Appropriate Use of TSR Renewal Rights

  • As part of customers exercising the Right of First Refusal (ROFR) under BPA’s Tariff of existing Transmission Service Requests (TSR), BPA has recently observed the batching of multiple renewal TSRs that vary in MW amounts yet are identical in term duration.

  • The intention of these actions appears to utilize BPA’s 30-day competition evaluation time limit and practice of serially competing requests in queue order to evade competition of some portion of the existing TSR’s ROFR. Such behavior has the potential to create harmful impacts to BPA’s ability to efficiently and equitably manage its transmission product offerings pursuant to its tariff.

  • BPA expects customers to submit TSR renewals that follow competitive, best practices. If BPA perceives that customers are engaging in anti-competitive behavior, we reserve the right to take actions to correct or mitigate the impacts of such behavior.