bpa rate case seasonal rates forwarded mary hain hou ect 03 14 2000 08 48 enron capital minnesota power light co opinion 12 issued april 14 1978 mimeo 24 5 65 229 cases commission rejected rate design features evidence record showing rate design features reflected cost incurrence id order setting proceeding hearing commission took note edison proposed seasonal differential specifically directed parties fully address issues related cost support seasonal rate design commission order issued march 30 1979 mimeo 4 5 october 9 1980 parties directed presiding judge identify initial briefs portions record relate cost support seasonal differential requirement edison provide cost support seasonal differential discussed supra also set forth commission filing requirements rate schedules rate design intended reflect costs applicant must show reflects costs rate design intended reflect costs applicant must justify departure costbased rates 18 cfr 35 13 b 4 iii statement p edison seasonal differential intended lessen costs imposed upon prominent summer peak edison reasons since must build capacity meet prominent summer peak charging summer would give customers incentive control summer demands therefore edison cost adding capacity would reduced tr 169 accordingly edison must show seasonal differential reflects costs imposed summer demand commission filing requirements 18 cfr 35 13 b 4 iii statement p even purpa section 111 4 relied upon edison states rates shall seasonal basis reflects costs providing service class consumers different seasons year extent costs vary seasonally utility emphasis added support relying marginal rather average costs comes commission order march 30 1979 setting cause hearing mimeo 4 5 commission commenting time day seasonal rates mentioned encourage innovative rate design match closely rates costs regard commission cited order 537 supra 4 specifically suggests use pricing mechanisms based marginal cost principles 65 236 jurisdictional wholesale sales circumstances case sale economy energy related edison costs adding eliminating additional excess capacity appropriate establish price economy transactions marginal costs provides close matching rate cost would rate design based average costs accordingly winnetka position pricing economy energy adopted affirmed reversed see next paragraph comm opinion order 23 ferc 61 219 commonwealth edison company docket nos er 79 182 000 er 80 106 000 may 12 1983 turning commonwealth exceptions find judge correctly rejected seasonal differential even accept company interpretation purpa still cited record evidence whatsoever difference costs summer nonsummer months without least showing cost difference impossible make judgment reasonableness company 15 25 proposal therefore uphold judge point reverse judge adoption price set 110 utility incremental costs however approve type b split savings method proposed commonwealth method economy transactions arranged 12 hour similar period fixed price based cost estimates time agreement utility incremental costs rise point continued supply would become burdensome utility may terminate supply find method superior proposed staff implementation greatly simplified cost determinations need made frequently related pmas reg preamble fercsr 36 710 procedures public participation power transmission rate adjustments extensions december 31 1980 10 cfr 903 45 fr 86976 36 741 historically many purpa type standards used designing wholesale rates sale federal hydroelectric power pmas analyze costs establish revenue requirements consider information designing rates declining block rates energy used pmas subsequently found inappropriate eliminated rate schedules many pmas years effectively using various forms load management measures rate schedules scheduling limitations loadshaping capacity energy overrun charges etc bpa history using seasonal rates wholesale firm capacity energy also offered direct service industrial customers interruptible rates time ago southwestern interruptible capacity rates effect since 1957 examples demonstrate willingness pmas implement purpa type standards applicable many purpa type standards applied appropriately design pma rates serve implement purposes purpa encouraging conservation energy efficient use resources facilities equitable rates public participation process provide opportunity examine appropriate concepts pmas continue review revise power marketing practices system system basis serve purpa objectives assistant secretary resource applications working administrators power administrations receiving public comment consider adoption rate design guidelines similar form guidelines ra 6120 2 financial accounting ratemaking reflect experience gained pmas system system approach rate design related purpa fed law fercsr 5021 purpa sec 111 consideration determination respecting certain ratemaking standards 4 seasonal rates rates charged electric utility providing electric service class electric consumers shall seasonal basis reflects costs providing service class consumers different seasons year extent costs vary seasonally utility fed reg notice fercsr 37 503 doe responsibilities title purpa 4 seasonal rates shall established costs vary season prop reg preamble fercsr 1988 1998 32 457 administrative determination full avoided costs sales power qualifying facilities inter connection facilities march 16 1988 docket rm 88 6 000 53 fr 9331 55 fr 31882 pricing flexibility may take several different forms instance contract could provide qfs price floor applicable power supplied utility still provide higher variable unit prices reflecting daily seasonal periods price floor would provide revenue stream necessary qf secure financial support 32 174 price variability would induce qf maximize deliveries peak load periods utility values additional supplies course price floor exceed minimum value utility avoided cost similarly contract could provide two part price fixed payment capacity energy price power delivered qf would assured minimum revenue stream based value capacity variable energy component would allow utility dispatch qf capacity economic whatever pattern contract payments rates purchases qfs always reflect well characteristics suppliers power match purchasing utility need ensure qf make production decisions basis rates reflecting avoided costs rather guaranteed average rate time receive revenues sufficient attract investors avoid problems associated take pay contracts natural gas industry commission wishes stress danger including forecasted fuel costs fixed rate structure long term contracts especially combination specification minimum purchase quantities commission also encourages use time day seasonal rates flexible pricing structures long term contracts reg preamble fercsr 1977 1981 30 128 small power production cogeneration facilities regulations implementing section 210 public utility regulatory policies act 1978 order 69 february 25 1980 docket rm 79 55 18 cfr 292 45 fr 12214 45 fr rather specifying exact time day seasonal rates purchases required however commission believes selection methodology best left state regulatory authorities nonregulated electric utilities charged implementation provisions