2007 Wholesale Power Rate Case Initial Proposal : Risk Analysis Study.

The Federal Columbia River Power System (FCRPS), operated on behalf of the ratepayers of the PNW by BPA and other Federal agencies, faces many uncertainties during the FY 2007-2009 rate period. Among these uncertainties, the largest revolve around hydro conditions, market prices and river operations for fish recovery. In order to provide a high probability of making its U.S. Treasury payments, BPA performs a Risk Analysis as part of its rate-making process. In this Risk Analysis, BPA identifies key risks, models their relationships, and then analyzes their impacts on net revenues (total revenues less expenses). BPA subsequently evaluates in the ToolKit Model the Treasury Payment Probability (TPP) resulting from the rates, risks, and risk mitigation measures described here and in the Wholesale Power Rate Development Study (WPRDS). If the TPP falls short of BPA's standard, additional risk mitigation revenues, such as PNRR and CRAC revenues are incorporated in the modeling in ToolKit until the TPP standard is met. Increased wholesale market price volatility and six years of drought have significantly changed the profile of risk and uncertainty facing BPA and its stakeholders. These present new challenges for BPA in its effort to keep its power rates as low as possible while fully meeting its obligations to the U.S. Treasury. As a result, the risk BPA faces in not receiving the level of secondary revenues that have been credited to power rates before receiving those funds is greater. In addition to market price volatility, BPA also faces uncertainty around the financial impacts of operations for fish programs in FY 2006 and in the FY 2007-2009 rate period. A new Biological Opinion or possible court-ordered change to river operations in FY 2006 through FY 2009 may reduce BPA's net revenues included Initial Proposal. Finally, the FY 2007-2009 risk analysis includes new operational risks as well as a more comprehensive analysis of non-operating risks. Both the operational and non-operational risks will be described in Section 2.0 of this study. Given these risks, if rates are designed using BPA's traditional approach of only adding Planned Net Revenues for Risk (PNRR), power rates would need to recover a much larger ''risk premium'' to meet BPA's TPP standard. As an alternative to high fixed risk premiums, BPA is proposing a risk mitigation package that combines PNRR with a variable rate mechanism similar to the cost recovery adjustment mechanisms used in the FY 2002-2006 rate period. The proposed risk mitigation package is less expensive on a forecasted basis because the rates can be adjusted on an annual basis to respond to uncertain financial outcomes. BPA is also proposing a Dividend Distribution Clause (DDC) to refund reserves in excess of $800M to customers in the event net revenues in the next rate period exceed current financial forecasts.