B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
ISSUE #1: EIM CHARGE CODE
ALLOCATION
Step 3: Data and/or analysis that supports the issue
Step 4: Discussions on possible alternatives to solve the issue
23
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Objective
Address charge code allocation policy issues to
determine the approach Bonneville should adopt to
recover its costs (or distribute credits) for charge codes it
receives as an EIM Entity.
Policy direction will be set as the starting point for
development of the BP-22 Initial Proposal
• Charge code allocation policy issues will not be finalized until the
BP-22 Record of Decision
Note: Settlement mechanics (e.g. frequency or type of BPA customer
billing) will be addressed separately in future workshops, if there is a
sub-allocation methodology adopted.
24
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Customer Feedback Themes
Customers expressed interest in phasing in changes for the EIM and
considering a partial insulation approach, which BPA has
considered in developing alternatives
Working towards a methodology that considers cost causation and
market implications was expressed, consistent with the charge code
allocation principles BPA developed
Requests for additional charge code education were received and
further discussion occurred at a customer-led workshop. Today’s
workshop will work to provide further information, in context of the
alternatives and the relationships to BPA’s existing structure
• Magnitude of charges/credits was requested, but there is not
comparative information available, given the complexities and size of
BPA’s BAA compared to other EIM entities
25
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Charge Code Allocation Approach
26
Phase One:
Approach Development
Phase Two:
Evaluation
Phase Three:
Proposal Development
December 12
Workshop
Today’s
Workshop
April 28
Workshop
Step 1:
Introduction & Education
Step 2:
Description of the Issue
Step 5:
Discuss Customer
Feedback
Step 6:
Staff Proposal
Step 3:
Analyze the Issue
Step 4:
Discuss Alternatives
The charge code allocation policy proposal will provide the
framework for rate design, then rate design will be developed later.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Timing Context for Rate Development
and EIM Information Availability
27
BP-22
• Spring-Summer
2020 Development
• November 2020
Release IP
• July 2021
Release FP
BP-24
• Spring-Summer
2022 Development
• November 2022
Release IP
• July 2023
Release FP
BP-26
• Spring-Summer
2024 Development
• November 2024
Release IP
• July 2025
Release FP
March 2022
Anticipated EIM Entry
Less than a half year of BPA
BAA-specific EIM data
available during
development
No BPA BAA-specific EIM
data available during
development
Two years of BPA BAA-
specific EIM data available
during development
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Sub-Allocation Focuses on EESC
Sub-allocation considerations included in today’s
workshop are focused on the EESC approach
Allocation of Bonneville Power’s costs and benefits as
the PRSC is a Power product issue that will be
discussed in a future workshop
28
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
• Real-Time Energy Offsets
• Congestion Offsets
• Bid Cost Recovery
• Grid Management
• Forecasting Service Fee
• Administrative Penalties
FERC Approved Allocation Method Overview
29
• Imbalance Energy
• Instructed
• Uninstructed
• Flexible Ramping
• Over Scheduling
• Under Scheduling
Measured Demand
by Direction
Measured Demand
Majority Not Sub-
Allocated
Primary Charge Exceptions: Not Sub-Allocated
• Real Time Unaccounted for Energy (64740)
• Daily Flex Ramp Up Uncertainty Capacity (7071)
• Daily Flex Ramp Down Uncertainty Capacity (7081)
Administrative Exceptions
• GMC (4564 & 4575): Measured Demand
• Forecasting Service Fee (701): Direct Assignment
• Enforcement Protocol Penalty Allocation (1592): Direct Assignment
Sub-Allocation Methods Defined
• Direct Assignment: Costs assigned to a customer through a rate or direct
pass through that can be linked to a specific action taken by the customer.
• Measured Demand: A cost shared among all customers regardless of
participation or actions taken.
• Measured Demand by Direction: Costs assigned to customers based on
contribution to the charge.
Primary
Charges
Penalty
Charges
Market
Clearing /
Neutrality /
Cost Recovery
Administrative
Imbalance:
Direct Assignment
Flexible Ramping:
Measured Demand
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
CAISO to BPA Comparisons
Similar to BPA’s Energy Imbalance (EI) and Generation
Imbalance (GI)
Imbalance Energy
(IIE & UIE)
• Intent is to settle for generation and load imbalances
• UIE is most similar to the EI/GI of today
• IIE also settles Interchange imbalances, which is different from today
Similar to BPA’s Intentional Deviation (ID) and Persistent
Deviation (PD)
Over & Under
Scheduling
• Over/Under Scheduling (applied to load) is meant to prevent entities from leaning on the
market
• ID (applied to variable generators) and PD (applied to load and dispatchable generators)
are meant to prevent leaning on the BAA
Similar to BPA’s DERBS, VERBS, & RFR
Flexible Ramping
• Intent is to ensure there is enough uncertainty capacity to meet unexpected load and
generation changes (or load forecast error)
• DERBS and VERBS is capacity to meet unexpected generation changes
• RFR is capacity to meet load
30
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Criteria for Evaluation
Feasibility of
Implementation
Administrative
Burden
Cost Recovery
Design
31
BPA Perspective
• Resource Costs to Implement
Design
• Recognition of Uncertainties in
Forecasting Costs and
Revenues
Customer Perspective
• Resource Costs
• Training Costs
(scaled to EIM experience)
Customer Perspective
• Cost of Administering
• Volume of Supporting
Billing Data
BPA Perspective
• Cost of Administering Billing
and Settlements
• Level of Service based on
Complexity of Billing
• Design Limitations based on
System Capabilities
• Full and Timely Cost Recovery
• Cost Allocation Consistent with Cost Causation
• Incentivize Appropriate Market Behaviors
• Understandable and Transparent Methodology
• Flexibility in Design to Develop with Market Experience
• Minimize Settlement Seams Issues
• Design with Consideration of Risk Mitigation
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Decision-Tree Based Alternatives
32
Existing FERC
Approved Sub-
Allocation Model
Level of Sub-
Allocation
No Sub-Allocation
BPA-Designed
Partial Sub-
Allocation
Sub-Allocation
Past Existing
Models
0 Codes
1-26 Codes
27 Codes
Greater than
27 Codes
• Customer Bills Do Not
Reflect Any Codes
• No Settlement Re-
Calculations for Customers
• Minimal Administrative
Burden for Customers &
BPA
• Market Experience Prior to
Charge Code Allocation
• Potential for Misalignment
on Behavioral Signals
• Limits Customer Ability to
Begin Adapting to EIM
• Customer Bills Reflect
Some Codes
• Settlement Re-Calculations
for Customers
• Low Administrative Burden
for Customers & BPA
• No Market Experience
Prior to Starting Charge
Code Allocation
• Potential for Misalignment
on Behavioral Signals
• Customers Start Adapting
to EIM from Beginning
• Customer Bills Reflect
FERC Approved Codes
• Settlement Re-Calculations
for Customers
• High Administrative Burden
for Customers & BPA
• No Market Experience
Prior to Charge Code
Allocation
• Behavioral Signals Aligned
with Others and Low Risk
of Misalignment with EIM
• Customers Adapt to EIM
from Beginning
• Customer Bills Reflect
Additional Codes
• Settlement Re-Calculations
for Customers
• High Administrative Burden
for Customers & BPA
• No Market Experience
Prior to Charge Code
Allocation
• Behavioral Signals Aligned
with EIM and Low Risk of
Misalignment with Others
• Customers Fully Adapt to
EIM from Beginning
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
No Sub-Allocation Alternative
33
No Sub-Allocation
0 Codes
Define Cost
Recovery
Mechanism
While cost recovery mechanisms would be
developed later, options for cost recovery under
any of the alternatives may include:
1) Rate Design Mechanisms
2) Planned Risk Mechanisms
3) Status Quo
(utilize existing risk mechanisms only)
Criteria
Considerations:
• Customer Bills Do Not
Reflect Any Codes
• No Settlement Re-
Calculations for Customers
• Minimal Administrative
Burden for Customers &
BPA
• Market Experience Prior to
Charge Code Allocation
• Potential for Misalignment
on Behavioral Signals
• Limits Customer Ability to
Begin Adapting to EIM
Feasible to
Implement
Administrative
Burden
Cost
Recovery
Design
Postpones settlement
process development,
but will require cost
recovery mechanisms
Minimal administrative
burden for customers,
thereby limiting BPA
administrative burden
Delays alignment with
EIM signals, but there is
flexibility for future
allocation development
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
BPA-Designed Partial Sub-Allocation
Alternative
34
BPA-Designed
Partial Sub-
Allocation
1-26 Codes
Behavior Driven or
Distribution Approach
Define
Code
Scope
Define Cost
Recovery
Mechanism for Out
of Scope Codes
Define Sub-
Allocation
Mechanics for In-
Scope Codes
• Customer Bills Reflect
Some Codes
• Settlement Re-Calculations
for Customers
• Low Administrative Burden
for Customers & BPA
• No Market Experience
Prior to Starting Charge
Code Allocation
• Potential for Misalignment
on Behavioral Signals
• Customers Start Adapting
to EIM from Beginning
Criteria
Considerations:
Feasible to
Implement
Administrative
Burden
Cost
Recovery
Design
Starts settlement
process and will require
some cost recovery
mechanisms
Some administrative
burden for customers,
thereby adding to BPA
administrative burden
Starts alignment with
EIM signals, but there is
flexibility for future
allocation development
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
BPA-Defined Partial Sub-Allocation
Code Number Description
FERC Allocation
Method
Rationale for
Allocation
64750
Uninstructed Imbalance
Energy (Schedule 4 and
Schedule 9)
Direct Assignment
Customer submits a
schedule to BPA based on
customer forecast
64600
FMM Instructed Imbalance
Energy (Energy Imbalance)
Direct Assignment
Customer has the ability to
change schedule in real-
time “EIM Market”
64700
Real-Time Instructed
Imbalance Energy (Energy
Imbalance)
Direct Assignment
Customer has the ability to
change schedule in real-
time “EIM Market”
35
Base Code Option
• Approach captures all energy imbalance calculations and real-time schedule
changes.
• Sub-allocating this set of codes on its own ignores the neutrality charges and
credits passed on by the CAISO to EIM entities.
• Today’s EI and GI bands may be further evaluated given the potential EIM entry.
Codes in bold are included in FERC-Approved sub-allocation.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
BPA-Defined Partial Sub-Allocation
Code Number Description
FERC Allocation
Method
Rationale for
Allocation
64770
Real Time Imbalance
Energy Offset EIM
Measured Demand
(BPA May Consider Alternative
Methods – such as Pro-Rata
Shares of Code Components)
Compensation or charges
used to achieve revenue
neutrality within each BAA
when the market settles.
64740
Real Time Unaccounted for
EIM Energy Settlement
Measured Demand
(BPA-Proposed Method)
Is presumed to be caused by
losses not calculated by the
CAISO.
69850
Real Time Marginal Losses
Offset EIM
Measured Demand
Associated with a change
in losses due to RT
generation dispatches.
6478
Real Time Imbalance
Energy Offset
Measured Demand
Last allocation to achieve
revenue neutrality within
CAISO after 64770 settles.
36
Base + Neutrality Code Option
• Neutrality Codes could be sub-allocated in addition to the Base Codes.
• While 64740 is not currently part of the FERC-approved sub-allocation, this code
is part of the neutrality codes that settle the market.
• See next slide for mapping between the Base and Neutrality codes.
Codes in bold are included in FERC-Approved sub-allocation.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Base + Neutrality Codes Relationship
37
• Within the CAISO financial settlements, the Base and Neutrality charge codes
are combined to complete the IIE and UIE transactions.
• The map above shows how the Base codes flow into the calculations for the
Neutrality codes in order to financially settle the market.
BASE Charge Codes
FMM Instructed Imbalance
Energy Charge Code 64600
Real Time System Imbalance
Energy Offset: Charge Code 6478
Real-Time Unaccounted for
Energy EIM Charge Code 64740
Real-Time Marginal Losses Offset
EIM Charge Code 69850
Real-Time Imbalance Energy
Offset Charge Code 64770
Real-Time Instructed Imbalance
Energy Charge Code 64700
Real-Time Uninstructed
Imbalance Energy
Charge Code 64750
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
BPA-Defined Partial Sub-Allocation
Code Number Description
FERC Allocation
Method
Rationale for
Allocation
6045
Under/Over Schedule Load
Charge
Measured Demand by
Direction
Bonneville decides to hold
customers responsible for
over and under scheduling
6046
Under/Over Schedule Load
Allocation
Measured Demand by
Direction
Bonneville decides to hold
customers responsible for
over and under scheduling
38
Potential Adder: Scheduling Penalty Codes
• If the Base or Base + Neutrality options are selected, Scheduling Penalties could
be a potential adder for sub-allocation.
• As described, Over/Under Scheduling prevents entities from leaning on the
market, whereas ID and PD prevent entities from leaning on the BAA.
Codes in bold are included in FERC-Approved sub-allocation.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
BPA-Defined Partial Sub-Allocation
Code Number Description
FERC Allocation
Method
Rationale for
Allocation
66200
RTM Bid Cost Recovery
EIM Settlement
Measured Demand
Reimbursements where the
commitment costs were not
covered by the LMP.
66780
Real Time Bid Cost
Recovery EIM Allocation
Measured Demand
Charges to EESC to
reimburse generating
resources for costs not
recovered through the LMP.
67740
Real Time Congestion
Offset EIM
Measured Demand
Recovers the difference
between market forecasted
congestion cost and
resulting congestion cost
based on EIM dispatches.
39
Potential Adder: EIM Dispatch Codes
• If the Base or Base + Neutrality options are selected, EIM Dispatch Codes could
be a potential adder for sub-allocation.
Codes in bold are included in FERC-Approved sub-allocation.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
BPA-Defined Partial Sub-Allocation
40
Potential Adder: Flexible Ramp Codes (Slide 1 of 2)
• If the Base or Base + Neutrality options are selected, Flexible Ramp Codes
could be a potential adder for sub-allocation.
• Flexible Ramping Defined: Capacity on participating units capable of meeting a
five minute ramping need used to address load uncertainty realized prior to
Real-Time Dispatch (RTD).
• Today’s DERBS, VERBS, and RFR are similar in working to meet unexpected
generation and load changes.
• FCRPS is the primary provider for the flexible ramping needed within BPA’s
BAA
Codes in bold are included in FERC-Approved sub-allocation.
Code Number Description
FERC Allocation
Method
Rationale for
Allocation
7076, 7077, 7078, 7087,
and 7088
Flexible Ramping
(Detail by Code on Next Slide)
Measured Demand
Capacity held out to cover
load forecast uncertainty.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
BPA-Defined Partial Sub-Allocation
41
Potential Adder: Flexible Ramp Codes (Slide 2 of 2)
Codes in bold are included in FERC-Approved sub-allocation.
Code Number Description
FERC Allocation
Method
Rationale for
Allocation
7076
Flexible Ramp Forecast
Movement Allocation
Measured Demand
Capacity held out to cover
load forecast uncertainty.
7077
Daily Flexible Ramp Up
Uncertainty Award Allocation
Measured Demand
7078
Monthly Flexible Ramp Up
Uncertainty Award Allocation
Measured Demand
7087
Daily Flexible Ramp Down
Uncertainty Award Allocation
Measured Demand
7088
Monthly Flexible Ramp Down
Uncertainty Award Allocation
Measured Demand
Codes in bold are included in FERC-Approved sub-allocation.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Existing FERC Approved Sub-Allocation
Model Alternative
42
Existing FERC
Approved Sub-
Allocation Model
27 Codes
Use
FERC
Model for
Code
Scope
Define Cost
Recovery
Mechanism for Out
of Scope Codes
Define Sub-
Allocation
Mechanics for In-
Scope Codes
• Customer Bills Reflect
FERC Approved Codes
• Settlement Re-Calculations
for Customers
• High Administrative Burden
for Customers & BPA
• No Market Experience
Prior to Charge Code
Allocation
• Behavioral Signals Aligned
with Others and Low Risk
of Misalignment with EIM
• Customers Adapt to EIM
from Beginning
Criteria
Considerations:
Feasible to
Implement
Administrative
Burden
Cost
Recovery
Design
Settlement process for
majority of codes and
will require cost recovery
mechanisms
High administrative
burden for customers
and BPA
Aligns with EIM signals,
with potential limitation
on flexibility for future
allocation development
Approved sub-allocation
methodologies are the result
of other EIM entities filing
tariffs with FERC.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Detailed FERC Approved Sub-Allocation
Code
Number
Description
FERC Allocation
Method
4564
GMC EIM Transaction Charge (Schedule 1A NEVP) Measured Demand
4575
GMC Scheduling Coordinator ID Charge Measured Demand
4989
Daily Rounding Adjustment Measured Demand
4999
Monthly Rounding Adjustment Measured Demand
6045
Under/Over Schedule Load Charge Measured Demand by Direction
6046
Under/Over Schedule Load Allocation Measured Demand by Direction
6478
Real Time Imbalance Energy Offset Measured Demand
43
Sub-Allocated Codes (slide 1 of 4)
• For codes not listed, there is not a sub-allocation method assigned (see
Codes without FERC-Approved Sub-Allocation List on Slide 2)
Codes in bold are included as options for sub-allocation under the BPA-Defined Partial Sub-Allocation alternative.
For Further Charge Code Details, See CAISO Code Matrix: http://www.caiso.com/Documents/ISOChargeCodesMatrix.xls
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Detailed FERC Approved Sub-Allocation
Code
Number
Description
FERC Allocation
Method
64750
Uninstructed Imbalance Energy (Schedule 4) Direct Assignment
64600
FMM Instructed Imbalance Energy (Schedule 4, Bonneville
Interpretation)
Direct Assignment
64700
Real-Time Instructed Imbalance Energy (Schedule 4, Bonneville
Interpretation)
Direct Assignment
64770
Real Time Imbalance Energy Offset EIM Measured Demand
67740
Real Time Congestion Offset EIM Measured Demand
66200
RTM Bid Cost Recovery EIM Settlement Measured Demand
66780
Real Time Bid Cost Recovery EIM Allocation Measured Demand
69850
Real Time Marginal Losses Offset EIM Measured Demand
44
Sub-Allocated Codes (slide 2 of 4)
Codes in bold are included as options for sub-allocation under the BPA-Defined Partial Sub-Allocation alternative.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Detailed FERC Approved Sub-Allocation
Code
Number
Description
FERC Allocation
Method
7070
Flexible Ramp Forecast Movement Settlement Measured Demand
7071
Daily Flexible Ramp Up Uncertainty Capacity Settlement Measured Demand
7076
Flexible Ramp Forecast Movement Allocation Measured Demand
7077
Daily Flexible Ramp Up Uncertainty Award Allocation Measured Demand
7078
Monthly Flexible Ramp Up Uncertainty Award Allocation Measured Demand
7081
Daily Flexible Ramp Down Uncertainty Capacity Settlement Measured Demand
7087
Daily Flexible Ramp Down Uncertainty Award Allocation Measured Demand
7088
Monthly Flexible Ramp Down Uncertainty Award Allocation Measured Demand
45
Sub-Allocated Codes (slide 3 of 4)
Codes in bold are included as options for sub-allocation under the BPA-Defined Partial Sub-Allocation alternative.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Detailed FERC Approved Sub-Allocation
Code
Number
Description
FERC Allocation
Method
8989
Daily Neutrality Adjustment Measured Demand
8999
Monthly Neutrality Adjustment Measured Demand
701
Forecasting Service Fee Direct Assignment
1592
Enforcement Protocol (EP) Penalty Allocation Payment Direct Assignment
46
Sub-Allocated Codes (slide 4 of 4)
Codes in bold are included as options for sub-allocation under the BPA-Defined Partial Sub-Allocation alternative.
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Sub-Allocation Past Existing Models
Alternative
47
Sub-Allocation
Past Existing
Models
Greater than
27 Codes
Behavior Driven or
Distribution Approach
Define
Code
Scope
Define Cost
Recovery
Mechanism for Out
of Scope Codes
Define Sub-
Allocation
Mechanics for In-
Scope Codes
• Customer Bills Reflect
Additional Codes
• Settlement Re-Calculations
for Customers
• High Administrative Burden
for Customers & BPA
• No Market Experience
Prior to Charge Code
Allocation
• Behavioral Signals Aligned
with EIM and Low Risk of
Misalignment with Others
• Customers Fully Adapt to
EIM from Beginning
Criteria
Considerations:
Feasible to
Implement
Administrative
Burden
Cost
Recovery
Design
Settlement process for
majority of codes and
will require cost recovery
mechanisms
Highest amount of
administrative burden for
customers and BPA
Aligns with EIM signals
past other entities, with
potential limitation on
flexibility for future
allocation development
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Additional Codes for Sub-Allocation
Code Number Description
64740
Real Time Unaccounted for EIM Energy
Settlement
2999
Default Invoice Interest Payment
3999
Default Invoice Interest Charge
5024
Invoice Late Payment Penalty
5025
Financial Security Posting Late Payment
Penalty
5900
Shortfall Receipt Distribution
48
Codes Without FERC-Approved Sub-Allocation
• Allocation method on each of the additional codes would need to be defined, as
currently there is not a FERC-approved method for sub-allocation.
Code Number Description
5901
Shortfall Allocation Reversal
5910
Shortfall Allocation
5912
Default Loss Allocation
7989
Invoice Deviation Interest Distribution
7999
Invoice Deviation Interest Allocation
8526
Generator Interconnection Process GIP
Forfeited Deposit Allocation
Code in bold is included as an option for sub-allocation under the BPA-Defined Partial Sub-Allocation alternative.
For Further Charge Code Details, See CAISO Code Matrix: http://www.caiso.com/Documents/ISOChargeCodesMatrix.xls
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Alternative Trade-Offs
49
Level of sub-allocation requires alternative trade-
offs, with considerations to the level of:
• Precision (behavior-driven cost causation)
• Market Impacts (understanding which behaviors
drive majority of costs)
• Administrative Complexity (transparency and
volume of data)
• Data for Billing (training needs and resources to
interpret bills)
• Service Needed to Support Design (potential for
increased costs to staff the support)
B O N N E V I L L E P O W E R A D M I N I S T R A T I O N
February 25, 2020 Pre-decisional. For Discussion Purposes Only.
Next Steps
Feedback on alternatives under consideration
• Please submit to techforum@bpa.gov (with copy to
your account executive) by Tuesday, March 10
Next Charge Code Allocation Workshop: April 28
• Step 5: Discuss Customer Feedback
• Step 6: Staff Proposal
50
