BP-22: Rate Period High Water Mark Process
The following comments were submitted in response to the open comment period described below.
Comments are numbered consecutively as they are received. Breaks in the number sequence result when comments are deleted because they
were submitted in error or have inappropriate content (such as SPAM). If you do not see your comment two business days after
you submit it, please contact (800) 622-4519.
BPA has started its formal process for establishing Rate Period High Water Marks that will be used in the BP-22 rate case to establish power rates for fiscal years 2022 and 2023. The RHWM is the amount of energy a customer is eligible to purchase at Tier 1 rates in the upcoming rate period. BPA shared its assumptions for preliminary RHWMs and the preliminary Tier 1 System Firm Critical Output at the kickoff event on May 19, 2020. In addition, BPA shared a proposal to extend the expiration date for New Tribal Utilities’ load growth CHWM augmentation, from 2021 to 2028. BPA encourages comments on this proposal and on factual matters relevant to individual or collective initial computations through June 3, 2020 which is the end of the comment period.
For More Information:
https://www.bpa.gov/Finance/RateCases/RHWM/Pages/Current%20RHWM%20Process.aspx
Close of comment: 6/3/2020
- RHWM22200001 -
Mendonca/PNGC PowerPNGC would like to request an update of Raft River’s load forecast for the upcoming BP-22 load forecast. We have two material forecast changes to implement, both resulting from the most recent virus related economic effects.
1- Jackpot Commercial Load. The commercial load in Raft River’s Jackpot service area has seen a decrease of roughly 1 aMW, and this load is not expected to return based on Raft River’s current knowledge.
2- The new scheduled load of the Dairy, digester, and aquifer recharge project have been revised downward significantly, with the digester project now in question. Raft River has seen some dairy load come online, but at much lower levels than anticipated. The current dairy load is 500 kW, and is expected to grow to 1,500 kW. The digester load should be removed at this time and the aquifer project is expected to use 2,000 kW for 3 months out of the year – for an average yearly usage of 500 kW. All together, the new forecast values for these loads is 2 aMW per year.
The PNGC forecast has Raft River’s base load at 34.55 aMW, and with the updated forecast adjustments we would expect the new Raft River Forecast to be at (or near) 35.55 aMW per year. We understand this is a large deviation from Andres’ previous forecast of 40.79 aMW, but the Economic conditions have changed substantially as new information has become available to Raft River as detailed in the attached email from Chad Black at Raft River.
- RHWM22200002 -
Mendonca/PNGC PowerPNGC would like to request an update of Clearwater’s load forecast for the upcoming BP-22 load forecast. We have one material forecast change to implement resulting from the most recent virus related economic effects.
1- Large Industrial Load Reduction. A large industrial customer in Clearwater’s system has seen a decrease of roughly 0.60 aMW, and this load is not expected to return based on Clearwater’s current knowledge.
The BPA forecast has Clearwater’s load forecast at 24.17 aMW and 24.28 aMW for FY22 and FY23, respectively. Incorporating the updated forecast adjustments we would expect the new Clearwater Forecast to be at (or near) 23.57 aMW and 23.68 aMW for FY22 and FY23, respectively. Please see the attached email from Dave Hagen with the data to confirm this load drop.
- RHWM22200003 -
Conger/Northern Wasco County PUDNorthern Wasco has updated its forecast to reflect recent events related to COVID-19 and other customer specific load data for the BP-22 Rate Period. The attached file is a summary of the load and ARHWM changes. NWCPUD will submit detailed data for review by BPA Load Forecasters.
View Attachment
- RHWM22200004 -
Stratman
- RHWM22200005 -
Sterzing/Umatilla Electric CooperativeUmatilla Electric Cooperative (UEC) has reviewed the BP-22 RHWM process information provided on May 19th, 2020 and the associated preliminary RHWM results. UEC has concerns that the TRL and NLSL values included in the preliminary RHWM results for UEC are not an accurate estimate of the potential TRL and NLSL energy that UEC anticipates at this time for the planning period. UEC proposes to work with BPA to resolve any discrepancies in the forecast to assure the TRL and NLSL values include current and known information regarding UEC’s projected energy requirements.
- RHWM22200006 -
Parke/United Electric Co-op, Inc
For the upcoming BP-22 load forecast, United Electric Co-op, Inc. would like to request an update. A large industrial customer served by UEC has a reduction of five (5) aMW. To our knowledge this load will not return to United in the next rate period and beyond. The BPA BP-22 forecast for United is 36.86 aMW in FY22 and 37.36 aMW in FY23. United would expect an updated forecast adjustment of 31.86aMW FY22 and 32.36 aMW FY23. BPA was notified of this reduction in March of 2020.
- RHWM22200007 -
Kallstrom/Snohomish PUD
- RHWM22200008 -
Neale/WPAG
- RHWM22200009 -
Stratman
- RHWM22200010 -
Dahl/WRECWREC is considering a change to its load forecast which it would like to discuss further with BPA.
- RHWM22200011 -
Gorsuch/Alliance of Western Energy ConsumersSee attached.
View Attachment
- RHWM22200012 -
Deen/Public Power CouncilSee attachment.
View Attachment
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