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<br />~ <br /> <br />~ <br /> <br />01442.. <br /> <br />Data was also available that showed Tri-State using as much regulation as Loveland. <br />Tri-State only pays for 6 MWs of regulation. Therefore, Tri-State is using CRSP <br />capacity and not paying a market rate for regulating services that amounts to <br />approximately 50 MWs. <br /> <br />CRSP's large electric customers compelling WAPA to ignore FERC NOPR <br /> <br />The Federal Regulatory Commission would require all utilities under its Notice of <br />Proposed Rule Making to offer the full range of utility services at the same charge a <br />utility would charge itself. FERC intended the NOPR to force utilities to "unbudle" their <br />services. In other words, price each service separably. For CRSP this would mean all <br />services that now carry one charge will be charged separately. Typical services that <br />are sometimes called ancillary services, are shown below: <br /> <br />. Load regulating services <br />. Firm and Non-firm transmission services <br />. Network wheeling services <br />. Reserves <br />. Voltage regulation <br />. System protection <br /> <br />For CRSP this is a revenue opportunity. CRSP can charge market based prices for <br />many of its short-term and seasonal surpluses. Historically, CRSP has sold its <br />surpluses at market-based prices whenever possible. Recently, however, It has been <br />a constant battle to sell any CRSP surpluses to third parties because of opposition by <br />the larger CRSP customers. These customers want surpluses sold exclusively to them <br />and at below market prices. This has created a situation were the smaller CRSP <br />customers, who are in many cases unable to obtain these surpluses, would rather have <br />CRSP sell to third parties and the resulting revenue used to hold CRSP costs down. <br />This latter method of equally sharing the costs and the benefits of CRSP is what many <br />believe is one of the many socialized benefits and original designs of CRSP. <br /> <br />As mentioned previously, the larger CRSP customers would rather have CRSP locked <br />up exclusively for their benefit. This exclusion would be harmful to the smaller CRSP <br />electric customers and the water interests. CRSP must be able now and in the future <br />have the.mandate to maximize revenue for the benefit of all CRSP whether done under <br />NOPR or by other means. Dangerously, WAPA is letting larger customers influence its <br />role as a Federal Resource Manager to create a caste system within CRSP, <br /> <br />6 <br />