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Commissioner Tony Clark Statement
June 20, 2013
Docket Nos. ER13-93-000, ER13-94-000, ER13-98-000, ER13-99-000, ER13-836-000 & NJ13-1-000
Item No. E-1

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ColumbiaGrids’s Order 1000 Compliance Filings

“This order rejects key elements of the Filing Parties Order No. 1000 compliance filings related to transmission planning and cost allocation for utilities serving the Pacific Northwest. I dissent because I would have, in large part, accepted the filings.

“The Commission has stressed throughout the Order No. 1000 process that flexibility and respect for regional differences would be a hallmark of this undertaking. I believe this order runs afoul of that stated principle. The Pacific Northwest is a unique region of the United States as it pertains to transmission planning. Approximately 75 percent of the transmission service in the region is provided by one entity: the Bonneville Power Administration (Bonneville), a federal agency that the Commission cannot compel to participate in the Order No. 1000 regime. Jurisdictional and non-jurisdictional utilities in this region have been planning together through ColumbiaGrid since 2006. In the compliance filings, these entities propose to continue this planning process while incorporating key elements of Order No. 1000. While Bonneville is either unable or unwilling to commit to the sort of binding cost allocation envisioned by Order No. 1000, I view these filings as a best effort to comply with the spirit of Order No. 1000, while acknowledging the reality of the transmission grid in the Pacific Northwest.

“Substantially accepting the filing would allow those much smaller jurisdictional utilities that are deeply embedded within the Bonneville region to effectively participate in an “Order No. 1000-like” process along with Bonneville and other non-jurisdictional utilities. By rejecting key elements of this filing, I am concerned that we may do more harm than good in this region. I hope that Bonneville will find a way to continue to participate, but by failing to accommodate the region’s unique characteristics, this order may cause the region to fracture, and thereby strand a number of jurisdictional utilities for purposes of Order No. 1000 planning. How those utilities would proceed under such a scenario, I do not know, for it is hard to contemplate an effective regional planning effort that ignores the reality of a region dominated by one non-jurisdictional transmission provider.

“Therefore, I respectfully dissent.”