UNITED STATES OF AMERICA

U.S. DEPARTMENT OF ENERGY

BEFORE THE

BONNEVILLE POWER ADMINISTRATION

Proposed Safety-Net Cost Recovery )

Adjustment Clause Adjustment to ) BPA Docket No.: SN-03

2002 Wholesale Power Rates )

INITIAL BRIEF

OF

PNGC GROUP (PN)

Pacific Northwest Generating Cooperative, Blachly-Lane County
Cooperative Electric Association, Central Electric Cooperative, Inc.,
Clearwater Power Company, Consumers Power, Inc., Coos-Curry Electric
Cooperative, Inc., Douglas Electric Cooperative, Inc., Fall River Rural
Electric Cooperative, Inc., Lane Electric Cooperative, Inc., Lost River
Electric Cooperative, Inc., Northern Lights, Inc., Okanogan County
Electric Cooperative, Inc., Raft River Rural Electric Cooperative, Inc.,
Salmon River Electric Cooperative, Inc., Umatilla Electric Cooperative
Association, West Oregon Electric Cooperative, Inc.

R. Erick Johnson

R. Erick Johnson PC

888 SW Fifth Av, Ste 870

Portland, OR 97204-2022

Phone: 503.295.2944

Fax: 503.295.1163

E-mail: <Erick_Johnson@PNGC.com>

Attorney for the

PNGC Group

May 23, 2003

#### TABLE OF CONTENTS

[Contents]{.underline} [Page]{.underline}

TABLE OF
AUTHORITIES.....................................................................\...ii

I.  INTRODUCTION.....................................................................
    .....1

II. STATEMENT OF THE PNGC GROUP's CASE..............
    ........................1

III. ISSUES AND
     ARGUMENT................................................\...............2

     A.  Should BPA have initiated this SN CRAC proceeding, and should
         BPA now withdraw the SN CRAC
         proceeding?................................................2

         1.  Did BPA improperly trigger the SN CRAC, relying on an
             outdated model in forecasting secondary revenues that
             resulted in an unreliable, flawed
             forecast?......................................................\...........2

         2.  Can the Region's retail customers absorb yet another BPA
             rate increase without a severe risk of loss of
             jobs?...........................\...3

         3.  Does BPA owe the Region a responsibility to cut its costs
             before it imposes an SN CRAC rate
             increase?........................................3

     B.  Should BPA employ available liquidity tools to avoid imposing
         an SN CRAC
         charge?.................................................................................\...5

     C.  If an SN CRAC is imposed, should it be a one-year or multi-year
         charge?.....8

     D.  If an SN CRAC is imposed, what should it be in FY 2004?
         .....................9

     E.  If an SN CRAC is imposed for years beyond FY 2004, what should
         it be? ...9

     F.  Should BPA have conducted a § 7(b)(2) rate test as part of the
         SN-03 rate proceeding?
         ................................................\.............................10

     G.  Should BPA impose an SN CRAC in order to accumulate reserves
         and hedge for uncertainty?
         ........................................................................10

IV. SUMMARY OF
    CONCLUSIONS......................................................11

V.  PNGC GROUP FINAL EXHIBIT
    LIST.............................................\...12

**TABLE OF AUTHORITIES**

[Authorities]{.underline} [Page]{.underline}

STATUTES

16 USC
§839e(b)(2).............................................................................1,
10

16 USC
§839(2).......................................................................................3

RULES

*Procedures Governing Bonneville Power Administration Rate Hearings,*

51 Fed. Reg. 7611 (1986), Rule 1010.13
.........................................................1

####### INTRODUCTION

The PNGC Group submits this Initial Brief pursuant to the *Special Rules
of Practice to Govern These Proceedings* (Special Rules) issued on March
31, 2003 (SN-03-O-01 at p. 6), the *Procedures Governing Bonneville
Power Administration Rate Hearings,* 51 Fed. Reg. 7611 (1986)
(Procedures), Rule 1010.13, and the *Order on Initial Briefs* and the
*Order Enforcing Post-Hearing Exhibit List*, both issued May 16, 2003.

####### STATEMENT OF THE PNGC GROUP's CASE

BPA should not have initiated this SN CRAC proceeding, and BPA should
now withdraw it. BPA improperly triggered the SN CRAC by ignoring the
clear requirements of the current GRSPs. It relied on an outdated model
in forecasting secondary revenues that resulted in an unreliable, flawed
forecast. The Region's retail customers cannot absorb yet another BPA
rate increase without a severe risk of loss of jobs. BPA owes the Region
an ethical and legal responsibility to rein in its spending and reduce
its costs before imposing an SN CRAC rate increase. BPA should employ
available liquidity tools to avoid imposing an SN CRAC charge. If an SN
CRAC is imposed, it should be a one-year, not a multi-year, charge. If
an SN CRAC is imposed, for FY 2004 it should be set at zero. If an SN
CRAC is imposed for years beyond FY 2004, BPA should not attempt to set
a rate at this time. Instead, BPA should wait to determine what
hydrological, financial, load, and market conditions exist just prior to
the fiscal year in which the SN CRAC would take effect and set the
surcharge as low as possible. BPA should have conducted a § 7(b)(2) (16
USC §839e(b)(2)) rate test as part of the SN-03 rate proceeding. BPA
should not impose a SN CRAC in order to accumulate reserves and hedge
for uncertainty.

I.  **ISSUES AND ARGUMENT**

    A.  **Should BPA have initiated this SN CRAC proceeding, and should
        BPA now withdraw the SN CRAC proceeding?**

The SN CRAC is available to BPA only on specified conditions: (1) that
it has missed a Treasury payment, or (2) forecasts that it will miss its
*next* Treasury payment. *See,* Administrator's Final Record of
Decision, WP-02-A-09, Appendix, pp. 24-25 (June 2001). With respect to
the first criteria, BPA has not missed a Treasury payment. BPA's
***next*** Treasury payment is due prior to the onset of FY 2004 and BPA
has adequate liquid financial resources to make that payment. These
facts were established when BPA announced its intent to trigger this
proceeding. It is improper for BPA to rely on a dubious forecast of
missing ***future*** Treasury payments in order to justify imposing an
SN CRAC charge now. Doing so contravenes the GRSPs, which were the
subject of a negotiated settlement between BPA PBL and its customers. It
is a breach of an agreement and of faith for BPA to attempt to remake
that deal to suit its purposes now. For these reasons, the SN CRAC
proceeding was improperly triggered. That issue is to be addressed in
litigation now pending before the Ninth Circuit. Moreover, BPA's
financial outlook has substantially improved since issuance of the SN
CRAC trigger notice. BPA can and should, at least, acknowledge that the
facts do not now require imposition of an SN CRAC and withdraw this
proceeding as unnecessary.

1.  **Did BPA improperly trigger the SN CRAC, relying on an outdated
    model in forecasting secondary revenues that resulted in an
    unreliable, flawed forecast?**

With respect to the second criteria, BPA improperly forecasted that it
would miss it upcoming Treasury payment. As demonstrated in the Joint
Customers' Direct Testimony, SN-03-E-JC-01, pp. 28-46, BPA's Aurora
model contained flaws, was outdated, and produced a flawed forecast of
secondary revenues. The determination to initiate the SN CRAC
proceeding, having depended on this flawed model, is wrong. Likewise is
the continuation of the proceeding; it should be withdrawn by BPA.

2.  **Can the Region's retail customers absorb yet another BPA rate
    increase without a severe risk of loss of jobs?**

Numerous regional utility customers of BPA and of some of their major
retail customers have submitted testimony that shows that the Region
cannot afford an SN CRAC charge without placing at risk many, many jobs
in the Region. *See, e.g.,* Direct Testimony of Customer Coalition,
SN-03-E-CC-01, pp. 3:4-4:2, pp. 11-17. BPA staff's rebuttal testimony
assures the customers that BPA is sensitive to these concerns, but the
agency's vigorous defense of its initial proposal indicates that the
agency still values more highly the ability to rebuild reserves, operate
programs at high cost levels, and ensure inordinately high levels of
Treasury payment probability than that it values the economic recovery
of the Region's people and businesses who have already been subjected to
painful rate increases.

BPA can and must strike a better balance between its financial needs and
the welfare of the Region's citizens, businesses and economy.

3.  **Does BPA owe the Region a responsibility to cut its costs before
    it imposes an SN CRAC rate increase?**

BPA is bound under the Regional Power Act "to assure the Pacific
Northwest of an adequate, efficient, ***economical***, and reliable
power supply." 16 USC §839(2) \[emphasis added\]. This obligation is, of
course, one of many obligations imposed by the Regional Act on the
agency. However, it is the most fundamental one. If the power supplied
by BPA is unaffordable, all of the other benefits that Congress intended
the Regional Act to confer, are lost. Testimony by BPA's customers shows
that the agency has pushed ratepayers to their limits, economic harm is
already widespread, and further increases are extremely risky to the
economy. Imposing an SN CRAC now is contrary to BPA's statutory
obligation.

Imposing an SN CRAC now under these circumstances is simply wrong. BPA
represented to its customers, the region and FERC that the rates set in
the WP-02 proceeding were adequate to cover its costs. *See,*
WP-02-A-09, p. 10-1 (June 20, 2001). This was, of course, after the
agency withdrew its original ROD (May 2000) in the WP-02 rate case,
reopened the case, and raised rates to cover forecasted augmentation
costs, including costs that BPA unlawfully incurred for service to DSI
customers at rates subsidized by preference and priority customers.

The supplemental proceedings in WP-02 were the subject of a settlement
agreement. BPA's customers extended their good faith and trust to BPA
and agreed to modify rates to include LB CRAC, FB CRAC and SN CRAC
provisions. The customers recognized that the future was uncertain and
offered their support to BPA.

What did BPA do in response? While incurring enormous losses in market
transactions that should have been seen as a major warning sign of cost
recovery problems, BPA made ill-considered decisions like the litigation
penalty payments to PacifiCorp and Puget Sound Energy and substantially
increased its spending program. *See,* SN-03-E-CC-01, pp. 17:19-21:11;
*and,* SN-03-E-JC-01, pp. 2:8-9:4.

We take some encouragement from the agency's renunciation of including
"offsetting revenues" in describing its current internal net costs and
its recent expressions of willingness to share timely and transparent
budget and spending information with customers. However, this is merely
the start of a potentially productive effort.

BPA must reduce its controllable spending to well below FY 2001 actual
levels. BPA must gain control over certain spending that heretofore has
been considered, as a practical matter, uncontrollable. BPA asked for
and was given the trust of its customers in the 2001 WP-02 supplemental
rate proceedings settlement. That settlement was predicated on cost
levels used in the WP-02 rate proceedings to develop base rates. That
trust was not well respected. BPA must prove to its customers that their
trust will not be misplaced before the agency asks for it again.

A.  **Should BPA employ available liquidity tools to avoid imposing an
    SN CRAC charge?**

In recent weeks, BPA management has conducted workshops on liquidity
tools available to the agency for financial and cash management. On May
21, 2003, the agency and the Western Public Agencies Group ("WPAG")
filed a motion to introduce into the record of this proceeding a list of
liquidity tools available to the agency. *See,* SN-03-M-BPA/WA-25, pp.
4-5. Judge Arlow granted the motion and admitted this list into
evidence. *See,* SN-03-O-20, p. 2 (May 22, 2003). This list is the
product of extensive discussion at BPA's workshops. It does not reflect
the advantages or disadvantages of any of the tools, which may be viewed
and evaluated differently by the parties and BPA.

The PNGC Group urges the agency to employ available liquidity tools to
the fullest responsible extent ***before*** imposing an SN CRAC in FY
2004 or any subsequent year during this rate period. Recognizing that
the circumstances present at a particular time will determine which
tool(s) are most appropriate, we have categorized the currently
available liquidity tools. The first, Category A -- Most Preferred,
includes actions that BPA should implement immediately or for which all
terms and conditions for their use should promptly be established so
they are available to be implemented. The second, Category B --
Preferred, requires either more extensive actions on BPA's part or
revisions to programs that change agreements with other parties. Actions
necessary to implement them should be initiated now to establish their
availability. The third, Category C -- Less Preferred, call for actions
by third parties to solve BPA's financial problems. They should be
pursued but will be more difficult to implement and coordinate. The PNGC
Group recommends the following sequence to BPA:

# ***Category A---Most Preferred***

# **Financing Fuel Costs /Long-term assets**

> Currently, nuclear fuel for the Columbia generating station is
> expensed at a cost of about \$30 million per year. The life of a fuel
> burn at the plant is about six years. The cost of a refueling is \$90
> million. Financing the cost of fuel over the six-year burn period
> would save \$12 million per year assuming a 5% borrowing rate.

# 

# **Use of \$250m Treasury Note**

> BPA has an MOU with the Treasury that allows it to borrow up to \$250
> million for up to a two-year period. BPA has used, and could use this
> note to cover its liquidity needs. BPA is currently discussing with
> Treasury the terms and conditions of such a use of the note.
>
> **Limited Use of ENW Debt Extension Proceeds \-- \$315 in 2003**
>
> Consistent with Steve Wright's letter to the ENW board of December 11,
> 2000, BPA could deviate from the debt optimization program "under dire
> financial circumstances." It is estimated that the DOP will generate
> \$315 million in FY 2003.

## Refinance Appropriations

> As a result of the BPA Appropriations Refinancing Act of 1996, BPA
> refinanced its appropriations at an average interest rate of 6.3%.
> While this was an attractive interest rate at the time, interest rates
> are now substantially lower. Working with its customers, BPA could
> refinance this obligation. While this could be expected to take some
> time to accomplish it could substantially reduce BPA's costs. BPA has
> \$4.6 billion in appropriated debt at 6.3%. A one percent reduction in
> the interest rate on this debt would save \$46 million per year.

######### Category B---Preferred

> \$170m Bond Roll Over (1)
>
> BPA has \$170 million in short term debt that needs to be repaid in
> 2003. BPA could repay these obligations by issuing long-term debt to
> cover these payments.
>
> \$170m Bond Roll over (2)
>
> BPA has \$170 million in short term debt that needs to be repaid in
> 2003. . In combination with the ENW DOP proceeds, on 9/30/2003
> Treasury receives its scheduled Treasury payment plus an advance
> amortization payment from the DOP. This additional payment will free
> up borrowing authority for future borrowings. On 10/1/2003 BPA borrows
> \$170 million over the remaining life of the now unencumbered assets.

# 

# **Bringing Interest Savings Forward from Debt Optimization Program** 

> BPA could explore the capability of bringing the interest expense
> savings from already completed ENW DOP that accrue between now and
> 2018 into the current rate period. These interest savings average
> about between \$4 and 5 million per year though 2018. The net present
> value of these savings is approximately \$40 million at a 6% discount
> rate.

# **Treasury Repayment Flexibility**

> BPA could negotiate with the Treasury to establish repayment
> flexibility over the rate period. BPA could work with the Treasury to
> establish that BPA's scheduled repayment plan is a rate period
> commitment as opposed to a year-to-year commitment. While flexibility
> in making payments over the rate period would be allowed, BPA would
> make the Treasury whole by the end of the rate period.

######### Category C---Less Preferred

# 

# **Bond Reserve Fund Free-ups**

> BPA has third party financing arrangements with publicly owned
> utilities where bonds have been issued by these utilities and BPA has
> committed to payment of the debt service on those bonds. These bonds
> have reserve funds associated with them that could be freed up and
> generate current cash in return for surety fees and longer-term
> interest and principal payments. The estimated value of these bond
> reserve free-ups is \$23 million. Negotiations would have to occur
> with the parties involved to accomplish this. BPA would need to secure
> insurance to replace bond fund reserves.

# **Voluntary prepayment of customer bills**

> BPA's customer could provide BPA liquidity by prepaying their bills
> for October in September. This would provide BPA with the cash it
> needs to make its Treasury payments by fiscal year end.

## Customer Commitments

> BPA's customers would commit to paying any shortfall at fiscal year
> end in order to help BPA meet its repayment obligations. This could
> take the form of letters of credit from customers with the conditions
> stated therein as to when it could be used

######## If an SN CRAC is imposed, should it be a one-year or multi-year charge? 

As discussed above, BPA should not have initiated this proceeding
because its analysis supporting the determination to initiate it was
deeply flawed. We understand that BPA disagrees, but major improvements
in forecasted runoff, improved market conditions, and BPA's recent
commitment to cut its internal costs below actual FY 2001 levels are
material changes that make imposition of an SN CRAC for FY 2004 entirely
unnecessary. These changes in circumstances also demonstrate the
profound error of BPA's proposal to impose a multi-year SN CRAC.

Although not officially a part of the record in this case, the elephant
in the BPA Rates Hearing Room is the reality that the agency does not
want to raise rates in a Presidential election year. This is eminently
understandable. Indeed, the agency's staff has made many creative
arguments trying to support a multi-year SN CRAC, offering
contingencies, variability, and expressing assurances that BPA would
lower a contingent and variable SN CRAC that later appears to have been
set too high in this proceeding.

This approach is not supported by the PNGC Group and many other
customers because it will exacerbate an already dismal economic
situation in the Region. It is evident that the agency seeks to
substantially reduce the possibility of future rate increases by holding
FY 2004 rates above what current BPA financial results dictate. In
contrast, our primary concern is to help employees and businesses merely
survive to see the out years.

If an SN CRAC is imposed, it should be limited to one year. The simple
truth is that preserving jobs and communities in the Region is more
important than further enhancing BPA's own financial position. BPA's
assurances about rates being reduced under a contingent and variable SN
CRAC are unconvincing. A demonstrably unnecessary rate increase this
year, when the Region is suffering with the nation's worst regional
economy and the highest unemployment, caused in part by previous BPA
rate increases, will have negative political ***and*** economic impacts.
In these times, the wise balance to be struck is in favor of the near
term interests of jobs, communities, and economic health in this region.

B.  **If an SN CRAC is imposed, what should it be in FY 2004?**

In light of:

-   vastly improved runoff conditions,

-   reasonable market prices,

-   BPA forecasts of year-end FY 2003 net revenues ***hundreds of
    millions of dollars higher than forecasted*** when this SN CRAC
    proceeding was initiated,

-   numerous available liquidity tools,

-   the depressed state of the Northwest economy and high unemployment
    rates, and

-   the pain and disruption that will inevitably be inflicted by another
    rate increase,

BPA certainly does not need an SN CRAC recovery greater than 0% for FY
2004, and it would be unwise and irresponsible for BPA to impose one.

A.  **If an SN CRAC is imposed for years beyond FY 2004, what should it
    be?**

As discussed above, BPA does not need an SN CRAC for FY 2004. If any SN
CRAC is imposed, it should be only for one year, and due to
circumstances now prevailing, it should be set at 0%. If an SN CRAC is
imposed for years beyond FY 2004, BPA should not attempt to set a rate
at this time. Instead, BPA should wait to determine what hydrological,
financial, load, and market conditions exist just prior to the fiscal
year in which the SN CRAC would take effect and set the surcharge as low
as possible. The changes in those circumstances that have occurred since
the inception of this proceeding demonstrate that out year SN CRAC
charges cannot accurately be forecast. In addition, establishing such a
figure serves no interest of the region. Doing so will depress forecasts
for the economy, deter investment and risk-taking by existing and
prospective employers, and generally make a bad economic and employment
picture much worse.

B.  **Should BPA have conducted a § 7(b)(2) rate test as part of the
    SN-03 rate proceeding?**

    BPA should have conducted a §7(b)(2) (16 USC §839e(b)(2)) rate test
    as part of this proceeding. The PNGC Group joins in the arguments on
    this point of the Public Power Council and the Idaho Energy
    Authority, *see,* SN-03-B-PP-01, the Canby Utility Board, *see,*
    SN-03-B-CA-01, and the Springfield Utility Board, *see,*
    SN-03-B-SP-01.

C.  **Should BPA impose an SN CRAC in order to accumulate reserves and
    hedge for uncertainty?**

BPA should not impose an SN CRAC in order to accumulate reserves and
hedge for uncertainty. An SN CRAC imposed for legitimate reasons should
not be set higher to permit accumulation of reserves or to create a
hedge against uncertainty. The PNGC Group joins in the arguments on this
point of the Public Power Council and the Idaho Energy Authority, *see,*
SN-03-B-PP-01.

BPA should not place its financial comfort and security above the
interests of the retail ratepayers of the Region, despite greatly
improved runoff forecasts and market conditions. BPA faces no material
risk of missing a Treasury payment at this time. BPA has ample means to
manage its financial obligations with the liquidity tools available to
it.

####### SUMMARY OF CONCLUSIONS

BPA did not need, does not need, and should not impose at this time any
SN CRAC charge in FY 2004 or thereafter in this rate period. BPA must
get closer to its customers, earn their trust, and be far more receptive
to concerns expressed about the impact of any further rate increases on
retail customers and the economy in the Northwest.

BPA wants to engage in "prudent" financial management, but what is
prudent under circumstances now prevailing is in the eye of the
beholder. Under BPA's SN CRAC proposal, BPA beholds a future where its
financial fortunes are subject to zero risk by virtue of collecting more
revenue in the near-term that is required. It avoids pressure to
strictly manage its costs and or advocate for system operations that are
fully cost-effective. Much of the rationale, while not explicitly
stated, boils down to a view of the politics rather than being justified
by numbers.

BPA's customers live in a time and behold a future where their
communities' economic growth and prosperity are memories, businesses are
downsizing or shutting down, and electrical service to families and
elderly citizens must be disconnected for non-payment. A substantial
reduction in wholesale power rates looks "prudent" to BPA's customers.

Acting on an opportunity to prevent more job losses now is more
important than avoiding the risk of having to raise rates later. BPA's
rates are much too high now. BPA does not need a rate increase. The
Region cannot afford an SN CRAC surcharge. It would not be prudent, by
any reasonable measure, to impose one.

####### PNGC GROUP FINAL EXHIBIT LIST

The PNGC Group sponsored testimony and offered documentary evidence in
this proceeding together with three groups: (a) the Customer Coalition
(CC), (b) the Joint Customers (JC), and (c) the Public Power Council and
the Idaho Energy Authority (PP).

A.  **List of Testimony and Exhibits Sponsored by PNGC Group Together
    with the Customer Coalition**

Testimony SN-03-E-CC-01 Direct Testimony of Davis Faddis, Steve Eldrige,
Jack Speer, and Lincoln Wolverton

Exhibits SN-03-Q-AI-01 Qualification Statement of Jack Speer

SN-03-Q-IN-01 Qualification Statement of David J. Faddis

SN-03-Q-IN-02 Qualification Statement of Lincoln Wolverton

SN-03-Q-PN-01 Qualification Statement of Steve Eldrige

SN-03-E-CC-01A ENW Debt Restructuring Results dated February 13, 2003
(PDF)

SN-03-E-CC-01B Letter From the BPA Administrator to Customers dated
March 26, 2003 (PDF)

SN-03-E-CC-01C BPA Response to Data Request SN-03-GE-BPA-005 (Word)

SN-03-E-CC-01D BPA Response to Data Request SN-03-GE-BPA-005C, excerpts
from Energy Northwest Official Statement (PDF)

SN-03-E-CC-01E Trigger Case With \$315 Million (Excel)

SN-03-E-CC-01F May 2000 Rate Documentation, WP-02-FS-BPA-05A at 366
(Word)

SN-03-E-CC-01G BPA Response to Data Request SN-03-AL-GN-BPA-005 (Word)

SN-03-E-CC-01H BPA Response to Data Request SN-03-AL-GN-BPA-006 (Word)

SN-03-E-CC-01I Oregonian Article dated April 4, 2003 (Word)

SN-03-E-CC-01J Oregonian Article dated April 17, 2003 (Word)

SN-03-E-CC-01K Press Release from the Oregon Employment Department dated
April 11, 2003 (Word)

SN-03-E-CC-01L Clearing Up Article dated April 14, 2003\--Bearing Down
(PDF)

SN-03-E-CC-01M National Association of Manufacturers Report---Montana
(PDF)

SN-03-E-CC-01N National Association of Manufacturers Report-Oregon (PDF)

SN-03-E-CC-01O National Association of Manufactures Report-Idaho (PDF)

SN-03-E-CC-01P National Association of Manufacturers Report---Washington
(PDF)

SN-03-E-CC-01Q BPA Response to Data Request SN-03-IN-BPA-015 (Word)

SN-03-E-CC-01R BPA Response to Data Request SN-03-CR-BPA-095 (Word)

SN-03-E-CC-01S BPA Response to Data Request SN-03-CR-BPA-115 (Word)

SN-03-E-CC-01T Kimberly Clark Comparison of Power Costs (PowerPoint)

SN-03-E-CC-01U Worldwide Comparison of Power Costs to Aluminum Smelters
(Excel)

SN-03-E-CC-01V Clearing Up Article dated March 31, 2003 (PDF)

SN-03-E-CC-01W BPA Journal dated April 2003 (PDF)

SN-03-E-CC-1X Summary Augmentation Data from February 18, 2003 Workshop
(PDF)

SN-03-E-CC-01Y BPA Response to Data Request SN-03-Al-GN-BPA-002 (Word)

SN-03-E-CC-01Z BPA Response to Data Request SN-03-IN-BPA-045 (Word)

SN-03-E-CC-01AA BPA Response to Data Request SN-03-IN-BPA-045A (Word)

SN-03-E-CC-01BB BPA Response to Data Request SN-03-IN-BPA-045B (Word)

SN-03-E-CC-01CC BPA Response to Data Request SN-03-IN-BPA-021 (Word)

SN-03-E-CC-01DD BPA Response to Data Request SN-03-IN-BPA-021A.xls
(Excel)

SN-03-E-CC-01EE Excerpt from ToolKit Model Run for SN CRAC proposal tab
CRAC_DATA, summary sheet which is at SN-03-E-BPA-02 at page 7 -1 (PDF)

Testimony SN-03-E-CC-02 Rebuttal Testimony of David Faddis, Steve
Eldrige, Jack Speer, and Lincoln Wolverton

Exhibit SN-03-E-CC-02A Exhibit 1

B.  **List of Testimony and Exhibits Sponsored by PNGC Group Together
    with the Joint Customers**

Testimony SN-03-E-JC-01 Direct Testimony of Raymond Bliven, Geoffrey
Carr, Kevin O\'Meara

Exhibits SN-03-Q-JC-01-03 Qualification Statements of Raymond Bliven,
Geoffrey Carr, Kevin O\'Meara

SN-03-E-JC-01A Data Response- Data Request SP-BPA-001A

SN-03-E-JC-01B-D Data Response- Data Request SP-BPA-001A

SN-03-E-JC-01E Nov. 22, 2002 Letter to BPA customers, tribes, and
interested parties

SN-03-E-JC-01F March 7, 2003 Workshop Handout

SN-03-E-JC-01G Dec. 11, 2000 Letter to Energy NW

SN-03-E-JC-01H Debt Restructuring Results to Date

SN-03-E-JC-01I Data Response-Data Request NR-BPA:001

SN-03-E-JC-01J Toolkit Results

SN-03-E-JC-01K Data Response- Data Request NR-BPA:002

SN-03-E-JC-01L Data Response - Data Request PP-BPA-011

SN-03-E-JC-01M SN CRAC ANR - Reserve Level Thresholds

SN-03-E-JC-01(E1) Errata to the Direct Testimony of the Joint Customers

Testimony SN-03-E-JC-02 Rebuttal Testimony of the Joint Customers

C.  **List of Testimony and Exhibits Sponsored by PNGC Group Together
    with the Public Power Council, et al.**

Testimony SN-03-E-PP-01 Direct Testimony of Rick Crinklaw, Kenneth
Sugden, and Steve Loveland

Exhibits SN-03-Q-PP-01-03 Qualification Statements for Rick Crinklaw,
Kenneth Sugden, and Steve Loveland; SN-03-Q-PP-01-03

SN-03-E-PP-01_doc.pdf PDF version of above Word document

SN-03-E-PP-01(E1) Erratum to the Direct Testimony of PPC, PNGC, IDEA;
SN-03-E-PP-01

Respectfully submitted this 23^rd^ day of May, 2003.

> R. Erick Johnson PC
>
> By: [*/s/ R. Erick Johnson*]{.underline}
>
> R. Erick Johnson
>
> Attorney for PNGC Power