Reminder – NIU and NRU Quarterly Meetings Scheduled for November 4th
The NIU and NRU meetings will both be held as planned on November 4th utilizing the same GoToMeeting virtual format as the May and August meetings. The agendas for both meetings are packed with information and we will be asking for feedback and guidance on a number of topics. Please plan for both meetings together, to span the entire morning. We will distribute virtual connection details with meeting materials approximately one week prior to the meeting date.
Comments on Bonneville Rates Issues – Submitted Tuesday 10/13
On Tuesday, NRU submitted the attached comments to Bonneville in response to issues discussed at the September 29 rate case workshop, consistent with the proposed comments we shared in last week’s Portland Update. NRU’s comments focused on the financial health of the agency and on transmission losses issues:
Financial Health – We reiterated statements we have previously made on BPA’s financial health issues, specifically access to capital and its Leverage Policy. We then stated that the current two-week comment period is far too short for us to have meaningful engagement with our members on an issue as complex as BPA’s financial health, but remain committed to working with the agency and customers to develop prudent actions to maintain the agency’s financial health while also maintaining affordable and reliable power supply to end-users. We stated that, as it is Transmission Services that is a net borrower and in a capital-intensive cycle, Bonneville’s transmission customers, not its power customers, must be financially responsible for the capital financing needs of Transmission Services. We encouraged Bonneville to identify a sustainable financing strategy that minimizes cost impacts on end users.
Transmission Losses – NRU reiterated support for positions we have previously provided, including:
Updating the loss factor, shaped monthly or seasonally in order to capture variations across the year.
The FCRPS should be properly compensated for providing capacity.
Both in-kind loss return and financial loss returns should continue to be allowed.
Support the Financial for Inaccuracy structure to penalize failure to return losses, but the proposed penalty is likely not sufficiently high enough.
The BP-22 and TC-22 rate cases are currently scheduled to begin December 1, with the Initial Proposal expected to be released on December 7. It is not clear if Bonneville will conduct further workshops or otherwise provide opportunity for customer input on financial planning issues prior to beginning the formal proceedings.
Governors of Northwest States Issue Letter of Agreement Related to Collaborating on Salmon and Steelhead Abundance
The Governors of the states of Montana, Idaho, Oregon and Washington issued a letter on October 9 agreeing to “define a future collaborative framework to analyze and discuss key issues related to salmon and steelhead with the purpose of increasing overall abundance”. This letter, attached to this update for your convenience, is the initial action from the “Four State Process” NRU described in the September 25 Portland Update.
In the letter, the Governors collectively commit to conducting a collaborative and public process to advance the goals of the Columbia Basin Partnership Task Force. The task force was convened in 2017 by NOAA to “develop shared goals and a comprehensive vision for the future of the Columbia Basin salmon and steelhead”. Information on the task force can be found here. The states participated in the task force and have clearly demonstrated their interest in seeing the goals identified by the task force come to fruition.
This is important because the letter refers to the recent Columbia River System Operations Final Environmental Impact Statement, The Biological Opinions and related Record of Decision and then goes on to say, “our respective states may view the adequacy of these documents differently”. With this statement, the states appear to be jointly agreeing that the extensive NEPA process and the resulting Preferred Alternative identified in the EIS does not go far enough in addressing salmon and steelhead survival.
The specific direction the Four State Process takes with formulation of the proposed collaborative framework remains to be sorted out but other stakeholder groups will be weighing in with their opinions and it is prudent that public power does the same. Northwest RiverPartners (NWRP) has taken the lead on drafting a letter to the four Governors outlining principles that should be embraced when developing the collaborative framework. Because the letter is still in draft form, we are not attaching it here but expect the letter to emphasize and expand on the points made in NWRP’s press release in response to the issuance of the Governors’ letter. That press release is attached to this update.
The final draft of the letter will be included with the November NRU Board materials and we will be requesting permission to sign on to the letter to show support of these important principles and to demonstrate solidarity within public power. If you have any comments or questions prior to the meeting, don’t hesitate to contact John directly at firstname.lastname@example.org or by phone at (509) 993-4088.