Precedent Transmission Service Agreement (PTSA) Reform Project
The following comments were submitted in response to the open comment period described below.
BPA has concluded its negotiations with customers seeking to terminate or
modify Precedent Transmission Service Agreements and sent each customer a term
sheet summarizing the negotiated outcomes. BPA started posting the final
draft of these term sheets for public review and comment on Nov. 26, 2012.
The comment period remains open through Friday, Dec. 14.
The agreements involve termination and redirection of transmission service,
and calculation of the value of marketable flowgate capacity that results from
the changes. None of the proposed agreements result in cost transfers to
other customers or PTSA holders.
BPA began discussions about PTSA modifications with customers in summer
2011. The goal of the discussions was to allow customers who requested to
modify or withdraw existing PTSAs to do so, provided this resulted in no adverse
cost impacts to other customers. As a result of this public process, BPA
has accepted proposals involving approximately 1,200 megawatts of service and
several customers.
The service being modified or terminated, plus the return of available
flowgate capacity created by these actions that can be remarketed by BPA, keeps
the region whole and supports BPA’s consideration of these requests.
Reaching a decision on customer requests to withdraw or terminate PTSAs is an
important milestone in BPA’s public discussion with customers regarding broader
changes to the content and terms of future PTSAs and the Network Open Season
process.
For More Information:
http://www.bpa.gov/goto/PTSAReform
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.
Close of comment: 12/14/2012
- PTSA12 0003 -
Bingham/PGEMPortland General Electric Company (PGE) appreciates the opportunity to comment on the PTSA Reform proposal and would like to commend the Bonneville Power Administration (BPA) staff on their diligence in the effort. PGE appreciates the patience and persistence shown in the process and hopes that BPA will continue to use creative thinking in the transmission reform process. PGE believes BPA has struck an appropriate balance for all stakeholders with the current proposal.
- PTSA12 0004 -
Neale/WPAGView attachment
View Attachment
- PTSA12 0005 -
Baker/Public Power CouncilView attached document
View Attachment
- PTSA12 0006 -
Scott/PNGC PowerView attachment
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- PTSA12 0008 -
Hill/Cowlitz PUDview attachment
View Attachment
- PTSA12 0009 -
Burch/Puget Sound Energyview attachment
View Attachment
- PTSA12 0010 -
Saven/Northwest Requirements Utilitiesview attachment
View Attachment
- PTSA12 0011 -
Yourkowski/Renewable Northwest Projectview attachment
View Attachment
- PTSA12 0012 -
Espenhorst/Seattle City Light
Seattle City Light thanks you for the efforts on PTSA reform. Over the past 18 months, BPA has done an admirable job of considering differing customer needs.
City Light agrees the proposals are financially preferable to a defer/default scenario.
Does BPA accrue interest on the performance assurances? Since these were paid in the past, interest, if any, should be included in the present value analysis, accrued to the same point in time to which the costs or revenues are discounted.
Thank you for providing updated BP and Iberdrola analyses with future rates estimated. The Risk Adjusted scenarios show greater financial risk remaining on BPAT customers in the event that BPA is not able to resell the assumed amount of transmission.
Future evaluations should include comprehensive analysis on flowgates and financial effects should include forecast of transmission costs and rates. A comprehensive evaluation with as many realistic assumptions as possible provides a reasoned basis for evaluating such requests.
- PTSA12 0013 -
Norris/Powerex Corp.
These comments are in response to the three posted draft proposals for PTSA termination. Powerex continues to oppose Bonneville’s decision to permit some customers to back out of existing transmission commitments. Customers participating in the Network Open Season (NOS) process have made significant investments, not only in transmission projects, but also in other regional projects and commercial arrangements which depend on receiving transmission service within a specified timeframe. In principle, it is discriminatory to subject those customers who fulfill their NOS obligations to uncertainty and potential financial harm because others have a new ability to terminate or modify their agreements. This is further complicated by the fact that the effects are not only within the BPA Balancing Authority Area but in the broader WECC region and as such, it is paramount that all transmission customers can rely on clear, non-discriminatory business practices when making their respective commercial decisions.
To the extent that BPA is allowing flexibility to individual customers, it must extend this flexibility to all customers. BPA is proposing custom modifications for individual companies that include: (1) an extended date for the option to terminate; (2) the ability to terminate early after service has commenced; and (3) a two-parent redirect. Any contract modification should be carried out under well-defined business rules in a non-discriminatory manner applicable to all customers including existing Firm Rights holders. To the extent BPA proposes to make changes to its tariff and/or business practices, it is important to consider whether such changes will result in equal or superior service to the pro-forma OATT.
Thank you for the opportunity to comment.
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Finance & Rates
