07/17/2020 Portland Update

Opportunity to Attend UAMPS / NuScale Carbon Free Power Plant Presentation & Virtual Tour

UAMPS and NuScale Energy have graciously extended an invite to the entire NRU membership to attend a half day virtual tour of the Small Modular Reactor (“SMR”) project that they are currently undertaking. This carbon free power supply option is planned to come online around the 2028 timeframe. The presentation will include an overview of the project and SMR technology and a virtual tour of NuScale’s prototype SMR facilities. The agenda is attached for your review.

If you are interested in attending, please RSVP to Ellyn Groves (egroves@nru-nw) no later than Thursday, July 23. If you would like to discuss specific project details, please reach out to Mark Gendron from UAMPS at 503-679-3337.

BP-22 RHWM Process and the Mysterious -110 aMW

At long last, BPA published a letter to the region in response to the comments NRU and others submitted regarding the preliminary BP-22 RHWM outputs. The lengthy letter satisfactorily addresses some of our questions but fails to sufficiently explain the proposed 110 aMW decrease to the Tier 1 system in BP-22. NRU intends to submit another letter to further drill into the underlying assumptions. Here is a summary of BPA’s letter:

  • In response to our request for a crosswalk showing the impact of changes to spill operations on critical water and average water generation since BP-16, BPA provided the following chart which shows that since BP-16, there has been a 403 aMW decrease in hydro generation under 1937 critical water and a 287 aMW decrease under average (80 year) water (the chart and associated footnotes are on page 5 of the letter).

  • In response to our request for more information regarding the 110 aMW decrease due to “sliding scale operations at Libby and Hungry Horse dams,” BPA shared that the Upper Basin Sovereigns (UBS), comprised of the State of Montana, Kootenay and Confederated Salish and Kootenai Tribes, “have requested a specific operational change for quite some time.” That change is to tie the draft at Libby and Hungry Horse to local water volume forecasts rather than to system-wide volume forecasts. The letter is unclear about whether this request by the UBS has been granted, or will be granted, and in what process. NRU intends to submit follow-up questions to clarify.

  • Also in the letter, BPA responded to the comments to extend the time period for New Tribal Utility CHWHM augmentation. The comments were supportive of the policy, but noted that would require a change to the Tiered Rate Methodology which must follow a certain process. BPA agreed with this evaluation and said that they will not pursue a formal change at this time, but if there is a written request by a New Tribal Utility in the future, it will “remain open to proposing an extension of the expiration date.” BPA also noted that the “unique challenges faced by Tribal utilities are not likely to go away after the Regional Dialogue contract expire” and they expect to work with Tribes and Tribal utilities on how to address their needs as part of the post-2028 discussions.

The next step in the RHWM Process is the workshop on August 4 to discuss the draft final RT1SC and draft final RHWM outputs, which will initiate the final public comment period through August 19. Final numbers are scheduled to be made available on September 30.

NRU and PNGC Submit Second Set of Joint Comments on CETA Draft Rulemaking

NRU and PNGC continue our collaborative efforts to steer the Dept of Commerce (Commerce) towards adopting a simplified set of compliance and planning rules for CETA that recognize the unique attributes of load following customers of BPA. The comments submitted jointly by NRU and PNGC on July 13, reinforce the notion that load following customers already perform the analysis required under the statute to set conservation and demand response targets via their direct funding of the BPA resource program. Our comments also list concerns we have with the initial draft rules published by Commerce and offer suggested changes that would better align the compliance rules with current business practices and/or recognize the analytical work performed by BPA.

As discussed in the Portland Update dated July 2, we also included our support for the concerns of a broader collaborative of public power that are related to sections of the rulemaking outside of our traditional purview. A copy of the comments is attached to this update. If you have any questions, please don’t hesitate to contact John at

NuScale-CFPP Web Event Agenda July 29 20
• 765KB

PNGC and NRU CETA Reporting and Complian
• 361KB

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