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CANBY UTILITY BOARD 



154 N.W FIRST AVENUE ■ P.O BOX 1070 ■ CANBY. OREGON 97013 



PHONE (503)266-1156 



FAX (5031 263-8621 



n PAYS TO OWN THE UTILITY THAT S€R\/£S YOU 



March 10, 1993 



Jo Ann Scott, Manager 

 Public Involvement Section 

 Bonneville Power Administration 

 P.O. Box 3621 

 Portland, OR 97208 



SUB.rECT: Participant Comments 



Bonneville Wholesale Power Rate Proceeding 

 Docket WP-93 and TR-93 



Dear Ms. Scott: 



The Canby Utility Board, which serves residential, commercial and industrial customers in 

 Canby, Oregon, submits the following participant comments regarding the 1993 Bonneville 

 wholesale power rate proceeding. 



We are generally concerned about the size of the proposed rate increase (11.6 percent) for the 

 same reasons that many other Bonneville preference customers are also concerned. I am writing 

 to raise a specific objection to the way that Bonneville values reserves provided by the Direct 

 Service Industrial (DSI) customers. 



The value that Bonneville has assigned to DSI reserves ~ 2.43 mills, equivalent to $59 million 

 as an annual credit to these industrial customers - appears to be based on faulty and out-of-date 

 assumptions. 



The Canby Utility Board believes Bonneville is under a legal obligation to its customers to revise 

 this number in light of several changing circumstances. At stake is between $15 and $41 million 

 in increased DSI revenue and commensurate decreases in preference revenue. 



Bonneville last valued the DSI reserves in 1985, when it conducted its first and only Value of 

 Reserves (VOR) analysis. The VOR was intended to place a value on three types of reserves 

 (forced outage, plant delay and system stability). 



These reserves are provided by series of restriction rights in the DSI's 20-year power sales 

 contracts with Bonneville. The restriction rights give Bonneville the right to interrupt the DSIs 

 at certain times and under certain conditions, thus providing reserves for Bonneville that it 



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