Title: Western Area Power Administration
1 Western Area Power Administration
- Rocky Mountain Region
- Customer Meeting - October 30, 2002
- Standard Market Design and Regional Transmission
Organizations Updates - Jane Meyer, Ron Moulton, Mark Fidrych, Bob
Easton, - Jeff Ackerman, Ed Hulls, Bob Kennedy
2Agenda
- Overview of Standard Market Design
- Overview of WestConnect Ruling
- Overview of RTO West Ruling
- How will the scheduling process change?
- Will transmission rights change?
- What could happen to existing contracts?
3Agenda (Cont.)
- Will the cost of transmission change?
- How could the planning process change?
- How is Westerns merchant preparing for possible
changes? - How is Westerns control area preparing for
possible changes? - Locational Marginal Pricing (LMP) Overview
4Standard Market Design Overview
- Jane Meyer
- Restructuring Project Manager
- RMR CRSP
5FERC believes Standard Market Design is Needed
- FERCs goal is to promote economic efficiency in
electricity for the benefit of all Americans - Order 888 in 1996
- Required all public utilities to
- file open access non-discriminatory transmission
tariffs - Functionally unbundle wholesale power services
from transmission services - Imposed a reciprocity condition for non-public
utilities
6FERC believes Standard Market Design is Needed
- Order 2000
- Encouraged all transmission owners to voluntarily
place their transmission facilities in the hands
of Regional Transmission Organizations (RTO) - Industry has been working toward that goal
- Independent System Operators (ISO) formed in
California, New York, New England, PJM, and ERCOT - RTOs formed in Midwest (MISO), Southeast
(SETrans), Southwest (WestConnect), and Northwest
(RTO West)
7FERC believes Standard Market Design is Needed
- FERC issued Notice of Proposed Rulemaking (NOPR)
- July 31, 2002 - Long name Remedying Undue Discrimination
through Open Access Transmission Service and
Standard Electricity Market Design - FERC Docket No. RM01-12-000
- http//www.ferc.gov/Electric/RTO/Mrkt-Strct-commen
ts/smd.htm
8FERC believes Standard Market Design is Needed
- FERCs Vision
- Same set of rules for all users of the grid
administered by a fair and independent entity - Eliminate Residual Discrimination
- Lower Costs to Customers
- Customer protection through market power
mitigation measures and oversight - Clear transmission pricing and planning policies
to incent investment in infrastructure - Provide a framework for effective State Federal
regulation
9Standard Market Design - Major Elements
- Independent Transmission Provider (ITP)
- New transmission tariff
- Transmission pricing reform
- Organized Day-Ahead (DA) and Real-Time (RT) spot
markets - Mitigation of market power and market monitoring
- Resource adequacy
- Regional planning process
10Independent Transmission Provider
- Jurisdictional utilities mandated to turn over
control of their transmission facilities to an
independent entity - Independent Transmission
Provider - Regional Transmission Organization (RTO)
- Independent System Operator (ISO)
- Independent Transmission Company (ITC)
11Independent Transmission Provider
- Jurisdictional utilities had three options
- Become an Independent Transmission Provider
- Cannot have financial interest, either through an
affiliate or any market participant - Contract with Independent Transmission Provider
for operational control of transmission
facilities - Join a Regional Transmission Organization
12Options for Non-jurisdictional Utilities
- SMD NOPR proposes that existing reciprocity
tariffs filed under 888 OATT will be
grandfathered - FERC requested comment on this provision
13Independent Transmission Provider
- Operates transmission facilities
- Administers Standard Market Design transmission
tariff - Transmission pricing
- Congestion management
- Administers organized spot market
- Long-term planning and expansions
- System impact and facilities studies
14Independent Transmission Provider
- Transmission transfer capability calculations
- Market monitoring and market power mitigation,
including establishing bid caps and must-offer
requirements - Establish long-term resource adequacy requirements
15New SMD Transmission Tariff
- Today - Two types of transmission service
- Network Integration Service
- Point-to-Point Service
- SMD - Network Access Service
- Characteristics of Network Integration Service -
access to all generators on the grid - Characteristics of Point-to-Point Service -
rights are tradable - Bundled retail load of jurisdictional utilities
must take transmission service under Tariff
16Transmission Pricing
- Today - Network and Point-to-Point transmission
customers pays transmission charge for embedded
costs - SMD
- Load pays embedded costs through access charge
- Load pays only one access charge for Network
Access Service - Pancaking (payment of more than one transmission
rate for delivery from source to sink) is
eliminated
17Organized Spot Markets
- Independent Transmission Provider must operate
day-ahead and real-time markets for energy and
ancillary services, in conjunction with the
transmission market - Voluntary, bid-based, security-constrained
day-ahead spot energy market
18Organized Spot Market
- NOPR includes the use of Locational Marginal
Pricing (LMP) of energy and congestion in both
day-ahead and real-time markets - NOPR includes the use of financial transmission
rights to assure that transmission is used by
those entities that value the transmission the
most - Congestion Revenue Rights
19Market Monitoring
- NOPR lays out framework
- Independent market monitoring unit
- Evaluates state of market
- Identifies need for changes in market rules
- Identifies load pockets areas where
infrastructure is needed for competition - Reports to FERC, Regional State Advisory
Committee, and Board of Directors
20Resource Adequacy Requirements
- Long-term Resource Planning will be policed by
independent Transmission Provider - Mandate load serving entities to provide their
share of resources through own resources and
contract purchases - Guard against over reliance on spot markets
- Assure that there are adequate transmission,
generation, and demand-side resources
21Reaction by Industry
- Western Governors
- FERC should specifically set aside the Western
Interconnection from its SMD rule and concentrate
on working with the states to develop RTOs that
address the specific problems in the Western
Interconnection. This process should begin with
a well-defined and factually-supported statement
of the problems in the Western Interconnection.
(September 17, 2002)
22Reaction by Industry
- Northwest Congressional Delegation
- In short, we believe this is an unnecessary,
poorly conceived and dangerous academic
experiment that would inject volatility and
uncertainty into the comparatively stable and
affordable energy system in the Northwest. We
would urge the Commission to abandon the
proposal. (September 27, 2002)
23Reaction by Industry
- Senate Energy and Natural Resources Committee
hearing September 17, 2002 - Senators were uniformly critical.
- Only two of the nine witnesses supported the
proposed SMD rule. - Kentucky Governor Patton slammed the proposed
rule, saying it fails the test of adopting
policies that are in the best interests of the
entire nation.
24SMD Comments Due
- The Commission extended comment period to
November 15, 2002, except for comments which
address the following - (1) market design for the Western
Interconnection (2) transmission planning and
pricing, including participant funding (3)
Regional State Advisory Committees and state
participation (4) resource adequacy and (5)
CRRs and transition issues - Comments dealing with the issues are due January
10, 2003
25Western Review of SMD NOPR
- Organized Western-wide review teams to develop
responses/positions to questions in SMD NOPR - Coordinating with BPA and DOE
- Customer comments input welcome
- Bulk of Westerns comments will be submitted in
January
26SMD Delayed
- Final rule delayed until next summer
- In the meantime, RTOs have been approved and
market designs are being developed by the
stakeholders
27RTOs in the West
28Overview of WestConnect Ruling
- Jurisdictional Participants (Applicants)
- Arizona Public Service Company
- El Paso Electric Company
- Public Service Company of New Mexico
- Tucson Electric Power Company
- Non-Jurisdictional Participants (Involved to
varying degrees) - Salt River Project
- Western Area Power Administration
- Southwest Transmission Cooperative, Inc. (AEPCO)
- Tri-State GT Association, Inc.
- Website http//wwwwestconnectrto.com
29Overview of WestConnect Ruling
- Requested Declaratory Order - October 16, 2001
- FERC Ruled - October 10, 2002
- Approved scope
- Approved governance structure
- Approved license plate rate for an interim period
- Approved voluntary conversion of existing
contracts - Requested more details about self-tracking
30Overview of WestConnect Ruling
- FERC Ruling (Continued)
- Approved congestion management proposal as a Day
One mechanism and directed Applicants to engage
in further discussions to develop a congestion
management program that reflects market-driven
solutions to clear congestion operations and that
does not create seams among the Western RTOs.
31Overview of WestConnect Ruling
- FERC clarified that it is not their intent to
overturn, in the final SMD rule, decisions that
are made in the WestConnect Ruling - Unclear what FERC has decided and therefore will
not be overturned - FERC was silent on many issues
- Critical items, such as congestion management,
were approved with modifications - Western needs clarification and details
32Overview of WestConnect Ruling
- Ron Moulton
- Restructuring Project Manager
- DSW
33RTOs in the West
34Overview of RTO West Ruling
- RTO West Participants
- Avista Corporation
- Bonneville Power Administration
- Idaho Power Company
- NorthWestern Energy L.L.C. (formerly Montana
Power Co.) - PacifiCorp
- Puget Sound Energy, Inc.
- TransConnect ITC
- Nevada Power Co., Sierra Pacific Power, Co.,
Portland General Electric - British Columbia Hydro and Power Authority
35Overview of RTO West Ruling
- Stage 2 Filing - March 29, 2002
- Request For Declaratory Order
- Attachments
- Pricing, Congestion Management, Transmission
Planning, Market Monitoring . . . - Agreements
- Transmission Owners Agreement, Scheduling
Coordinator Agreement, Paying Agent Agreement - Implementation Plan (June 28, 2002)
- Operational 2006
36Overview of RTO West Ruling
- FERC Ruled - September 18, 2002
- Approved Scope Governance
- Approved License Plate Pricing Transition
Period (8 Yrs) - Conditionally Approved Congestion Management
- Approved Voluntary Contract Conversion
- Approved Planning Expansion
- Approved Framework for Interregional Coordination
37Overview of RTO West Ruling
- FERC Ruling (Continued)
- Rejected TOA Trumps Tariff
- Defers Addressing TOA Until Tariff Complete
- Directs Applicants to File Tariff (120 days)
- Directs Development of Standards of
Interconnection - Conditionally Approves Market Monitoring Proposal
- Will Not Overturn with SMD Final Rule
38Overview of RTO West Ruling
- Stage 3 Activities (Oct 02 - Jan 03)
- Market Design Workgroup
- Market Operations
- Ancillary Services
- Cataloguing/Options
- Losses
- Metering, Control Communications
- Tariff Development Workgroup
- Visit http//www.rtowest.com/ for more information
39Seams Steering Group - Western Interconnection
(SSG-WI)
40Seams Steering Group - Western Interconnection
(SSG-WI)
- Steering Group (Closed)
- SSG-WI serves as the discussion forum for
facilitating the creation of a Seamless Western
Market and for proposing resolutions for issues
associated with differences in RTO practices and
procedures. - Workgroups (Open)
- Planning
- Congestion Management
- Pricing Reciprocity
- Market Monitoring
- Commons Systems Interface Coordination
41Seams Steering Group - Western Interconnection
- FERC Directed CAISO, RTO West WestConnect
(within 90 days of Order) - Codify the MOU between parties to define their
commitments and the forum by which issues will be
resolved. - Provide a list of pending issues before the
Steering Group and timeline for resolution of
those issues. - Visit http//www.ssg-wi.com/ for more information
42How Could Scheduling Process Change?
- Mark Fidrych
- Utility Restructuring Advisor
- RMR CRSP
43How Could Scheduling Process Change?
- Today (Day(s) Ahead)
- Independently or via Scheduling Agent
- Customers have various Op Agreements with Service
Providers - Forecast Needs (Determine Loads)
- Decide on Supplier(s)
- Arrange/Verify Transmission
- Submit Pre-Schedule to Control Area for System
Reliability Analysis
44How Could Scheduling Process Change?
- Today (Next Hour)
- Independently or via Scheduling Agent
- Evaluate Forecast (Incorporate Load Changes)
- Verify Supplier(s)
- Verify Transmission
- Modify Pre-Schedule
45How Could Scheduling Process Change?
- Today (Real-Time)
- Independently or via Scheduling Agent
- Respond to Contingencies/Curtailments
- Adjust Schedules
- Acquire Emergency Resources
- Interrupt Load
- Verify Delivery
46How Could Scheduling Process Change?
- SMD (Day Ahead)
- Independently or Load Serving Entity
- Network Operating Agreement with ITP
- Forecast Needs (Determine Loads)
- Determine if want price/delivery certainty
- Decide on Supplier(s)
- Bilateral Transactions
- Venture into the Day-Ahead Real-time Spot
Markets
47How Could Scheduling Process Change?
- SMD (Day Ahead)
- Designate Receipt Delivery Points
- Transmission Service Scheduled in the Day Ahead
Market - Synchronizes Energy and Transmission Schedules
- Analysis of Physically Feasible Dispatch
- Source/Sink required for Simultaneous Feasibility
Evaluation - Must hold Congestion Revenue Rights (CRR) or
Agree to Congestion Costs
48How Could Scheduling Process Change?
- SMD (Real-Time)
- Independently or Load Serving Entity
- Evaluate Forecast (Incorporate Load Changes)
- Revise Receipt and/or Delivery Points
49How Could Scheduling Process Change?
- SMD (Real-Time)
- Independently or Load Serving Entity
- Respond to Contingencies
- Interrupt Load
- Take other Emergency Actions which may be
required - Respond to Curtailments
- Should only be associated with trapped loads
- Verify Delivery
50How Could Scheduling Process Change?
- SMD Versus Today
- No Longer Required
- Load/Resource Balanced Schedule
- Transmission Reservations
- 100 of Forecasted Load Met by Resource
- Designation of Network Resources
- New Features
- Voluntary, Bid-Based Energy Markets
- Ancillary Service Bid-Based Markets
- Transmission Energy Delivery are Coupled
51How Could Scheduling Process Change?
- Differences Between SMD and RTOs In the West
- Both WestConnect and RTO West require Balanced
Schedules - Both Require a Scheduling Coordinator Function
52How Could Transmission Rights Change?
- Ron Moulton
- Restructuring Project Manager
- DSW
53How Could Transmission Rights Change?
- Today
- Physical Transmission Rights
- Network Integration
- Long-Term Firm Point-to-Point
- Short-term Non-Firm Point-to-Point
- Acquired
- OASIS
- Pre-888 Transmission Service Agreements
54How Could Transmission Rights Change?
- SMD (Financial Rights Model)
- Network Access Transmission Service
- Congestion Revenue Rights (CRR)
- Hedge Congestion Costs
- Tradable
- Obligation or Option
- Acquired
- Directly Assigned from the ITP
- Auction
- Secondary Markets
55How Could Transmission Rights Change?
- WestConnect (Physical Rights Model)
- Non-Converted Rights (NCRs)
- Firm Transmission Rights (FTRs)
- Recallable Transmission Rights (RTRs)
- Non-firm Transmission Rights (NTRs)
- Acquired
- Directly Assigned from WestConnect
- Auction
- Secondary Market
56How Could Transmission Rights Change?
- RTO West (Financial Rights Model)
- Catalogued Transmission Rights (CTRs)
- Financial Transmission Options (FTOs)
- Acquired
- Directly Assigned from RTO West
- Auction
- Secondary Market
57How could Transmission Rights Change? (Summary
Table)
58What Could Happen to Existing Contracts?
- Today
- Firm Electric Service Agreements
- Bundled (Power Transmission)
- Transmission Service Agreements
- Network Integration
- Long-term Firm Point-to-Point
- Short-term Non-Firm Point-to-Point
- Pre-888 Transmission Service Agreements
59What Could Happen to Existing Contracts?
- SMD
- All OATT Agreements Converted to Network Access
Service (NAS) - Receive CRRs (Subject to Simultaneous
Feasibility) - Pre-Order 888 Agreements Given Opportunity to
Convert to NAS - Converted
- Receive CRRs
- Non-Converted
- Transmission Owner Receives CRRs
- Transmission Owner Takes Network Access Service
to Honor Pre-Order 888 Agreements - Transmission Owner Picks Up Cost Differences
60What Could Happen to Existing Contracts?
- WestConnect
- Converted
- Receive Firm Transmission Rights
- Non-Converted
- Receives Non-Converted Rights
- WestConnect Picks Up Cost Differences in Grid
Management Charge
61What Could Happen to Existing Contracts?
- RTO West
- Converted
- Receive Financial Transmission Options
- Non-Converted
- Receives Catalogued Transmission Rights
- Transmission Owner Picks Up Cost Differences
62How will Costs Change?
- Jane Meyer
- Restructuring Project Manager
- RMR CRSP
63How will Costs Change?
- Today
- Standard Market Design
- WestConnect
- RTO West
64Costs - Today and SMD
- TODAY
- Transmission Service
- Network Integration Service
- Long-term Point-to-Point
- Short-term and non-firm Point-to-Point
- Pre-OATT arrangements
- Pay pancaked rates if use more than one system
from generator to load
- SMD
- Transmission Service
- Network Access Service (ITP)
- Pre-OATT arrangements
65Costs - Today and SMD
- TODAY
- Bilateral generation agreements
- Long-term
- Short-term
- Bundled
- Unbundled
- SMD
- Bilateral generation agreements
- Long-term
- Short-term
- Bundled
- Unbundled
- Cost of congestion under Locational Marginal
Pricing - (ITP)
66Costs - Today and SMD
- TODAY
- Spot market generation purchases
- SMD
- Day Ahead Settlement
- Real Time Settlement
- - Locational
- Marginal Price
- (LMP)
- - LMP reflects the
- cost of energy and
- congestion
- - (ITP)
-
67Costs - Today and SMD
- SMD
- Purchase and Sale of Congestion Revenue Rights
(financial hedge for cost of congestion during
Day Ahead)
68Costs - Today and SMD
- TODAY
- Ancillary Services
- - Scheduling and Dispatch
- - VAR Support
- Regulation
- Energy Imbalance
- Reserves
- Self provide or purchase from Transmission Owner
or Control Area
- SMD
- Ancillary Services - ITP
- - Scheduling and Dispatch
- VAR Support
- Regulation
- Reserves
- Self provide or purchase from ITP
69Costs - Today and SMD
- SMD
- Real Time Settlement
- Generators will be paid or will pay the variance
between Day Ahead Schedules and actual generation - Load will pay or be paid for the variance between
Day Ahead Schedule and actual load.
70Costs - Today and SMD
- SMD
- Other costs
- Grid Management Charge
- Annual operating cost of ITP/RTO
- PJM - 0.40/ MWh
- CAISO - 0.84/ MWh - (Source RTO West Cost
Benefit Study dtd March 11, 2002)
71 A
G2
G3
C
B
G1
Embedded Cost Transmission Rate 2.00 Rate
3.00 Rate 4.00
- Today Load A pays
- 2.00 transmission rate for delivery of G1
generation - 2.00 3.00 5.00 for delivery of G2
generation - Load A pays pancaked transmission rates for
delivery of generation from G2
72 A
G2
G3
B
C
G1
Transmission Rate 2.00 Rate
3.00 Rate 4.00
License Plate Rate 2.25 Rate
3.60 Rate 4.15
- Under SMD and License Plate Rate
- Revenue currently collected from pancaked rates
is paid by load physically located on
transmission system. - Revenue currently paid by non-firm and
short-term transactions is collect from load
physically located on transmission system - Load pays License Plate Rate for access to
generators on grid, plus congestion costs - Load A pays 2.25 for delivery of G1 or G2 or
G3 generation - Load C pays 4.15 for delivery of G1 or G2 or
G3 generation - The cost shifts which occur depend on each
customers situation -
73 A
G2
G3
B
C
G1
Transmission Rate 2.00 Rate
3.00 Rate 4.00
License Plate Rate 2.25 Rate
3.60 Rate 4.50
Postage Stamp Rate 3.14 (Blue, Yellow, Purple
Transmission Revenue
Requirement/ABC load)
- Under Postage Stamp Rate
- All load pays the same rate for access to all
generators on grid, plus payment of congestion
costs. - Load A, B or C pay
- 3.14 for delivery of G1 or G2 or G3 generation
-
74Estimate of Embedded Cost Rate (/kW-Mo) -
Today and SMD
-
LAP CRSP - Today 2.88 2.06
- License Plate 1/ 3.28 4.45
- Postage Stamp 2/ 2.38 2.38
- 1/ LAP and CRSP transmission owners would no
longer receives revenue from non-firm,
short-term, and long-term transactions to loads
physically located on other systems. - 2/ All loads pay the average transmission rate.
75Embedded Costs under WestConnect
- License Plate Rate - Access Area Rate
- Model approved by FERC, but rate formulas will
not be approved until later - WestConnect model includes several mitigation
proposals to reduce costs shifts among
transmission customers - Transmission Adjustment Component (TAC)
- Revenue currently collected by Western from
non-firm, short-term or converted long-term
contracts would be offset by congestion
management revenues or export fees and the
balance collected through the TAC
76Embedded Costs under WestConnect
- Mitigation measures (continued)
- TAC concept approved by FERC, but rate formulas
will not be approved until later - Transfer Payments between participating
transmission owners for converted contracts - With these mitigation measures in place,
Westerns transmission rate should not increase
above todays rate
77Embedded Costs under WestConnect
- Transition to end-state by Jan 1, 2009
- End-State embedded cost model includes a postage
stamp rate for higher voltage (highway) and a
license plate rate for lower voltage transmission
facilities (zone) - Impact unknown until details are developed
78WestConnect Highway-Zonal Model
- Highway Rate
- (A B C high voltage)
Zone A (A low voltage)
Zone B (B low voltage)
Zone C (C low voltage)
79Embedded Costs under RTO West
- License Plate Rate - Company Rate
- Company Rate in effect for eight years
- Filing includes several mitigation proposals
including - Transfer Payments for converted contracts between
participating transmission owners - Backstop Recovery triggered if revenues from
short-term, non-firm and long-term contracts are
not offset by net surplus from congestion
management and or export fees
80Costs - Summary
- Bilateral transactions continue
- Two-step settlement process for spot market under
LMP - Congestion revenue rights would be purchased and
sold to hedge against congestion costs - Pancaked rates would be eliminated
- WestConnect and RTO West include mitigation
measures for cost shifting
81How Could the Planning Process Change?
- Bob Easton
- Operations, Engineering, Planning
- Manager
- RMR
82How Could the Planning Process Change?
- Todays process
- Possible Seams Steering Group - Western
Interconnection (SSG-WI) planning process
83Existing Planning Process
84(No Transcript)
85RTO Price Signals
LSE Resource Planning
SSG-WI analysis of inter-RTO system needs
Post system needs and corresponding transmission
solutions for market to screen for alternatives
RTO Expansion Plans
WECC Joint Regional Planning (Unsponsored
projects, potential needs)
Market proposes non-tx alternatives to relieve
inter-RTO needs
Implement non-tx project
Voluntary Sponsorship of specific projects
TLRP input
SSG-WI Expansion Plan
Environmental, Siting Process
Build transmission project
WECC rating process and regional planning
participation interest)
SSG-WI Planning Process
86Proposed Planning Process for SSG-WI
SSG-WI
PWG
WECC
CREPC
Planning Process
RTO Planning Processes
Public Workshops
Individual Stakeholders
Fundamentals Invite WECC representation on
PWG PGW open to all Stakeholders - CCPG,
generator owners, marketers, TOs, etc. Reports
made to SSG_WI will be in the form of Majority
and Minority Reports Extensive use of Internet
to make information public subject to security
concerns
Solicit Input Present Results
CCPG, NWPP, ETC.
87Merchant Preparations forSMD / RTO Implementation
- Jeff Ackerman
- Montrose Energy Management and
- Market Office
- Manager
88Merchant Preparations forSMD / RTO Implementation
- Montrose merchant is preparing to act as
Scheduling Coordinator for Federal Generation
Resources. - Potential for scheduling Federal generation into
four separate RTOs. - - RTO West
- - WestConnect
- - CAISO
- - MISO
89Merchant - RTO Scheduling and Settlement Process
Concerns
- Multiple RTO participation will increase
scheduling and settlement complexity. - Increase workload in real-time, pre-schedule, and
settlement functional areas. Seams coordination
and common tools among RTOs will help. - Increase in IS software development and
programming support will be required. Automation
will be a key requirement!
90Items of Concern for the Merchant Office
- Extent of RTO participation?
- Electronic scheduling requirements.
- Transmission reservation rights CRRs for
Federal Generation and Firm Electric Service
obligations. - IT programming support and overall staffing
requirements.
91How is Westerns Control Area preparing for
possible changes?
- Ed Hulls
- Operations Manager
- RMR
92How is Westerns Control Area preparing for
possible changes?
93Operational Impacts
94Operational Impacts
95Flexible Staffing
96Questions
- Jane Meyer
- meyer_at_wapa.gov or 970-461-7245
- Mark Fidrych
- fidrych_at_wapa.gov or 970-461-7240
- Ron Moulton
- moulton_at_wapa.gov or 602-351-2446
- Bob Easton
- aeaston_at_wapa.gov or 970-461-7272
97Questions
- Jeff Ackerman
- ackerman_at_wapa.gov or 970-240-6209
- Ed Hulls
- hulls_at_wapa.gov or 970-461-7566
- Bob Kennedy
- rkennedy_at_wapa.gov or 970-461-7259