WEQ Executive Committee Contract Path Task Force Additional Issues Related To Contract Path Management ( WEQ and WEQ )

Documents filed with the Task Force Comments Submitted for the meeting on September 30:  NCEMC Work Paper NCEMC Work Paper Comments Submitted for the meeting on October 8:  BPA Issue 6 Work Paper BPA Issue 6 Work Paper  NCEMC Issues 6 and 7 Work Paper NCEMC Issues 6 and 7 Work Paper  PJM Work Paper PJM Work Paper  SPP Issue #4 Work Paper SPP Issue #4 Work Paper Comments Submitted for the meeting on October 15:  MISO Work Paper MISO Work Paper  SPP Issue #3 and #5 Work Paper SPP Issue #3 and #5 Work Paper  BPA Issue 6 Work Paper (rev) BPA Issue 6 Work Paper

Issues 1.Placement of the new standards 2.Accounting for the expected transmission system utilization 3.Clarification about “mutually agree” and “the right to use” and their establishment 4.System changes impacts and the lack of flexibility 5.Necessity for using ATC Path Limits in AFC systems 6.The lack of timing requirements 7.Transparency of the calculations 8.Ensure the standards do not preclude existing and future agreements  Order does not signify importance or agreement by the task force.

1. An evaluation is needed to determine if there is a more appropriate placement for standards 1.4 and within the NAESB WEQ Business Practices Standards (BPA)  Concern that Reservations and Scheduling are covered in other NAESB Standards.  BPA proposes that WEQ be moved to WEQ and WEQ be moved to WEQ – 004.  BPA recommends the NAESB Coordinate Interchange Standards and OASIS subcommittees review and confirm location within their standards).  Task Force Member Support Level:

2. The sum of Facility Ratings of Tie Facilities referenced in these requirements should take into account the expected use of reservations and schedules to help ensure efficient use of the transmission system (PJM)  Entities are currently granting Reservations and approving Schedules (e- Tags) that exceed “sum of the Facility Ratings of Tie Facilities”, however this is only during the period of time before ramp and actual flow on the grid occurs. This is because of existing market evaluation processes to determine what is economic to flow.  PJM recommends NAESB BPS review WEQ and WEQ to allow for a TP defined timeframe prior to actual flow (pre-schedule time) where facility limits of Reservations and Schedules ( e-Tags ) could exceed the “sum of the Facility Ratings of Tie Facilities”.

3. Language regarding “mutually agree” and “right to use” is unclear and clarity on how the rights are established (SPP)  Current language does not address outages/de-rates that impact the tie line facilities of an ATC path  Potential commercial impacts for Inter-BA paths, should the same apply for Intra-BA paths  What is mutually agree?  Disagreements occur  How are the agreements formalized

4. Additional clarity regarding scenarios where system changes occur and create a violation of 1.4 and such that in a situation that a transmission provider has granted service of a facility and is now no longer able to honor the service that was granted. (SPP)  The current language suggests that the limit cannot (ever) be exceeded. SPP believes that the “ever” is physically impossible  SPP agrees with BPA, Idaho Power and NCEMC that adherence to WEQ and WEQ by NAESB BPS could lead to the undesired result of allowing a Non Firm e-Tag to flow ahead of Firm ETag  SPP agrees with BPA, Idaho Power and NCEMC that if a timing allowance is addressed in WEQ and WEQ by NAESB BP it could alleviate the concern

5. Necessity for calculating and documenting compliance of ATC path limits when there may be no need to do so (SPP)  Instead of an industry requirement (1.4 and 1.4.1) to address blanket concerns, the standards should address the individual instances where the concerns exist  For most cases the flowgates are more limiting than the ATC Path Limit  Suggest addressing specific instances with a requirement to do so, but not for the entire industry

6. There is not a start time or stop time for the transmission service provider in WEQ and WEQ (BPA, Idaho Power, NCEMC)  BPA and NCEMC both presented examples and reasons for including a timing allowance during the “preschedule” timeframe to allow the “sum of the Facility Ratings of Tie Facilities” to be exceeded for Reservations and Schedules.  Understanding that by the time that the reservations and schedules become active and begin to flow on the grid that net flow would not exceed “sum of the Facility Ratings of Tie Facilities”

7. For the sake of transparency how would Transmission Service Providers apply these general requirements for each of the ATC methodologies? This should be documented in the greatest detail possible. (NCEMC)  There is a lack of transparency in the calculation regarding the posted ATC/AFC values across common seams and NCEMC recommends that the standards should address how a TP will describe to customers how they will apply WEQ and WEQ

8. Ensure the standards do not preclude existing and future agreements (MISO)  Existing and future agreements will be allowed to take precedent over the standard provided the combined contract path capacity of the two BAs (reduced for any outages or de-rates) does not exceed the firm transmission service reservation limits or the firm and non-firm transmission scheduling limits for the two BAs  The standard language in 1.4 and is vague and does not reference the existence of current or future agreements and may raise TSP/BA concerns that they have language in agreements that contradict standard language

Issue of note  Issue six was submitted independently by multiple parties regarding the timing issues  All other issues had varied levels of support

Questions /Discussion