March 1, 2018

  1. Nevada’s not-for-profit electric cooperatives, public power districts, and municipalities (“Rural Electrics”) are voluntary Associations of people, not electrical generation monopolies.
  2. Rural Electrics have locally elected Boards and are not subject to PUCN jurisdiction other than for service territory identification and the reporting of certain information.
  3. Rural Electrics’ existing Federal hydro-generation resource contracts should be preserved and included in the calculation of Nevada’s carbon-free footprint.
  4. Rural Electrics share a serious concern that the State is attempting to define a competitive retail energy market before a properly structured, robust wholesale electric market can be identified.
  5. Although mandated to serve energy load requests within PUCN defined geographic service areas, locally elected Rural Electric Boards implement rules for membership application from persons within their independent service territories, under the same terms as other similar persons within the same customer class.
  6. Under ECI, existing transmission contracts must be preserved in order to continue affordable rates and meaningful choice in rural Nevada.
  7. The cost of NV Energy’s stranded assets and abrogated contracts should only be shared by those for whom the assets were planned and acquired.
  8. Rural Electrics are concerned about the enormous task of informing and educating Nevada’s consumers to the realities and nuances of a completely restructured retail energy market for the State.