UNCONDITIONAL AND LEAD TIMES PREEMPTION AND COMPETITION TIMING

PURPOSE Define timing rules for when Preemption and Competition may be initiated Defender Lead Time Challenger Lead Time Conditional Reservation Deadline

PARKING LOT ITEMS New Issue BB (unresolved) Review Conditional Reservation deadlines and verify that conditional reservation deadlines do not violate the reservation timing table. i.e. Defender has moved into unconditional window before the deadline to respond to the competition. Issue 74 (unresolved) Business practices shall be developed that specify the minimum timing requirements to be applied to the competition for each pro forma transmission service. These requirements will include 1) minimum time prior to start of service that preemption/competition must be initiated (lead time), 2) maximum time required to complete the preemption/competition process (deadline), 3) maximum time a given defender has to exercise ROFR (match deadline), 4) business vs. calendar day, etc. Include consideration for market impacts, etc.

DEFENDER LEAD TIME There are two thresholds that are used to define the Defender lead time Conditional Reservation Deadline Defender Scheduling Deadline Preemption and Competition must be concluded prior to the earlier of the two thresholds Defender lead time is determined by counting backward from the threshold, accounting for the longest possible time it takes for each action to occur

DEFENDER LEAD TIME CONSIDERATIONS Matching Time Limit - Always 24 hours for Firm Challenger Confirmation Time Limit Applies to ROFR Defenders only Recommend 24 hours This is consistent with the time the Defender has to evaluate the Matching request of equal or greater duration This will require a change to Table 4-2 TP Evaluation Includes AFC evaluation, Match communication, and TP processing time Remain silent (See Table 4-2, footnote 6) Regional timing or disruption to TP Business Practices TP shall have the right to account for these items in their Business Practices See definition in

DEFENDER LEAD TIME EXAMPLE In the general case a Daily PTP TSR may not be identified as a Defender by a PTP Challenger 72 hours prior to start of service An additional buffer may be added at TP discretion to account for ‘Silent’ and ‘TP Right’ options

CHALLENGER LEAD TIME There is one threshold that is used to define the Challenger Lead Time Challenger Scheduling Deadline Preemption and Competition must be concluded prior to the Challenger scheduling deadline Challenger Lead Time is determined by counting backward from the threshold, accounting for the longest possible time it takes for each action to occur

CHALLENGER LEAD TIME CONSIDERATIONS Challenger Confirmation Time Limit Applies to ROFR Defenders only This may dissolve based on Sandbox development TP Evaluation Includes AFC evaluation, Match communication, and TP processing time Remain silent (See Table 4-2, footnote 6) Regional timing or disruption to TP Business Practices TP shall have the right to account for these items See definition in

CHALLENGER LEAD TIME EXAMPLE In the general case a Daily PTP Challenger may not identify a PTP TSR 48 hours prior to the scheduling deadline An additional buffer may be added at TP discretion to account for ‘Silent’ and ‘TP Right’ options

CHALLENGER LEAD TIME VS. DEFENDER LEAD TIME

ITEMS NOT ADDRESSED Should the Challenger Confirmation time limit be included in the Challenger lead time? If a TSR is excluded from Preemption and Competition due to Defender lead time, should higher priority defenders be excluded as well? What is an appropriate TP evaluation time limit? What is the time allowed for TP communication of ROFR?

RECOMMENDATION 1.The TP shall account for, if applicable, the Defender’s Matching time limit and the Challenger’s Confirmation time limit when determining if the Preemption and Competition process should be initiated. 2.Capacity shall not be taken from a Defender through the Preemption and Competition process after the earlier of the Defender’s conditional reservation deadline or the Defender’s scheduling deadline. Preemption and Competition shall not be initiated if the Preemption and Competition process would not conclude until after the earlier of the Defender’s conditional reservation deadline or scheduling deadline.

RECOMMENDATION (CONT.) 3.Preemption and Competition shall not be initiated for a Challenger if the Preemption and Competition process would not conclude until after the Challenger’s scheduling deadline. 4.The Transmission Provider may include consideration for the timing requirements of any regional practices. The TP may include additional timing requirements if the Transmission Provider determines that such additional timing requirements are reasonably necessary to avoid disruption of the Transmission Provider’s business practices. Consideration and adoption of any such additional timing requirements shall be established by business practice.

QUESTIONS?