​​​ANSWER OF THE TRADE ASSOCIATIONS AND SUPPORTING CUSTOMERS IN SUPPORT OF MOTION FOR PARTIAL SUMMARY DISPOSITION

Pursuant to Rule 213 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”),1 the American Public Power Association (“APPA”), the Large Public Power Council (“LPPC”), the National Rural Electric Cooperative Association (“NRECA”), the Public Power Council, the Northwest Requirements Utilities and the Pacific Northwest Generating Cooperative (collectively, “the Trade Associations”) hereby answer in support of the Motion for Partial Summary Disposition (“Motion”) filed by Bonneville Power Administration (“BPA”) in this docket on February 22, 2016.2 The Trade Associations’ support for BPA is compelled by their conviction that PacifiCorp has no basis in FERC precedent for denying transmission service to BPA, and the concern that PacifiCorp’s position, if uncorrected and widely adopted, could disrupt transmission service to municipal and cooperative utilities nationwide, to the detriment of millions of consumers. FULL FILING