Reserves Distribution Clause Proposal
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 invites you to comment on the preliminary proposal for use of the Reserves Distribution Clause amount as outlined in the Quarterly Business Review Technical workshop presentation, slides 19 – 30, which was shared on November 15, 2022. BPA will announce its final determination for applying the RDC amounts no later than December 15.
For More Information:
https://www.bpa.gov/-/media/Aep/finance/quarterly-business-review/qbr-2022/fy22-q4-qbr-technical-workshop.pdf
Close of comment: 12/1/2022
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Brown/Governor of OregonLetter from Gov. Brown attached.
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McCloy/NW Energy Coalition and Natural Resources Defense CouncilPlease see the attached.
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TruePlease see the attached.
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Simms/Public Power CouncilSee attached.
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Gregory/Monmouth power and light• It is essential for BPA to follow through on its settlement proposal to maintain the
faith and trust of their customers.
• PPC cannot support any additional funds being diverted away from relief to
customers.
• Utilities are facing unprecedented cost challenges from inflation and supply chain
disruptions.
• BPA cannot be the only funding source for fish recovery efforts with broad regional
and national value.
• Single-issue advocates are asking BPA customers to accept a “lose – lose” dynamic
on the inherently variable output of the hydro system.
• When market conditions leave BPA short of cash, legal and contractual provisions
require power customers to pay more. We cannot accept a lopsided arrangement that
denies power customers the benefits when BPA has a rare “good” financial year
• Fish expenditures already comprise upwards of a quarter to a third of every ratepayer
dollar paid to BPA.
• BPA ratepayers already cover our fish and wildlife mitigation responsibilities. Any
additional funds must come from other sources.
• It must be acknowledged that current mitigation efforts are working – this includes
strong (in some case records) returns this year that allowed for increased harvest.
• Juvenile survival through the hydro system is already at extremely high levels
comparable with undammed rivers.
• When ocean and other conditions allow, the federal hydro system can support robust
returns of adult salmon
Monmouth power suports the PPC points
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Darrington/United Electric Co-op, Inc.Please see the attached comments of United Electric Co-op, Inc.
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Black/Raft River Rural Electric Cooperative, Inc.Please see attachment
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VanSlyke/PUD No 1 of Ferry CountyP.U.D. No. 1 of Ferry County supports the PPC position (Attached), regarding the proposed use of RDC funds.
• It is essential for BPA to follow through on its settlement proposal to maintain the faith and trust of their customers.
• PPC cannot support any additional funds being diverted away from relief to customers.
• Utilities are facing unprecedented cost challenges from inflation and supply chain disruptions.
• BPA cannot be the only funding source for fish recovery efforts with broad regional and national value.
• Single-issue advocates are asking BPA customers to accept a “lose – lose” dynamic on the inherently variable output of the hydro system.
• When market conditions leave BPA short of cash, legal and contractual provisions require power customers to pay more. We cannot accept a lopsided arrangement that denies power customers the benefits when BPA has a rare “good” financial year
• Fish expenditures already comprise upwards of a quarter to a third of every ratepayer dollar paid to BPA.
• BPA ratepayers already cover our fish and wildlife mitigation responsibilities. Any additional funds must come from other sources.
• It must be acknowledged that current mitigation efforts are working – this includes strong (in some case records) returns this year that allowed for increased harvest.
• Juvenile survival through the hydro system is already at extremely high levels comparable with undammed rivers.
• When ocean and other conditions allow, the federal hydro system can support robust returns of adult salmon.
Thank you.
View Attachment
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Hart/Idaho Consumer Owned Utilities Association (ICUA)The Idaho Consumer-Owned Utilites Association (ICUA)represents 22 rural electric power cooperatives and municipal power companies serving over 140,000 customers across the State of Idaho. We implore BPA to hold the line against any attempts divert our ratepayer's rightful RDC distribution beyond what was proposed in the BP-24 rate settlement.
We are in full agreement with the comments from the Public Power Council below:
RE: Reserves Distribution Clause Proposal
Dear Administrator Hairston:
The Public Power Council (PPC) appreciates this opportunity to comment on the proposed use of Reserves Distribution Clause (RDC) funds. PPC is the overall trade association for the non-profit, locally-governed utilities in the Pacific Northwest that have the priority right to purchase wholesale power from BPA at cost. PPC’s members rely on BPA power and transmission products to provide their communities and businesses with reliable, affordable, and environmentally responsible power supply.
PPC and its members are also committed to scientific, cost-effective efforts to mitigate for the operations of Columbia River System Operations on fish and wildlife. The interest of PPC’s members in environmental conservation is twofold. First, preference customers bear responsibility for the costs of mitigation, which represent one quarter to one third of the power rates and typically amounting to over $600 million per year. This mitigation program today is one of the largest of its kind in the world. Second, as locally-governed, non-profit utilities, PPC members reflect the values of their Northwest communities, including conservation.
PPC supports BPA’s proposed distribution of RDC funds for Power in the context of the overall proposed settlement, including BP-24 rates. This includes $350 million for rate relief, $100 million of additional long-term debt repayment, and $50 million for accelerated spending on certain existing fish and wildlife mitigation efforts, subject to the condition identified in the proposed settlement agreement.
The RDC funds in question were accrued as a result of customers paying higher rates than necessary to recover BPA’s costs given hydrological and market conditions. Conversely, when financial results have been poor for BPA, customers face higher rates and surcharges as a result. This dynamic has played out many times over BPA’s history and customers must receive the benefits of rare good years in order to truly achieve BPA’s statutory construct of delivering power at cost for non-profit preference customers.
• It is essential for BPA to follow through on its settlement proposal to maintain the faith and trust of their customers.
• PPC cannot support any additional funds being diverted away from relief to customers.
• Utilities are facing unprecedented cost challenges from inflation and supply chain disruptions.
• BPA cannot be the only funding source for fish recovery efforts with broad regional and national value.
• Single-issue advocates are asking BPA customers to accept a “lose – lose” dynamic on the inherently variable output of the hydro system.
• When market conditions leave BPA short of cash, legal and contractual provisions require power customers to pay more. We cannot accept a lopsided arrangement that denies power customers the benefits when BPA has a rare “good” financial year
• Fish expenditures already comprise upwards of a quarter to a third of every ratepayer dollar paid to BPA.
• BPA ratepayers already cover our fish and wildlife mitigation responsibilities. Any additional funds must come from other sources.
• It must be acknowledged that current mitigation efforts are working – this includes strong (in some case records) returns this year that allowed for increased harvest.
• Juvenile survival through the hydro system is already at extremely high levels comparable with undammed rivers.
• When ocean and other conditions allow, the federal hydro system can support robust returns of adult salmon.
PPC and ICUA appreciates your consideration of these comments.
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Anderson/Midstate Electric CooperativeJohn Hairston
Administrator
Bonneville Power Administration
Dear Administrator Hairston:
Midstate Electric Cooperative supports BPA’s proposed distribution of RDC funds for Power in the context of the overall proposed settlement, including BP-24 rates. This includes $350 million for rate relief, $100 million of additional long-term debt repayment, and $50 million for accelerated spending on certain existing fish and wildlife mitigation efforts, subject to the condition identified in the proposed settlement agreement.
The RDC funds in question were accrued as a result of customers paying higher rates than necessary to recover BPA’s costs given hydrological and market conditions. Conversely, when financial results have been poor for BPA, customers face higher rates and surcharges as a result. This dynamic has played out many times over BPA’s history and customers must receive the benefits of rare good years in order to truly achieve BPA’s statutory construct of delivering power at cost for non-profit preference customers.
Midstate has a long history with BPA and we respectively request that you consider the following:
• It is essential for BPA to follow through on its settlement proposal to maintain the faith and trust of their customers.
• PPC cannot support any additional funds being diverted away from relief to customers.
• Utilities are facing unprecedented cost challenges from inflation and supply chain disruptions.
• BPA cannot be the only funding source for fish recovery efforts with broad regional and national value.
• Single-issue advocates are asking BPA customers to accept a “lose – lose” dynamic on the inherently variable output of the hydro system.
• When market conditions leave BPA short of cash, legal and contractual provisions require power customers to pay more. We cannot accept a lopsided arrangement that denies power customers the benefits when BPA has a rare “good” financial year
• Fish expenditures already comprise upwards of a quarter to a third of every ratepayer dollar paid to BPA.
• BPA ratepayers already cover our fish and wildlife mitigation responsibilities. Any additional funds must come from other sources.
• It must be acknowledged that current mitigation efforts are working – this includes strong (in some case records) returns this year that allowed for increased harvest.
• Juvenile survival through the hydro system is already at extremely high levels comparable with undammed rivers.
• When ocean and other conditions allow, the federal hydro system can support robust returns of adult salmon.
We thank you for taking time to consider these important points in your decision on this important issue.
Respectfully, James “Jim” Anderson
CEO and General Manager
Midstate Electric Cooperative
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Norton/Centralia City LightThe effects of COVID-19 have adversely affected the economy of the City of Centralia and other small towns throughout BPA's service territory. During this period of economic hardship, Centralia City Light (CCL) has been able to avoid rate increases. CCL's customers have confirmed they are against rate increases according to recent surveys that have been conducted. Holding the line on rates has contributed to new loads with their new jobs choosing Centralia as the site of their new facilities. The forecast amount that the RDC would contribute to CCL should allow us to avoid a rate increase in the near future. If these funds are diverted, it could adversely affect those plans.
Thank you for your attention in this matter.
Sincerely,
M.L. Norton
General Manager
Centralia City Light
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Barquin/Kootenai Tribe of IdahoThe Kootenai Tribe of Idaho and others in the Basin have unmet needs to address aging fish and wildlife infrastructure, increased capacity building and inflation. Specifically, the Kootenai Tribe needs to replace aging infrastructure at the Kootenai Tribe Sturgeon and Burbot Hatcheries and expand office space to accommodate increased staffing, as well as ensure budgets are keeping up with inflation.
The Kootenai Tribe recommends BPA conduct an analysis of these unmet fish and wildlife needs to determine if the proposed 10% (approximately $50M) is sufficient. If it is not, the Kootenai Tribe recommends the proposal to increase that amount.
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Hillebrand/Central Lincoln PUD
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Schroettnig/Northwest Requirements UtilitiesSee attached.
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Elliott/Kootenai ElectricPlease see attached document with comments.
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Peters/Columbia REAPlease see the attached.
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Garrity/WDFWPlease see the attached.
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Webb/Lower Valley EnergyDear Administrator Hairston:
Lower Valley Energy appreciates the opportunity to comment on the proposed use of the Reserves Distribution Clause (RDC) funds. Lower Valley's members are very dependent on BPA for reliable, affordable and environmentally responsible power.
Lower Valley is very supportive of BPA's efforts to mitigate for the impact of the dams on fish and wildlife. We support the settlement amount of $50 million for accelerated spending on fish and wildlife but are against any more of the RDC funds being diverted to that cause. The return of $350 million in RDC funds to the end users who ultimately pay all the cost of operating the system and for the fish and wildlife programs is very important. They bare the risk when the financial situation at BPA isn't as good as it is now. They deserve the proposed rate relief especially with the looming potential of a serious economic recession and the devastating impacts they have felt from inflation.
Our board members, employees, and many of our members are already aware of BPA's RDC proposal and any reduction in the amount would diminish their faith and trust in BPA.
I urge you to stick to the agreed upon plan and continue with the $350 million RDC as currently scheduled.
Sincerely,
Jim Webb
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Kline/Northern Wasco Co PUDPlease see the attached.
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Calnon/Hood River Electric & Internet Co-opPlease see the attached.
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Grotbo/Ravalli Electric CooperativePlease see the attached.
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Bronec/Inland Power & LightDecember 1, 2022
John Hairston
Administrator
Bonneville Power Administration
Submitted electronically
RE: Reserves Distribution Clause Proposal
Dear Administrator Hairston:
Inland Power & Light appreciates this opportunity to comment on the proposed use of Reserves Distribution Clause (RDC) funds. Inland Power is the largest electric cooperative in Washington state serving more than 46,000 meters in 13 counties in eastern Washington and northern Idaho. Inland Power relies on BPA power and transmission products to provide our communities and businesses with reliable, affordable and environmentally responsible electricity.
Inland Power is also committed to scientific, cost-effective efforts to mitigate for the operations of Columbia River System Operations on fish and wildlife. As a locally governed, non-profit utility, Inland Power’s interest in environmental conservation reflects the values of our communities, including conservation.
Inland Power supports BPA’s proposed distribution of RDC funds for power in the context of the overall proposed settlement, including BP-24 rates. This includes $350 million for rate relief, $100 million of additional long-term debt repayment, and $50 million for accelerated spending on certain existing fish and wildlife mitigation efforts, subject to the condition identified in the proposed settlement agreement.
The RDC funds in question were accrued as a result of Inland Power paying higher rates than necessary to recover BPA’s costs given hydrological and market conditions. Conversely, when financial results have been poor for BPA, Inland Power faces higher rates and surcharges as a result. This dynamic has played out many times over BPA’s history and we must receive the benefits of rare good years in order to truly achieve BPA’s statutory construct of delivering power at cost for non-profit preference customers.
• It is essential for BPA to follow through on its settlement proposal to maintain the faith and trust of their customers.
• Inland Power cannot support any additional funds being diverted away from relief to our member-owners.
• Utilities are facing unprecedented cost challenges from inflation and supply chain disruptions.
• BPA cannot be the only funding source for fish recovery efforts with broad regional and national value.
• Single-issue advocates are asking BPA customers to accept a “lose – lose” dynamic on the inherently variable output of the hydro system.
• When market conditions leave BPA short of cash, legal and contractual provisions require power customers to pay more. We cannot accept a lopsided arrangement that denies power customers the benefits when BPA has a rare “good” financial year
• Fish expenditures already comprise upwards of a quarter to a third of every ratepayer dollar paid to BPA.
• BPA ratepayers already cover our fish and wildlife mitigation responsibilities. Any additional funds must come from other sources.
• It must be acknowledged that current mitigation efforts are working – this includes strong (in some case records) returns this year that allowed for increased harvest.
• Juvenile survival through the hydro system is already at extremely high levels comparable with undammed rivers.
• When ocean and other conditions allow, the federal hydro system can support robust returns of adult salmon.
Inland Power appreciates your consideration of these comments.
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Missel/Idaho Conservation League et al.Please see the attached comment letter.
Because the attachment to the letter is larger than 10 MB, it has been uploaded to the cloud rather than included in the attached PDF. It can be accessed here: https://drive.google.com/file/d/1FDufJ6d6-E4syxLZoTkUoeJpw0veJi1y/view?usp=sharing
As discussed in the comment letter, the attachments are incorporated by reference into the comment letter.
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Gray/PNGCPlease see attachment submitted.
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Moser/Alliance of Western Energy ConsumersPlease see the attached.
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Patterson/Mason PUD 3Please see the attached.
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McBartlett/City of Ashland Electric UtilityAshland Electric supports the PPC position
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Neale/WPAGPlease see the attachment.
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Case/Fall River Rural Electric CooperativeThank you for the opportunity to make comments.
Bryan Case
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Dizes/Salmon River Electric CooperativeDear Administrator Hairston,
Salmon River Electric Cooperative supports BPA's proposed distribution of RDC funds in the context of the overall proposed settlement, including BP-24. This includes $350 million for rate relief, $100 million of additional long-term debt repayment, and $50 million for accelerated spending on certain existing fish and wildlife mitigation efforts, subject to the condition identified in the proposed settlement agreement.
SREC appreciates BPA's wise management of the valuable Federal Hydro System, which has made this proposed action possible. BPA's proposed settlement demonstrates that BPA values their ratepayers and acknowledges the rate payer's contribution to BPA's success.
Every dollar that is proposed for SREC to receive in the settlement is needed. We are raising rates to our member owners currently because our non-power costs are sky rocketing. This relief on power costs will mitigate the amount rates will have to increase at our utility. SREC serves lower income communities and any help to help those who struggle to pay their power bill is much appreciated.
SREC supports the PPC comments on the Reserve Distribution Clause Proposal as well.
Thank you for your commitment to SREC and our members.
Sincerely,
Ken Dizes. General Manager
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Currier/Emerald PUDPlease see the attached.
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Watkins/City of Milton-Freewater, OR.The City of Milton-Freewater Light and Power supports the PPC's approach to the distribution of BPA reserves, this includes $350 million for rate relief, $100 million of additional long-term debt repayment, and $50 million for accelerated spending on certain existing fish and wildlife mitigation efforts.
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Payne/Public Utility District No. 1 of Skamania CountyPlease see attached pdf file.
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Johnson/Flathead Electric CooperativePlease see the attached.
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Reichart/Washington Department of CommercePlease see the attached.
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Methson/Coeur d'Alene Tribeattached comments
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Hagen/Clearwater Power CompanyPlease see attached comments.
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Marr/Snohomish PUD
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Kay/Wahkiakum PUDDear BPA,
Thank you for the opportunity to comment and express Wahkiakum PUD's support of the attached letter from PPC to BPA regarding the RDC proposal.
We would like to highlight and express again our absolute support of the bullet points expressed in the paper.
• It is essential for BPA to follow through on its settlement proposal to maintain the faith and trust of their customers.
• PPC cannot support any additional funds being diverted away from relief to customers.
• Utilities are facing unprecedented cost challenges from inflation and supply chain disruptions.
• BPA cannot be the only funding source for fish recovery efforts with broad regional and national value.
• Single-issue advocates are asking BPA customers to accept a “lose – lose” dynamic on the inherently variable output of the hydro system.
• When market conditions leave BPA short of cash, legal and contractual provisions require power customers to pay more. We cannot accept a lopsided arrangement that denies power customers the benefits when BPA has a rare “good” financial year
• Fish expenditures already comprise upwards of a quarter to a third of every ratepayer dollar paid to BPA.
• BPA ratepayers already cover our fish and wildlife mitigation responsibilities. Any additional funds must come from other sources.
• It must be acknowledged that current mitigation efforts are working – this includes strong (in some case records) returns this year that allowed for increased harvest.
• Juvenile survival through the hydro system is already at extremely high levels comparable with undammed rivers.
• When ocean and other conditions allow, the federal hydro system can support robust returns of adult salmon.
The funds being proposed back to Wahkiakum PUD and its customers are crucial to our financial position in these challenging times.
Wahkiakum PUD appreciates your consideration of these comments.
Daniel Kay, P.E.
General Manager
Wahkiakum PUD
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Bennett/City of Cascade LocksAs a member of PPC and OMEU Cascade Locks feels it is essential for BPA to follow through on its settlement proposal to maintain the faith and trust of their customers and cannot support any additional funds being diverted away from relief to customers.
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Knight/Spokane Tribe of IndiansPlease accept these comments on behalf of the Spokane Tribe of Indians (“Tribe”) on Bonneville’s proposal for the use of the Reserved Distribution Clause (“RDC”) funds. The current proposal plans to use the $500 million in the following way: 70% to rate reduction, 20% to debt reduction and 10% to one-time “non-recurring maintenance needs of existing fish and wildlife mitigation assets….” The Tribe requests that Bonneville reconsider this proposal.
Several of the NW Region’s emerging priorities as identified in the 2014 Fish and Wildlife Program have suffered from an almost complete lack of funding and meaningful investment. Bonneville is well aware of this lack of investment. Further, current inflation rates coupled with the impacts of the unsustainable insistence on flat fish and wildlife mitigation budgets has created a perfect storm of underfunded mitigation projects and no new investment in the identified emerging priorities. The decision to insist on flat budgets and failure to meaningfully fund the emerging priorities has helped create this windfall RDC. Accordingly, significantly more of this windfall should be used to repair the damage done by the decisions of the past 14 years.
For the Tribe two priorities are in glaring need of significant increased investment. First, as described within the 2020 Fish and Wildlife Program Addendum, the areas above Grand Coulee Dam have been under mitigated for years, particularly when considering the vast wealth that Grand Coulee Dam provides the NW Region and the damage done to the Tribe’s resources and the Upper Columbia Region generally caused by its construction and operation. Recognizing this with a significant investment of the RDC funds into the many mitigation projects needed would be appropriate and well within Bonneville’s authority and discretion under 16 U.S.C. Section 839b(h)(10)(A) and (11)(A).
Second, the Northwest Power and Conservation Council within the 2020 Addendum instructed Bonneville and others to continue to make progress on the Phased Approach to reintroducing salmon to the habitats above Chief Joseph and Grand Coulee Dams. This measure is one of the emerging priorities identified in the 2014 Fish and Wildlife Program that has received very little funding from Bonneville, and utilizing a portion of the RDC funds would again be authorized by 16 U.S.C. Section 839b(h)(10)(A) and (11)(A).
In closing, these funds are available because of “savings” made possible by not fully funding and addressing mitigation needed to tackle the externalities of the FCRPS. Bonneville’s trust responsibility and the Biden Administration’s focus on environmental justice demand a different outcome on the use of these funds. Funds that were generated in part by ignoring the impacts of the system that generated them. The Tribe requests that Bonneville reallocate the use of the RDC substantially, and commit a portion to address the under mitigation for Grand Coulee Dam by investing in the reintroduction effort and the need for greater mitigation to begin to address all of the impacts behind Grand Coulee Dam. This must be in addition to increased use of the RDC funds to address the underfunding and flat budgets that are impacting the important mitigation work throughout the NW Region.
Sincerely,
Ted Knight
Special Legal Counsel
Spokane Tribe of Indians
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Ballard/Wells Rural Electric CompanyPlease see attached letter.
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Dietz/McMinnville Water & LightPlease see attached.
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Munro/Grant PUDPlease see attached.
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GraceThe Bonneville Power Administration should use its $500 million in financial reserves to breach the four lower Snake River dams. This is inarguably the highest value purpose in BPA’s realm.
Breaching will lower power costs; increase reliability of the grid; make room on the transmission grid for 3300 megawatts of clean and green renewable power; and eliminate methane produced by the four reservoirs behind the dams, which is more than 80,000 metric tons, or roughly equivalent to a natural gas power plant generating 165 megawatts.
And even more important than all these high value items, without immediate breaching, Snake River wild salmon and steelhead will not recover. (NOAA Report September 2022.) Salmon and steelhead extinction will be followed quickly by the extinction of the salmon-dependent Southern Resident orcas.
Breaching the four lower Snake River dams is priceless for the Pacific Northwest and its values.
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Penney/Nez Perce TribeThe attached file contains the Nez Perce Tribe's comment/objection to Bonneville Power Administration's proposed FY 2022 Power Reserves Distribution Clause Allocation. Thank you.
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Huhta/Cowlitz PUDCowlitz PUD supports the comments submitted by the Public Power Council (PPC) and the Western Public Agencies Group (WPAG). In particular, we support the return of 70% of the Power RDC amount toward rate reduction. Cowlitz County communities face ongoing financial challenges given a disproportionate number of residents live in poverty at a rate 25% higher than Washington State as a whole.
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Simpson/Okanogan PUDPlease see the attached.
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Villanueva/TroutmanAvangrid Renewables, LLC and M-S-R Public Power Agency (together “Joint Commenters”) hereby submit comments to the Bonneville Power Administration (“Bonneville”) concerning the Q4 Quarterly Business Review and Q4 Quarterly Business Review Technical Workshop held on November 16, 2022 (the “Workshops”) wherein Bonneville shared its preliminary proposal for the utilization of the $63 million Transmission Reserves Distribution Clause (“RDC”). Joint Commenters appreciate Bonneville’s willingness to provide Transmission Customers some rate relief, but urge Bonneville to provide more substantive rate relief as opposed to “holding” nearly $34 million to cover recently forecasted cost increases in FY 2023.
The Workshops outlined the preliminary proposal for the Transmission RDC whereby BPA would apply approximately 50 percent for “rate reduction” and hold approximately 50 percent to cover forecasted cost increases for FY 2023. With respect to the 50 percent being used for rate reduction, Bonneville proposes to use $16.6 million to hold BP-24 rates flat and $12.7 million will be applied to a Transmission Dividend Distribution (“Transmission DD”), which Bonneville estimates as a 1.44% credit. With respect to the other approximately 50 percent, as Bonneville explained in the Workshops, the agency recently increased the Transmission Business Unit’s FY 2023 budget by $33.8 million to address certain costs that have increased significantly above the BP-22 rate case forecasts. Bonneville suggests that should Transmission revenues come in higher than anticipated, Transmission customers would be well positioned for a FY 2023 RDC as well.
Bonneville’s preliminary proposal is akin to a one-sided true-up and contrary to fundamental concepts of ratemaking. Rather than hold on to $33.8 million that may or may not ultimately be needed to address potential shortfalls in Bonneville’s BP-22 forecasts, Bonneville should provide the full amount of rate relief currently available under its financial policies. That is, rather than provide $12.7 million for a Transmission DD, Bonneville should use $16.6 million to hold BP-24 rates flat and use the full remaining $46.5 million ($12.7 + $33.8 million) for a Transmission DD.
Joint Commenters appreciate Bonneville’s review of these comments and consideration of the recommendations contained herein. Nothing contained in these comments constitutes a waiver or relinquishment of any rights or remedies provided by applicable law or provided under Bonneville’s tariff or otherwise under contract. By return e-mail, please confirm Bonneville’s receipt of these comments.
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Samuelson/Lewis County PUDThank you for the opportunity to comment. Lewis County PUD (The District) writes in support of the BPA’s proposed distribution of RDC funds set forth within the overall proposed BP-24 rate settlement. These RDC funds were accrued as a result of customers paying higher rates than necessary to recover BPA’s costs given hydrological and market conditions. It is very appropriate for BPA to refund the majority of these over-collected funds to its preference customers.
Rather than reiterate the well-articulated and extremely important points laid out in the PPC’s comment letter on this same matter, it seems appropriate to state the District’s full support of these points in their entirety.
Preference utility customers are already funding fish and wildlife mitigation at a monumental level, and at a time when utilities are also facing unprecedented inflationary pressures all while being asked to keep local rates stable, as our customers face these same pressures within their own budgets.
Thank you.
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Smith/Klickitat Public Utility DistPlease see attached
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Sykes/Columbia River PUDPlease see attachment.
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Hayden/Missoula Electric CooperativeMissoula Electric Cooperative (MEC) files these comments in support of PPCs' position on the distribution of BPA reserves. This includes $350 million for rate relief, $100 million of additional long-term debt repayment, and $50 million for accelerated spending on certain existing fish and wildlife mitigation efforts, subject to the condition identified in the proposed settlement agreement.
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Hall/Hall LawPlease see the attached.
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Martin/Modern Electric Water CompanyDecember 1, 2022
John Hairston
Administrator
Bonneville Power Administration
Submitted electronically
RE: Reserves Distribution Clause Proposal
Dear Administrator Hairston:
Modern Electric Water Company appreciates this opportunity to comment on the proposed use of Reserves Distribution Clause (RDC) funds. Our customers rely on Bonneville Power Administration (BPA) power and transmission products to provide our community and businesses with affordable, reliable, and environmentally responsible power supply.
We fully support conservation efforts and BPA’s proposed 10% ($50 million) allocation as part of the overall BP-24 rate settlement to mitigate for the operations of Columbia River System Operations on fish and wildlife. However, we cannot support further expansion of the RDC fund uses dedicated to fish and wildlife at an unjustified additional expense to our utility customers.
Our ratepayers presently subsidize fish and wildlife mitigation efforts to the tune of one-third of their utility costs as they are simultaneously reeling from the financial sting of U.S. power prices rising the most in 41 years. Consumers have been compelled to bear the burden of increased power costs when hydrological and market conditions have been unfavorable to BPA; in times of “good” financial years, it is imperative that those customers see some degree of relief from ever-increasing rates. In this unprecedented time of inflation and economic uncertainty, these vital funds must be used to provide our customers with that much-needed benefit.
We urge BPA to follow through on the settlement proposal to maintain the faith and trust of our customers. Modern Electric Water Company appreciates your consideration of these comments.
Sincerely,
Chelsea Martin
Government Relations & Communications Coordinator
Modern Electric Water Company
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O'Toole/Northwest Power and Conservation CouncilPlease see attached.
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Marckworth/Yakama NationPlease see attached.
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Levy/bluefish.orgPlease see the attached.
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Walter/Seattle City LightPlease see the attached.
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