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The City of Boulder City has its own municipal electric utility and is a customer of the Western Area Power Administration. Boulder City is one of the Hoover Contractors and as such, relies heavily on the Hoover generation resource for much of our wholesale power. As a partner with the other Contractors in this project in the Lower Colorado Region, we have a good working relationship with the Bureau and the local program and area offices. In accordance with the Hoover Power Plant Act of 1984 and the Boulder Canyon Project Implementation Agreement, we have established this relationship in full coordination with the Bureau of Reclamation, the Coordinating Committee and Engineering and Operating Committee. This relationship was achieved after much tribulation (including litigation) and at great expense to us, the “customer”. We do not want anything to disrupt this process, not from any external pressure nor internal Bureau “process”. In the Lower Colorado River Region, we have developed detailed procedures for interaction and communication between the Bureau and us, its partners, in the development of work plans and budgets. These processes and procedures are codified by Contractual agreement. We are very concerned about any policy or process that the Bureau might employ that would alter or overrule any decision that the Program or Area Managers have already made in accordance to our Contractual process. Team 12, who has been tasked to develop a business model that could manage work load and its distribution in order to obtain the optimum balance between work force and work load or “rightsizing”, appears to made proposals that would contradict our current Contracts and agreements. Team 12 current proposals would mandate work load distribution to be determined by either a “Guidance Document” or by parties not currently in our own Contract process. From our understanding, the program and area offices work plans are available to the TSC and others to review. At this time they are able to “bid” on the upcoming work. This is the process for the private sector. Team 12 maintains that the TSC offers the best “bang for the buck”. If so, then it stands to reason that they could rise above the competition and be able to win enough of the workload. Requirements that mandate the program and area offices to automatically provide their work plans to the TSC or COG (or any other new level of bureaucracy) are unduly expensive and burdensome. Even more onerous is the idea that any work plan decision by the area manager could be over-ridden by the TSC if the TSC wants the work and appeals the local managers’ decision to another level at the Bureau. This process completely removes the Program and Area Managers and their partners (us) from this decision making process. This appears to violate, at least the intent, of our current agreements. We understand and appreciate the self-examination the Bureau has undertaken with Managing for Excellence and also appreciate being able to participate in the process. We also acknowledge that the Bureau has many different responsibilities and partners with a wide range of views and goals. It is a daunting task attempting to develop business practices and procedures that are a benefit to all. With this in mind, we would suggest Team 12 realize the many, differing interests of its partners and customers. This would preclude any business model or processes that would mandate the same process for all of its varied projects and responsibilities and remove the local managers and their partners from the final decisions.	10/08/2007

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The City of Boulder City has its own municipal electric utility and is a customer of the Western Area Power Administration. Boulder City is one of the Hoover Contractors and as such, relies heavily on the Hoover generation resource for much of our wholesale power. As a partner with the other Contractors in this project in the Lower Colorado Region, we have a good working relationship with the Bureau and the local program and area offices. In accordance with the Hoover Power Plant Act of 1984 and the Boulder Canyon Project Implementation Agreement, we have established this relationship in full coordination with the Bureau of Reclamation, the Coordinating Committee and Engineering and Operating Committee. This relationship was achieved after much tribulation (including litigation) and at great expense to us, the “customer”. We do not want anything to disrupt this process, not from any external pressure nor internal Bureau “process”. In the Lower Colorado River Region, we have developed detailed procedures for interaction and communication between the Bureau and us, its partners, in the development of work plans and budgets. These processes and procedures are codified by Contractual agreement. We are very concerned about any policy or process that the Bureau might employ that would alter or overrule any decision that the Program or Area Managers have already made in accordance to our Contractual process.

Team 12, who has been tasked to develop a business model that could manage work load and its distribution in order to obtain the optimum balance between work force and work load or “rightsizing”, appears to made proposals that would contradict our current Contracts and agreements. Team 12 current proposals would mandate work load distribution to be determined by either a “Guidance Document” or by parties not currently in our own Contract process.

From our understanding, the program and area offices work plans are available to the TSC and others to review. At this time they are able to “bid” on the upcoming work. This is the process for the private sector. Team 12 maintains that the TSC offers the best “bang for the buck”. If so, then it stands to reason that they could rise above the competition and be able to win enough of the workload. Requirements that mandate the program and area offices to automatically provide their work plans to the TSC or COG (or any other new level of bureaucracy) are unduly expensive and burdensome. Even more onerous is the idea that any work plan decision by the area manager could be over-ridden by the TSC if the TSC wants the work and appeals the local managers’ decision to another level at the Bureau. This process completely removes the Program and Area Managers and their partners (us) from this decision making process. This appears to violate, at least the intent, of our current agreements.

We understand and appreciate the self-examination the Bureau has undertaken with Managing for Excellence and also appreciate being able to participate in the process. We also acknowledge that the Bureau has many different responsibilities and partners with a wide range of views and goals. It is a daunting task attempting to develop business practices and procedures that are a benefit to all. With this in mind, we would suggest Team 12 realize the many, differing interests of its partners and customers. This would preclude any business model or processes that would mandate the same process for all of its varied projects and responsibilities and remove the local managers and their partners from the final decisions.

10/08/2007