Bud and Chris:
 
The RTO West Filing Utilities asked for comments from interested stakeholders, to be returned to you today, regarding the following topics:
 
Paying Agent Agreement
Schedule Coordinator Agreement
Bylaws Revisions
Pricing and Losses -- Revised Draft Proposal
Planning -- Revised Draft Proposal
 
Pricing and Planning.
On behalf of NRU, we have previously commented on the basic pricing and planning components proposed by the FUs.  A copy of our comments is attached here.  What with the quite recent distribution of the revised pricing and planning drafts, and given the clarification session last Friday re: same, we are still working to understand the revised pricing and planning drafts.  To that end, we are meeting today with certain FU representatives in order to flesh out our understanding.  As such, for purposes of the comment you seek today, NRU repeats its previous basic comments as contained in the attachment.  We will provide you with any further comment once we have a handle on the newly revised pricing and planning proposals.
 
That said, we have a specific request of the Filing Utilities and consultants.  We may best understand the pricing proposal when we know which charges are imposed on a transmission customer, in a variety of scenarios.  Prior to the Feb. 11-12 negotiation sessions, please provide us with materials specifying the applicable transmission charges under the revised draft pricing and congestion management proposals, for the following transmission customer scenarios.  Assume in each case that  the transmission customer: (a) is located within the RTO West geographic footprint; (b) is subject to BPA's "company rate"; and either (c)(1) is not exposed to congestion, or (c)(2) is exposed to congestion:
 
1.  Unconverted NT, nominal forecasted load growth, one power supply source (e.g., a BPA "full requirement" customer):
   a.   with no GTA service.
   b.  with GTA service.
2.  Unconverted NT, unexpected load growth (e.g., greater than current cataloged rights), one power supply source (e.g., a BPA "full requirement" customer):
   a.  with no GTA service.
   b.  with GTA service.
3.  Unconverted NT, nominal forecasted load growth, multiple power supply sources (e.g., a BPA "partial requirement" customer):
   a.  with no GTA service.
   b.  with GTA service.
4.  Unconverted NT, unexpected load growth (e.g., greater than current cataloged rights), multiple power supply sources (e.g., a BPA "partial requirement" customer):
   a.  with no GTA service.
   b.  with GTA service.
5.  Unconverted NT that changes power suppliers.
6-10.  Same as 1-5 above, but assume in each case that the NT contract was converted to RTO West service.
11.  Unconverted PTP, used for service to load only:
   a.  with no GTA service
   b.  with GTA service
12.  Unconverted PTP, used for service to load and through wheeling:
   a.  with no GTA service
   b.  with GTA service
13.  Unconverted PTP, used for through wheeling
14-16. Same as 11-13 above, but assume in each case that the PTP contract was converted to RTO West service.
 
Bylaws.
Regarding the proposed changes to the Bylaws Article VI, NRU recommends that the original text concerning the number of candidates to the Board of Trustees be retained.  That is, an "executive search firm" would assemble "a slate of qualified candidates numbering twice the number of vacancies to be filled . . . [except for the first full Board, when the search firm would] assemble a slate of 15 qualified candidates."  Article VI.3.2.  Reducing the number of candidates to the same number of vacancies on the Board, as proposed, puts authority in the hands of the "executive search firm" seeking candidates, rather than with the Trustees Selection Committee.  That search firm may, or may not, be responsive to the Trustees Selection Committee.  The Trustees Selection Committee was intended to be, and should remain, the ultimate authority in selecting Trustees.  The proposed Bylaws change inappropriately places that authority in the hands of a third party search firm.
 
In addition, NRU renews its objections to the Bylaws as previously made in FERC Docket No. RT01-35.  Our comments herein do not in any way express or imply acquiescence to the Bylaws as filed in RTO West's prior submittals to FERC.
 
PA and SC Agreements.
Finally, as to the Paying Agent and Scheduling Coordinator Agreements, each of them need to be part of the March 1 filing with FERC.  NRU is coordinating our comments with other interested stakeholders, and with BPA, regarding these agreements.
 
RRG Negotiations.
We expect the RRG's Feb. 11-12 sessions to consist of negotiations between and among stakeholders, including the FUs. To that end, persons with authority to negotiate materials to be contained in the March 1 filing should be present for the full negotiation session.  Two days should be adequate to resolve any differences among us, but if not then NRU strongly urges that the negotiations continue so that something like consensus be reached.  We are much better served by an honest attempt at closure, than we are by meeting self-imposed deadlines that may impede actual resolution.
 
Please give me a call if you have any questions.
 
Shelly Richardson, Attorney at Law
P.O. Box 61845
Vancouver, Washington  98666-1845
U.S.A.
voice (360) 737-2464
fax (360) 737-2661
shellyr@pacifier.com <mailto:shellyr@pacifier.com>