WSP06848 - Laserfiche WebLink

Home Browse Search

01353 i DRAFT at the 2010 level until after the rate-setting period. By using the same depletion-suppression technique it used for the 1990 rate, Western was able to significantly lower its proposed 1995 rate. In April of 1994, the Commission developed a new depletion table and provided it for use in Reclamation's energy and capacity studies. Western alleges that use of this table "would have delayed the public process for the current rate adjustment by several additional months" (59 FR 55107). Never- theless, the Commission maintains that this is the best depletion data available and the only information that Western can justifiably use in its rate-setting process. Therefore, the Commission urges the Federal Energy Regulatory Commission (FERC) to remand Western's interim rates with the direc- tion to use the complete data in the States' July 1994 depletion tables, without depressing depletions at the 2010 level through the rate-setting period and recognizing that the States will ultimately achieve full levels of depletion. The Commission insists that Western lacks the statutory authority to "choose" which depletion data are reasonable in an attempt to suppress the power rates. As outlined above, the Colorado River Compacts grant the Upper Division States the right to develop their compact-apportioned waters "in perpetuity," without establishing a time schedule ror such development. It is the States that have the hands-on experience with .ater development/planning depletions and are the experts on the likelihood and progress of such deple- tions. Western makes the following astonishing statement about depletions: Western has determined that [its estimate of] depletions affect[sJ the firm power rate, at most, by 0.32 mills/kWh (compos- ite). The impact is small enough so that po~er rates could (and would) be adjusted to assure full repayment. if more rapid deple- 4