Letter to the Chairman of the Federal Energy Regulatory Commission Jon Wellinghoff - FERC Transmission Rules

Letter

Energy and Natural Resources Committee Chairman Ron Wyden, D-Ore., called for the Federal Energy Regulatory Commission to allow the Northwest to maintain control over its power future, by providing flexibility regarding compliance with FERC's Order No. 1000 on transmission planning and cost allocations, in a letter sent today.

"As you know, the majority of the Northwest power system is composed of utilities that generally are not subject to FERC jurisdiction and that are the creation of, and subject to, state or federal statutes," Wyden wrote. "This makes the Order No. 1000 process akin to trying to hammer a square peg into a round hole for the Bonneville Power Administration and other governmental utilities."

Wyden asked FERC not to use the Order No. 1000 compliance process to attempt to take away the authority of Bonneville and other governmental utilities to decide what transmission they build in the Northwest and who pays for it. Instead, Wyden suggested the Commission show that it is truly committed to the principle of regional flexibility in the Order No. 1000 process.

Order No. 1000 is a FERC rule that changes transmission planning and cost allocation requirements applicable to transmission entities subject to its jurisdiction. The Commission initiated the Order No. 1000 rulemaking process in 2010. A final rule was issued in 2012 and FERC has shifted to consideration of compliance filings, including, in the Northwest, ColumbiaGrid.

The letter is below.

The Honorable Jon Wellinghoff
Chairman
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426

Dear Chairman Wellinghoff:

I am writing to express my concerns regarding the potential adverse impact of Order No. 1000 on the Northwest region.

As you know, the majority of the Northwest power system is composed of utilities that generally are not subjects to FERC jurisdiction and that are the creation of, and subject to, state or federal statutes. This makes the Order No. 1000 process akin to trying to hammer a square peg into a round hole for the Bonneville Power Administration and other governmental utilities. For example, ColumbiaGrid, acting on behalf of Bonneville and other non-jurisdictional utilities, has proposed to develop approaches to cost allocation through the Order No. 1000 process but emphasizes that any allocation of costs it develops will be a recommendation only and not binding on any member utility. The reason for this is that Bonneville and other non-jurisdictional utilities that belong to ColumbiaGrid believe that it would be both unwise and unlawful for them to cede their authority over transmission cost allocation to FERC. I strongly agree.

The commission, in particular Commissioner Moeller, has repeatedly stated support for "regional flexibility" regarding Order No. 1000 compliance. Now is the time for the Commission to show that it s truly committed to that principle. The Northwest electric power industry, acting through ColumbiaGrid and the Northern Tier Transmission Group, has made a good faith effort to respond to Order No. 1000 in a constructive manner that preserves the ability of the region to continue to chart its own electric power destiny. I strongly urge the Commission to respond in kind.

Thank you for you consideration.

Sincerely,

Ron Wyden
Chairman

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