2010 Integrated Program Review
The following comments were submitted in response to the open comment period described below.
The 2010 IPR process is designed to provide customers and interested parties an opportunity to review, discuss, and provide meaningful comment on: 2010 Draft Long Term Asset Strategies for Transmission, Federal Hydro, Information Technology (IT) and Facilities. Specifically, comments may address the following:
* Current proposed expense spending levels for FY 2012-2013.
* Current proposed capital investment levels for FY 2012-2017.
* Updated FY 2011 proposed program spending level forecasts.
* Reduction scenarios addressing the impacts of lower expense spending levels for major programs in FY 2012-2013
We have expanded our discussion of asset strategies in this IPR and adjusted the timing to take place at the beginning of the process. We think it is important to have this context prior to discussing proposed capital spending levels.
Based on feedback received during the 2008 IPR, the 2010 IPR process will, again, consist of a series of technical and managerial workshops covering the major program categories for Power, Transmission and Agency Services.
For More Information:
http://www.bpa.gov/corporate/Finance/IBR/IPR/
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: 7/29/2010
- IPR100001 -
Farrow Ferman/Confederated Tribes of the Umatilla Indian ReservationView attached document.
View Attachment
- IPR100002 -
Saven/Northwest Requirements UtilitiesView attachment
View Attachment
- IPR100003 -
Goode/Mission Valley PowerJune 14, 2010 Mission Valley Power Feedback on 2010 Integrated Program Review This is the first time I have participated since 2003 task force, so I have some familiarity with the process. I sat through the presentations May 17 thru 20 and participated on the phone May 13 and May 24. I appreciate all the presentations and willingness to share details and answer questions. The information was presented in a good format. One of the future challenges is to develop an outline for all presentations that is consistent. I think that would streamline our understanding and reduce some work by all the presenting groups. What I took away is the generation and transmission systems are aging and are in need of maintenance. I felt like the message from the presenters was the systems are falling down and we need to rebuild immediately. I will be the first to admit we need to invest in maintenance and refurbishing the systems. I would just ask that the approach have a long term plan of 10 to 15 years, not all be fixed by the end of 2013. I did see some long range planning forecast on dollars. For example, the Energy Northwest had pretty good details on their plan for Columbia Generating Station. The Federal Hydro Assessment sounds like a great start. I remember someone saying Steve Oliver (I believe) had recognized the Columbia Generating Station condenser work shouldn’t go on at the same time as Grand Coulee work. I understood it was because of costs and generation impacts. I would hope this type of thought process is used every time in all future Transmission and Power projects when looking at reliability and costs. I will be the first to say Mission Valley Power has been lucky to have a pre-subscription contract for the last 10 years. Starting in October 2011, we realize our wholesale power supply costs will be increasing significantly. I realize that this rate increase is likely to be a large one, but my expectation is this will not happen during every two year rate period. One area that I would like more understanding on is the Personnel Compensation and Benefits increases. Your FTE additions did not seem to be out of line. I encourage you to use contract employees where it makes sense. The costs for transmission and power increasing 18% and 16% each from actual 2009 to 2012 IPR seemed high. Here locally our Union wages have been increasing 4 to 5% to move to the Northwest average and other personnel wages have been less than 2%. FY 10 our non union employees received no cost of living increase. Starting next year I expect the Union wages to go back to less than 3% and other personnel to below 2% per year if any for the next few years. Fortunately our benefits costs have been holding. I heard your transmission system needs to be evaluated for its maintenance needs, for example how long insulators should be used. All I can tell you, my observation is your system gets lots of maintenance compared to the IOU that crosses Mission Valley Power service area. I would encourage you to do maintenance but do not recommend overly aggressive plan. Use an industry standard of a mix between IOU and Federal owned. The ability to capital or expense items is confusing to me. I assume you have some guideline to follow. I don’t know the trade offs. If it is something customers can assist you in changing, let us know. I appreciate you are holding a meeting to discuss this process. Reserve dollars target, Risk and Insurance, and Debt structures, needs some discussion. I will leave that to Geoff Carr, Bill Drummond and others. I look forward to continuing to rebuild BPA Transmission and Power back into one organization. I’m seeing some efficiency results here at the Utility. In closing, I know rates need to rise but I expect it to be gradual after Fiscal Year 2012. We need to invest in the system to ensure the Northwest benefits from the Federal generation and transmission. You can reach me at 406-883-7905 if you want to discuss further. Thank you for all your hard work. Ralph Goode General Manager
- IPR100005 -
Langer/Northern Wasco PUDWe appreciate you keeping us apprised of the various meetings associated with the IPR process. We appreciate BPA’s openness and opportunities to participate. On Tuesday I attended the IPR General Manager meeting and you know me, I couldn’t keep my mouth silent. I thanked the Administrator and BPA for allowing the GMs this opportunity to comment. I was a little disappointed/surprised that there went not more GMs present. But at any rate, I commented that the present environment and the foreseeable future is not ‘business as usual.’ For NWasco the cost of energy is a significant contributor to our economic recovery. Escalating wholesale rates drives escalating energy prices at the retail which means an increasing risk of load loss which translates into job losses and impacts a community’s overall quality of life. Comments that I’m sure are obvious, but I made them all the same. As it stands, according to the handouts at the meeting, we’re facing a 17-19 percent wholesale rate increase – this is before replenishment of BPA reserves, purchased power costs, Residential Exchange and DSI service. And, to top it off, before the community must endure the loss of support from the State as Oregon’s budget is a mere $580 M in the red for the last year of this biennium! I commented further that we’re concerned about reliability of the system with the integration of impressive (but challenging) levels of intermittent resources. While we know BPA is doing all they can, we’re concerned that political pressures will prevail and we’ll witness the FBS being deployed more and more exclusively for support for intermittent resources. I commented further, hopefully not to his chagrin that I understood the Administrator’s comments in Sacramento on the occasion of the NWPPA annual conference to solely identify wind resources as BPA’s future portfolio resources to the exclusion of all other types of resources including baseload resources. This is a concern to us. In conclusion I suggested/commented that if an expenditure is not mission critical that it be deleted or cut. Later in the meeting, and this is something I have thought about for quite awhile and/or on several occasions. Would there be/is there value in BPA’s customers pre-paying a portion of their power and/or transmission services charges? At what threshold level, if applicable, could BPA offer incentives in the form of cost discounts for customers to pre-pay? (BPA’s total revenues are approx $3 B I believe.) What if the customers collectively paid a quarter or a third of their annual power/transmission charges and thus infusing $ 1 B into the BPA accounts? Dave Armstrong, acting interim asst administrator and former CFO, stated that it would involve cash management responsibilities that BPA has not to date encountered. I still think it may have some merit, but that’s my mind for ya. For what it’s worth Dan, those were my comments. NWasco has been and continues to be a BPA supporter and includes you and all of BPA has one of our most important partners. That hasn’t changed, but what also hasn’t changed is our concern and caution about our regional and national economy.
- IPR100006 -
Toulson/Snohomish County PUDView attached letter
View Attachment
- IPR100016 -
Finley/Confederated Tribes of the Colville Reservation
View attached document.
View Attachment
- IPR100018 -
Measure/Northwest Power and Conservation CouncilView the attached document.
View Attachment
- IPR100019 -
Owens, PE/Columbia River PUDview attached document.
View Attachment
- IPR100027 -
Shimshak/Renewable Northwest ProjectView attached document.
View Attachment
- IPR100033 -
Dawsey/Benton Rural Electric AssociationView attached document.
View Attachment
- IPR100036 -
Saven/Northwest Requirements Utilitiesview attachment
View Attachment
- IPR100037 -
Drummond/wmgtView attachment
View Attachment
- IPR100038 -
Rodewald/GCPHAView attachment
View Attachment
- IPR100039 -
Norris/Eugene Water and Electric BoardView attachment.
View Attachment
- IPR100040 -
Kern/Seattle City LightPlease see attached letter.
View Attachment
- IPR100042 -
Sugden/Flathead Electric Cooperativeview attached document
View Attachment
- IPR100043 -
Muller/Lewis County Public Utility DistrictView attached document.
View Attachment
- IPR100044 -
Early/Industrial Customers of Northwest UtilitiesView attached document
View Attachment
- IPR100045 -
Coates/Tacoma Powerview attached document
View Attachment
- IPR100046 -
OMeara/Public Power Council
View attached document
View Attachment
- IPR100047 -
Corwin/Public Power CouncilView attached document.
View Attachment
- IPR100048 -
Hirsh/NW Energy CoalitionBonneville Power Administration Integrated Program Review - Energy Efficiency 2010 IPR Draft Close Out Report Comments of the NW Energy Coalition, South Central Community Action Partnership (Twin Falls, ID), Natural Resources Defense Council July 29, 2010 The Coalition, Partnership and NRDC appreciate the opportunity to submit these comments in support of BPA's proposed energy efficiency budget for FY 2012 and 2013. This proposed budget is consistent with the energy savings targets committed to in the Regional Dialogue policy and the Post-2011 efficiency plan. BPA is responding appropriately to the fact that the Northwest Power and Conservation Council has identified more cost-effective energy efficiency opportunities than ever before. BPA's continued leadership and experience will be essential in delivering those potential benefits to all Northwest utility customers. The proposed IPR efficiency funding levels properly reflect the need for an even more robust coordinated regional and local delivery strategy. We support BPA's decision to maintain funding in three categories: expense, capital and administrative support. Expensing investments in areas such as NEEA, RD&D, program design, marketing, evaluation and technical support is an effective and clear strategy. Except for NEEA, the benefits of these types of programs are measured not in long-term savings but in near-term capacity building, facilitation and education. Using the capital budget as the tool to significantly increase efficiency investments is the right strategy for BPA and its customers at this time. Capitalizing investments that produce clear savings and have savings targets attached to them makes sense for BPA. Energy savings persist over time, just like supply-side generation or other infrastructure investments. Because efficiency measures have varied life expectances, a 5- to 13-year amortization period seems reasonable. Many measures with much longer useful lives merit 20- to 30-year amortization periods, but we recognize that extended depreciation periods lead to excessive interest payments and to accumulated debt that could make continued funding a challenge. One benefit of increased capital financing is increased involvement by the federal treasury -- a lender that recognizes the value of efficiency assets and can provide low-cost capital to help the region meet its savings and rate stability goals. While we support BPA's general approach and budget levels, we do have two areas of concern: 1. The low-income and tribal weatherization program receives no funding increase despite the considerable increase in BPA's overall energy savings goal. The previous savings goal was 260 aMW over five years and now BPA's target is 504 aMW. BPA funding allows state and local community action agencies to leverage other funds to maximize the impact of low-income weatherization services. The need for these services has grown and increased funds for 2012-13 would reach state and local agencies just as their ARRA funding runs out. In fact, ARRA funds have caused local agencies to expand their delivery capacity and infrastructure and leaves them well-situated to take on additional funding that maintains important weatherization infrastructure and the pace of delivery. BPA should work with state and local agency staff to determine an appropriate increase in funding for this program, recognizing the increased capacity of the agencies to delivery more service. 2. Given the greater program savings goals and dollar investments, the proposed funding increase for energy efficiency staffing and overhead may be insufficient. While BPA should keep its administrative costs low, it must continue to operate an efficient and effective department. No customer utility should blame BPA’s administrative processing of support services for holding up its programs and delivery of services. BPA should consider increasing the internal operating costs for conservation support beyond the $10.4-10.7 million proposed. Thank you again for the opportunity to comment. We congratulate BPA for its determined progress on energy efficiency. If you have any questions regarding these comments please contact Nancy Hirsh, NW Energy Coalition at 206-621-0094 or nancy@nwenergy.org.
- IPR100049 -
Arthur/on behalf of MSR Public Power Agencyview attachment.
View Attachment
- IPR100050 -
Mundorf/Western Public Agencies Groupview attachment
View Attachment
- IPR100051 -
Toulson/Snohomish County PUDView attachment for additional comments
View Attachment
- IPR100052 -
Prescott/PNGC PowerView attachment
View Attachment
|
|
|
Finance & Rates
