phases of the Reopening Oregon plan.
Given the uncertainty around availability of our meeting venue and feedback from a number of members regarding their utilities having travel restrictions in place through at least August, we are making the decision to hold August meetings via virtual format only. Our intention is to present a full agenda for both NIU and NRU, including guests from BPA for both meetings.
We are tentatively planning to hold the November meetings in person. As the date gets closer, we will coordinate with members to assess interest in and ability to attend an in-person meeting. As always, safety will be our primary consideration when making these decisions. Please let us know if you have any questions or concerns regarding the August meetings.