Official File
Department of Energy
Bonneville Power Administration
P.O. Box 3621
Portland, Oregon 97208-3621
POWER SERVICES
August 23, 2013
In reply refer to: PST-6
Re:
Comments on Business Practice #64: Calculating Operating Reserve Charges (Schedules
5 and 6) for Self-Supply Transmission Customers
PacifiCorp Business Practice Forum
PacifiCorp
700 NE Multnomah, Suite 1600
Portland, OR 97232
Dear Sirs:
Thank you for the opportunity to comment on the above-noted business practice. The
Bonneville Power Administration (“BPA”) submits the following comments and questions
regarding the Business Practice #64.
First, for a system sale of power within PACE, how does one determine the amount of reserves
to provide? Will the seller of such power have to determine what portion of its system is hydro,
wind, and thermal at the time of the sale or when power is delivered?
Second, what reserve obligation will apply for the resale of excess energy that has already been
supplied with reserves? That is, if BPA purchases a system sale within PACE, but does not use
all of the energy to serve its network load, will BPA have to acquire additional reserves to resell
or export the excess energy? For example, assume BPA purchases within PACE a 100 MW
block of thermal-based energy. The sale includes reserves. BPA’s network load is forecast to be
90MW. BPA intends to undesignated 10MW of the resource for the hour and sell the excess
energy (using PTP) to another customer within PACE or to export the energy. Based on the
Business Practice it appears BPA may be required to acquire reserves (7% x 10MW = .7 MW)
for this sale. If this is correct, then BPA will have paid for reserves twice: once with the original
purchase and once again when reselling the energy. BPA comments that if reserves are already
being provided through an original purchase, the Business Practice should be clear that the seller
of such power will not be charged for additional reserves.
2
Thank you again for the opportunity to comment on the aforementioned business practice.
Sincerely,
Todd E. Miller
Transfer Service Manager