Bonneville’s transmission customers can compensate BPA for transmission losses through financial settlement or by returning power to BPA. In the Spring of 2017, BPA unilaterally decided it could force its customers to keep the energy they planned to deliver to BPA through “mandatory waivers” of those real power loss returns during oversupply conditions. While BPA was able to save customers facing oversupply costs over $1 million, BPA shifted much of that cost savings to other customers who were forced to dump suddenly surplus energy into a negative pricing market. In order to effectuate this cost shift, BPA had to forget its representations to FERC and the region that it would pursue only mutually agreeable waivers of loss returns. To better understand why BPA’s implementation of mandatory waivers was an overreach and why BPA should reconsider its negative pricing policy and cost allocation under its Oversupply Management Protocol, feel free to contact me and I’ll forward you a copy of the letter I drafted for NIPPC on this issue.