north american energy standards board · 2019-09-30 · for quadrant: wholesale electric quadrant...

NORTH AMERICAN ENERGY STANDARDS BOARD

Executive Committee Meeting – WEQ, REQ, RGQ, WGQ Meeting Materials May 8-10, 2007

North American Energy Standards Board

Executive Committee Meeting

Wholesale Electric Quadrant Retail Gas Quadrant

Retail Electric Quadrant Wholesale Gas Quadrant

May 8-10, 2007

AGA Offices - Washington, DC



Table Of Contents

General Materials Applicable to Multiple Quadrants

Tab 1. Welcome & Opening Remarks • EC Members and Terms • Schedule of 2007 Meetings

Tab 2. Agendas

Tab 3. Executive Committee Draft Minutes

Tab 4. Triage Subcommittee Update

Tab 5. Board Updates

Tab 6. FERC Actions

Wholesale Electric Quadrant Materials

Tab 7. Proposed Standard WEQ Annual Plan Item 2 – Business practice standards for support of OATT Reform and Revision to Final Action R04006D to align the Resales Standards with Order 890

Tab 8. Proposed Standard AP Item 3-b-1: companion business practices to NERC's cyber standard (CIP002-009)

Tab 9. Proposed Standard for R04035 and R05002 (S&CP): Amend sections 9.5 and 10.5 of OASIS 1A redirect standards

Tab 10. Scoping Document for R05026

Tab 11. Specific Issue Updates and Subcommittee Updates

Tab 12. 2007 WEQ Annual Plan

Tab 13. Request to the Drafting Collaborative

Retail Electric and Retail Gas Quadrants Materials

Tab 14. Proposed Standard AP Item 1: Billing and Payment

Tab 15. Proposed Standard AP Item 3(a)(ii): Customer Drops

Tab 16. Proposed Standard AP Item 3: Customer Information

Tab 17. Proposed Standard R05016: Customer Billing and Payment Notification via UET

Tab 18. Subcommittee Updates

Tab 19. 2007 Retail Annual Plan

Wholesale Gas Quadrants Materials

Tab 20. Proposed Standard R06008 – Gas Quality Enhancements

Tab 21. Proposed Standard AP Item : Canadian Addendum

Tab 22. Subcommittee Updates

Tab 23. 2007 Retail Annual Plan

Assembled Document of 632



TAB 7

Proposed Standard WEQ Annual Plan Item 2 – Business practice standards for support of OATT Reform and Revision to Final Action

R04006D to align the Resales Standards with Order 890

• Action may be required of the WEQ EC to approve the proposed standard. The recommendation and its redlined version are provided.

• Comments are due May 4 and will be provided under separate cover as they are received.

• Tab 7 corresponds to agenda item 3 for WEQ.

Assembled Document Page 92 of 632

RECOMMENDATION TO NAESB WEQ EXECUTIVE COMMITTEE

For Quadrant: Wholesale Electric Quadrant Requesters: Wholesale Electric Quadrant Electronic Scheduling Subcommittee Request No.: WEQ 2007 Annual Plan Item 2 Request Title: Revision to Final Action R04006D to align the

Resales Standards with Order 890

April 4, 2007 Page 1

1. RECOMMENDED ACTION: EFFECT OF EC VOTE TO ACCEPT RECOMMENDED ACTION:

X Accept as requested X Change to Existing Practice Accept as modified below Status Quo Decline

2. TYPE OF DEVELOPMENT/MAINTENANCE

Per Request: Per Recommendation:

Initiation Initiation X Modification X Modification Interpretation Interpretation Withdrawal Withdrawal

Principle Principle Definition Definition X Business Practice Standard X Business Practice Standard Document Document Data Element Data Element Code Value Code Value X12 Implementation Guide X12 Implementation Guide Business Process Documentation Business Process Documentation






3. RECOMMENDATION

SUMMARY:

This recommendation revises standard business practices related to secondary market sales of transmission service. These standards address certain provisions of Section 23 in the FERC Pro Forma Open Access Transmission Tariff titled “Sale or Assignment of Transmission Service.” The standards set forth in Final Action R04006D were ratified on October 2, 2006. This recommendation includes revisions to Final Action R04006D to align with the requirements found in FERC Order 890 paragraphs 808-827, revised pro forma OATT section 23 Sale or Assignment of Transmission Service and revised pro forma OATT ATTACHMENT A-1. No other changes have been recommended for these standards other than to align the language with the directives in Order 890.

RECOMMENDED STANDARDS: Definitions–The following definitions shall be added to the Business Practice Standards:

Assignee – An Eligible Customer that receives point-to-point transmission service rights from a Reseller either through a Resale or a Transfer. Eligible Customer – as defined in the FERC Pro Forma Open Access Transmission Tariff. Financially Obligated Transmission Customer (FOTC) – The customer financially obligated to the Transmission Provider for transmission service (i.e., service procured either through direct purchase from the Transmission Provider, Reseller, or through a Transfer of transmission rights). Resale – The request to convey scheduling rights associated with a reservation for Point-To-Point Transmission Service from a Reseller to an Assignee. Transfer – Request to convey all rights and obligations associated with a reservation for Point-To-Point Transmission Service from a Reseller to an Assignee.






Definitions–The following existing definitions in the WEQ OASIS Business Practice Standards (WEQ BPS-001-000) shall be modified:

Parent Reservation – an existing, confirmed reservation being modified by a Redirect, Transmission Customer’s request to redirect, Transferreassign, rResale, etc. Reseller – The customer that holds Point-To-Point Transmission Service rights and offers those rights for sale on the (secondary) transmission market.any Transmission Customer who offers to sell transmission capacity it has purchased.

Business Practice Standards for Sale or Assignment of Transmission Service

Standard Y: Resales Any Transmission Customer (Reseller) shall have the right to offer for sale the scheduling rights associated with the points of delivery and receipt of a Firm or Non-Firm Point-To-Point Transmission Service reservation (i.e. Parent Reservation). Any Eligible Customer (Assignee) may request to purchase scheduling rights from the Reseller.

Standard Y.1: Rights Conveyed The confirmation of a Resale shall convey the rights to schedule Point-To-Point Transmission Service from the Reseller to the Assignee, but shall also convey any outstanding conditions that may exist on the Parent Reservation (such as conditional approval pursuant to Section 13.2(ii) of the OATT).

Standard Y.1.1 Upon confirmation of a Resale on OASIS, the Reseller shall lose those conveyed scheduling rights for the time frame and in the amount of the Resale. Standard Y.1.2 If the Transmission Provider (TP) determines the Reseller is not the legitimate owner of the reserved capacity in the Parent Reservation(s), the TP has the right to nullify the Resale. Standard Y.1.3 The Assignee shall be obligated directly to the TP for all arrangements required for scheduling transactions on the TP’s system, including submission of schedules, provision for losses, etc. Standard Y.1.4 Renewal rights, if any, are not conveyed in a Resale.






Standard Y.1.5 The Assignee shall have the right to resell rights acquired through a Resale in accordance with these standards subject to Standard Y.7. Standard Y.1.6 The Assignee shall have the right to Redirect rights acquired through a Resale in accordance with these standards subject to Standard Y.6 and OASIS Business Practice Standards 9 and 10 (Redirects). Standard Y.1.7 The Assignee must execute a service agreement with the Transmission Provider that will govern the provision of reassigned service no later than twenty-four hours prior to the scheduling deadline applicable for the commencement of the reassigned service. The Transmission Provider may establish a blanket service agreement to govern Resale transactions.

Standard Y.2: Financial Obligations Resales shall not affect the Financially Obligated Transmission Customer’s (FOTC) financial obligations to the TP or any other terms of service under the tariff with respect to fixed reservation-based charges. The TP shall collect from the Assignee the agreed upon Resale transaction charges as posted on OASIS and credit that amount to the Reseller.

Standard Y.2.1 The Assignee shall be obligated directly to the TP for any usage-based charges and overuse penalties resulting from its subsequent use of the Resale.

Standard Y.2.2 The TP may annul the Resale in absence of an executed agreement as specified in Standard Y.1.7.

Standard Y.3: Service Attributes and Timing A Resale shall retain all the same transmission service attributes, transmission service priority, and points of delivery and receipt of the Parent Reservation. For example, if one hour of a Monthly Firm reservation is Resold, the Resale reservation shall be a Monthly Firm Resale reservation lasting one hour.

Standard Y.3.1 The TP’s OASIS shall not impose any restrictions regarding the timing of a Resale, either submission times or service duration, except that the start and stop times of the Resale must be within the bounds of the Parent Reservation(s) that are designated as supporting the Resale.






Standard Y.3.2 The Reseller shall have the right to aggregate multiple reservations into a single Resale provided that each reservation being aggregated is of exactly the same service attribute, priority, product and point of receipt/point of delivery. Standard Y.3.3 A Resale must be in whole hours, beginning at the top of the hour, and within the start and stop time(s) of the Parent Reservation(s). Standard Y.3.4 Service arranged through a Redirect on a non-firm basis (i.e., secondary service) cannot be resold.

Standard Y.4: Quantity A Resale must be in whole MWs and equal to or less than the Granted Capacity of the Parent Reservation(s), less any reductions (e.g. confirmed Redirects, previous Resales, curtailments, or implemented schedules) to the capacity available for scheduling of that Parent Reservation. Standard Y.5: Posting on OASIS All Resales shall be posted on OASIS.

Standard Y.5.1 A Resale may be arranged between the Assignee and Reseller on OASIS, in accordance with the OASIS Standards and Communication Protocols (S&CP) for “Secondary Sales – On OASIS.” Standard Y.5.2 If the Resale is not conducted on OASIS, the Reseller must notify the TP of the Resale via the OASIS, in accordance with the OASIS S&CP for “Secondary Sales – Off OASIS.” This posting should be made as soon as practicable, but in any case prior to the Assignee’s exercising of any rights under the Resale. Standard Y.5.3 All resales must include the price of the Resale. Price units shall always be $/MW-Hour reserved.

Standard Y.6: Redirect of a Resale The Assignee shall have the right to Redirect firm rights acquired through a Resale. Any such request shall be submitted directly to the TP and will be queued and evaluated in the same manner as any other Redirect. (Subject to any limitations otherwise identified in these standards).

Standard Y.6.1 The Assignee shall be obligated directly to the TP for any charges or credits resulting from any Redirect on a firm basis.






Standard Y.6.2 Prior to accepting a Redirect request on a firm basis from the Assignee, the TP shall have the right to require that the Assignee execute a Transmission Service Agreement. Standard Y.6.3 The TP may reject a Redirect of a Resale in absence of an executed agreement as specified in Standard Y.1.7.

Standard Y.7 Displacement of a Resale In the event a Transmission Provider’s Tariff requires that a higher priority, competing transmission service request must displace all or a portion of a confirmed lower priority reservation, the TP shall have the right to nullify any Resales that reference the displaced reservation as their Parent.

Standard Y.7.1 Once the conditional window on the Parent Reservation has closed, Resales for firm service are not subject to displacement in accordance with Standard Y.

Revision to OASIS S&CP Section 002-4.2.10.2: ANNULLED = assigned by Provider or the Seller when, by mutual agreement with the

Customer, a confirmed reservation is to be voided or assigned unilaterally by the Provider when a confirmed reservation is to be voided. (Final state).

Add definition of ANNULLED to OASIS Data Dictionary Section 003 under Data Dictionary

Element Name: STATUS.

Assembled Document 8 of 632

RECOMMENDATION TO NAESB WEQ EXECUTIVE COMMITTEE NAESB WEQ FINAL ACTION RATIFIED 10/02/2006

For Quadrant: Wholesale Electric Quadrant Requesters: Wholesale Electric Quadrant Electronic Scheduling Subcommittee Request No.: R04006-DWEQ 2007 Annual Plan Item 2 Request Title: Revision to Final Action R04006D to align the

Resales Standards with Order 890OASIS 1A Enhancements - Sale or Assignment of Transmission Service


1. RECOMMENDED ACTION: EFFECT OF EC VOTE TO ACCEPT RECOMMENDED ACTION:

X Accept as requested X Change to Existing Practice Accept as modified below Status Quo Decline



X Initiation X Initiation X Modification X Modification Interpretation Interpretation Withdrawal Withdrawal

Principle Principle Definition Definition X Business Practice Standard X Business Practice Standard Document Document Data Element Data Element Code Value Code Value X12 Implementation Guide X12 Implementation Guide Business Process Documentation Business Process Documentation






3. RECOMMENDATION

SUMMARY:

This recommendation establishes revises standard business practices related to secondary market sales of transmission service. These standards address certain provisions of Section 23 in the FERC Pro Forma Open Access Transmission Tariff titled “Sale or Assignment of Transmission Service.” The Business Practice Standards recommendation is divided into three sections:

•Definitions •Resales • Transfers

In reviewing this recommendation, please note the questions posed in Section 4(d) – Commentary/Rationale of Subcommitte(s)/Task Force(s) for specific questions posed by the Subcommittee. The standards set forth in Final Action R04006D were ratified on October 2, 2006. This recommendation includes revisions to Final Action R04006D to align with the requirements found in FERC Order 890 paragraphs 808-827, revised pro forma OATT section 23 Sale or Assignment of Transmission Service and revised pro forma OATT ATTACHMENT A-1. No other changes have been recommended for these standards other than to align the language with the directives in Order 890.

RECOMMENDED STANDARDS: Definitions–The following definitions shall be added to the Business Practice Standards:

Assignee – An Eligible Customer that receives point-to-point transmission service rights from a Reseller either through a Resale or a Transfer. Eligible Customer – as defined in the FERC Pro Forma Open Access Transmission Tariff.






Financially Obligated Transmission Customer (FOTC) – The customer financially obligated to the Transmission Provider for transmission service (i.e., service procured either through direct purchase from the Transmission Provider, Reseller, or through a Transfer of transmission rights). Resale – The request to convey scheduling rights associated with a reservation for Point-To-Point Transmission Service from a Reseller to an Assignee. Transfer – Request to convey all rights and obligations associated with a reservation for Point-To-Point Transmission Service from a Reseller to an Assignee.

Definitions–The following existing definitions in the WEQ OASIS Business Practice Standards (WEQ BPS-001-000) shall be modified:

Parent Reservation – an existing, confirmed reservation being modified by a Redirect, Transmission Customer’s request to redirect, Transferreassign, rResale, etc. Reseller – The customer that holds Point-To-Point Transmission Service rights and offers those rights for sale on the (secondary) transmission market.any Transmission Customer who offers to sell transmission capacity it has purchased.

Business Practice Standards for Sale or Assignment of Transmission Service

Standard Y: Resales Any Transmission Customer (Reseller) shall have the right to offer for sale the scheduling rights associated with the points of delivery and receipt of a Firm or Non-Firm Point-To-Point Transmission Service reservation (i.e. Parent Reservation). Any Eligible Customer (Assignee) may request to purchase scheduling rights from the Reseller.

Standard Y.1: Rights Conveyed The confirmation of a Resale shall convey the rights to schedule Point-To-Point Transmission Service from the Reseller to the Assignee, but shall also convey any outstanding conditions that may exist on the Parent Reservation (such as conditional approval pursuant to Section 13.2(ii) of the OATT).






Standard Y.1.1 Upon confirmation of a Resale on OASIS, the Reseller shall lose those conveyed scheduling rights for the time frame and in the amount of the Resale. Standard Y.1.2 If the Transmission Provider (TP) determines the Reseller is not the legitimate owner of the reserved capacity in the Parent Reservation(s), the TP has the right to nullify the Resale. Standard Y.1.3 The Assignee shall be obligated directly to the TP for all arrangements required for scheduling transactions on the TP’s system, including submission of schedules, provision for losses, etc. Standard Y.1.4 Renewal rights, if any, are not conveyed in a Resale. Standard Y.1.5 The Assignee shall have the right to resell rights acquired through a Resale in accordance with these standards subject to Standard Y.7. Standard Y.1.6 The Assignee shall have the right to Redirect rights acquired through a Resale in accordance with these standards subject to Standard Y.6 and OASIS Business Practice Standards 9 and 10 (Redirects). Standard Y.1.7 The Assignee must execute a service agreement with the Transmission Provider that will govern the provision of reassigned service no later than twenty-four hours prior to the scheduling deadline applicable for the commencement of the reassigned service. The Transmission Provider may establish a blanket service agreement to govern Resale transactions.

Standard Y.2: Financial Obligations Resales shall not affect the Financially Obligated Transmission Customer’s (FOTC) financial obligations to the TP or any other terms of service under the tariff with respect to fixed reservation-based charges. The TP shall collect from the Assignee the agreed upon Resale transaction charges as posted on OASIS and credit that amount to the Reseller.

Standard Y.2.1 The Assignee shall be obligated directly to the TP for any usage-based charges and overuse penalties resulting from its subsequent use of the Resale.






Standard Y.2.1.1 In the event of default by the Assignee, the Reseller is responsible for the financial obligations of the Assignee.

Standard Y.2.2 The TP shall have the right to require may annul the Resale that the potential Assignee execute a transmission service agreement and may nullify all Resales in absence of such an executed agreement as specified in Standard Y.1.7.or if the Resale exceeds the financial limits in such agreement.

Standard Y.3: Service Attributes and Timing A Resale shall retain all the same transmission service attributes, transmission service priority, and points of delivery and receipt of the Parent Reservation. For example, if one hour of a Monthly Firm reservation is Resold, the Resale reservation shall be a Monthly Firm Resale reservation lasting one hour.

Standard Y.3.1 The TP’s OASIS shall not impose any restrictions regarding the timing of a Resale, either submission times or service duration, except that the start and stop times of the Resale must be within the bounds of the Parent Reservation(s) that are designated as supporting the Resale.

Standard Y.3.2 The Reseller shall have the right to aggregate multiple reservations into a single Resale provided that each reservation being aggregated is of exactly the same service attribute, priority, product and point of receipt/point of delivery. Standard Y.3.3 A Resale must be in whole hours, beginning at the top of the hour, and within the start and stop time(s) of the Parent Reservation(s). Standard Y.3.4 Service arranged through a Redirect on a non-firm basis (i.e., secondary service) cannot be resold.

Standard Y.4: Quantity A Resale must be in whole MWs and equal to or less than the Granted Capacity of the Parent Reservation(s), less any reductions (e.g. confirmed Redirects, previous Resales, curtailments, or implemented schedules) to the capacity available for scheduling of that Parent Reservation.






Standard Y.5: Posting on OASIS All Resales shall be posted on OASIS.

Standard Y.5.1 A Resale may be arranged between the Assignee and Reseller on OASIS, in accordance with the OASIS Standards and Communication Protocols (S&CP) for “Secondary Sales – On OASIS.” Standard Y.5.2 If the Resale is not conducted on OASIS, the Reseller must notify the TP of the Resale via the OASIS, in accordance with the OASIS S&CP for “Secondary Sales – Off OASIS.” This posting should be made as soon as practicable, but in any case prior to the Assignee’s exercising of any rights under the Resale. Standard Y.5.3 All resales must include the price of the Resale. Price units shall always be $/MW-Hour reserved.

Standard Y.6: Redirect of a Resale The Assignee shall have the right to Redirect firm rights acquired through a Resale. Any such request shall be submitted directly to the TP and will be queued and evaluated in the same manner as any other Redirect. (Subject to any limitations otherwise identified in these standards).

Standard Y.6.1 The Assignee shall be obligated directly to the TP for any charges or credits resulting from any Redirect on a firm basis. Standard Y.6.2 Prior to accepting a Redirect request on a firm basis from the Assignee, the TP shall have the right to require that the Assignee execute a Transmission Service Agreement. Standard Y.6.3 The TP may reject a Redirect of a Resale in absence of an executed agreement as specified in Standard Y.1.7.

Standard Y.7 Displacement of a Resale In the event a Transmission Provider’s Tariff requires that a higher priority, competing transmission service request must displace all or a portion of a confirmed lower priority reservation, the TP shall have the right to nullify any Resales that reference the displaced reservation as their Parent.






Standard Y.7.1 Once the conditional window on the Parent Reservation has closed, Resales for firm service are not subject to displacement in accordance with Standard Y.

Revision to OASIS S&CP Section 002-4.2.10.2 ANNULLED = assigned by Provider or the Seller when, by mutual agreement with the

Customer, a confirmed reservation is to be voided or assigned unilaterally by the Provider when a confirmed reservation is to be voided.. (Final state).

Add definition of ANNULLED to OASIS Data Dictionary Section 003 under Data Dictionary

Element Name: STATUS.




Wholesale Electric Quadrant

TAB 8

Proposed Standard AP Item 3-b-1: companion business practices to NERC's cyber standard (CIP002-009)

• Action may be required of the WEQ EC to approve the proposed standard.

• Comments were due March 2 for which none was received.



RECOMMENDATION TO NAESB EXECUTIVE COMMITTEE For Quadrant: Wholesale Electric Quadrant Requesters: Southern Company Services Request No.: Recommendation WEQ 2006 Annual Plan Item

3(b)(i) (Develop companion business practices to NERC’s Cyber Sandard (CIP002-009), and specifically review section 1303-Personnel & raining to determine if business practices are needed)

Request Title: Annual Plan Item

January 24, 2007 Page 1

1. RECOMMENDED ACTION: EFFECT OF EC VOTE TO ACCEPT

RECOMMENDED ACTION: Accept as requested Change to Existing Practice Accept as modified below X Status Quo X Decline



Initiation Initiation Modification Modification Interpretation Interpretation Withdrawal X Withdrawal

Principle Principle Definition Definition X Business Practice Standard Business Practice Standard Document Document Data Element Data Element Code Value Code Value X12 Implementation Guide X12 Implementation Guide Business Process Documentation Business Process Documentation

3. RECOMMENDATION

SUMMARY: NAESB WEQ 2006 Annual Plan Item 3(b)(i) stated that the JISWG should review NERC’s Cyber Standard (CIP002-009), and specifically review section 1303-Personnel & Training to determine if business practices are needed.

RECOMMENDED STANDARDS: It is the recommendation of the JISWG that no commercial standards are needed at this time.


RECOMMENDATION TO NAESB EXECUTIVE COMMITTEE For Quadrant: Wholesale Electric Quadrant Requesters: Southern Company Services Request No.: Recommendation WEQ 2006 Annual Plan Item

3(b)(i) (Develop companion business practices to NERC’s Cyber Sandard (CIP002-009), and specifically review section 1303-Personnel & raining to determine if business practices are needed)

Request Title: Annual Plan Item


4. SUPPORTING DOCUMENTATION

a. Description of Request:

b. Description of Recommendation:

In support of the Recommendation to the NAESB Executive Committee, please see the following sets of NAESB (JISWG) subcommittee minutes:

WEQ JISWG November 2, 2006

January 23-24, 2007

c. Business Purpose:

d. Commentary/Rationale of Subcommittee(s)/Task Force(s):





TAB 9

Proposed Standard for R04035 and R05002 (S&CP): Amend sections 9.5 and 10.5 of OASIS 1A redirect standards

• Action may be required of the WEQ EC to approve the proposed standard.

• Comments were due March 15 for which none was received.



RECOMMENDATION TO NAESB EXECUTIVE COMMITTEE For Quadrant: Wholesale Electric Quadrant Requesters: ESS/ITS Request No.: R04035 and R05002 (S&CP) Request Title: Request to Modify Standards & Revision of

Redirect Standards 9 and 10


1. RECOMMENDED ACTION: EFFECT OF EC VOTE TO ACCEPT

RECOMMENDED ACTION: Accept as requested Change to Existing Practice Accept as modified below x Status Quo _ Decline



Initiation Initiation Modification Modification Interpretation Interpretation Withdrawal Withdrawal

Principle Principle Definition Definition x Business Practice Standard Business Practice Standard Document Document Data Element Data Element Code Value Code Value X12 Implementation Guide X12 Implementation Guide Business Process Documentation Business Process Documentation

3. RECOMMENDATION

SUMMARY: Standard request R04035 and R05002 requested modification to Standards 9 and 10 business practices. The WEQ EC adopted the recommendation for R04035/R05002 on November 29, 2005. The recommendation was ratified by the WEQ membership on January 5, 2006. (Final Action R04035/R05002; R04035/R05002 Final Action Attachment 1 - Appendix B; R04035/R05002 Final Action Attachment 2). On January 9, 2007, the ESS/ITS reviewed the modifications to the current standards and common practices employed by transmission providers on OASIS with respect to the S&CP documentation. Therefore, the ESS/ITS recommends no additonal modifications to the S&CP documentation at this time.


RECOMMENDATION TO NAESB EXECUTIVE COMMITTEE For Quadrant: Wholesale Electric Quadrant Requesters: ESS/ITS Request No.: R04035 and R05002 (S&CP) Request Title: Request to Modify Standards & Revision of

Redirect Standards 9 and 10


RECOMMENDED STANDARDS: With respect to OASIS Redirect modification requested in R04035 and R05002 the ESS/ITS recommends that no modification is necessary to the S&CP documentation.

4. SUPPORTING DOCUMENTATION

a. Description of Request:

b. Description of Recommendation:

In support of te Recommendation to the NAESB Executive Committee, please see the following sets of NAESB subcommittee minutes:

WEQ ESS/ITS January 9-10, 2007

WEQ ESS/ITS January 26, 2007

c. Business Purpose:

d. Commentary/Rationale of Subcommittee(s)/Task Force(s):





TAB 10

Scoping Document for R05026

• Action may be required of the WEQ EC to approve the proposed direction outlined in the scoping document.

The request and the scoping document prepared by the Standards Review Subcommittee are provided in this section.



R05026


Request for Initiation of a NAESB Business Practice Standard, Model Business Practice or Electronic Transaction

or Enhancement of an Existing NAESB Business Practice Standard, Model Business

Practice or Electronic Transaction Instructions: 1. Please fill out as much of the requested information as possible. It

is mandatory to provide a contact name, phone number and fax number to which questions can be directed. If you have an electronic mailing address, please make that available as well.

2. Attach any information you believe is related to the request. The

more complete your request is, the less time is required to review it. 3. Once completed, send your request to: Rae McQuade NAESB, Executive Director 1301 Fannin, Suite 2350 Houston, TX 77002 Phone: 713-356-0060 Fax: 713-356-0067 by either mail, fax, or to NAESB’s email address, [email protected]. Once received, the request will be routed to the appropriate subcommittees for review.

Please note that submitters should provide the requests to the NAESB office in sufficient time so that the NAESB Triage Subcommittee may fully consider the

request prior to taking action on it. It is preferable that the request be submitted a minimum of 3 business days prior to the Triage Subcommittee meetings. Those meeting schedules are posted on the NAESB web site at

http://www.naesb.org/monthly_calendar.asp.


R05026


Request for Initiation of a NAESB Business Practice Standard, Model Business Practice or Electronic Transaction

or Enhancement of an Existing NAESB Business Practice Standard, Model Business

Practice or Electronic Transaction

Date of Request: October 11, 2005

1. Submitting Entity & Address: Terry Dodson – Calpine 717 Texas Avenue Suite 1000 Houston, TX 77002 2. Contact Person, Phone #, Fax #, Electronic Mailing Address: Name : Terry Dodson Title : ___________________________________ Phone : ___________________________________ Fax : ___________________________________ E-mail : ___________________________________ 3. Description of Proposed Standard or Enhancement: Incrementally improve OASIS through the following:

A. Standardize the method of communication between transmission providers from point to point (analogous to the standard communication procedures followed by the interstate natural gas pipelines in electronically transmitting transactional information).

B. Review and modify the method in which standards are implemented to allow for more uniformity among Market Information Systems.

• Currently, non-standard systems are not successful in communicating with each other. This enhancement would provide the market with more information in a “standard” format, so that the market can make better decisions. This enhancement is commercial in nature and should be national in its scope. An example approach to this request could be the setting up a “standard” for communication between Market Information Systems (common schema, API, etc.) without mandating a “standard” MIS implementation. attempting to talk to each other. This enhancement does not require a change in tariff. It would


R05026

affect RTOs/ISOs, market participants, vendors, and Purchasing-Selling Entities (PSE’s).

C. Adapt OASIS systems to better interface directly with energy trading platforms

• This enhancement would include OASIS capability to reference Energy Sale Tag as a cross reference and provide for a more effective method of verifying complete tags. Such a standard does not exist in a uniform method. If developed, it would allow for better understanding of transmission service use by the market. This enhancement is commercial and should be developed on a national level. This is a new enhancement or standard and would affect all market participants.

D. Review and study of TSRs for Day Ahead need to be accomplished before market functions for next-day close (10-11am for most market regions).

• This standard would allow for coordination between the TP response and market closing for day ahead transmission studies. There are two major markets on short term – real time and day ahead. In order for market functions to coordinate day ahead, the analysis is performed before the trading stops the day before. It is not efficient for TSR to be studied after the energy trades are completed. The studies should be completed before the market closes the next day. Such a standard would allow for market participants to have a better understanding of what is available and create a more efficient market place. This standard is commercial in nature and should be national in scope. It would affect market participants that deal with short term trading and procurement.

E. Represent ALL pre-Order 888 (“grandfathered”) transmission and ancillary services in current use in OASIS.

• Currently, when transmission service is shown on OASIS, it is supposed to represent all of the service that has been procured by market participants to do functions. Transmission rights in existence before the issuance of FERC Order 888 were grandfathered and the Order did not mandate that these transmission rights be included in OASIS. It is difficult to have a full understanding of all commercial sales, when grandfathered transmission rights are not apparent. Utilities that own these rights should be required to use an OASIS number when they redirect. Such a standard would provide for a more efficient and equitable market and should be national. This enhancement would affect market participants that do not possess knowledge of


R05026

the grandfathered transmissions. This standard is commercial in nature.

F. Eliminate masking of TSR tag source and sink when request status is denied, withdrawn, refused, displaced, invalid, declined, annulled or retracted.

• FERC required that transition service tags that are in study and haven’t been confirmed keep confidential the Source and Sink of the tag. The goal was to keep participants from manipulating the market based on what other participants are doing. However, there is no need to mask the Source and Sink once service has been denied. This information should only be masked during the study time frame. The enhancement would be beneficial in stopping the blockage of an entity’s transition service by other market participants. It would also help put an end to participants giving false study claims to bias the market interaction –i.e. “stacking the queue”. This enhancement should apply to all market participants. It impacts FERC Order 888. The standard is commercial in nature and should be national in its scope.

G. Use same TSR tag number when status is changed to recall; do not create a new TSR tag number for this event.

• When a service request is submitted and confirmed but there is a mistake and subsequent recall, the status of the tag does not change. Rather, a new order is created. It then becomes difficult to confirm a service request because of the need to locate the new order. This enhancement would improve the market through better communication to Transmission customers and provide for more efficiency in transmission service procurement. This enhancement is commercial in nature and should be national in its scope.

H. Reduce multiple POR, POD, source, and sink listings that represent the same joint to just one acronym for each.

• Many acronyms are employed in OASIS to represent the same points of receipts and delivery. This enhancement would provide for a better understanding of the OASIS tag and of the market itself. It should be national in its coverage and is a commercial change.

I. Allow for multiple Redirect TSR numbers to be entered on the same Original reservation tag.

• To redirect with an end point at a different location requires a new reservation tag. The status of the old tag is not changed. A new number is assigned for redirect. It would be more efficient to


R05026

update the old tag for market participants. This change is commercial in nature and should be national in its scope.

J. Initiate standard that requires ALL historical transmission service reservations to be available for review up to a number of years in the past.

• The capability to retrieve historical transmission service request information for certain period of time in past is needed. The availability of this information would provide for a better understanding of historical use of the market. This enhancement is commercial in nature and its scope should be national. This request for standards development suggests a historical information time frame of 3 years.

K. Initiate standard that eliminates disparity of posting “sensitive” information. This standard should also include procedures of user certification that allows access to this class of information.

• Information that is entitled to protection on the OASIS website is not interpreted in a standardized method. A standardized security application for OASIS is needed. This enhancement would provide for more consistent availability of information for market participants. This enhancement should be national in its scope and would affect all market participants.

L. Enhance the TSR result postings to allow showing of (i) limiting transmission elements and (ii) available generation dispatch options that would allow acceptance of reservation request.

• An enhancement is needed to the existing study process for transmission service to show what caused the decline of service requests. In particular, the enhancement should assist in identifying specific transmission elements that would restrict the commercial flow of power and in identifying generation redispatch options that would allow a successful service request study. This enhancement would assist in making those that have been declined transmission service aware of the reasons behind the decline. This standard is commercial in nature and should be national in its scope. It would require a change to the tariff. Transmission service customers would be impacted.

M. Standardize the availability of TSR study result postings, eliminating practice of some Transmission Owners that charge for viewing these documents.

• Transmission owners should post service request study results free of charge for public viewing. The studies have already been paid for by the customer requesting the service. This enhancement would make information more open and lead to a more efficient market. The standard is commercial in nature and should be


R05026

national in its scope. Customers procuring transmission service are affected.

4. Use of Proposed Standard or Enhancement (include how the standard will be used,

documentation on the description of the proposed standard, any existing documentation of the proposed standard, and required communication protocols):

The proposed enhancement to the OASIS Standards will allow for more uniformity in implementation across OASIS sites. Additionally, the proposed enhancements will increase the functionality of OASIS.

5. Description of Any Tangible or Intangible Benefits to the Use of the Proposed

Standard or Enhancement: More uniform implementation of OASIS systems should allow for more efficiency. In addition, standardization would provide for a less fragmented system of implementation across the grid. 6. Estimate of Incremental Specific Costs to Implement Proposed Standard or

Enhancement: Not determinable at this time. 7. Description of Any Specific Legal or Other Considerations: Other Considerations: These items were part of the original list of items by Calpine to be included in this request. However, after further development it was determined that they were mainly reliability in nature. Consequently, NAESB will notify NERC of the following items:

Improve ATC posting timing requirements to represent most current conditions as soon as possible.

• This enhancement would provide for standardized hourly procurement timeframes. Such a standard would improve the ability of the market to optimize transmission service use by providing better real time operations of the transmission system. The enhancement would is mainly reliability in nature and should be developed on a national scale. This enhancement would affect all market participants.

Standardize calculated ATC values (including scenario analyzer functions), to accommodate for differing commercial operations in each market region.

• Currently, Transmission Providers have their own specific way to calculate Available Transmission Capacity (ATC). The TPs utilize a scenario analyzer in the process – conditions are inserted and the system performs its analysis. The analyzers are not standardized


R05026

in operations – i.e. they are not standardized in how much credit is received for firm v. non-firm, how much credit is received from point to point, or in how they perform market participations. The process to analyze the capabilities of ATC should be nationalized and all participants should perform under the same guidelines and operate in the same manner. A common understanding of the process used to determine ATC is needed. This enhancement is mostly reliability in nature. Such a standard would require changes in tariffs and would affect all market participants.

Standardize TLR posting requirements, eliminating practices of some Transmission Owners that do no show transmission service curtailments unless they affect transactions across their control area boundary.

• Some transmission owners only post a TLR to NERC if curtailment impacted flow outside the Control Area. If it is outside of the Control Area, the transmission owners will instead record it as a transmission problem. More accurate information is needed on transmission capability. The enhancement is reliability in nature and its scope should be national. This enhancement would also affect all market participants and regulatory officials.

In addition, the original list of items provided by Calpine contained the following item that was determined to be a legal consideration:

Perform routine auditing to ensure all functions a Transmission Owner’s OATT represents are actually allowed by its OASIS website.

• Transmission Providers apply too much bias against the service request capability. TPs should follow the described process outlined in their own OATT. Performance should be measured against the process in the OATT. This enhancement would improve the market by having transmission request studied as required by tariff. This enhancement is commercial in nature and should be national in its scope. Transmission customers and owners will be affected. This enhancement could affect FERC policy.

8. If This Proposed Standard or Enhancement Is Not Tested Yet, List Trading Partners

Willing to Test Standard or Enhancement (Corporations and contacts): 9. If This Proposed Standard or Enhancement Is In Use, Who are the Trading Partners: Not applicable.


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10. Attachments (such as : further detailed proposals, transaction data descriptions, information flows, implementation guides, business process descriptions, examples of ASC ANSI X12 mapped transactions):

For further details regarding the contents of this request please reference “Calpine – presentation” located on the NAESB website at http://www.naesb.org/pdf2/weq_oasis2_032905w19.doc.

In addition, the minutes where the contents of the above presentation were discussed (March 29, 2005 NERC/NAESB Future of OASIS Conference) are located on the NAESB website at http://www.naesb.org/pdf2/weq_ess_oasis2_032905rm.doc. A transcript of the March 29, 2005 Future of OASIS Conference can be obtained through ACE Federal Reporting, contact information provided on the NAESB website at http://www.naesb.org/weq/weq_ess_oasis_2.asp)


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Scoping Document For

R05026 (Thirteen Incremental Enhancements to OASIS)

NAESB WEQ Executive Committee - Standards Review Subcommittee November 20, 2006

Background:

This request for thirteen incremental enhancements to OASIS was submitted after the March 2005 NERC/NAESB Future of OASIS Conference by representatives of Calpine. The purpose of the Conference was to provide a forum for the industry to give input on potential enhancements to OASIS and the proposed scope of OASIS II. The conference addressed the July 2000 Advanced Notice of Proposed Rulemaking (ANOPR) RM00-10-0001 on communications between customers and Transmission Providers, electronic scheduling, dynamic notification, and generator run status information.

It was the consensus of the participants at the Conference that through the implementation of e-Tags and the incorporation of e-Tags into organizations’ scheduling systems, the industry is in the midst of a migration towards electronic scheduling today without the need for a major redefinition of OASIS requirements. The changes to OASIS to better support the market are being done on an incremental basis as the industry determines those changes are needed and can prioritize and staff the standards development work. The group determined that this was an effective and efficient way to move forward and adapt OASIS to market needs. NAESB filed a report on the results of the conference and its direct relation to the above ANOPR in July 2005. The report included a summary of the intention of NAESB to proceed with incremental enhancements to OASIS as discussed during the conference.

.

Below is a summary of Calpine’s presentation at the conference: • Adapt OASIS systems to better interface directly with energy trading platforms

• Improve ATC posting timing requirements to represent most current conditions as quickly as possible

• Review and study of day ahead Transportation Service Requests (TSRs) need to be accomplished before market functions for next-day close

Mr. Cox commented that less than efficient outcomes and arbitrage opportunities result when markets do not close at the same time. Calpine’s points continued:

• Standardize Transmission Loading Relief (TLR) posting requirements, eliminating practices of some Transmission Owners that do not show transmission service curtailments unless they affect transactions across their control area boundary.

• Routine auditing should be performed to ensure all functions a Transmission Owner’s OATT represents is actually allowed by its OASIS website.

1 Open Access Same-Time Information System Phase II, Advance Notice of Proposed Rulemaking, RM00-10-000, 92 FERC ¶61,047 (July 14, 2000).


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Mr. Cox stated in summary that the market simply wants to move power without too many encroaching restraints.

Overall, Calpine and Dynegy summarized that standards implemented on a non-uniform or standardized scale continue to be inefficient and that allowing for regional differences generally equals less than efficient end results. Following the conference, the NAESB office worked with both Mr. Cox of Dynegy and Mr. Dodson of Calpine to develop Request R05026.

This informal scoping document has been developed over the course of several months by the NAESB Standards Review Subcommittee and the Electronic Scheduling and Information Technology Subcommittee.

Vision: Scope:

A. Standardize the method of communication between transmission providers from point to point (analogous to the standard communication procedures followed by the interstate natural gas pipelines in electronically transmitting transactional information).

• Subcommittees’ comments: The OASIS S&CP already defines a programmatic template interface. The OASIS 2 Industry Workshop did not emphasize a need to adopt newer messaging technologies, e.g., XML and SOAP. Unless the Industry now deems this a significant benefit, WEQ should not revise the fundamental communications standard for OASIS.

• No need for assignment to subcommittee.

B. Review and modify the method in which standards are implemented to allow for more uniformity among Market Information Systems.

• Currently, non-standard systems are not successful in communicating with each other. This enhancement would provide the market with more information in a “standard” format, so that the market can make better decisions. This enhancement is commercial in nature and should be national in its scope. An example approach to this request could be the setting up a “standard” for communication between Market Information Systems (common schema, API, etc.) without mandating a “standard” MIS implementation. attempting to talk to each other. This enhancement does not require a change in tariff. It would affect RTOs/ISOs, market participants, vendors, and Purchasing-Selling Entities (PSE’s).

• Subcommittees’ comments: The OASIS S&CP already defines a programmatic template interface. The OASIS 2 Industry Workshop did not emphasize a need to adopt newer messaging technologies, e.g., XML and SOAP. Unless the Industry now deems this a significant benefit, WEQ should not revise the fundamental communications standard for OASIS.

• Commercial software is available that can help with these issues.

C. Adapt OASIS systems to better interface directly with energy trading platforms

• This enhancement would include OASIS capability to reference Energy Sale Tag as a cross reference and provide for a more effective method of


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verifying complete tags. Such a standard does not exist in a uniform method. If developed, it would allow for better understanding of transmission service use by the market. This enhancement is commercial and should be developed on a national level. This is a new enhancement or standard and would affect all market participants.

• Subcommittees’ Comments: This is a new enhancement or standard and would affect all market participants. This will require a change in OASIS S&CP schedule detail template and clarification in the OASIS implementation guidelines being developed under another standard (R04006 C1) in terms of providing more transparency of information related to scheduled use of transmission service. Development of a method to cross-reference energy purchases/sales in tagging would require a business standard and possibly modifications to the tag XML schema. A more complex solution, frag-tag, was discussed as part of OASIS Phase 2 implementation. Industry consensus on the relative cost-benefit of developing a standard solution to track energy sales/purchases should be sought before any significant work is expended in this area.

• It remains unclear what the requestor is asking for here and the requestor has not responded to requests for clarification.

• ESS/ITS and/or JISWG to address this issue.

D. Review and study of TSRs for Day Ahead need to be accomplished before market functions for next-day close (10-11am for most market regions).

• This standard would allow for coordination between the TP response and market closing for day ahead transmission studies. There are two major markets on short term – real time and day ahead. In order for market functions to coordinate day ahead, the analysis is performed before the trading stops the day before. It is not efficient for TSR to be studied after the energy trades are completed. The studies should be completed before the market closes the next day. Such a standard would allow for market participants to have a better understanding of what is available and create a more efficient market place. This standard is commercial in nature and should be national in scope. It would affect market participants that deal with short term trading and procurement.

• Subcommittees’ Comments: The Market Operators and their stakeholders would be the appropriate group to push for this type of standardization. To date there is little incentive and actually some stakeholder resistance to aligning market closing periods.

• ESS/ITS requests that R04020 (WEQ Annual Plan Items 3 & 4 - establish business standards relating to electric transaction scheduling and timelines) be referenced. The request was addressed in the Gas Electric Interdependency Report filed with the Commission in June 2005 and the request was subsequently withdrawn.

E. Represent ALL pre-Order 888 (“grandfathered”) transmission and ancillary services in current use in OASIS.

• Currently, when transmission service is shown on OASIS, it is supposed to represent all of the service that has been procured by market


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participants to do functions. Transmission rights in existence before the issuance of FERC Order 888 were grandfathered and the Order did not mandate that these transmission rights be included in OASIS. It is difficult to have a full understanding of all commercial sales, when grandfathered transmission rights are not apparent. Utilities that own these rights should be required to use an OASIS number when they redirect. Such a standard would provide for a more efficient and equitable market and should be national. This enhancement would affect market participants that do not possess knowledge of the grandfathered transmissions. This standard is commercial in nature.

• Subcommittees’ Comments: Some TPs currently do have all grandfathered transactions visible on OASIS however there is not a current regulatory requirement to post such information in detail. This information is part of the transmission provider’s ATC calculation which is being addressed in response to R05004A.

• This issue would be addressed by the ESS/ITS and BPS similar to the ATC work.

F. Eliminate masking of TSR tag source and sink when request status is denied, withdrawn, refused, displaced, invalid, declined, annulled or retracted.

• FERC required that transition service tags that are in study and haven’t been confirmed keep confidential the Source and Sink of the tag. The goal was to keep participants from manipulating the market based on what other participants are doing. However, there is no need to mask the Source and Sink once service has been denied. This information should only be masked during the study time frame. The enhancement would be beneficial in stopping the blockage of an entity’s transition service by other market participants. It would also help put an end to participants giving false study claims to bias the market interaction –i.e. “stacking the queue”. This enhancement should apply to all market participants. It impacts FERC Order 888. The standard is commercial in nature and should be national in its scope.

G. Use same TSR tag number when status is changed to recall; do not create a new TSR tag number for this event.

• When a service request is submitted and confirmed but there is a mistake and subsequent recall, the status of the tag does not change. Rather, a new order is created. It then becomes difficult to confirm a service request because of the need to locate the new order. This enhancement would improve the market through better communication to Transmission customers and provide for more efficiency in transmission service procurement. This enhancement is commercial in nature and should be national in its scope.

• Subcommittees’ Comments: This will require a change in OASIS S&CP and clarification in the OASIS implementation guidelines being developed under another standard (R04006 C1). Recall is not a standardized request type, so changes could be made to implement this function without creation of a new TSR. A similar concept for revising load forecasts and designated resources is envisioned for Network Integration


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Transmission Service on OASIS. This is part of the R04006 standards request and will also be brought forward under the FERC OATT Reform NOPR.

• It is unclear what the requestor is asking for. Recall’s are not used to reflect mistakes. It is not clear what is meant by a ‘new order’. This may be creating a standard to address a specific problem which may not occur frequently. Recall is generally used to implement a partial recall.

• If the issue is that a recall of a reservation does not automatically affect the tag, we question whether it is desirable to do this automatically without giving the customer the chance to decide which tag they want to remove or modify (if there are several). If there is a reliability issue, the transmission provider will ‘curtail’ the tag as necessary. Otherwise, the customer has the choice of modifying their own tag.

• If the issue is the fact that the recall has an additional AREF number and does not directly affect the amount of the Parent reservation that is confirmed: Even though the AREF of the recall is different, the recall does affect the parent MW available. Some systems currently show the available capacity on the parent reservation.

• We need more information to proceed with the development of a standard.

H. Reduce multiple POR, POD, source, and sink listings that represent the same joint to just one acronym for each.

• Many acronyms are employed in OASIS to represent the same points of receipts and delivery. This enhancement would provide for a better understanding of the OASIS tag and of the market itself. It should be national in its coverage and is a commercial change.

• Subcommittees’ Comments: The Western Interconnection has addressed this issue for the West. The ESS/ITS has already weighed in to not do name standardization due to potential impacts on existing systems. Please refer to ESS/ITS and Recommendation R04006 F, adopted by the WEQ EC on May 9, 2006. This is also a reliability issue to be addressed by NERC, if desired.

• This request addresses POR/POD, a bigger issue is that SOURCE/SINK may not similarly named.


I. Allow for multiple Redirect TSR numbers to be entered on the same Original reservation tag.

• To redirect with an end point at a different location requires a new reservation tag. The status of the old tag is not changed. A new number is assigned for redirect. It would be more efficient to update the old tag for market participants. This change is commercial in nature and should be national in its scope.

• Subcommittees’ Comments: A change could be made to the OASIS S&CP transstatus template to have OASIS return the current available


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MW profile on the TSR in addition to the original reserved CAPACITY_GRANTED. This would allow the customer to see more efficiently the impacts of any redirects, resales, and transfers made against the reservation.

• Recently developed Redirect Standards provide a check to ensure that redirected capacity is available and tagged capacity may not be redirected.

• Tags cannot be automatically changed based on changes in reservations. Not enough information is known.

J. Initiate standard that requires ALL historical transmission service reservations to be available for review up to a number of years in the past.

• The capability to retrieve historical transmission service request information for certain period of time in past is needed. The availability of this information would provide for a better understanding of historical use of the market. This enhancement is commercial in nature and its scope should be national. This request for standards development suggests a historical information time frame of 3 years.

• Subcommittees’ Comments: The OATT Reform NOPR is proposing to extend the time period for keeping data offline from 3 years to 5 years. Customers have the ability to programmatically retrieve reservation and schedule data online for up to 90-days per the current requirements. The cost benefit for customers to maintain their own records of past transmission use versus placing a requirement for OASIS to retain this data in an online form for 5 years should be explored before developing such a standard recommendation.

• It is unclear whether this request is to be able to retrieve data online, although this is assumed.

• One alternative is that the customer could download data every 90 days and keep it in their own database.


K. Initiate standard that eliminates disparity of posting “sensitive” information. This standard should also include procedures of user certification that allows access to this class of information.

• Information that is entitled to protection on the OASIS website is not interpreted in a standardized method. A standardized security application for OASIS is needed. This enhancement would provide for more consistent availability of information for market participants. This enhancement should be national in its scope and would affect all market participants.

• Subcommittees’ Comments: This issue is already being addressed by NAESB/NERC JISWG. They are currently finalizing the PKI security standard to be applied to OASIS and tagging systems. This addresses the requested standardization.


7

L. Enhance the TSR result postings to allow showing of (i) limiting transmission elements and (ii) available generation dispatch options that would allow acceptance of reservation request.

• An enhancement is needed to the existing study process for transmission service to show what caused the decline of service requests. In particular, the enhancement should assist in identifying specific transmission elements that would restrict the commercial flow of power and in identifying generation redispatch options that would allow a successful service request study. This enhancement would assist in making those that have been declined transmission service aware of the reasons behind the decline. This standard is commercial in nature and should be national in its scope. It would require a change to the tariff. Transmission service customers would be impacted.

• Subcommittees’ Comments: Elements of this request may be addressed in either the NAESB ATC standardization effort, e.g., posting of limiting transmission elements, and/or the standard requests that develop out of the FERC OATT Reform NOPR, e.g., generation redispatch options.

• ESS/ITS and/or BPS to address this issue. ESS/ITS also advises that we delay further explanation of this topic until the Order is issued for RM05-25.

M. Standardize the availability of TSR study result postings, eliminating practice of some Transmission Owners that charge for viewing these documents.

• Transmission owners should post service request study results free of charge for public viewing. The studies have already been paid for by the customer requesting the service. This enhancement would make information more open and lead to a more efficient market. The standard is commercial in nature and should be national in its scope. Customers procuring transmission service are affected.

• Subcommittees’ Comments: Should transmission owner be replaced with Transmission Service Provider?

• Current rules require availability of transmission study results at a cost limited to the cost of reproducing the material. Only a list of studies is required to be posted. Possibly could standardize what exactly is posted as the list of studies (e.g. name, location, dates, etc.)

For more information, please see the following:

• The Revised Draft Minutes from the NERC/NAESB Future of OASIS Conference

• Calpine - Presentation from the NERC/NAESB Future of OASIS Conference

• NERC/NAESB Conference Letter to FERC

• R05026

Functionality/Usability: This request seeks to maximize the functionality of OASIS by moving towards industry wide standards, instead of regional practices. Calpine states that efficiency is often lost in attempting to comply with varying practices in different regions. Many of the proposed standards affect the transparency of market postings related to OASIS and the standardization of communication


8

methods. Calpine proposes that these enhancements will contribute to the overall efficiency of the market.





TAB 11

Specific Issues and Subcommittee Updates

• The synopsis of subcommittee activities is included. The materials are provided for discussion purposes and no

action is required of the WEQ EC members.

• The most recent Order 890 plan is included for discussion.

• The most recent update for the TLR split is included.

• The materials in Tab 11 correspond to agenda items 5 and 6 for the WEQ EC agenda.



1301 Fannin, Suite 2350, Houston, Texas 77002 Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail: [email protected]

Home Page: www.naesb.org

NAESB EXECUTIVE COMMITTEE MEETING MATERIALS WEQ SUBCOMMITTEE SUMMARY AS OF MAY 1, 2007

WWEEQQ SSUUBBCCOOMMMMIITTTTEEEESS AANNDD TTAASSKK FFOORRCCEESS Electronic Scheduling/Information Technology

• January 4, 2007: The ESS/ITS met via conference call on January 4, 2007. During this call, the ESS/ITS reviewed the informal comments submitted on Draft S&CP Modifications Standards of Conduct Modifications (WEQ 2006 Annual Plan Item 3(c)(i)(S&CP). After making revisions in response to the comments, the subcommittee voted to send the recommendation to the WEQ Executive Committee for adoption. The recommendation will be posted for formal comment with the title Recommendation 2007 Annual Plan Item 3(a)(2) – Implementation of S&CP changes to support Standards of Conduct business practices due to the adoption of the 2007 WEQ Annual Plan. The ESS/ITS also reviewed the draft Implementation Guide and companion revisions to the S&CPs drafted by Mr. Sorenson.

• January 8, 2007: The WEQ BPS and ESS/ITS met via conference call jointly to review comments submitted on the Contract Path definition (Item 1D of R05004A). The group also reviewed progress made on work papers drafted to outline the standards language for Item 3E of R05004A. The subcommittee reviewed the progress of the NERC ATC Drafting Team.

• January 9-10, 2007: The ESS/ITS met at NAESB’s offices in Houston, Texas on January 9-10. During this meeting, the subcommittee continued its review of the draft Implementation Guide and companion revisions to the S&CPs, reviewed work papers submitted in response to Request No. R04006E (Network Service Transactions), reviewed any comments submitted on Recommendation 2007 Annual Plan Item 3(a)(2) in preparation of the WEQ Executive Committee meeting, and planned the work of the subcommittee for the first quarter 2007.

• January 26, 2007: The ESS/ITS met via conference call on January 26. During this meeting, the participants voted to send Recommendation R04035/R05002 (S&CP) for formal comment. This recommendation states that no additional changes to the S&CPs are needed to implement the modifications to the OASIS business practices adopted in Final Action R04035/R05002. The ESS/ITS also began considering what changes are needed to the S&CPs to implement the OASIS business practices adopted in Final Action R04006D. During this meeting, the ESS/ITS also continued reviewing the draft Implementation Guide and companion revisions to the S&CPs drafted by Mr. Sorenson.

• January 30, 2007: The ESS/ITS and BPS met jointly via conference call on January 30. During this call, the subcommittees reviewed the draft language for NERC MOD002, and MOD003. The group made comments on MOD003 for review by the NERC ATC Drafting Team. The joint subcommittees also continued to discuss Items 1A and 3E of Request No. R05004A.

• February 9, 2007: The ESS/ITS and BPS met jointly via conference call on February 9. During this meeting, the subcommittees conducted a final review of the draft language for NERC MOD001 scheduled to be posted for comment by NERC on February 15. The subcommittees continued to discuss potential language for Item 1A of Request No. R05004A, discussed draft language for Item 3E, and discussed Items 2 and 3(d) for Request No. R05004A (the CBM Items).

• February 12-13, 2007: The ESS/ITS met at NAESB’s offices in Houston, Texas on February 12-13. During this meeting, the subcommittee reviewed the draft Implementation Guide that contains the business process components of the existing Standards & Communication Protocols (S&CPs); reviewed draft language for the S&CPs to implement the OASIS business practices ratified for Resales and Transfers; reviewed work papers for Network Service on OASIS, and had an update on the ATC work.

• February 26, 2007: The ESS/ITS met via conference call on February 26. The ESS/ITS continued the review of the draft Implementation Guide and proposed revision to the S&CPs with recommended changes included to complement the business practice standards ratified in Final Action R04006D – Sale or Assignment of Transmission






Service (Resales and Transfers) and conducted a discussion of FERC Order 890 with special attention to the sections in the Order regarding Capacity Reassignment

• March 1-2, 2007: The ESS/ITS and BPS met jointly with the NERC ATC Drafting Team in Memphis, Tennessee. During this meeting, the joint groups discussed the implications of Order 890 on the work of the NERC ATC Drafting Team; discussed the fact that NERC would like to retire MOD003 in favor of NAESB adopting the business practices covered in MOD003; discussed the protocol for reviewing comments on draft standards per the Joint Development Procedure. The NERC ATC Drafting Team also made assignments on various aspects of ETC and TRM and discussed changes that need to be made to NERC FACs 12 and 13.

• March 7, 2007: The ESS/ITS and BPS met jointly via conference call on March 7. During this call, the subcommittees reviewed the Order 890 Matrix and developed a preliminary work plan for the groups to draft business practices to address the ATC items in the Order in addition to drafting complementary standards to the NERC ATC standards.

• March 15-16, 2007: The ESS/ITS is scheduled to meet at NAESB’s offices in Houston, Texas on March 15-16. During this meeting, the ESS/ITS reviewed the work papers drafted to address Request No. R04006E (Network Service Transactions); created a work plan to complete the Implementation Guide for the S&CPs and the Order 890 work (this work product was posted for informal comment after this meeting); reviewed the proposed modifications to the Resales and Transfers business practices in light of Order 890; and discussed participants’ comments on how to proceed on the modification of Standard WEQ001-9.7 ;; and had an update on the ATC efforts with the BPS and the NERC ATC Drafting Team.

• March 23, 2007: The ESS/ITS and BPS met jointly with the NERC ATC Drafting Team via conference call on March 23. The NAESB ESS/ITS and BPS participants provided comments on the draft of NERC MOD008 and the NERC ATC Drafting Team to assigned teams to draft responses to any comments that are received on MOD001.

• March 26, 2007: The ESS/ITS met via conference call on March 26. During this call, the ESS/ITS reviewed comments submitted in response to the request for informal comment for the proposed changes to the Resales Standards in light of Order 890. The revised document was posted for informal comment a 2nd time.

• April 3-4, 2007: The ESS/ITS met at NAESB’s offices in Houston, Texas on April 3-4. During this meeting, the ESS/ITS reviewed comments submitted in response to the request for informal comment for the proposed changes to the Resales Standards in light of Order 890 and voted to send the revised recommendation to the Executive Committee and for formal comment. The ESS/ITS also worked on splitting the S&CP into two documents: The S&CP and Implementation Guide pursuant to Request No. R07002 (Request to divide the OASIS S&CP into two documents: The S&CP and 2) an Implementation Guide).

• Planned, April 17, 2007: The ESS/ITS and BPS is scheduled to meet jointly at NAESB’s offices in Houston, Texas. The agenda for this meeting will include: review draft of language for business practices to incorporate the requirements of NERC MOD003 (NERC plans to retire this standard); drafting of language to address adoption of requirements currently in MOD006 (NERC plans to retire this standard); review draft of language for business practices for frequency and posting requirements for all ATC components; identify need for additional business practices to complement MOD001; and identification of how to account for counterflows in the posting requirements.

• April 23, 2007: The WEQ BPS and ESS/ITS met jointly with the NERC ATC Standards Drafting Team in Houston, TX to review comments submitted on NERC MOD-001. The team noted commercial issues identified in those comments, and the NERC chart on comments was updated to include action items for the NAESB team. This chart is posted on the NAESB website at http://www.naesb.org/pdf2/weq_atc_afc042307a4.doc. Most action items identified for the NAESB team were the corresponding posting requirements for MOD-001. In addition, the team discussed a web-ex to be held by NERC for the industry to explain the upcoming changes to be implemented under the revised MOD-001. The NAESB team reviewed language drafted for NERC MOD-003, recently posted for an informal comment period. It is NERC’s plan to retire MOD-003 and for the standard to be held at NAESB. Comments on this language are due May 1, 2007.






• Planned, May 3, 2007: The WEQ BPS and ESS/ITS will meet via conference call to review comments submitted on

the standards language drafted for NERC MOD-003. In addition and time permitting, the WEQ BPS will begin drafting the posting requirement language for posting standards that correspond to NERC MOD-001.

• Planned, May 9, 2007: The ESS/ITS is scheduled to meet in Washington, DC hosted by American Gas Association on May 9. The agenda for this meeting will include: continued review and discussion of the split of the S&CP into two documents per Request No. R07002 (Request to divide the OASIS S&CP into two documents: The S&CP and 2) an Implementation Guide). These split documents will also incorporate some of the revisions needed to the S&CP to comply with Order 890.

• Planned, May 10, 2007: The WEQ BPS and ESS/ITS will meet jointly via conference call to continue work on standards language for ATC posting requirements as identified in the development of NERC MOD-001.

• Planned, May 17, 2007: The WEQ BPS and ESS/ITS will meet jointly in Atlanta, Georgia to review and update each other on progress made regarding standards development for Order No. 890. NERC will review language drafted for their CBM and TRM standards. NAESB will review industry comments submitted on language drafted for NERC MOD-003 (NERC plans to retire this standard). In addition, the NAESB team will update the NERC team on progress made regarding posting requirements for ATC.

NERC/NAESB Joint Interchange Scheduling Working Group

• January 23-24, 2007: The JISWG met in Houston, TX to continue work to update the NAESB R05001 Coordinate Interchange Standard and the NERC INT Version 1 Standards to align them with changes made to the e-Tag tool and Interchange timing tables. In addition, reviewed section 1303-Personnel & Training and found out that no business practices are needed. The working group also recommended a minor change to the “timing table” previously published, to correct an inadvertent error affecting only WECC.

• February 14, 2007: The JISWG met jointly with NERC’s Interchange subcommittee to explain the e-Tag update and WECC minor change JISWG had approved on January 24.

• February 26, 2007: The JISWG met via conference call on February 26 and approved for NERC and NAESB publication for informal industry comments the Draft e-Tagging Functional Specifications, Version 1.8

• March 5, 2007: The JISWG met via conference call with the e-Tag software vendors to collect their informal comments on draft Version 1.8.

• March 9, 2007: The JISWG again met via conference call with the e-Tag software vendors to collect the remainder of their informal comments on draft Version 1.8.

• March 16, 2007: The JISWG again met via conference call with the e-Tag software vendors to dialogue about the last of their informal comments on draft Version 1.8.

• March 19, 2007: The JISWG met via conference call to discuss all comments received on draft Version 1.8 of the e-Tag specification and schema. Members also agreed on an implementation plan to ratify, publish, test and train, culminating in a “go live” of Version 1.8 on December 5, 2007.

Business Practices Subcommittee

• January 3, 2007: The WEQ BPS met to plan for upcoming joint meetings with the NERC TLR Standards Drafting Team. These meetings will be held in January, February, and March in an effort to complete the NERC portion of the TLR post split standards. The subcommittee discussed how the development of the NERC standards could affect the companion NAESB business practices, ratified in April 2006.

• Planned, January 8, 2007: The WEQ BPS and ESS/ITS met via conference call jointly to review comments submitted on the Contract Path definition (Item 1D of R05004A). The group also reviewed progress made on work






papers drafted to outline the standards language for Item 3E of R05004A. The subcommittee reviewed the progress of the NERC ATC Drafting Team.

• January 9-10, 2007: The WEQ BPS met jointly with the NERC TLR Drafting Team in Houston, Texas. The grouped helped the NERC team to draft the split of the TLR reliability standards.

• January 30, 2007: The ESS/ITS and BPS met jointly via conference call on January 30. During this call, the subcommittees reviewed the draft language for NERC MOD002, and MOD003. The group made comments on MOD003 for review by the NERC ATC Drafting Team. The joint subcommittees also continued to discuss Items 1A and 3E of Request No. R05004A.

• February 9, 2007: The ESS/ITS and BPS met jointly via conference call on February 9. During this meeting, the subcommittees conducted a final review of the draft language for NERC MOD001 scheduled to be posted for comment by NERC on February 15. The subcommittees continued to discuss potential language for Item 1A of Request No. R05004A, discussed draft language for Item 3E, and discussed Items 2 and 3(d) for Request No. R05004A (the CBM Items).

• February 27-28, 2007: The WEQ BPS met jointly with the NERC TLR Drafting Team in Birmingham, Alabama hosted by Southern Company. During this meeting, the joint groups heard a Report of Incremental Changes that Have Been Incorporated into the Existing NAESB TLR Standards; worked on the Mapping of NERC IRO-006 Attachment 1; discussed the NERC Field Test for MISO and PJM; and developed an IDC Reference Document for TLR;.

• March 1-2, 2007: The ESS/ITS and BPS met jointly with the NERC ATC Drafting Team in Memphis, Tennessee. During this meeting, the joint groups discussed the implications of Order 890 on the work of the NERC ATC Drafting Team; discussed the fact that NERC would like to retire MOD003 in favor of NAESB adopting the business practices covered in MOD003; discussed the protocol for reviewing comments on draft standards per the Joint Development Procedure. The NERC ATC Drafting Team also made assignments on various aspects of ETC and TRM and discussed changes that need to be made to NERC FACs 12 and 13..

• March 7, 2007: The ESS/ITS and BPS met jointly via conference call on March 7. During this call, the subcommittees reviewed the Order 890 Matrix and developed a preliminary work plan for the groups to draft business practices to address the ATC items in the Order in addition to drafting complementary standards to the NERC ATC standards.

• March 19, 2007: The BPS met via conference call to discuss the progress of the NERC TLR Drafting Team and draft language to address minor changes identified during the last meeting with the NERC TLR Drafting Team including a revision to TLR Level 5A. The team copied language for Reallocation from TLR level 3A and modified it for a Reallocation under a TLR Level 5A. The WEQ BPS will review these changes with the NERC TLR Standards Drafting Team at the next joint meeting.

• March 23, 2007: The ESS/ITS and BPS met jointly with the NERC ATC Drafting Team via conference call on March 23. The NAESB ESS/ITS and BPS participants provided comments on the draft of NERC MOD008 and the NERC ATC Drafting Team to assigned teams to draft responses to any comments that are received on MOD001.

• April 17, 2007: The ESS/ITS and BPS is scheduled to met jointly at NAESB’s offices in Houston, Texas. The ESS/ITS and BPS drafted standards language for NERC MOD-003. NERC plans to officially retire this MOD, as it has been determined to be commercial in nature (standards language is on how to contact a company with questions concerning their ATCs.) The team posted the draft language for an informal comment period. Comments on the language are due May 1, 2007. The team will review comments submitted during their May 3rd call. The agenda for this meeting will include: review draft of language for business practices to incorporate the requirements of NERC MOD003 (NERC plans to retire this standard); drafting of language to address adoption of requirements currently in MOD006 (NERC plans to retire this standard); review draft of language for business practices for frequency and






posting requirements for all ATC components; identify need for additional business practices to complement MOD001; and identification of how to account for counter flows in the posting requirements.

• April 18-19, 2007: The WEQ BPS met jointly with the NERC TLR Standards Drafting Team in Carmel, Indiana to continue work on the NERC TLR Reliability Standards. The team identified the documents that would be necessary for the NERC comment posting period, scheduled for May 1, 2007. Those documents included the redlined changes for the NERC reliability standards, this document with all changes accepted, IRO-006-4 (both redline and clean), and the comment form. The team recognized that several reference pieces would be necessary for the comment period, for commenters to make sure no piece of the TLR standard was overlooked in the split. The NAESB TLR Business Practices were noted by the team as being a necessary reference tool for the NERC comment period. The team also drafted a white paper for TLR to explain the process behind the split of the reliability standards and commercial standards. Minor corrections were identified by the joint team for the NAESB TLR Business Practice Standards. Those minor corrections will be considered by the WEQ BPS on May 1, 2007. Those minor corrections include corrected reference numbers to standards and the inclusion of Dynamic Schedule language for TLR Levels 5A and 5B.

• April 23, 2007: The WEQ BPS and ESS/ITS met jointly with the NERC ATC Standards Drafting Team in Houston, TX to review comments submitted on NERC MOD-001. The team noted commercial issues identified in those comments, and the NERC chart on comments was updated to include action items for the NAESB team. This chart is posted on the NAESB website at http://www.naesb.org/pdf2/weq_atc_afc042307a4.doc. Most action items identified for the NAESB team were the corresponding posting requirements for MOD-001. In addition, the team discussed a web-ex to be held by NERC for the industry to explain the upcoming changes to be implemented under the revised MOD-001. The NAESB team reviewed language drafted for NERC MOD-003, recently posted for an informal comment period. It is NERC’s plan to retire MOD-003 and for the standard to be held at NAESB. Comments on this language are due May 1, 2007.

• April 26, 2007: The WEQ BPS met jointly with the NERC TLR Standards Drafting Team via conference call to prepare the NERC TLR Reliability Standards for their comment posting period. The documents to be posted for the comment period were reviewed. The team noted minor changes to be made to the documents prior to posting. It is NERC’s plan to post the standards for comment on May 1, 2007. The comment period is 45 days long. The NERC team submitted the standards to Ms. Maureen of Long of NERC for her review prior to posting. As of today, May 1, it is the intent of NERC to post the standards by the end of the day for comment.

• May 1, 2007: The WEQ BPS considered the minor corrections identified by the joint NERC/NAESB TLR team on April 18-19, 2007. Those minor corrections were voted out of the subcommittee and will be posted to the WEQ Executive Committee. The WEQ BPS discussed the upcoming schedule of meetings for summer 2007.

• Planned, May 3, 2007: The WEQ BPS and ESS/ITS will meet via conference call to review comments submitted on the standards language drafted for NERC MOD-003. In addition and time permitting, the WEQ BPS will begin drafting the posting requirement language for posting standards that correspond to NERC MOD-001.

• Planned, May 10, 2007: The WEQ BPS and ESS/ITS will meet jointly via conference call to continue work on standards language for ATC posting requirements as identified in the development of NERC MOD-001.

• Planned, May 17, 2007: The WEQ BPS and ESS/ITS will meet jointly in Atlanta, Georgia to review and update each other on progress made regarding standards development for Order No. 890. NERC will review language drafted for their CBM and TRM standards. NAESB will review industry comments submitted on language drafted for NERC MOD-003 (NERC plans to retire this standard). In addition, the NAESB team will update the NERC team on progress made regarding posting requirements for ATC.

• Planned, May 23-24, 2007: The WEQ BPS will meet jointly with the NERC TLR Standards Drafting Team in Chattanooga, TN to being work on phase 2 of the NERC TLR SAR. Phase 2 is a field test for PJM/MISO to change their curtailment threshold. The results of this field test will most likely become commercial TLR standards






• Planned, June 19-20, 2007: The WEQ BPS will meet jointly with the NERC TLR Standards Drafting Team

(location to be determined) to review comments submitted on the NERC TLR Reliability Standards. After this meeting, it should become clear whether a second posting for comments is necessary for the NERC TLR standards.Planned, May 23-24, 2007: The WEQ BPS will meet jointly with the NERC TLR Standards Drafting Team in Chattanooga, TN to continue work on the TLR standards. The teams expect to begin work on Phase 3 of the NERC TLR SAR, the field test on curtailment threshold for PJM.

• Planned, June 19-20, 2007: The WEQ BPS will meet jointly with the NERC TLR Standards Drafting Team to review comments submitted on the NERC TLR standard. At this time, it will be determined if the TLR standard must undergo an additional round of industry comments. If changes are made to the standard as a result of the first round of comments, it must be reposted for comment.

Standards Review Subcommittee

• January 29, 2007: The SRS reviewed the following NERC reliability standards in development to determine if complementary NAESB business practice standards are needed: Resource Adequacy Assessments, Revisions to BAL-004 – Time Error Correction, Revisions to BAL-005 – ACE Equation Implementation, Revisions to BAL-006 – Inadvertent Interchange Data, Revisions to IRO-004 – Require timely submission of data, Nuclear Plant Off-site Power Supply Coordination, Under-frequency Load Shedding and Voltage and Reactive Control. The group also agreed to add to their phone conferences web casts of the text of each SAR posted by NERC, so that comments can be prepared on the spot.

• March 19, 2007: The SRS met for the first time with web conferencing and proceeded straight to NERC’s website list of Standards Under Development. Seventeen SARS and draft Standards were reviewed and five were determined not to involve any commercial impacts. The other twelve will involve NAESB, but in most cases, the drafting at NERC is so prolonged it is impossible to determine at this time what in particular NAESB will be called upon to draft.

Seams Subcommittee

• January 16, 2007: The Seams Subcommittee, reactivated by the WEQ Executive Committee during the November 14 meeting, met via conference call on January 16, 2007. During this call, the Seams Subcommittee will to discuss the Seams Catalog and any potential business practice standards related issues. This group will be chaired by Mr. Schwermann.

• February 7, 2007: The Seams Subcommittee met in Houston, Texas on February 7. The Seams Subcommittee reviewed and updated the Seams Matrix dated February 2004 to determine if any of the remaining issues are ripe for business practice standards development. An outreach will be conducted to the WECC, the IRC, EEI, and WSPP to determine if some of the issues are being addressed in those forums.

• March 9, 2007: The NAESB office distributed several letters on behalf of the chair of the Seams Subcommittee, Mr. Schwermann. The letters were distributed via e-mail to: APPA, WSPP, WECC (the Seams Issues Subcommittee and the Information Scheduling and Accounting Subcommittee), EEI, and IRC. The included several inquiries regarding some of the Seams issues and whether the various organizations could provide additional information on the resolution of those issues and/or were willing to participate in an effort to address the issues with the NAESB Seams Subcommittee.






JJOOIINNTT QQUUAADDRRAANNTT EEFFFFOORRTTSS

DDSSMM--EEEE PPRROOJJEECCTT –– AASSSSIIGGNNEEDD TTOO RREETTAAIILL GGAASS,, RREETTAAIILL EELLEECCTTRRIICC AANNDD WWHHOOLLEESSAALLEE EELLEECCTTRRIICC::

• April 11, 2007: Several representatives of the NAESB WEQ, REQ, and RGQ as well as representatives of the US Department of Energy, US Environmental Protection Agency, FERC, and other industry experts met at the Department of Energy offices in Washington, D.C. to discuss the NAESB effort to draft business practices for Demand Side Management and Energy Efficiency. Ongoing Energy Efficiency and DSM projects and programs by other groups (such as NAPEE) were reviewed by the meeting attendees. The following resolution outlines the scope of the initial effort by NAESB to draft business practice standards for these topics: It was decided that NAESB should begin its standards development focus on measurement and verification of energy savings and peak demand reduction from both a wholesale and retail electric market perspective. A future schedule of meetings for DSM and Energy Efficiency should be posted on the NAESB website shortly.

EE--TTAARRIIFFFF SSTTAANNDDAARRDDSS DDEEVVEELLOOPPMMEENNTT –– AASSSSIIGGNNEEDD TTOO WWHHOOLLEESSAALLEE GGAASS AANNDD WWHHOOLLEESSAALLEE EELLEECCTTRRIICC::

• February 1, 2007 : A meeting was held at the FERC, opened by Chairman Kelliher. Proposals from INGAA, EEI, AOPL and Texas Intrastate Association were given, along with a review by FERC staff of requirements to be met for an e-Tariff program.

• March 13, 2007: A meeting was held at NAESB offices, chaired by Keith Sappenfield and Jane Daly. The FERC staff further delineated their requirements and answered questions from EEI and INGAA. The group began drafting standards.

• April 26, 2007: The e-Tariff Subcommittee met in Washington DC hosted by AGA. During this meeting, FERC Staff reviewed their work paper Filing Field Data Example Submitted by FERC Staff and answered questions on what data will be required for submittal of electronic tariff and related documents. The pipeline segment also presented their proposed approach regarding development of e-Tariff standards. After further discussion, it was determined that the e-Tariff Subcommittee needed to schedule a conference call prior to the June 4 meeting to determine what approach the NAESB e-Tariff standards will take.

• Planned, May 21, 2007: The e-Tariff Subcommittee will meet via conference call for a one topic agenda – to determine the approach the NAESB e-Tariff standards will take.

• Planned, June 4, 2007: The group plans to meet in Phoenix, hosted by APS to continue drafting standards.


North American Energy Standards Board 1301 Fannin, Suite 2350, Houston, Texas 77002

Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail: [email protected] Home Page: www.naesb.org

Order 890 Identification of NAESB Standards Development Tasks – Updated April 16, 2007 Page 1 of 45

March 2, 2007

TO: NAESB OATT Distribution List, NAESB Subcommittee Chairs and NAESB OATT NOPR Team

cc: Gerry Adamski

FROM: Rae McQuade, Kathy York

RE: Order 890 Identification of NAESB Standards Development Tasks, Planning

via email

Dear OATT Distribution List, Subcommittee Chairs, and OATT NOPR Team:

On February 16, the FERC released Order No. 890 (Docket Nos. RM05-17-000 and RM05-25-000); “Preventing Undue Discrimination and Preference in Transmission Service.” It can be accessed through the hyperlink provided in the above text. The final order has not yet been published in the Federal Register. As provided on February 26, the attached matrix identifies the cites and the language in the final order in which the Commission has specifically notes that NAESB should develop business practices or is not expected to develop business practices (as noted in the sections on “Commission Determination”).

The matrix now has some open spaces, where we would ask you to do the following:

Column 1 Review the item and if the work is already underway in a particular subcommittee, please indicate which NAESB committee is performing the task. If you have opinions on where the item should be assigned, please also note in this column..

Column 2 If the work described by the item is already underway, the status should be “underway”. If the work is planned but has not yet started, the status should be “assigned.” Otherwise the status should be blank.

Column 3 Any notes you have on a given item that would help in the planning should be put in column 3.

This matrix and your comments will be the basis for planning how NAESB will address the items assigned to it. We would appreciate your remarks by March 19.

Several of you are now on a OATT Order 890 distribution list ([email protected]), and can email each other through the use of this distribution lists. You can be seen on page 2 of this document. If you would like to work on this effort or have colleagues that would like to work on this effort, please inform the NAESB office that you would like to be added to the OATT Order 890 distribution list. The OATT NOPR team list put together last year is not automatically added to this distribution, so please check to see if you want your address added. We very much appreciate the 18 individuals that have volunteered to date, and hope to see more volunteers in the future.

For response to the FERC, once published in the Federal Register, NAESB is to provide the following:

90 days after publication NERC/NAESB status report and work plan for completion of ATC related business practices and standards, (paragraph 223)

90 days after publication NAESB status report and work plan for completion of OASIS functionality or uniform business practices (other than those related to ATC), (paragraph 141)

We appreciate the recognition given to NAESB in this final order and look forward to working with you in our NAESB committee structure to meet the Commission’s and the industry’s expectations.

With Best Regards,

Rae and Kathy





NAESB ORDER 890 ANALYSIS TEAM

MEMBERS OF THE OATT ORDER 890 DISTRIBUTION LIST ([email protected])

Jim Busbin Southern Company Services, Inc.

Roman Carter Southern Company

Valerie Crockett Tennessee Valley Authority

Michael Desselle Southwest Power Pool

Joel Dison Southern Company

Bill Gallagher Vermont Public Power Supply Authority

Mike Gildea Constellation Generation Group

Terri Grabiak Allegheny Power

Jim Hansen Seattle City Light

Bob Harshbarger Puget Sound Energy

Laura Kennedy NAESB

Rae McQuade NAESB

Ron Mucci Williams Power

Clay Norris Carolina Municipal Power Agency #1

Lou Oberski Dominion Resource Services, Inc.

Alan Pritchard Duke Energy

Barbara Rehman Bonneville Power Administration

Narinder Saini Entergy

Paul Sorenson Open Access Technology International, Inc.

Jim Stanton Representing ICF International

Roy True ACES Power Marketing, Inc.

Dean Ulch Southern Company

J.T. Wood Southern Company Services Inc.

Kathy York Tennessee Valley Authority





Order 890 Identification of NAESB Standards Development Tasksf

Page Cite 1. Assigned ? 2. Status 3. Notes/Comments

95-6 141. Other reforms adopted in the Final Rule will involve coordination with the North American Energy Standards Board (NAESB) to establish OASIS functionality or uniform business practices. The Commission requests that NAESB file a status report within 90 days of publication of the Final Rule in the Federal Register that contains a work plan for development of such OASIS functionality and business practices. This work plan should indicate, for each reform, what actions are necessary and an estimate of the timeframe for completing those actions. Pending resolution of these issues with NAESB, the Commission requires that each transmission provider develop its own OASIS functionality or business practice necessary to implement each such reform within 90 days of publication of the Final Rule in the Federal Register, unless a different compliance requirement is otherwise specified in this Final Rule. Upon review of this work plan, the Commission will issue an order establishing further compliance deadlines as necessary.

K. York, TVA Comment: Joint SCs - BPS/ESS/

ITS

K. York, TVA Comment: Underway

ESS/ITS comment: Timeframes for Implementation.

K. York, TVA Comment: Joint BPS/ESS/ITS Committee prepared short-term plan and ESS/ITS preparing detailed plan as well

127 194. In the NOPR, the Commission proposed to address this potential for undue discrimination by requiring industry-wide consistency and transparency of all components of the ATC calculation methodology and certain definitions, data, and modeling assumptions. The Commission proposed to provide guidance regarding aspects of ATC calculations that should be more consistent and proposed to direct public utilities, working through NERC and NAESB, to revise reliability standards and business practices that are relevant to ATC calculations. The Commission also proposed to require increased detail in Attachment C of each transmission provider’s OATT and proposed amending the OASIS regulations to require increased transparency. Although commenters challenged aspects of this proposed remedy, no commenters challenged the underlying finding that ATC reform is necessary to remedy undue discrimination in the provision of transmission service.

K. York, TVA Comment: Joint BPS/ESS/ITS working on ATC


ESS/ITS comment: Actions are addressed under specific citations with respect to ATC.

K. York, TVA Comment: Some progress made; working with NERC on comments to MOD-001 will allow more clarity

128 196. In light of these concerns, we direct public utilities, working through NERC reliability standards and NAESB business practices development processes, to produce workable solutions to complex and contentious issues surrounding improving the consistency and transparency of ATC calculations. We are directing our guidance to public utilities and require that they implement our direction by working with NERC to develop reliability standards that accomplish the ATC reforms required in this rulemaking. We will coordinate our directives here with the ATC-related reliability standards that are pending in Docket No. RM06-16-000. The specifics of our findings

ATC Group and ESS/ITS Comment: ATC Group

K. York, TVA


BPS and ESS/ITS (ATC Group) comment: NERC community recognizes that MOD003 (Procedure for Input on TTC and ATC Methodologies and Values), MOD006 (Procedure for use of CBM Values) and MOD009 (Procedure for Verifying TRM Values) are business practices and recommend that those be retired at NERC and adopted by






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments with respect to ATC reform are discussed below. Comment:

Joint BPS/ESS/ITS

NAESB as business practice standards.

K. York, TVA Comment: Review of industry comments to NERC MOD-001 for ATC Calculations will provide more clarity; review to begin March 23rd

139 214. In the NOPR, the Commission expressed confidence that the existing NERC and NAESB processes were well-suited to achieving greater consistency in ATC calculations. The Commission therefore proposed to require public utilities, working through NERC and NAESB, to revise the reliability standards and business practices relating to ATC, consistent with the guidance provided in the Final Rule, within 180 days after the publication of the Final Rule in the Federal Register.

K. York, TVA Comment: Joint BPS/ESS/ITS


ESS/ITS comment: Actions are addressed under specific citations with respect to ATC.

K. York, TVA Comment: Also joint work with NERC

144 221. The Commission directs public utilities, working through NERC and NAESB, to modify the ATC-related reliability standards and business practices in accordance with specific direction provided in this Final Rule. As we explain above, the development of a more coherent and uniform determination of ATC across a region will help limit the potential for undue discrimination in the calculation of ATC. The Commission concludes that the NERC reliability standards development process and the NAESB business practices development process are the appropriate forums for developing this consistency.

K. York, TVA Comment: Join BPS/ESS/ITS


ESS/ITS comment: General directive

K. York, TVA Comment: Also joint work with NERC

144-5 222. NERC has been certified as the ERO and, as such, has been found to have the ability to develop reliability standards through processes with reasonable notice and opportunity for public comment. NERC’s processes are open and provide due process as well as a balance of interests, while assuring independence from users and owners and operators of the bulk-power system. Moreover, NAESB has a long history of developing standard business practices for the electric industry, on which the Commission has relied in various contexts. While other entities may bring certain benefits, commenters have not demonstrated the superiority of IEEE, a regional reliability organization, or a particular RTO over NERC and NAESB. Once components of ATC are made consistent and ATC calculation methodologies are made transparent, opportunities for discretion that may lead to undue discrimination in the calculation of ATC will be sufficiently eliminated to invalidate the need for the creation of independent entities to oversee that calculation. To the extent that, even following the adoption of these reforms, customers have complaints regarding the calculations performed by individual transmission owners, they can be

K. York, TVA Comment: Joint BPS/ESS/ITS SC


ESS/ITS comment: General directive






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments addressed on a case-by-case basis.

145-6 223. With respect to a timeline for completion, the Commission concurs with NERC that a significant amount of work remains to be done on ATC-related reliability standards development. We also agree with the many commenters who state that the NOPR’s proposed six-month timeline is too short for such a complex assignment. Although NERC projects that it may be able to complete the process by the summer of 2007 (which is approximately six months from the date of the Final Rule), we believe NERC should have additional flexibility with respect to its timeline. Accordingly, we direct public utilities, working through NERC, to modify the ATC-related reliability standards within 270 days after the publication of the Final Rule in the Federal Register. We also direct public utilities to work through NAESB to develop business practices that complement NERC’s new reliability standards within 360 days after the publication of the Final Rule in the Federal Register. Finally, we direct NERC and NAESB to file, within 90 days of publication of the Final Rule in the Federal Register, a joint status report on standards and business practices development and a work plan for completion of this task within the timeframe established above.

K. York, TVA Comment: Joint BPS/ESS/ITS SC

K. York, TVA Comment: Work plans underway

ESS/ITS comment: Timeline

K. York, TVA Comment: Short-term plan for BPS complete; ESS/ITS working on more detailed plan for OASIS work

155 243. To achieve greater consistency in ETC calculations and further reduce the potential for undue discrimination, the Commission adopts the NOPR proposal and directs public utilities, working through NERC and NAESB, to develop a consistent approach for determining the amount of transfer capability a transmission provider may set aside for its native load and other committed uses. We expect that NERC will address ETC through the MOD-001 reliability standard rather than through a separate reliability standard. By using MOD-001, the ETC calculation can be adjusted to be applicable to each of the three ATC methodologies under development by NERC.

ESS/ITS Comment: ATC Group

And

ESS/ITS

K. York, TVA Comment: Joint BPS/ESS/ITS and joint NERC team


BPS and ESS/ITS (ATC Group) comment: NAESB should review NERC’s ETC work carefully to provide insight into ETC

BPS and ESS/ITS (ATC Group) comment: NAESB: provide place to post ETC and develop frequency of posting requirements in business practice standards

ESS/ITS comment: Posting requirements will require development/revisions to the S&CP by the ESS/ITS. The ESS/ITS/BPS (ATC Group) should develop any necessary business practices other than S&CPs.

K. York, TVA Comment: NERC is working on ETC and plans to have NAESB develop definition for ETC







M. Gildea, Constellation Gen. Group Comment: NERC and NAESB, to develop a consistent approach for determining the amount of transfer capability a transmission provider may set aside for its native load and other committed uses. {Key work that will be difficult. We see the reference to MOD-001 is undertaking this task. This is positive. Will have to watching closely if this standard completely covers this assignment.}

156 246. We agree with NERC that some elements of ETC are candidates for business practices rather than reliability standards. Accordingly, we direct public utilities, working through NAESB, to develop business practices necessary for full implementation of the developed MOD-001 reliability standard.




BPS and ESS/ITS (ATC Group) comment: NAESB: Implementation of MOD001 via business practice standards

K. York, TVA Comment: Draft language being developed for 4/17/07 meeting

161 257. The Commission therefore adopts a combination of the NOPR options one and two, and declines to adopt option three. First, we require public utilities, working through NERC and NAESB, to develop clear standards for how the CBM value shall be determined, allocated across transmission paths, and used. We understand that NERC has already begun the process of modifying several of the CBM-related reliability standards and that the drafting process is a joint project with NAESB. Second, we require transmission providers to reflect the set-aside of transfer capability as CBM in the development of the rate for point-to-point transmission service.



K. York, TVA Comment: Assigned

BPS and ESS/ITS (ATC Group) comment: NAESB: NERC plans to retire MOD006 so that NAESB can adopt business practice standards for use of CBM values

ESS/ITS comment: This item is also covered in Request No. R05004A items 2a and 3d

K. York, TVA Comment: NERC to send work on CBM uses to NAESB for business practice

M. Gildea, Constellation Gen. Group Comment:






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments NERC and NAESB, to develop clear standards for how the CBM value shall be determined, allocated across transmission paths and used. {This is an important subcomponent of the ATC elements identified in page 127 above}

163 262. Concerning TAPS’ proposal to remove the reservation decision from the sole discretion of transmission providers, we determine that LSEs should be permitted to call for use of CBM, if they do so pursuant to conditions established in the reliability standards development process. We direct public utilities working through NERC to modify the CBM-related standards to specify the generation deficiency conditions during which an LSE will be allowed to use the transfer capability reserved as CBM. In addition, we direct that transmission set aside as CBM shall be zero in non-firm ATC calculations. Finally, we order public utilities to work with NAESB to develop an OASIS mechanism that will allow for auditing of CBM usage.


And

ESS/ITS



BPS and ESS/ITS (ATC Group) comment: NAESB ESS/ITS: need to develop mechanism for LSEs to call for use of CBM: not clear will be an online request or done outside of OASIS

ESS/ITS comment: Will require changes for S&CP, new templates. NAESB may need to define the product depending on the outcome of NERC standards development.

BPS and ESS/ITS (ATC Group) comment: NAESB ESS/ITS should come up with mechanism to track the usage of CBM (tagging requirements, etc.)

M. Gildea, Constellation Gen. Group Comment: Two important sub-components of page 161 above:

1) LSEs should be permitted to call for use of CBM;

OASIS mechanism that will allow for auditing of CBM usage

167 272. The Commission adopts the NOPR proposal and requires public utilities, working through NERC, to complete the ongoing process of modifying TRM standards MOD-008 and MOD-009. We understand that the standard drafting process is underway as a joint

ESS/ITS Comment:

ESS/ITS comment: NAESB needs to develop Business Practices for verification of TRM (NERC plans to recommend that MOD 009 be






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments project with NAESB. ATC Group

K. York, TVA Comment: NERC

retired at NERC and adopted by NAESB as Business Practice Standards)

K. York, TVA Comment: NAESB to review and comment on MOD-008 on 3/23/07; NERC to post 4/1/07

M. Gildea, Constellation Gen. Group Comment: TRM standards MOD-008 and MOD-009. We understand that the standard drafting process is underway as a joint project with NAESB. {This is another element identified on page 127 above where NAESB must work with NERC.)

167-8 273. The Commission also adopts the NOPR proposal to establish standards specifying the appropriate uses of TRM to guide NERC and NAESB in the drafting process. Transmission providers may set aside TRM for (1) load forecast and load distribution error, (2) variations in facility loadings, (3) uncertainty in transmission system topology, (4) loop flow impact, (5) variations in generation dispatch, (6) automatic sharing of reserves, and (7) other uncertainties as identified through the NERC reliability standards development process. Because load, facility loading and other uncertainties constantly deviate, we will not require that TRM set aside capacity be set at zero in the non-firm ATC calculation. In other words, we will not require transfer capability that is set aside as TRM to be sold on a non-firm basis. We find that clear specification in this Final Rule of the permitted purposes for which entities may reserve CBM and TRM will virtually eliminate double-counting of TRM and CBM.


K. York, TVA Comment: NERC

ESS/ITS comment: NAESB will need to work with NERC to ensure these elements are included in the reliability standards

ESS/ITS comment: NAESB will need to develop Business Practices to prevent double counting of CBM and TRM.

177 293. With regard to EPSA’s request for the standardization of additional data inputs, we believe they are already captured in the Commission’s proposal as adopted in this Final Rule. Xcel asks the Commission to require consistency in the determination of counterflows in the calculation of ATC. Counterflows are included in the list of assumptions that public utilities, working through NERC, are required to make consistent. We believe that counterflows, if treated inconsistently, can adversely affect reliability and competition, depending on how they are accounted for. Accordingly, we reiterate that public utilities, working through NERC and NAESB, are directed to develop an approach


K. York, TVA Comment: Joint


BPS and ESS/ITS (ATC Group) comment: NAESB: need to identify how account for counterflows in the posting

M. Gildea, Constellation Gen. Group Comment: NERC and NAESB, are directed to develop an approach for accounting for counterflows {Another important component of the ATC work






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments for accounting for counterflows, in the relevant ATC standards and business practices. We find unnecessary Xcel’s request that we require a date certain for specific issues in the Western Interconnection to be addressed. Above we require public utilities, working through NERC, to modify the ATC standards within 270 days after the publication of the Final Rule in the Federal Register.

BPS/ESS/ITS

identified on page 127 above.}

181 301. The Commission adopts the NOPR proposal and requires the development of reliability standards that ensure ATC is calculated at consistent intervals among transmission providers. The Commission thus directs public utilities, working through NERC and NAESB, to revise reliability standard MOD-001 to require ATC to be recalculated by all transmission providers on a consistent time interval and in a manner that closely reflects the actual topology of the system, e.g., generation and transmission outages, load forecast, interchange schedules, transmission reservations, facility ratings, and other necessary data. This process must also consider whether ATC should be calculated more frequently for constrained facilities. ATC-related requirements for OASIS posting are discussed below.




BPS and ESS/ITS (ATC Group) comment: NAESB needs to develop business practices for intervals for posting of ATC (Request No. R05004A Item 3e (paragraph 168 of the NOPR) (ATC/AFC)

M. Gildea, Constellation Gen. Group Comment: ATC is calculated at consistent intervals among transmission providers. {Another important component of the ATC work identified on page 127 above.}

186 310. The Commission adopts the NOPR proposal and directs public utilities, working through NERC, to revise the related MOD reliability standards to require the exchange of data and coordination among transmission providers and, working through NAESB, to develop complementary business practices. The following data shall, at a minimum, be exchanged among transmission providers for the purposes of ATC modeling: (1) load levels; (2) transmission planned and contingency outages; (3) generation planned and contingency outages; (4) base generation dispatch; (5) existing transmission reservations, including counterflows; (6) ATC recalculation frequency and times; and (7) source/sink modeling identification. The Commission concludes that the exchange of such data is necessary to support the reforms requiring consistency in the determination of ATC adopted in this Final Rule. As explained above, transmission providers are required to coordinate the calculation of TTC/TFC and ATC/AFC with others and this requires a standard means of exchanging data.




ESS/ITS comment: NERC plans to address in MOD001 and FAC12 and NAESB plans to coordinate with NERC the development of these reliability standards.

K. York, TVA Comment: In NERC MOD-001 draft; need more clarity after 3/23/07 review of industry comments

M. Gildea, Constellation Gen. Group Comment: MOD reliability standards to require the exchange of data and coordination among transmission providers and, working through NAESB….standard means of exchanging data

{Another important component of the ATC work identified on page 127 above.}







194-5 325. We do not believe our requirement to include additional information in Attachment C will be overly burdensome or lead to an excessive level of future tariff revisions. Attachment C must provide an accurate documentation of processes and procedures related to the calculation of ATC, not the actual mathematical algorithms themselves, which should be posted on the transmission provider’s web site. These processes define service availability and, as such, must be part of the transmission provider’s OATT. It is entirely appropriate that, because revisions to such processes impact transmission availability, they should be filed for Commission approval and included in a transmission provider’s OATT. We also require transmission providers to file a revised Attachment C to incorporate any changes in NERC’s and NAESB’s revised reliability standards and business practices related to ATC calculations, as requested by the Commission in this Final Rule. This filing should be made within 60 days of completion of the NERC and NAESB processes. As we expect transmission providers to rarely change their ATC calculation methodologies, we do not believe this requirement will trigger an unacceptable level of tariff filings modifying the Attachment C description of the ATC components and processes.

K. York, TVA Comment: N/A

ESS/ITS comment: TP compliance issue after completion of standards development.

ESS/ITS QUESTION: what is the definition of the completion of NERC and NAESB processes?

214 369. The Commission adopts the NOPR proposal, with the modifications discussed below, to require that the transmission provider post a brief, but specific, narrative explanation of the reason for a change in monthly and yearly ATC values on a constrained path. Rather than requiring a narrative when a monthly or yearly ATC value changes as a result of transactions being reserved, service ending, or the TTC estimate for the path changing by more than 10 percent, we will require a narrative when a monthly or yearly ATC value changes only as a result of a 10 percent change in TTC. This will reduce the number of ATC changes for which a narrative will be required and address concerns that the new requirement unduly burdens transmission providers. Any remaining burden is justified by the benefit to transmission customers of receiving timely information regarding changes in TTC that result in changes to ATC. In addition, we adopt NAESB’s suggestion that posted information include the (1) specific events which gave rise to the change and (2) new values for ATC on that path (as opposed to all points on the network).

ESS/ITS Comment: ESS/ITS


ESS/ITS Comment: underway


BPS and ESS/ITS (ATC Group) comment: NAESB needs to review whether there is a place for posting the reason for change in ATC values on OASIS; consider whether to develop standard explanations

ESS/ITS comment: NOTE: may need to look at the design of the security template.

M. Gildea, Constellation Gen. Group Comment: “adopt NAESB’s suggestion that posted information include the (1) specific events which gave rise to the change and (2) new values for ATC on that path (as opposed to all points on the network”

NAESB may or may not need to provide and






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments standards guidance on this FERC directive. This should be examined after implementation or after taking requests from those doing the implementing.

220-1 385. The Commission adopts the NOPR proposal and requires transmission providers and network customers to use OASIS to request designation of new network resources and to terminate designation of network resources. This information shall be posted on OASIS for 90 days and available for audit for a five-year period. Transmission customers thus shall be able to query requests to designate and terminate a network resource. This requirement adds valuable transparency without undue burden, since it is nothing more than maintaining a database of designation requests made and responded to electronically. The Commission orders public utilities, working through NAESB, to develop appropriate templates for OASIS.





BPS and ESS/ITS (ATC Group) Comment: NAESB: ESS/ITS already working on this item under Request No. R04006E (Network on OASIS). The ESS/ITS will incorporate the directives in the order within the network on OASIS standards.

K. York, TVA Comment: Templates will most likely be worked on exclusively by ESS/ITS

M. Gildea, Constellation Gen. Group Comment: network customers to use OASIS to request designation of new network resources and to terminate designation of network resources… NAESB to arrive at templates…{needs to be assigned to a NAESB working group}

223 394. In response to NRECA and other commenters regarding the availability and format of data available on OASIS, we note that current regulations already require that OASIS data be made available in a useable, machine-readable user friendly format to transmission customers. The improvements required in the Final Rule will enhance the level of detail posted on OASIS and, in turn, transmission customers’ ability to verify the transmission provider’s treatment of transmission requests. Thus, to the extent NRECA or others desire greater consistency in data formats, they should propose such revisions through the NERC and NAESB processes.


K. York, TVA Comment: Will work on if requests are filed

232-3 413. The Commission adopts the proposed requirement to post on OASIS metrics related to the provision of transmission service under the OATT. Specifically, transmission providers must post (1) the number of affiliate versus non-affiliate requests for transmission service that have been rejected and (2) the number of affiliate versus non-affiliate requests for transmission service that have been made. This posting must detail


K. York,


BPS and ESS/ITS (ATC Group) comment: NAESB needs to develop business practices related to posting the metrics related to the provision of transmission service on OASIS






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments the length of service request (e.g., short-term or long-term) and the type of service requested (e.g., firm point-to-point, non-firm point-to-point or network service). The Commission also will require transmission providers to post their underlying load forecast assumptions for all ATC calculations and, to post on a daily basis, their actual daily peak load for the prior day. The Commission directs transmission providers to work through NAESB to develop standards for consistent methods of posting the new requirements on OASIS.

TVA Comment: Joint BPS/ESS/ITS

ESS/ITS comment: Posting, standardized format and Business Practices should be developed by the ESS/ITS.

M. Gildea, Constellation Gen. Group Comment: directs transmission providers to work through NAESB to develop standards for consistent methods of posting the new requirements on OASIS.:

1) the number of affiliate versus non-affiliate requests for transmission service that have been rejected;

2) the number of affiliate versus non-affiliate requests for transmission service that have been made

{Needs to be assigned to a NAESB working group}

262-3 460. The Commission adopts the NOPR’s proposal and will require that transmission planning meetings be open to all affected parties including, but not limited to, all transmission and interconnection customers, state commissions and other stakeholders. We recognize that it may be appropriate in certain circumstances, such as a particular meeting of a subregional group, to limit participation to a relevant subset of these entities. We emphasize, however, that the overall development of the transmission plan and the planning process must remain open. We agree with the concerns of some commenters that safeguards must be put in place to ensure that confidentiality and CEII concerns are adequately addressed in transmission planning activities. Accordingly, we will require that transmission providers, in consultation with affected parties, develop mechanisms, such as confidentiality agreements and password-protected access to information, in order to manage confidentiality and CEII concerns. Lastly, concerns surrounding the application of the Commission’s Standards of Conduct to planning participants, and



ESS/ITS comment: NERC assess Transmission needs and develop Transmission Plans Supplemental SAR is posted for comment with comments due 3/16.






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments whether and how these standards should affect access to and use of information obtained in the planning process, will be discussed below.

470-1 815. As with any innovative rate program, however, the Commission will monitor the secondary capacity market to ensure that participants are not exercising market power. To enhance oversight and monitoring by the Commission, we adopt reforms to the underlying rules governing capacity reassignments. First, we require that all sales or assignments of capacity be conducted through or otherwise posted on the transmission provider’s OASIS on or before the date the reassigned service commences. The Commission thus eliminates the current ability of transmission customers to assign the transmission rights to another party with subsequent notification to the transmission provider. The mechanisms for negotiating a reassignment remain the same. The transmission customer may either request that the transmission provider make the capacity available on its OASIS or the transmission customer may negotiate the terms of an assignment bilaterally. In either instance, however, the resulting sale or assignment must be posted by the transmission provider on its OASIS prior to the date the reassigned service commences. We require transmission providers working through NAESB to develop appropriate OASIS functionality to allow such postings. Transmission providers need not implement this new OASIS functionality and any related business practices until NAESB develops appropriate standards.


K. York, TVA Comment: ESS/ITS



ESS/ITS comment: ESS/ITS needs to modify the Resale Standards and the S&CPs to address paragraph 815.

M. Gildea, Constellation Gen. Group Comment: NAESB develops appropriate standards:

“we require that all sales or assignments of capacity be conducted through or otherwise posted on the transmission provider’s OASIS on or before the date the reassigned service commences”

While this may need to be assigned to NAESB working Group, Constellation would hope that FERC reconsiders this request and hence would put this as lower in the queue of projects to get underway immediately

594-5 1005. The Commission will not mandate the use of network customer resources or other third party resources in the provision of planning redispatch. If they choose, network customers and third parties may voluntarily provide planning redispatch services. A seller is free to post its price to relieve a specific congested transmission facility and its ability to relieve the congestion. To facilitate provision of such service by third parties, we direct transmission providers to modify their OASIS sites to allow for posting of these third party offers. Accordingly, we direct transmission providers to work in conjunction with NAESB to develop this new OASIS functionality and any necessary business practice standards. Transmission providers need not implement this new OASIS functionality and any related business practices until NAESB develops appropriate standards.


And

ESS/ITS

K. York, TVA Comment: New

K. York, TVA Comment: Not Assigned

ESS/ITS comment: ATC/AFC Business Practices and the ESS/ITS S&CPs. NOTE: this might affect the split TLR Business Practices and Reliability Standards Development.

K. York, TVA Comment: Please check with Paul Sorenson on this

M. Gildea, Constellation Gen. Group Comment: we direct transmission providers to modify their OASIS sites to allow for posting of these third party offers {This needs to be assigned to a NAESB working group}.

617-8 1046. Further, as discussed in more detail below, we disagree that NERC must modify its K. York, ESS/ITS comment: Assigned to Transmission






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments processes in order to allow transmission providers to implement this product. However, we will allow for a sufficient period of time for development of business practices and tracking mechanisms to implement the product. We recognize that there may be some regional variation in the way transmission providers approach the provision of conditional firm service beyond the minimum attributes that we establish in this Final Rule. Thus, we do not direct that transmission providers work with NAESB to develop business practices for implementation of the conditional firm service. Rather, we direct transmission providers located in the same region to coordinate such development among themselves. We also encourage participation of non-public utility transmission providers in the region and interested transmission customers in the development of these business practices. Public utility transmission providers should make efforts to include these interested parties in their regional coordination efforts. We direct transmission providers to implement these mechanisms and business practices within 180 days after the publication of this Final Rule in the Federal Register.

TVA Comment: N/A

Providers regionally, not assigned to NAESB.

P. Sorenson, TranServ comment: TranServ will be filing comments to FERC on Order 890 in which we ask for delay on implementation of conditional firm to 270 days to better align with JISWG’s 1.8 rev to tagging

K. York, TVA Comment: BPS to be developed at regional levels

634-5 1078. Finally, we address requests to allow for automatic assignment of short-term firm point-to-point service to conditional firm customers. We agree that transmission providers must take into account the conditional firm service in evaluating the availability of short-term firm service. Because conditional firm is a long-term firm use of the system, it should not be interrupted prior to short-term firm service. However, short-term firm service reserved prior to the reservation of conditional firm service should maintain priority over conditional firm service in the periods when conditional firm service is conditional, i.e., when specified system conditions exist or conditional curtailment hours apply. Because the assignment proposal meets both of these objectives, we direct transmission providers to assign short-term firm service to conditional firm customers as the service becomes available. Accordingly, we direct transmission providers to work with NAESB to develop the appropriate communications protocols to implement this attribute of conditional firm service. Transmission providers need not implement this requirement until NAESB develops appropriate communications protocols.


K. York, TVA Comment: No

BPS and ESS/ITS (ATC Group) comment: NAESB: development of communication protocols for conditional firm including tracking mechanism and regional variation; NAESB will have to review the tagging rules related to the use of conditional firm (IDC, JISWG)

K. York, TVA Comment: Check with Paul on this one; also with the introduction of a new conditional firm service, the TLR procedure will have to be revised before the product is implemented

M. Gildea, Constellation Gen. Group Comment: “we direct transmission providers to assign short-term firm service to conditional firm customers as the service becomes available”

NAESB to develop the appropriate communications protocols to implement this attribute of conditional






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments firm service

{This needs to be sent to a NAESB working group}

686-7 1162. Accordingly, to provide greater availability of redispatch information, the Commission adopts certain additional posting requirements for transmission providers. Specifically, we direct each transmission provider to post on OASIS its monthly average cost of redispatch for each internal congested transmission facility or interface over which it provides redispatch service using planning redispatch or reliability redispatch under the pro forma OATT. Additionally, to demonstrate the range of redispatch costs each month, the Commission directs transmission providers to post a high and low redispatch cost for the month for each of these same transmission constraints. The transmission provider shall calculate the monthly average cost in $/MWh for each congested transmission facility by dividing monthly total redispatch costs (at the facility) by the total MWhs that would otherwise be curtailed (at the facility) in the month absent the redispatch. Transmission providers shall post internal constraint or interface data for the month if any planning redispatch or reliability redispatch is provided during the month, regardless of whether the transmission customer is required to reimburse the transmission provider for those exact costs. Thus, if the transmission customer pays for redispatch pursuant to a negotiated fixed rate, the transmission provider is required to post and calculate the monthly average redispatch costs and the high and low costs in the month even though the transmission provider will bill the customer the fixed rate. The same posting requirement applies if the customer is paying a monthly “higher of” rate. The transmission provider shall post this data on OASIS as soon as practical after the end of each month, but no later than when it sends invoices to transmission customers for redispatch-related services. We direct transmission providers to work in conjunction with NAESB to develop this new OASIS functionality and any necessary business practice standards.



ESS/ITS comment: Posting Requirements to need be developed.

K. York, TVA Comment: Cannot find this one on our work list; may need to check with Paul Sorenson as well

M. Gildea, Constellation Gen. Group Comment: we direct each transmission provider to post on OASIS its monthly average cost of redispatch for each internal congested transmission facility or interface over which it provides redispatch service using planning redispatch or reliability redispatch

{This needs to be sent to a NAESB working group}

753-4 1269. In Order No. 676, the Commission adopted the “Standards for Business Practices and Communication Protocols for Public Utilities” developed by the NAESB’s Wholesale Electric Quadrant (WEQ). Order No. 676 incorporated the aforementioned standards by reference into the Commission’s regulations, required public utilities to implement the standards by July 1, 2006, and required public utilities to file revisions to their OATTs to include these standards. The WEQ Standards include a number of standards addressing


K. York, TVA Comment:


K. York, TVA Comment:

ESS/ITS comment: ESS/ITS has begun modification to standard 9.7 to address paragraph 1269.

ESS/ITS QUESTION: How to reconcile 1269 with the last sentence of 2.2 of the revised tariff.






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments requirements for dealing with redirects on both a firm and non-firm basis. All of the WEQ Standards dealing with redirects were adopted by the Commission in Order No. 676, except for WEQ Standard 001-9.7, which addresses the impact of a firm redirect on a long-term firm transmission customer’s rollover rights under section 2.2 of the pro forma OATT. The Commission directed the WEQ to reconsider WEQ Standard 001-9.7 and to adopt a revised standard consistent with the Commission’s policies. The Commission also offered guidance to assist the WEQ in developing a standard that is consistent with Commission policy.

ESS/ITS Underway

758-9 1278. The Commission also concludes that the NAESB WEQ is the appropriate standard-setting body for developing business practices and implementing the Commission’s redirect policy. The Commission will refrain from commenting here on the NAESB process itself because we believe that the industry is best situated to determine how to structure the standard-setting process to provide for the widest possible participation and consensus. We nevertheless clarify that, consistent with precedent, NAESB is charged with implementing Commission policy through business practices. The Commission finds that the NAESB WEQ is an acceptable standards development process, representing a cooperative effort by industry participants to develop business practices that enhance the efficiency of the electric grid. Where necessary, NAESB participants may seek clarification of Commission policy so that NAESB may develop the appropriate standards.

K. York, TVA Comment: ESS/ITS


784 1318. We agree, however, with EEI’s recommendation that the Commission delegate to NAESB the responsibility for developing the Standard and Communications Protocols, business practices and OASIS modifications that will be necessary to provide the performance metrics adopted above. NAESB is in the best position to develop the standards and the processes by which the performance metrics are posted.



ESS/ITS comment: develop S&CP/see paragraph 413.

K. York, TVA Comment: Need to check with Paul Sorenson to be sure

820-1 1377. The Commission agrees that transmission requests across multiple transmission systems should be coordinated by the relevant transmission providers. We will not, however, amend the pro forma OATT to require such coordination. Rather, we require transmission providers working through NAESB to develop business practice standards related to coordination of requests across multiple transmission systems. In order to

ESS/ITS: ATC Group

And

ESS/ITS comment: ESS/ITS and BPS need to develop Business Practices and S&CP changes to address 1377.

K. York, TVA Comment: Check with Paul to






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments provide guidance to NAESB, we will articulate the principles that should govern processing across multiple systems. All the transmission providers involved in a request across multiple systems should consider a request that requires studies across multiple systems to be a single application for purposes of establishing the deadlines for rendering an agreement for service, revising queue status, eliciting deposits and commencing service. In order to preserve the rights of other transmission customers with studies in the queue, the priority for the single application should be based on the latest priority across the transmission providers involved in the multiple system requests. We note that regional entities like wesTTrans are already coordinating requests across multiple transmission systems and we believe such coordination is an acceptable solution to this issue.

ESS/ITS


ensure not embedded in other work

M. Gildea, Constellation Gen. Group: “we require transmission providers working through NAESB to develop business practice standards related to coordination of requests across multiple transmission systems. “

{This needs to sent to a NAESB working group}

821-2 1378. We interpret Exelon’s request that we require all transmission providers to allow transmission customers to link consecutive requests for firm point-to-point transmission service and to evaluate such requests as a single request as asking us to (1) allow transmission customers to require the transmission provider to either grant service for the entire period, deny service for the entire period, or offer the same partial quantity for the entire period and (2) require the transmission provider to consider the full duration of the linked requests when determining reservation priority pursuant to sections 13.2 of the pro forma OATT (short-term firm point-to-point transmission service). We require transmission providers working through NAESB to develop business practice standards to allow a transmission customer to rebid a counteroffer of partial service so the transmission customer is allowed to take the same quantity of service across all linked transmission service requests. Transmission providers need not implement these business practice standards until NAESB develops appropriate standards. We note that the transmission customer should not be required to take the same quantity of service across consecutive transmission service requests; it should simply have the option to do so. On the second issue, we reiterate that, according to existing NAESB business practice standard 001-4.16, the transmission provider is required to consider the full duration of the linked requests when determining reservation priority pursuant to section 13.2 of the pro forma OATT.




ESS/ITS comment: ESS/ITS need to develop an extension to the TRANSCUST template in the S&CP.

K. York, TVA Comment: Draft language went out for informal comment and modifications made based on comments; holding to be submitted as part of overall package

M. Gildea, Constellation Gen. Group: “We require transmission providers working through NAESB to develop business practice standards to allow a transmission customer to rebid a counteroffer of partial service so the transmission customer is allowed to take the same quantity of service across all linked transmission service requests.”

{We need to have a NAESB working group address this matter}

826-7 1390. We will not modify the pro forma OATT to address requests to allow the transmission provider to terminate idle transmission service requests. NAESB’s business practice 001-4.11 allows the transmission provider to retract a request if the transmission


ESS/ITS comment: ESS/ITS should review if this has any impact on business functions.






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments customer does not respond to an acceptance within the time established in NAESB business practice standard 001-4.13. Therefore, we interpret TDU Systems comments to refer to circumstances when a transmission customer fails to respond to the transmission provider’s request for additional information during the course of a request study. As discussed above, by the time the transmission provider offers a system impact study agreement, it should have all of the information that it needs to complete the study. Pursuant to section 17.4 of the pro forma OATT, the transmission provider can deem a transmission service request deficient if the transmission customer does not provide all of the information the transmission provider needs to evaluate the request for service. We will revise section 17.7 of the pro forma OATT so that the transmission provider is able to terminate a request for transmission service if a transmission customer that is extending the commencement of service does not pay the required annual reservation fee within 15 days of notifying the transmission provider that it would like to extend the commencement of service. We will not change the pro forma OATT to allow the transmission provider to terminate a transmission service request if the transmission customer changes its application for service. We believe the existing pro forma OATT is sufficient to allow a transmission provider to manage situations where the transmission customer modifies its application for service to the point that the customer is requesting transmission service that is meaningfully different than its initial request.


827 1392. Commenters also suggest changes to the OASIS protocols, including prohibiting transmission customers from changing a request into a pre-confirmed request and requiring OASIS platforms to be accessible on non-Windows/Explorer computers. We believe these issues are best addressed by NAESB.




ESS/ITS comment: This will require a change to the TRANSCUST template in the S&CP. Revised S&CP will incorporate changes to implement accessibility.

K. York, TVA Comment: Needs to be assigned

M. Gildea, Constellation Gen. Group Comment: changes to the OASIS protocols, including prohibiting transmission customers from changing a request into a pre-confirmed request

{I read this optional, after we get assigned worked completed.}

836-7 1407. In response to requests for clarification from MidAmerican and TranServ, we ESS/ITS ESS/ITS comment: Request No. R05019






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments clarify that a new pre-confirmed request for transmission service would preempt a request of equal duration that has been accepted by the transmission provider but not yet confirmed by the transmission customer. Thus, we decline to adopt TDU Systems’ suggestion that the Commission include a time window between acceptance of a request and confirmation of the request, during which a request can not be preempted by a pre-confirmed request for transmission service. This is consistent with our desire to give transmission service first to those customers that are committed to taking the transmission service if it is granted. In the case of monthly firm point-to-point transmission service, the transmission customer has up to four days to confirm an accepted request. This is a potentially long delay when there is another transmission customer that is willing to commit to take the same service. Moreover, this policy is consistent with NAESB business standard 001-4.25, which allows a pre-confirmed request for non-firm point-to-point transmission service to preempt a request of equal duration and lower price that has been accepted but not confirmed.

Comment: ESS/ITS

K. York, TVA Comment: Complete

(Modify OASIS standards and S&CP to clearly document the procedures used to implement the displacement/interruption terms of the Pro Forma tariff) addresses 1407 as well as the other instances of preemption. Scope of this item will be difficult.

K. York, TVA Comment: FERC accepts current BPs

878 1477. We direct transmission providers to develop OASIS functionality to (1) allow all of the information required for a request to designate network resources to be provided electronically, (2) mask information about operating restrictions and generating cost on OASIS, and (3) allow for queries of all information provided with designation requests in accordance with section 37.6 of the Commission’s regulations. As provided in paragraph 385, we also direct transmission providers to work in conjunction with NAESB to develop business practice standards describing procedural requirements for submitting designations over any new OASIS functionality. Transmission providers need not implement this new OASIS functionality and any related business practices until NAESB develops appropriate standards. Prior to implementation of this new OASIS functionality, any information that cannot be provided electronically may be submitted by transmitting the information to the transmission provider by telefax or providing the information by telephone over the transmission provider’s time recorded telephone line.



ESS/ITS Comment: Underway



M. Gildea, Constellation Gen. Group Comment: we also direct transmission providers to work in conjunction with NAESB to develop business practice standards describing procedural requirements for submitting designations over any new OASIS functionality:

(1) allow all of the information required for a request to designate network resources to be provided electronically,

(2) mask information about operating restrictions and generating cost on OASIS,







(3) allow for queries of all information provided with designation requests in accordance with section 37.6 of the Commission’s regulations

(This needs to be assigned to a NAESB working group)

891-2 1504. In response to South Carolina E&G’s request, we reiterate that not all of the information required by section 29.2 of the pro forma OATT for designation of a network resource will be made publicly available on OASIS. As discussed above, information about operating restrictions and generating cost will be masked to protect commercially sensitive information. South Carolina E&G has also requested clarification of the Commission’s intent with respect to how designated network resource information is posted. Our existing regulations specify the view, download, and query requirements for information posted regarding network resource designations. The details of how those informational postings are accomplished are best left to be determined as part of the NAESB standards development process.



ESS/ITS: Underway



905-6 1532. In response to TranServ’s request that the exact nature of how the customer would make an attestation should be determined in the NAESB forum, we note that the contents and the specific information that is required to be provided with the attestation are specified in the pro forma OATT, and we are requiring that the attestation be submitted through OASIS with each request to designate a new network resource. The appropriate subject for transmission providers to coordinate with NAESB to resolve is limited to the appropriate formatting of such information to be provided in OASIS. In response to TranServ's request that NAESB should also determine the treatment of OASIS requests where the customer fails to provide the necessary attestation, we point out that we have already directed that such requests are to be found deficient by the transmission provider and treated in accordance with the procedures in section 29.2 of the pro forma OATT.


K. York, TVA: No


ESS/ITS comment: NAESB: ESS/ITS will address mechanisms for attestation in R04006E.

K. York, TVA Comment: Needs to be assigned

M. Gildea, Constellation Gen. Group Comment: how the customer would make an attestation should be determined in the NAESB forum

{Another item for NAESB working group. However, I can not say that is has any priority






Page Cite 1. Assigned ? 2. Status 3. Notes/Comments with Constellation.}

909-10 1541. We direct transmission providers to develop OASIS functionality and, working through NAESB, business practice standards describing the procedural requirements for submitting both temporary and indefinite terminations of network resources, to allow network customers to provide all required information for such terminations. Such OASIS functionality should allow for electronic submittal of the type of termination (temporary or indefinite), the effective date and time of the termination, and identification and capacity of resource(s) or portions thereof to be terminated. For temporary terminations, such OASIS functionality should also allow for electronic submittal of (1) effective date and time of redesignation, following the period of temporary termination; (2) information and attestation for redesignating the network resource following the temporary termination, in accordance with section 30.2 of the pro forma OATT; and (3) identification of any related transmission service requests to be evaluated concomitantly with the request for temporary termination. In response to TranServ’s request, we clarify that the request for temporary termination of the resource and the requests for the related transmission service identified in item (3), if any, should be evaluated as a single request, and approved or disapproved as such. We specifically direct transmission providers, working through NAESB, to develop business standards describing the procedures for submitting and processing requests for concomitant evaluations of transmission requests and temporary terminations. When processing such requests, the evaluation of the transmission service requests identified in item (3) should take into account the undesignation of the network resources identified in the request for termination. However, the evaluation of the transmission service requests in item (3) should be processed taking proper account of all competing transmission service requests of higher priority.





K. York, TVA Comment: This provides more clarity to current request.

M. Gildea Constellation Gen. Group Comment: OASIS functionality and, working through NAESB, business practice standards describing the procedural requirements for submitting both temporary and indefinite terminations of network resources .. items listed in detail (1), (2) …

{This needs to be assigned to a NAESB working group}

911 1543. Transmission providers need not implement this new OASIS functionality and any related business practices until NAESB develops appropriate standards. Prior to implementation of this new OASIS functionality, requests for temporary or indefinite terminations of network resources may be submitted by transmitting the required information to the transmission provider by telefax or providing the information by telephone over the transmission provider’s time recorded telephone line.










933-4 1591. We agree with parties arguing that network customers should not be required to use the new NAESB processes and OASIS tools to be developed in response to this section until such time as the NAESB standards and OASIS functionality have been developed and implemented. However, once the new standards and functionality are in place, network customers must use these new procedures to undesignate (whether temporarily or as part of an indefinite termination) any network resources, regardless of the date that those resources were originally designated.




K. York, TVA Comment: Just clarification

953-4 1627. We agree with suggestions for the posting of additional curtailment information on OASIS and, therefore, require transmission providers, working through NAESB, to develop a detailed template for the posting of additional information on OASIS regarding firm transmission curtailments. Transmission providers need not implement this new OASIS functionality and any related business practices until NAESB develops appropriate standards. These postings must include all circumstances and events contributing to the need for a firm service curtailment, specific services and customers curtailed (including the transmission provider’s own retail loads), and the duration of the curtailment. This information is in addition to the Commission’s existing requirements: (1) when any transmission is curtailed or interrupted, the transmission provider must post notice of the curtailment or interruption on OASIS, and the transmission provider must state on OASIS the reason why the transaction could not be continued or completed; (2) information to support any such curtailment or interruption, including the operating status of facilities involved in the constraint or interruption, must be maintained for three years and made available upon request to the curtailed or interrupted customer, the Commission’s Staff, and any other person who requests it; and, (3) any offer to adjust the operation of the transmission provider’s system to restore a curtailed or interrupted transaction must be posted and made available to all curtailed and interrupted transmission customers at the same time.



ESS/ITS comment: NOTE: schedule detail, reduction and security templates could be impacted.

K. York, TVA Comment: Needs to be assigned; check with Paul Sorenson first

M. Gildea, Constellation Gen. Group Comment: NAESB, to develop a detailed template for the posting of additional information on OASIS regarding firm transmission curtailments.

{Needs to be assigned to a NAESB working group}

Items that do not require NAESB Action, but were noted by the commenters as important

for NAESB Standards Development for Order 890





Page Cite 1. Assigned ? 2. Status 3. Notes/Comments 61-2 88. Increases in transparency to lessen the opportunities to

discriminate and reduce transaction costs. In addition to the increased transparency we require regarding the calculation of ATC and transmission planning, we increase the transparency of transmission service provided under the pro forma OATT in several other respects. For example, we require transmission providers and their network customers to use the transmission providers’ OASIS to request designation of a new network resource and to terminate the designation of an existing network resource. In addition, we require transmission providers to modify their OASIS so that requests to designate and terminate a network resource can be queried, allowing all parties access to such information. We also require transmission providers to post a list of their current designated network resources and all network customers’ current designated network resources on their OASIS. Finally, we require transmission providers to post on OASIS all their business rules, practices and standards that relate to transmission services provided under the pro forma OATT

B. Rehman, BPA Comment: Use OASIS to request designation and termination of network resources; list network resources on OASIS; provide a link on OASIS to all business practices, rules and standards related to transmission services under the OATT.

62-3 89. Strengthening enforcement of the pro forma OATT. The reforms adopted in this Final Rule provide greater clarity in the terms and conditions of the pro forma OATT, resolving ambiguities in the existing pro forma OATT that have made undue discrimination easier to accomplish and more difficult to detect. Our new civil penalty authority under EPAct 2005 gives us ample power to remedy tariff violations, but it also places upon us an increased responsibility to make the rules as clear as possible. We fulfill that responsibility in the Final Rule by providing greater clarity where appropriate to several critical OATT provisions. We also adopt a number of posting and reporting requirements that will provide the Commission and market participants with information about each transmission provider’s performance of pro forma OATT obligations. For example, we require transmission providers to post specific performance metrics related to their completion of studies required under the pro forma OATT. We note that the Commission will continue to audit compliance with the pro forma OATT, and toward that end require transmission information kept on OASIS to be retained for audit purposes for five years. Finally, we adopt a number of reforms to operational penalties assessed under the pro

B. Rehman, BPA Comment: Post metrics on completion of studies; keep info for 5 yr for audits.






for NAESB Standards Development for Order 890 Page Cite 1. Assigned ? 2. Status 3. Notes/Comments

forma OATT, including so-called “over-use” penalties and the treatment of operational penalty revenues collected from transmission providers and their affiliates

196-7 328. We reject proposals to address the transparency of ATC methodology by merely referencing business practices and reliability standards developed by NERC, NAESB, and WECC. ATC calculations have a direct and tangible effect on the granting of open access transmission service. As such, an accurate and detailed statement of the methodology and its components that defines how the transmission provider determines ATC belongs in the transmission provider’s OATT as the means of holding the transmission provider accountable for following non-discriminatory procedures for granting service, not in business practices kept by the transmission provider. However, as noted above, the actual mathematical algorithms should be posted on the transmission provider’s web site, with the link noted in the transmission provider’s Attachment C.

ESS/ITS Comment: ESS/ITS K. York, TVA Comment: N/A

BPS and ESS/ITS (ATC Group) comment: NAESB should develop a requirement for posting the actual mathematical algorithms for ATC on OASIS

ESS/ITS comment: This is a TP compliance issue, no action for NAESB required.

204 349. In addition, we agree with the requests of APPA and TAPS to require the additional posting of, at a minimum, a listing of all system impact studies, facilities studies, and studies performed for the transmission provider’s own network resources and affiliated transmission customers, to be made available upon request. We note that appropriate procedures to accommodate CEII concerns should be developed to ensure eligible entities with a legitimate interest in transmission study data can receive access to it. Also, we adopt TAPS’ suggestion that the studies be made available for five years to make the requirement consistent with data retention requirements pertaining to denial of service requests.

B. Rehman, BPA Comment: Add to posted list of studies, all System Impact Studies performed for the transmission providers own network resources and affiliated customers to be made available upon request

212 354. The Commission adopts the CBM posting requirements proposed in the NOPR. In doing so, we amend our OASIS regulations to incorporate the directives established in the CBM Order. Accordingly, we require transmission providers to post (and update) the CBM amount for each path. In addition, the Commission

B. Rehman, BPA Comment: Post and update TRM values for the paths on which ATC/TTC and CBM are posted. Post and update CBM for each path and







requires transmission providers to make any transfer capability set aside for CBM but unused for such purpose available on a non-firm basis and to post this availability on OASIS. Furthermore, the Commission requires transmission providers to post (and update) the TRM values for the paths on which the transmission provider already posts ATC, TTC, and CBM.

make any unused transfer capability set aside for CBM available for nonfirm and post such availability on OASIS

209 358. The Commission incorporates into its regulations the requirement in the CBM Order for a transmission provider to periodically reevaluate its transfer capability setaside for CBM. With respect to TAPS’ concerns over the effort involved in the reevaluation process, we will require CBM studies to be performed at least every year. This requirement is consistent with the CBM Order, in which the Commission stated that the level of ATC set aside for CBM should be reevaluated periodically to take into account more certain information (such as assumptions that may not have, in fact, materialized).204 While changes requiring a reevaluation of CBM are longer-term in nature (e.g., installation of a new generator or a long-term outage), quarterly may be too frequent, though two years may be too long and may prevent a portion of the CBM setaside from being released as ATC. Moreover, annual reevaluation is consistent with the current NERC standard being developed in MOD-005.205 The requirement to evaluate CBM at least every year also is consistent with the CBM Order in that the Commission directed transmission providers to periodically reevaluate their generation reliability needs so as to make known the need for CBM and to post on OASIS their practices in this regard.

B. Rehman, BPA Comment: Periodically re-evaluate generation reliability needs to make known the need for CBM and post practices in this regard on OASIS

215 371. We do require, as suggested in the NOPR, a narrative with regard to monthly or yearly ATC values when ATC remains unchanged at a value of zero for a significant period, and will set that period at six months or longer. This information will be valuable to customers and regulators in assessing the ability of a transmission provider’s facilities to meet existing service requests. The information also will provide assurance to customers that the

B. Rehman, BPA Comment: Post narrative when ATC (mthly/yrly) remains zero for 6 mo or longer







transmission provider is diligent in regularly evaluating ATC on all paths, monitoring persistent constraints and addressing them in its planning processes.

217 376. As proposed in the NOPR, the Commission maintains the requirement that a transmission provider post the reason for a denial of service and extends from three years to five years the period for which transmission providers must maintain data providing reasons for denial of service. In general, commenters support the requirement for posting denial of service information and the increase in retention time to five years, indicating that such information can be helpful to customers in their awareness of actual transmission congestion, rather than relying on simulation models.

B. Rehman, BPA Comment: Keep data providing reasons for denial for 5 yrs. (This item may only be a heads up for OASIS Administrators)

217-8 377. We also adopt TAPS’ suggestion to expand the regulations to include availability of information supporting the disposition of a transmission provider’s own network resource designations and to make such information available to any eligible customer rather than just to that customer denied service. In addition, we clarify that a partial denial of service triggers the requirements as well. Such information is consistent with the new regulations established by this Final Rule and will help ensure that customers receive transmission service that is not unduly discriminatory. The development of a log of service denials, full or partial, will establish an ongoing record of service requests and transmission provider responses demonstrating the transmission provider’s provision of nondiscriminatory open access service. Furthermore, repeated denials of service over a particular path or flowgate will provide an indication of congestion that can be used in the transmission planning process. In addition, we agree with East Texas Cooperatives that postings of denials of service should indicate whether the requested service was firm or non-firm.

B. Rehman, BPA Comment: Postings of denials should indicate whether the request was for firm or non-firm service

224 396. With respect to Williams’ request for additional OASIS postings, we agree that such additional data would be useful to transmission customers and is already posted on some ISO and RTO

B. Rehman, BPA Comment: Post all transmission related standards, business practices,







web sites and, to a lesser extent, on the NERC web site (TLR data). Therefore, we require that all transmission service-related business practices and local procedures, including waivers, should be posted on or made available through OASIS. With respect to real-time data and import/export limits by constrained area, estimated return-to-service dates and line de-ratings, we are confident that most of this data is already required by this Final Rule and shall be provided whenever TTC and ATC changes in value trigger the posting of a narrative explanation of the causes of those changes. Moreover, the Final Rule requires a broad data exchange among transmission providers, including information on line outages and other data relating to ATC calculations. Accordingly, we will not require additional OASIS postings for this data.

rules, local procedures, including waivers, on OASIS

228 404. In order to provide transparency and avoid undue delays in providing information to those with a legitimate need for it, the Commission requires transmission providers to establish a standard disclosure procedure for CEII required to be disclosed by this Final Rule. We note that transmission customers already have digital certificates or passwords to access publicly restricted transmission information on OASIS. Transmission providers may set up an additional login requirement for users to view CEII sections of the OASIS, requiring users to acknowledge that they will be viewing CEII information. Transmission providers may require customers to sign a nondisclosure agreement at the time that the customer obtains access to this portion of the OASIS. Only information that meets the criteria for CEII, as defined in section 388.113 of the Commission’s regulations,221 should be posted in this section of the OASIS. Transmission providers will be responsible for identifying CEII and facilitating access to it by appropriate entities, and the Commission will be available to resolve disputes if they arise.

B. Rehman, BPA Comment: Identify any additional login/security requirements for appropriate users to view the CEII (Critical Energy Infrastructure Information) section of the OASIS.

234-5 416. With regard to posting of load forecasts and actual daily peak load, we conclude that such postings are necessary to provide transparency for transmission customers. We agree with E.ON that

B. Rehman, BPA Comment: Post underlying load forecast assumptions for all ATC







RTO and ISO load data needs to be posted at a sufficient granularity to allow for meaningful comparison of control area and LSE load levels. Most RTOs and ISOs post load data for the entire footprint, but few post it on an LSE or control area basis. We therefore direct ISOs and RTOs to post load data for the entire ISO/RTO footprint and for each LSE or control area footprint within the ISO/RTO. This will not create an undue burden on ISOs and RTOs, since the load data for the entire footprint is an aggregation of load data across the LSEs or control areas in the footprint. We also agree with EEI that the peak load applies to system-wide load, including native load. We direct transmission providers to post load forecasts and actual daily peak load for both system-wide load (including native load) and native load, as this data will be useful to customers and regulators. We deny EEI’s request for a guarantee that transmission providers will not be held accountable for producing a reasonable load forecast. While we do not intend to penalize transmission providers for failing to account for unforeseen circumstances, we retain our ability to investigate any allegations of manipulation of load forecasts, as this could be used as a means of inappropriately denying requested transmission service.

calculations.

253 443. In order to assist transmission providers in complying with the Final Rule, and ensure that the planning procedures are developed with customer and stakeholder participation, the Commission will convene staff technical conferences in several broad regions around the country to discuss regional implementation and other compliance issues in advance of the compliance date. We extend an invitation to state regulatory commissions to participate in these technical conferences with our staff in order to ensure that state concerns are fully addressed. The Commission will endeavor to hold the technical conferences 90 to 120 days after the publication of the Final Rule in the Federal Register. To facilitate these conferences, each transmission provider should, within 75 days after the publication of the Final Rule in the Federal Register, post a “strawman” proposal

B. Rehman, BPA Comment: Post planning strawman on OASIS 75 days after publication in Federal Register. (Due May 29th?)







for compliance with each of the planning principles adopted in the Final Rule, including a specification of the broader region in which it will conduct coordinated regional planning. This strawman may be posted on the transmission provider's OASIS, or its website if it does not have its own OASIS (e.g., in the case of a transmission owning member of an RTO or ISO that does not have its own OATT). We strongly urge transmission providers to consult with their stakeholders in the development of this strawman.

312-3 546. Some commenters express concern that this principle may result in costly congestion studies that are of little interest or value to customers. Our intent is not to impose a costly study requirement that is unrelated to the real-world concerns of consumers. In the NOPR, we sought comment on whether specific metrics (e.g., zero ATC or TLR frequency) should be used to trigger the congestion study requirement. After considering the comments on this topic, we do not believe that any single metric, or group of metrics, is adequate for that purpose. Relying on discrete metrics in this instance would risk both over- and under-inclusiveness – i.e., triggering too many studies, thereby imposing cost burdens on transmission providers that are not appropriate, or triggering too few studies, thereby omitting important studies that could help customers identify cost-effective solutions to congestion. Additionally, we direct transmission providers, in consultation with their stakeholders during development of their Attachment K compliance filings (as discussed above), to develop a means to allow the transmission provider and stakeholders to cluster or batch requests for economic planning studies so that the transmission provider may perform the studies in the most efficient manner. We will also require the requests for economic planning studies, as well as the responses to the requests, be posted on the transmission provider’s OASIS or web site, subject to confidentiality requirements.

B. Rehman, BPA Comment: Post requests and responses for economic planning studies on OASIS or Web site, subject to confidentiality requirements.

401 703. We also note that management of inadvertent energy is needed to adhere to NAESB standards. Historically, transmission

K. York, TVA Comment: Complete ESS/ITS comment: No action required at this time until the







providers have paid back inadvertent interchange imbalances in kind, which has not, as a general matter, proven to be problematic. Our primary concern with respect to inadvertent energy is to avoid incentives that could degrade reliability. To date, the return-in-kind approach has proven to be adequate as a general matter. However, if there is evidence that it is no longer sufficient to maintain reliability, or is allowing certain entities to lean on the grid to the detriment of other entities, the Commission has authority under FPA section 215 to direct the ERO to develop a new or modified standard to address the matter.

need is identified. K. York, TVA Comment: Reference to current BPs only

472 817. Third, in addition to existing OASIS posting requirements, we require transmission providers to aggregate and summarize in an electronic quarterly report the data contained in these service agreements. As proposed in the NOPR, the use of quarterly reports will assist the Commission in gathering data to ensure the effectiveness of market forces and regulatory requirements to mitigate the exercise of market power. The Commission directs that this quarterly report be submitted electronically in spreadsheet format consistent with the electronic filing system used for Electric Quarterly Reports so that it is readily accessible to the Commission and the public.

B. Rehman, BPA Comment: Submit quarterly report on aggregated data from reassignment transmission service agreements, in spreadsheet format, and submit consistent with the electronic filing system (EQR) used for Electric Quarterly Reports so it is readily accessible to the Commission and the public. (See also footnote 499) (Not sure whether NAESB would be assisting transmission providers with this spreadsheet, as it relates to EQR. If not, please delete from this list.)

671-2 1139. Next, we also decline to adopt a requirement for transmission providers to incorporate offers to redispatch from third parties into their reliability redispatch or planning redispatch. Mandatory inclusion of third party offers is not necessary to remedy undue discrimination. The pro forma OATT obligates transmission providers to use their resources to provide, where available consistent with reliability, redispatch service because they do so when serving their native load customers. Third party generators do not have this obligation, nor do the Transparent Dispatch Advocates

B. Rehman, BPA Comment: Modify OASIS to allow for posting of 3rd party offers to supply planning redispatch, provided appropriate agreements are reached between customer, 3rd party redispatch provider, transmission provider and reliability coordinator.







propose to create such an obligation. Rather, under the TDA proposal, transmission providers would remain obligated to provide redispatch service, but third party generators would have only the option of doing so. Transparent Dispatch Advocates are therefore not proposing comparable treatment and we decline to adopt the proposal. This notwithstanding, we believe that redispatch offers by third party generators can increase system reliability and reduce costs to customers by increasing the planning redispatch options available to transmission providers. We therefore are adopting, as explained above, a requirement that transmission providers modify their OASIS to allow for the posting of third party offers to supply planning redispatch. This OASIS posting requirement does not obligate transmission providers to incorporate bids from third parties into their redispatch; rather, posting of third party offers to provide redispatch may be used by transmission customers to secure planning redispatch provided the appropriate agreements are reached between the customer, third party redispatch provider, transmission provider and reliability coordinator.

683 1157. In balancing these considerations, we will, as explained further below, adopt a requirement that transmission providers post certain redispatch cost information associated with the existing redispatch services that must be provided under the pro forma OATT. We find that providing customers with additional transparency and greater information regarding the cost of congestion, will facilitate their consideration of planning redispatch options which in turn will provide for more efficient use of the grid. We stress, however, that this posting requirement relates only to the existing redispatch services required under the pro forma OATT; it does not expand those service obligations. The primary purpose of the posting requirement is to ensure that all customers have access to this information, not only the customer receiving the redispatch service

B. Rehman, BPA Comment: Post certain redispatch cost information on existing redispatch services required under the OATT. (Add to 1162)

725-6 1231. The Commission finds that the current rollover policy is no B. Rehman, BPA Comment: Modify







longer just, reasonable, and not unduly discriminatory. The rights and obligations of a rollover customer should bear a rational relationship to the planning and construction obligations imposed on the transmission provider by the rollover rights. We find, for the reasons explained below, that the current policy no longer meets this standard and that a five-year term will ensure greater consistency between the rights and obligations of customers and the corresponding planning and construction obligations of transmission providers. We also believe that an increase to a five-year term is consistent with the native load protections contained in new section 217 of the FPA, primarily because requiring longerterm agreements ensures that the rollover right is used by transmission customers with long-term obligations to purchase capacity.749 Accordingly, the Commission adopts a five-year minimum contract term in order for a customer to be eligible for a rollover right. At the end of its initial five-year contract term, a transmission customer must, within the one-year notice period (discussed more fully below), agree to another five-year contract term or match any longer-term competing request in order to be eligible for a subsequent rollover.

9.7 to reflect new minimum 5 yr term and 1 year notice period. (Add 1245)

775-6 1308. The Commission will require transmission providers to post the performance metrics proposed in the NOPR, as modified by this Final Rule. The proposed metrics will enhance the transparency of the study process and shed light on whether transmission providers are processing request studies in a non-discriminatory manner. We also agree with comments by MidAmerican and EEI that transmission providers should be able to track delays in the study process caused by transmission customers. Doing so will allow the Commission and market participants to determine the extent to which delays by transmission customers are causing transmission providers to process request studies on an untimely basis, which will add needed transparency to the study process. Therefore, we will revise the performance metrics transmission providers are required to post to include metrics that track delays by transmission

B. Rehman, BPA Comment: Post on a quarterly calendar basis, study performance metrics and add one to track transmission customer delays.







customers. 776-7 1309. Transmission providers will be required to post the

performance metrics, outlined below, for each calendar quarter. Transmission providers will be required to begin tracking their performance upon the effective date of this Final Rule and keep the quarterly performance metrics posted on their OASIS sites for three calendar years. The transmission provider will be required to post the quarterly performance metrics within 15 days of the end of the quarter. The performance metrics outlined below must be calculated separately for affiliates’ and non-affiliates’ requests, in order to identify potential instances when the transmission provider is processing requests on a discriminatory basis. The transmission provider is required to aggregate studies associated with requests for short-term and long-term transmission service when calculating the metrics defined below. While a transmission provider could offer to study a request for short-term firm point-to-point transmission service, we acknowledge that the transmission customer often is unwilling to pay for such a study. Therefore, to ease the reporting burden, the transmission provider is not required to report the performance metrics defined below separately for requests for short-term and long-term firm point-to point transmission service. A transmission provider is also required to post performance metrics for studies that it conducts for RTOs.

B. Rehman, BPA Comment: Begin tracking performance on effective date of Order (May 14). Post metrics by affiliate/non-affiliate and aggregate studies associated with requests for short term and long term transmission services (not for interconnection services requests).

782-3 1316. We will not adopt any of the changes to the proposed performance metrics requested by commenters, other than adding metrics to track delays by customers as discussed above. The Commission is in a better position to determine the specific performance metrics that will achieve our policy goals and thus we will not request that NAESB develop the metrics to be posted. We believe the set of performance metrics we have chosen strike the appropriate balance between requiring information that will enhance transparency and help ensure that the transmission provider is processing request studies in a timely and non-discriminatory

K. York, TVA Comment: N/A ESS/ITS comment: No action for NAESB.







fashion while limiting the burden the transmission provider faces. For instance, we believe the performance metrics that address the cost of system impact studies and facilities studies as well as the cost of any proposed transmission upgrades can be calculated with relatively little effort by the transmission provider and should provide meaningful benefits to transmission customers. The transmission provider readily knows the cost of studies it completes and the costs of proposed system upgrades and summaries of this information should enhance the transmission customer’s ability to decide whether to submit a request for service that may result in a study offer.

803 1346. As we discuss below, we believe NAESB’s queue hoarding and queue flooding business practices, as well as additional reforms adopted in this Final Rule, will address the problem surrounding the submission of multiple requests. With regard to requests for a technical conference or further procedures to consider the effect of our operational penalty regime, we believe the commenters’ proposals would largely provide anecdotal information and speculation on the impacts of the new planning and coordination requirements. Our experience from the last ten years, and the comments provided in response to the NOI and NOPR, provide a sufficient basis to develop a penalty regime. In addition, the very requirement that transmission customers post performance metrics and submit notification filings prior to assessment of operational penalties will provide actual experience with the new regime. As explained above, the notification procedures adopted today will ensure that we will not assess a penalty for late studies unless justified by the circumstances. We can propose additional changes to the study process or penalty regime based on the actual experience under this Final Rule if our experience warrants it.

K. York, TVA Comment: Complete ESS/ITS comment: No action for NAESB.

K. York, TVA Comment: FERC accepts current BPs for multiple requests

785-6 1320. As the Commission proposed in the NOPR, starting the quarter following a notification filing, the transmission provider will be required to post: (1) the average, across completed system impact

B. Rehman, BPA Comment: Starting the quarter following a notification filing, post additional







studies, of the employee-hours expended per completed system impact study; (2) the average, across completed facilities studies, of employee hours expended per completed facilities study; (3) the number of employees devoted to processing system impact studies; and (4) the number of employees devoted to processing facilities studies. The transmission provider is not required to post these additional performance metrics separately for affiliates’ and non-affiliates’ requests for transmission service and for short-term and long-term transmission service. The transmission provider is instead required to aggregate studies associated with requests for short-term and long-term transmission service when calculating these additional metrics. The transmission provider is not required to post the additional metrics if the Commission concludes that delays in completing studies are due to extenuating circumstances. However, the transmission provider is required to post the additional metrics while the Commission considers the transmission provider’s notification filing arguing that extenuating circumstances prevented it from processing request studies on a timely basis. Based on the timing described in this Final Rule, the transmission provider will be required to post the additional performance metrics approximately two months after the provider makes its notification filing. The Commission will have this time to evaluate the transmission provider’s contention that it was unable to complete request studies due to extenuating circumstances. As a result, we expect the transmission provider with legitimate extenuating circumstances typically will not have to post any additional metrics.

metrics, not separately for affiliate and non-affiliates.

814 1365. The Commission will not require transmission providers to charge a fee for duplicative requests for transmission service. We will instead first consider whether the newly adopted NAESB queue flooding and queue hoarding business practices reduce the number of requests that the transmission customer does not intend to confirm. We are concerned that benefits to market participants would not justify the administrative costs of a new fee if the NAESB

K. York, TVA Comment: Complete ESS/ITS comment: No action for NAESB.

K. York, TVA Comment: FERC accepts current BPs for multiple requests







business practices can effectively discourage transmission service requests the transmission customer does not intend to confirm. We also believe that the current deposit mechanism in section 17.3 of the pro forma OATT should have the same effect as a fee based on the transmission provider’s cost to process the request for transmission service, like the fee MISO and CREPC propose. Pursuant to section 17.3, in the event a transmission customer retracts or withdraws a request, the transmission provider is allowed to deduct from the transmission customer’s deposit the costs the transmission provider incurred to process the request. As a result, we do not believe any other fee structure is necessary to make the transmission provider whole when a transmission customer submits a transmission service request it does not expect to confirm.

829 1395. In the NOPR, the Commission proposed to change the priority rules to give priority to pre-confirmed requests for firm point-to-point transmission service. Specifically, the Commission proposed that a pre-confirmed short-term request for firm transmission service would preempt any non-pre-confirmed short-term requests, regardless of duration. Similarly, the Commission proposed that a pre-confirmed request for long-term firm transmission service would preempt a request for long-term transmission service that is not pre-confirmed. Under the Commission’s proposal, a preconfirmed request for short-term transmission service would not pre-empt a non-preconfirmed request for long-term transmission service.

B. Rehman, BPA Comment: Evaluate need to modify Table 4-3 in WEQ 001-4.16 to accommodate priority for pre-confirmed non-firm and short-term firm Point to Point transmission service requests

833-4 1401. The Commission generally agrees with those commenters that argue that giving a priority to pre-confirmed requests can increase the efficient utilization of the system by giving priority to customers who are committed to purchase service over those who have not so committed, including customers that submit multiple requests without any intent to take service if each request is granted. However, we are mindful of concerns that doing so could undermine the Commission’s desire to promote longer-term uses of the transmission system, disrupt the study process, or disadvantage

B. Rehman, BPA Comment: Evaluate need to modify Table 4-3 in WEQ 001-4.16 to accommodate priority for pre-confirmed as a tie-breaker for requests of equal duration and where pre-confirmed requests do not preempt requests for unconfirmed longer duration







transmission customers that are not in the position to pre-confirm their requests. As a result, we will modify the NOPR proposal and give priority only to pre-confirmed non-firm point-to-point transmission service requests and short-term firm point-to-point transmission service requests. In addition, longer duration requests for transmission service will continue to have priority over shorter duration requests for transmission service, with preconfirmation serving as a tie-breaker for requests of equal duration. This policy will still give an advantage to pre-confirmed requests without imposing substantial implementation difficulties or undermining the Commission’s goals to encourage longerterm uses of the transmission system. Our revised policy on priority for pre-confirmed requests thus addresses the comments that we should preserve the priority of longer duration requests for transmission service over shorter duration requests for transmission service. For instance, a pre-confirmed daily or hourly request will not preempt a weekly request that has not been pre-confirmed. Pre-confirmed short-term service requests therefore will not have a priority superior to that of long-term service requests that have not been pre-confirmed.

requests.

834 1402. We acknowledge that our revised policy on priority for pre-confirmed requests may be less effective than the NOPR proposal in alleviating the problems that arise when transmission customers submit multiple identical requests for service. However, we have taken other steps – notably accepting the NAESB business practices on queue flooding and queue hoarding – that we believe will substantially reduce the instances of multiple identical requests for service.

K. York, TVA Comment: Complete ESS/ITS comment: No action required.

K. York, TVA: FERC accepts current BPs for queue hoarding

834-5 1403. The Commission also acknowledges the concerns expressed regarding operational difficulties caused by giving priority to pre-confirmed requests and clarify our policy as follows. First, we will prohibit transmission customers from withdrawing pre-confirmed non-firm and short-term firm point-to-point transmission service

B. Rehman, BPA Comment: Prohibit withdrawals of pre-confirmed non-firm and short-term firm Point to Point transmission service requests







requests prior to when the transmission customer is offered service or a system impact study. This policy will address MidAmerican’s concern that a transmission customer may withdraw a preconfirmed request for transmission service at any time prior to acceptance by a transmission provider. We believe prohibiting withdrawal of a pre-confirmed request is less administratively burdensome than the non-refundable deposit on requests proposed by Nevada Companies and achieves the same goals. The Commission will allow transmission providers to invalidate a pre-confirmed request at the request of the transmission customer in the very near term following submittal of the request, in the event the transmission customer makes an inadvertent error in submitting its request. We expect the transmission provider to log such occurrences as an act of discretion so we can verify that transmission customers are not abusing this flexibility.

prior to when the transmission customer is offered service (i.e., the transmission provider's acceptance) or a system impact study. Log occurrences as act of discretion when a pre-confirmed request is invalidated upon the request of the transmission customer in the very near term, due to an inadvertent error in submittal of the request.

838-9 1410. The Commission adopts the NOPR proposal to add price as a tie-breaker in determining reservation queue priority when the transmission provider is willing to discount transmission service. As a result, price will serve as a tie-breaker after preconfirmation for those requests that have not yet been confirmed by the transmission customer or have not yet been evaluated by the transmission provider. Consistent with the principles currently embodied in the pro forma OATT and articulated in Order No. 638, we clarify that, in the event a later queued short-term request for transmission service preempts a conditional confirmed short-term request for transmission service based on price, then the conditional confirmed request has a right to match the price offer of the later queued request.

B. Rehman, BPA Comment: Evaluate need to modify Table 4-3 in WEQ 001-4.16 to accommodate priority for price, as a tie-breaker in determining reservation queue priority when the transmission provider is willing to discount transmission service, after pre-confirmation priority for those requests that have not yet been confirmed or have not yet been evaluated

840 1413. In the NOPR, the Commission responded to comments that transmission customers that have the financial resources to purchase software and employ staff to continually monitor OASIS sites have an unfair advantage under a first-come, first-served approach by seeking comment on whether any such advantage would be

B. Rehman, BPA Comment: Evaluate need to modify State Diagram or status values in WEQ 002-4.2.10.2 to accommodate a specified "no







mitigated if all requests submitted within a five-minute window were deemed to have been submitted simultaneously. The Commission also sought comment on whether transmission customers could game a five minute equivalent priority standard to request transmission service only after another transmission customer has made a request. The Commission further sought comment on how to allocate limited transmission capacity among equivalent priority requests of equal duration, in the event a five minute equivalent priority standard is adopted.

earlier than" Window for Requests.

846 1421. We agree with NRECA and Bonneville’s suggestion that requests submitted within a specified window should not be publicly available until the window has closed in order to prevent competitors from requesting the same service simply to disrupt the transmission service procurement process.

B. Rehman, BPA Comment: Mask such requests on OASIS until close of the "no earlier than" window.

877-8 1476. As revised by the Final Rule, section 29.2(v) of the pro forma OATT will require the following information to be provided with the request and posted on OASIS when designating an off-system resource: (1) identification of the resource as an off-system resource; (2) amount of power to which the customer has rights; (3) identification of the control area(s) from which the power will originate; (4) delivery point(s) to the transmission provider’s transmission system; and (5) transmission arrangements on the external transmission system(s). Additionally, section 29.2(v) is revised to require that the following information be provided with such designation, but such information must be masked on OASIS to prevent the release of commercially sensitive information including (1) any operating restrictions (periods of restricted operation, maintenanceschedules, minimum loading level of resource, normal operating level of resource); and, (2) approximate variable generating cost ($/MWH) for redispatch computations. Requests to designate off-system network resources submitted on or after the effective date of this Final Rule must include all of the information listed above.

B. Rehman, BPA Comment: Mask specific network resource information on OASIS pursuant to OATT 29.2(v). (Add to 1504)






for NAESB Standards Development for Order 890 Page Cite 1. Assigned ? 2. Status 3. Notes/Comments 892 1505. TranServ requests that the Commission clarify the minimum

term, if any, that a transmission provider must honor for designations of new network resources. We agree with TranServ that the minimum term should be the same as the minimum time period used for firm point-to-point service (i.e., daily), unless otherwise demonstrated by the transmission provider and approved by the Commission.

B. Rehman, BPA Comment: Minimum term for designations should be the same as the minimum time period used for firm Point to Point service (i.e., daily).

900 1521. The Commission adopts the NOPR proposal that transmission providers continue to be responsible for verifying that third-party transmission arrangements to deliver the purchase to the transmission provider's system are firm, but that transmission providers are not responsible for verifying that the generating units and power purchase agreements network customers designate as network resources satisfy the requirements in sections 30.1 and 30.7 of the pro forma OATT. We also adopt the proposal to require both the transmission provider’s merchant function and network customers to include a statement with each application for network service or to designate a new network resource that attests, for each network resource identified, that (1) the transmission customer owns or has committed to purchase the designated network resource and (2) the designated network resource comports with the requirements for designated network resources. The network customer should include this attestation in the customer’s comment section of the request when it confirms the request on OASIS.

B. Rehman, BPA Comment: Transmission customers must add attestation to the Customer Comment section of their request, when they confirm the request on OASIS.

900-1 1522. If the network customer does not include the attestation when it confirms the request, the transmission provider must notify the network customer within 15 days confirmation that its request is deficient, in accordance with the procedures in section 29.2 of the pro forma OATT. Whenever possible, the transmission provider shall attempt to remedy deficiencies in the request through informal communications with the network customer. If such efforts are unsuccessful, the transmission provider shall terminate network customer's request and change the status of the request on OASIS to

B. Rehman, BPA Comment: Notify transmission customers within 15 days of confirmation and attempt to remedy deficiency in attestation with informal communication; if unsuccessful change OASIS status to "retracted".







“retracted.” This termination shall be without prejudice to the network customer submitting a new request that includes the required attestation. The network customer shall be assigned a new priority consistent with the date of the new request.

903-4 1527. We disagree with Pinnacle’s argument that transmission providers should not be responsible for verifying the firmness of the network customer's transmission arrangements on other systems. We find that having transmission providers verify firmness of such transmission arrangements provides a significant benefit to the system and is not unduly burdensome. The confirmation or lack thereof of service on the thirdparty's system should be readily available on OASIS. If firm third-party service is not confirmed in OASIS, the transmission provider should attempt to remedy any information deficiency in the request through informal communications with the network customer. If such efforts are unsuccessful, the transmission provider should find the request to designate the network resource deficient. Because this information is available on OASIS, we disagree with Detroit Edison's request that the Commission require proof that customers have obtained requisite transmission service on external systems.

B. Rehman, BPA Comment: Find requests to designate "deficient", if informal communication efforts to remedy information deficiencies in the request are unsuccessful.

909 1540. We clarify that requests to undesignate network resources that are submitted concurrently with a request to redesignate those network resources at a specific point in time shall be considered temporary terminations. Conversely, requests to undesignated network resources submitted without any concurrent request to redesignate those network resources shall be considered a request for indefinite termination of those network resources.

B. Rehman, BPA Comment: Distinguish between temporary and indefinite terminations.

910-1 1542. Consistent with the requirements for requests for designation of new network resources, the new OASIS functionality should also allow for queries of requests to undesignate and redesignate network resources. In accordance with section 37.6 of the Commission’s regulations,892 such requests must be able to be queried by the publicly available information posted on OASIS.

B. Rehman, BPA Comment: Allow network resource requests to be queried.






for NAESB Standards Development for Order 890 Page Cite 1. Assigned ? 2. Status 3. Notes/Comments 930 1582. In response to a request by South Carolina E&G, we clarify

that firm third-party sales may be made from an undesignated portion of a network customer’s network resources (i.e., a “slice-of-system sale”), so long as all of the applicable requirements are met. In particular, the network customer must submit undesignations for each portion of each resource supporting the third-party sale. If the undesignation is temporary, then the request must be accompanied by a request to redesignate the resource(s) on a specific date. When the undesignation takes effect, the network customer must update the capacities specified in its list of designated network resources posted on OASIS.

B. Rehman, BPA Comment: Update list on OASIS and transfer capacities when designation, undesignation or termination is effective.

941

942

943-4

1606. The Commission clarifies that secondary service must be requested in accordance with section 18, including the timing restrictions set forth in section 18.3, of the pro forma OATT. Secondary service is on an as-available basis, and network customers should not be permitted to lock in such service in advance of other non-firm uses of available transmission. Allowing lower-priority secondary service to have a scheduling advantage over non-firm transmission would be inappropriate and would discourage the use of non-firm transmission service, thereby minimizing the revenue credits from nonfirm transmission service that benefit all firm transmission customers.

1608. The Commission proposed to clarify that network customers may not redirect network service in a manner comparable to redirect of point-to-point service, as network service involves no identified contract path and is, therefore, not a directable service. Should a network customer wish to substitute one designated network resource for another, the Commission stated that it must terminate the existing resource and designate a new one. The Commission explained that the network customer could also request to redesignate its original network resource by making a request to designate a new

B. Rehman, BPA Comment: Question on section 18, arranging for non-firm/secondary service, network customers would not have POR/POD or maximum capacity at each point, is that correct?







network resource. Alternatively, a network customer could use secondary network service when it wants to substitute a non-designated network resource for a designated network resource on an as-available basis.

1612. The Commission clarifies that network customers may not redirect network service in a manner comparable to the way customers redirect point-to-point service. Point-to-point service consists of a contract-path with a designated point of receipt and point of delivery. Network service has no identified contract-path and is therefore not a directable service. Network service instead provides for the integration of new network resources and permits designation of another network resource, which has the same practical effect as redirecting network service. If the customer wants to permanently substitute one designated network resource for another, it should terminate the designation of the existing network resource and designate a new network resource. The customer could then simply request to redesignate its original network resource, if it so desires, by making a request to designate a new network resource. The ability of a network customer to also temporarily substitute one designated network resource for another is addressed in section V.D.6.

969 1652. The Commission instead requires transmission providers to post on their public websites all rules, standards, and practices that relate to transmission service and provide a link to those rules, standards, and practices on OASIS. We conclude that it would not be appropriate to place the rules, standards, and practices only on OASIS as some transmission providers use certificates to restrict access to their OASIS sites. By providing a link on OASIS to the rules, standards, and practices that are otherwise publicly posted, the Commission ensures that all potential customers will have access to the information necessary for them to understand the terms and conditions of

B. Rehman, BPA Comment: Provide link to business practices, rules, standards, etc. on OASIS







service. We amend section 4 of the pro forma OATT to expressly establish this posting requirement.

972-3 1655. We also agree with requests to require a transparent process for amending rules, standards, and practices previously posted by a transmission provider. We therefore require each transmission provider also post on its public website (with a corresponding link on OASIS) a statement of the process by which the transmission provider will amend these rules, standards, and practices that are accessible via OASIS. As part of this process, the transmission provider must specify a mechanism to provide reasonable notice of any proposed changes to a posted business practice and the respective effective date of such change.943 We amend section 4 of the pro forma OATT to formalize this posting requirement and obligate transmission providers to follow the amendment procedures specified by the transmission provider. As with the requirement to post the underlying standards, rules and practices, we believe the amendment procedures required here will increase transparency and help minimize opportunities for undue discrimination.

B. Rehman, BPA Comment: Post link on OASIS to statement about process used to amend rules, business practices, etc., including mechanism to provide reasonable notice of changes and effective date of such change or additional procedures, such as opportunities for comment on proposed changes, etc.

973-4 1657. To that end, each transmission provider’s Attachment L must specify the qualitative and quantitative criteria that the transmission provider uses to determine the level of secured and unsecured credit required. Attachment L must also contain the following elements: (1) a summary of the procedure for determining the level of secured and unsecured credit; (2) a list of the acceptable types of collateral/security; (3) a procedure for providing customers with reasonable notice of changes in credit levels and collateral requirements; (4) a procedure for providing customers, upon request, a written explanation for any change in credit levels or collateral requirements; (5) a reasonable opportunity to contest determinations of credit levels or

B. Rehman, BPA Comment: Allow for credit guide or manual to be posted on OASIS.







collateral requirements; and (6) a reasonable opportunity to post additional collateral, including curing any noncreditworthy determination. We will allow the transmission provider to supplement Attachment L with a credit guide or manual to be posted on OASIS.




Order 890 Work Plan – April 16, 2007 Page 1 of 9

Order 890 Work Plan

Order Cite Action Item/Work Plan Action Item

Home Target Dates Status

ATC GROUP ASSIGNMENTS (ESS/ITS and BPS) 196 MOD003 (Procedure for Input on TTC and ATC Methodologies and Values)

NERC plans to retire MOD003 and recommend that the requirements included in MOD003 be adopted as NAESB Business Practices. Mr. Saini volunteered to draft NAESB Business Practices based on the requirements in MOD003 for review during the April 17, 2007 meeting.

WEQ 2007 Annual Plan Item 2

FORMAL COMMENT: The ESS/ITS and BPS plan to post a recommendation that includes NAESB Business Practices based on the requirements in NERC MOD003 for formal comment on June 1, 2007 WEQ EC VOTE: RATIFICATION:

196, 257, and 262

MOD006 (Procedure for Use of CBM Values)

NERC plans to retire MOD006 and recommend that the requirements included in MOD006 be adopted as NAESB Business Practices. The agenda for the April 17 meeting will include drafting NAESB Business Practices based on the requirements in MOD006. The participants noted that the Business Practices need to include a mechanism for Load Serving Entities to call for the use of CBM. It is not yet clear whether this will be an online request or done outside of OASIS. The Business Practices should also include the tagging requirements for use of CBM Values

WEQ 2007 Annual Plan Item 2 and Request No. R05004A Item 2

FORMAL COMMENT: The ESS/ITS and BPS plan to post a recommendation that includes NAESB Business Practices based on the requirements in NERC MOD006 for formal comment on August 1, 2007 WEQ EC VOTE: RATIFICATION:

196, MOD009 (Procedure for Verifying TRM Values WEQ 2007 FORMAL COMMENT: The





Order 890 Work Plan



272, 273 NERC plans to retire MOD009 and recommend that the requirements included in

MOD009 be adopted as NAESB Business Practices. The Business Practices will need to include verification of the TRM values posting as well as requirements for frequency of posting TRM Values. The BPS and ESS/ITS will begin drafting NAESB Business Practices based on the requirements in MOD009 as soon as NERC finalizes the revisions to MOD008, which is the TRM standard

Annual Plan Item 2

ESS/ITS and BPS plan to post a recommendation that includes NAESB Business Practices based on the requirements in NERC MOD009 for formal comment on August 1, 2007, however this date will depend on NERC’s revision to MOD008 WEQ EC VOTE: RATIFICATION:

243, 301, 328, and 369

Frequency and posting requirements for all ATC components (includes what, where and how)

Ms. Rehman volunteered to work with Mr. Wood to draft language for Business Practices for frequency and posting of all ATC components for review during the April 17, 2007 meeting

*See ESS/ITS Assignments GROUP 4 for development of OASIS business practices related to ATC and all ATC components posting requirements. The ATC Group should develop standards related to the NERC reliability standards and the ESS/ITS should develop posting requirements/revisions to S&CPs to implement the ATC Group’s standards.

WEQ 2007 Annual Plan Item 2 and Request No. R05004A

FORMAL COMMENT: The ESS/ITS and BPS plan to post a recommendation that includes NAESB Business Practices for frequency and posting requirements for all ATC components for formal comment on June 1, 2007 WEQ EC VOTE: RATIFICATION:





Order 890 Work Plan



246 293, 310

Business Practice requirements for any other requirements that come out of MOD001

During the April 17, 2007 meeting, the ESS/ITS and BPS plans to identify need for additional business practices to complement MOD001 and assign the drafting of language to a subcommittee member for review during the next meeting

Counterflows

WEQ 2007 Annual Plan Item 2 and Request No. R05004A

FORMAL COMMENT: The ESS/ITS and BPS plan to post a recommendation that includes Business Practices for any other requirements that come out of NERC’s revision to MOD001 for formal comment on July 1, 2007 WEQ EC VOTE: RATIFICATION:

Business practices to complement reliability standards contained in MOD004, MOD005, MOD007, and MOD008

The ESS/ITS and BPS is waiting on NERC to determine what business practices are needed to complement MOD004, MOD005, MOD007, and MOD008

WEQ 2007 Annual Plan Item 2(b)(ii)

FORMAL COMMENT: The ESS/ITS and BPS plan to post recommendations that includes NAESB Business Practices to complement the reliability standards contained in NERC MOD004, MOD005, and MOD007 for formal comment on August 1, 2007, however this date will depend on NERC’s revisions to those particular reliability standards WEQ EC VOTE:





Order 890 Work Plan



RATIFICATION:

1005 Redispatch: Develop any necessary business practices for redispatch.

** See ESS/ITS Assignments GROUP 1 for development of OASIS business practices related to redispatch posting requirements. The ATC Group should develop any standards necessary and the ESS/ITS should develop posting requirements/revisions to S&CPs to implement the ATC Group’s standards for redispatch.

FORMAL COMMENT: WEQ EC VOTE: RATIFICATION:

1377 Develop business practices related to coordination of request across multiple transmission systems.

*** See ESS/ITS Assignments GROUP 5 for development of S&CPs related to posting requests across multiple transmission systems.. The ATC Group should develop any standards necessary and the ESS/ITS should develop posting requirements/revisions to S&CPs to implement the ATC Group’s standards for requests across multiple transmission systems.

FORMAL COMMENT: WEQ EC VOTE: RATIFICATION:





Order 890 Work Plan



ESS/ITS ASSIGNMENTS

815 GROUP 0: RESALES

Revise existing Resales standards to align with directives in Order 890 WEQ 2007 Annual Plan Item 2

FORMAL COMMENT: The ESS/ITS plans to post a recommendation for formal comment that includes revisions to the Resales standards to address the directives in Order 890 after the April 3-4 meeting in time for the WEQ EC to vote on the recommendation at the May 8 meeting. WEQ EC VOTE: Planned to have recommendation in front of WEQ EC for May 8, 2007 meeting. RATIFICATION:

The Recommendation for the business practices was posted for formal comment on April 5, 2007 with comments due on May 4. The WEQ Executive Committee is scheduled to vote on this Recommendation at its May 8, 2007 meeting in Washington, DC. The modifications to the S&CPs will be processed under a separate recommendation that will also include other changes to the S&CPs required in Order 890.

GROUP 1: METRICS; RE-BID OF PARTIAL SERVICE; PRECONFIRMATION OF PRIORITY; REDISPATCH COST POSTING*

413 Metrics: Develop consistent methods of posting the required metrics related to the provision of transmission service under the OATT. Transmission Providers must

WEQ 2007 Annual Plan

FORMAL COMMENT: The ESS/ITS plans to post a





Order 890 Work Plan



also post underlying load forecast assumptions for all ATC calculations and actual daily peak load for the prior day. Specific requirements set forth in Paragraph 413 or Order 890.

1318 Metrics: Development of S&CPs, business practices , and OASIS modifications to provide performance metrics set forth in the order.

1378 Re-Bid of Partial Service: Develop business practice standards to allow a transmission customer to rebid a counteroffer of partial service so the transmission customer is allowed to take the same quantity of service across all linked transmission service requests. This will be an option for transmission customers.

Need to develop an extension to the TRANSCUST template in the S&CP.

1392 Preconfirmation of Priority: Need to revise S&CPs to prohibit Transmission Customers from changing a request into a pre-confirmed request and require OASIS platforms to be accessible on non-Windows/Explorer computers.

This will require a change to the TRANSCUST template in the S&CP. The S&CPs have been revised (at the subcommittee level) regarding the accessibility requirements.

1005 Redispatch Cost Posting: OASIS to allow for posting of third party offers of planning redispatch services.

Item 2

1162 Redispatch Cost Posting: Develop posting requirements for posting on OASIS monthly average cost of redispatch for each internal congested transmission facility or interface over which the TP provides redispatch service using planning redispatch or reliability redispatch under the pro forma OATT.

Posting requirements for posting high and low redispatch cost for the month for each of the same transmission constraints.

recommendation for the ESS/ITS Group 1 items for formal comment with comments due by the end of 2nd Quarter 2007 WEQ EC VOTE: RATIFICATION:





Order 890 Work Plan



Posting requirements for posting internal constraint or interface data for the monty.

This data should be posted as soon as pratcial after the end of each month, but no later than when the TP sends invoices to TCs for redispatch related services.

GROUP 2: NETWORK SERVICE ON OASIS

385 Develop appropriate templates for OASIS for requesting the designation of new network resources and to terminate the designation of network resources. Shall be posted on OASIS for 90 days and available for audit for a 5 year period Will result in ability of Transmission customers to be able to query requests to designate and terminate a network resource. Requests and responses made electronically.

WEQ 2007 Annual Plan Item 2 and Request No. R04006E

1477 Develop business practice standards describing procedural requirements for submitting designations over any new OASIS functionality.

1504 Develop details of how the view, download, and query requirements for information posted regarding network resource designations informational postings.

1532 Attestation: Formatting of attestation information that will be provided on OASIS.

1541 Develop OASIS functionality and business practice standards describing the procedural requirements for submitting both temporary and indefinite terminations of network resources, to all network customers to provide all required information for such terminations. See paragraph 1541 of Order 890 for specific requirements for this functionality.

FORMAL COMMENT: The ESS/ITS plans to post a recommendation for ESS/ITS Group 2 items for formal comment with comments due by the end of 3rd Quarter 2007 WEQ EC VOTE: RATIFICATION:

GROUP 3: CONDITIONAL FIRM; PRE-EMPTION; REQUEST R05019; and REVISIONS TO STANDARD 9.7





Order 890 Work Plan



1046, 1078

Conditional Firm: Development of communication protocols for conditional firm including tracking mechanism and regional variation. Need to review the tagging rules related to the use of conditional firm.

1407 Pre-emption: A pre-confirmed request for transmission service will preempt a request of equal duration that has been accepted by the transmission provider but not yet confirmed by the transmission customer. This is consistent with NAESB Standard WEQ 001-4.25 See also, Request No. R05019: Modify OASIS standards and S&CP to clearly document the procedures used to implement the displacement/interruption terms of the Pro Forma tariff.

1269 Revisions to Standard 9.7: Revise 9.7 consistent with the Commission’s policies.

FORMAL COMMENT: The ESS/ITS plans to post a recommendation for ESS/ITS Group 3 items for formal comment with comments due by the end of 4th Quarter 2007 WEQ EC VOTE: RATIFICATION:

GROUP 4: ATC RELATED POSTINGS and COUNTERFLOWS**

ATC Related Postings

Develop all ATC related postings changes to the S&CPs

243 Consistency in ETC calculations: Posting requirements will require development/revisions to the S&CP

293, 310

Counterflows

262 Develop OASIS mechanism that will allow for auditing of CBM usage

369 Posts the reason for change in ATC values on OASIS; consider whether to develop standard explanations. This may require an evaluation of the design of the security template.

FORMAL COMMENT: The ESS/ITS plans to post a recommendation for ESS/ITS Group 4 items for formal comment with comments due by the end of 1st Quarter 2008 WEQ EC VOTE: RATIFICATION:





Order 890 Work Plan



1377 GROUP 5: PARAGRAPH 1377***

Develop S&CPs related to coordination of request across multiple transmission systems.

MISCELLANEOUS

1390 FERC: OATT is sufficient to allow a Transmission Provider to manage situations where the Transmission Customer modifies its application for service to the point that the request is “meaningfully different” than initial request. ESS/ITS: need to review if this has any impact on business functions.

1627 Posting of curtailment information on OASIS: develop a detailed template for the posting of additional information on OASIS regarding firm transmission curtailments.




Two page update on Status of post-split development of TLR standards, January 29, 2007 Page 1

TO: Rae McQuade, President, NAESB

FROM: DeDe Kirby, NAESB Meeting and Project Manager

RE: Update on development of the split Transmission Loading Relief (TLR) NAESB Business Practice Standards and the status of the standards

DATE: January 29, 2007

August 2-3, 2004: On August 2-3, 2004, team leaders from the NERC Version 0 Standards Drafting Team and the NAESB Business Practices Subcommittee (BPS) met in Chicago, IL to develop a joint recommendation on the division of the NERC Operating Policies into NAESB Business Practice Standards and NERC Reliability Standards. The unanimously endorsed recommendation of the task force for TLR was for NERC and NAESB to adopt a TLR procedure document with the same language and format in their respective Version 0 standards and immediately begin a joint project to develop replacement Version 1 standards distinguishing reliability requirements and business practices by the end of 2005.

August 16, 2004: The final recommendation of the joint task force that meant in Chicago was presented to the Joint Interface Committee on August 16, 2004. The recommendation above for the separation of business practices and reliability standards from the Version 0 TLR standard with commitment to file the Version 1 standards with the FERC by end of year 2005 was unanimously approved by the members of the JIC.

December 31, 2004: NAESB WEQ membership ratified the Version 0 TLR (pre-split) standards.

December 8, 2004: The joint TLR Task Force met 8 times from December of 2004 until June of 2005 to complete the designated split of the business practices from the reliability standards of TLR Version 0. On June 1-2, 2005 the NAESB members of the task force unanimously supported the division completed by the task force and the NERC members took a straw man vote to show their unanimous support. At this point, the standards moved to their assigned drafting teams at NERC and NAESB for completion.

June 14-15, 2005: The NAESB WEQ BPS met 7 times, from June 14-15, 2005 to October 12, 2005, to complete the NAESB post-split TLR standard. It was voted out of subcommittee on October 12th. Please note the standard was posted for informal comments prior to being voted out of subcommittee.

(NERC) July 14, 2005: NERC Operating Reliability Subcommittee (ORS) submitted a Standards Authorization Request (SAR) for the post-split NERC TLR Standards. Twelve sets of comments were submitted on the SAR: six sets supported the division and six did not.

October 10, 2005: R05009 Recommendation (Modify the NAESB Version 0 TLR business practices to remain consistent with the NERC Version 0 TLR reliability standards [dynamic flows]) was ratified by NAESB WEQ membership.1

(NERC) November 18, 2005: NERC ORS sent a letter to NAESB requesting that NAESB cease development of Recommendation R04013A (NAESB post-split TLR standards) based upon the comments received at NERC. This letter was received as comments on Recommendation R04013A. All comments received on the recommendation were reviewed by the NAESB BPS on November 22nd in preparation of the NAESB November 29th WEQ Executive Committee (EC) meeting. Although these comments were officially considered by the WEQ EC, the BPS members noted the following reasons that NAESB should move forward with Recommendation R04013A: a separate standard should exist at NAESB to adequately address the commercial needs of the industry; division and maintenance of standards had been addressed previously by NERC and NAESB during other standards drafting activities (Coordinate Interchange); the JIC had previously unanimously supported the assignment of this project and; not moving forward with the standard could effect the standards drafting process at both NERC and NAESB.

1 Please note that this change to the NAESB pre-split Version 0 standard was completed to correspond with NERC changes to their Version 0 TLR standards to account for dynamic schedules. This change followed up on the commitment of NERC and NAESB to keep the standards in line with the “same language and format.” The Urgent Action SAR was approved by the NERC Board of Trustees in June 2005.





November 29, 2005: Recommendation R04013A (post-split TLR standards) was reviewed by the WEQ Executive Committee. The WEQ EC recommended the adoption of the TLR Business Practices with ratification held in abeyance until TLR implementation issues between NERC and NAESB were clearly defined. The WEQ EC recommended the WEQ Board members make this determination.

December 19, 2005: The WEQ EC approved the Recommendation by notational ballot on December 19, 2005.

February 17, 2006: NAESB filed a progress report with the FERC updating them on the state of the NERC-NAESB joint standards development process.2 The following statement, found in the progress report, reaffirms NAESB’s commitment to complete the joint development of the TLR standards and to work with NERC to provide for standards that complement each other:

NAESB would not immediately file these business practices with the Commission for consideration until NERC and NAESB have had an additional opportunity to determine if further changes are needed, and NERC has completed it process of developing the reliability standards. It is expected that NERC and NAESB will employ the joint development process to ensure that the coordination of the development of the two products is achieved.

February 22, 2006: Joint development template for NERC and NAESB efforts was presented to the Board of Directors via email. The Board unanimously adopted the template and authorized the NAESB office to move forward with ratification of the post-split TLR standards.

(NERC) February 24, 2006: NERC filed a statement with the FERC in support of the progress report on joint standards development filed by NAESB on February 17, 2006.3

April 10, 2006: The post-split standard was ratified by 80% of the NAESB WEQ Membership that voted.

(NERC) May 3, 2006: NERC ORS discussed SAR for post-split standards and future action plan.

(NERC) June 22-23, 2006: NERC Standards Authorization Committee (SAC) approved the formation of a TLR SAR Drafting Team and asked for nominations for this team.

(NERC) August 2, 2006: URGENT ACTION: SPP Regional Difference - IRO-006-3 posted for NERC Board of Trustees adoption.

(NERC) August 17, 2006: The NERC TLR SAR Drafting Team began meeting. Its first priority is to answer the comments submitted on the previous NERC TLR SAR.

September 1, 2006: R06002 Recommendation - Modify NAESB pre-split Version 0 TLR business practices to remain consistent with NERC IRO-006-1 pre-split TLR reliability standards (inclusion of market flows). – was ratified by 100% OF THE NAESB WEQ Membership that voted.4

(NERC) September 11, 20065: The NERC TLR SAR Drafting Team held its second meeting.

2 Progress Report on NAESB Activities impacting Docket No. RM05-5-000, "Standards for Business Practices and Communication Protocols for Public Utilities", filed with the Commission on February 17, 2006, Accession Number 20060217-5041. 3 Statement of North American Electric Reliability Council In Support of Comments and Report by North American Energy Standards Board, under RM05-5 filed with the Commission on February 21, 2006, Accession Number 20060217-5082. 4 Please note that Recommendation R06002 also follows up on NERC and NAESB’s commitment to keep the Version 0 standards in line with the “same language and format.” However, this commitment was made in reference to the standards held in NERC Operating Policy IRO-006-Attachment 1. NERC waivers in the version 0 standards were not contained in Attachment 1. It would not have been appropriate to contain these waivers in the NAESB Version 0 standard, since there originally not part of Attachment 1. However, during the Version 1 effort it was determined that these waivers were commercial in nature (please reference the addition to the NAESB standard of the PJM/MISO regional difference). Therefore, NERC has made the SPP change to IRO-006 (NERC’s version 0 standard) and NAESB has made the corresponding change to its version 1 standard (more specifically, regional differences are included in Appendix D of the NAESB post-split standard). When NERC completes its version 1 standard, the SPP waiver should not be included. 5 Please note that more information is not available for this meeting (or the following meeting) on the NERC website at this time.





(NERC) October 2, 2006: The NERC TLR SAR Drafting Team held its third meeting in Carmel, Indiana.

(NERC) October 13, 2006: The NERC TLR SAR Drafting Team held its fourth meeting.

(NERC) November 6, 2006: The NERC TLR SAR Drafting Team held its fifth meeting.

(NERC) December 5, 2006: The NERC TLR SAR Drafting Team held its sixth meeting. NERC SC (Executive Committee) held a conference call the same day and approved the TLR SAR that includes the General Update with NAESB. The SC EC authorizes team to keep moving forward with drafting, even thought the SAR is posted for commented and nominations must be submitted for the NERC TLR Drafting Team. The SAR Drafting Team sent a memo to Gerry Cauley and Rae McQuade notifying them of their intent to move forward was under the joint development process. The NERC Standards Drafting Team and WEQ BPS will now meet jointly to continue development of TLR NERC Reliability Standards and to make modifications to the ratified post-split TLR business practices as needed. The NAESB team is proceeding with any changes necessary under the WEQ 2007 Annual Plan Item 1 (d) (ii) and (iii).

January 10-11, 2007: The NERC TLR Drafting Team and the NAESB WEQ BPS met jointly in Houston, TX to continue work on the development of the NERC TLR post-split reliability standards and any modifications to the NAESB ratified post-split standards. The group discussed how best to develop a joint operator’s manual for the two sets of standards, once the NERC standards are complete. It is anticipated that in order to have a manual that makes sense, transition language must be added to the NAESB standards. In addition, NERC staff informed the teams that when balloted, it would be necessary to include the NAESB standards. The balloting body will be informed that the NAESB standards are not to be voted on. However, the removal of those portions from the NERC TLR standards must be voted on. Therefore, the group continued with delineating the standards and which were included in the NAESB business practices, and which are to be included in the NERC reliability standards. The group also discussed the implication and effect of the PJM/MISO curtailment threshold field test (included in the SAR) on the development of the TLR standards and the incorporation of the regional differences for PJM and SPP in the NAESB ratified standards (Appendix D). 6

February 27-28, 2007: The teams met jointly in Birmingham, AL to continue work on the development of the NERC post-split reliability TLR standard. Much of the content of IRO-006 Attachment 1 assigned to NERC deals with the IDC. A decision was made to include these sections in an IDC Reference Document that would become Attachment 2 of IRO-006, instead of including in Attachment 1. A decision was also made to maintain Section E of IRO-006 (PJM Regional Differences) in both documents (in NAESB it is part of Appendix D) until after the completion of the PJM field test on curtailment at NERC. The WEQ BPS noted that it would change the NAESB requirements to clarify reallocation for a TLR level 5a and 5b. It was also decided by the team that NERC should not post the standard for comment until all parts of the standard package were complete because it is the opinion of the team that if commenters are able to view the entire package there will be more support for NERC’s post-split Attachment 1.

March 19, 2006: The WEQ BPS met to revise the R06002 post-split TLR standard to include Reallocation language for a TLR level 5a and 5b. It was the decision of the team to mimic the Reallocation language for a TLR level 3a and 3b. The team will review the change with the joint team on March 28-29.

March 28-29, 2007: The teams met in Houston, TX to continue work on the draft standards. The language added to the NAESB business practices for Reallocation for a TLR level 5a and 5b mimics that for a TLR level 3a and 3b and is included as a separate requirement. The joint team approved of the change made by the BPS. The team completed a list of action items for IRO-006, including compliance measures that NERC noted must be completed before the standard can be submitted for comment. In addition, the team discussed the joint operator’s manual for TLR. NERC will not post the IRO-006 and Attachment 1 for comment without a thorough example of the manual because it is their opinion the standard will receive too many negative comments without the manual to continue. A timeline was laid out for the completion of the NERC process for the standard. It is included in this timeline.

April 18-19, 2007: The teams will meet in Houston, TX to continue work on the draft standards. The agenda for the meeting will include the following:

• Completion of all documentation and review for posting 6 Please note that these are notes kept by Ms. Kirby, as minutes are not available for this meeting from the NERC TLR drafting team at this time. When available, these notes will be updated.





• It is anticipated that the standard will be posted for comment on May 1st. The comment period is for 45 days.

May 23-24, 2007: The team will meet jointly in Chattanooga, TN and NERC will host. The agenda for the meeting will include the following:

• NERC Phase 3 items to begin – (discussion on how this will affect the NAESB standard)

June 15, 2007: Comments are due back on the NERC posting.

June 19-20, 2007: The teams will meet in Houston, TX to answer comments submitted on the NERC reliability standard.

July 11-12, 2007: This meeting date will be held on the calendar. It is likely that the NERC standard will require another round of comments. If so, this meeting will be used to prepare for that posting.

July 15, 2007: If a second round of comments is necessary for the NERC standard, the goal is to post by this date. An additional 30 day posting will be necessary if changes are made to the standard as a result of the first round of comments.

August 15, 2007: Comments on revised NERC standard are due.

August 22-23, 2007: This date will be held on the calendar to address the second round of comments.

September 4, 2007: NERC 30 day pre-ballot posting date.

October 5, 2007: NERC 10 day ballot posting.

October 15, 2007: (NERC) Answer no votes with comments.

October 19, 2007: Additional NERC 10 day ballot posting.

October 29, 2007: NERC ballots are due. If the standard passes, it is sent to the NERC Board. If it fails, a new process must begin.

Note that if quorum is not met at NERC for a balloting period, it extends the period for 10 days. In addition, the standard must be sent to the NERC Compliance Review group.

(NERC) 2nd Quarter, 2008: NERC’s expected date of completion of TLR Split





TAB 12

2007 Annual Plan

• The 2007 plan as approved by the Board of Directors at its March 2007 meeting is included. Should the WEQ

EC determine that changes are to be made to the plan as a result of the subcommittee updates; a motion to approve the changes for forwarding to the Board for approval would be required. The motion would require a simple majority to pass.

• The materials in Tab 12 correspond to agenda item 6 for the WEQ EC agenda. .


North American Energy Standards Board 1301 Fannin, Suite 2350, Houston, Texas 77002 Phone: (713) 356-0060, Fax: (713) 356-0067, E-mail: [email protected]


2007 NAESB Wholesale Electric Quadrant Annual Plan Approved by the Board of Directors on March 22, 2007

Page 1 of 7

NORTH AMERICAN ENERGY STANDARDS BOARD 2007 WEQ Annual Plan – Approved by the Board of Directors on March 22, 2007

Item Description Completion1 Assignment2

1 Develop business practices standards as needed to complement reliability standards

Develop business practice standards to support and complement NERC reliability standards, NERC policies and NERC standards authorization requests (SARs) using the NERC/NAESB Coordination Joint Standards Development Process as appropriate. Current NAESB activities underway to develop business practice standards that are supportive of this annual plan item are:

a) Make version 1 changes to business practices as requested. Ongoing BPS

i) Make changes to business practices as related to inclusion of the NERC Reliability Functional Model functional model entities as NERC undertakes the same efforts.

Status: No requests.

As requested BPS

b) Develop business practices to support Coordinate Interchange – R05020 “Include a guideline for rounding schedules with partial mWh's in the coordinate interchange business practice WEQ BPS-002-000”

Status: Not Started.

2nd Q, 2007 BPS

JISWG

c) Develop business practice standards to support Operate Within Limits (R03017).

Status: Not Started. Coordination of NAESB timeline with NERC timeline is required.

2007 BPS

d) Develop business practices to support the reliability components of TLR.

i) Version 0 Split of TLR business practices from reliability components.

Status: Completed ratification and delayed publication and filing with FERC until NERC has had the opportunity to complete its split.

2nd Q, 2007 BPS

ii) Continuous support of TLR Procedure in alignment with NERC efforts including version 1 development.

Status: Ongoing as NERC makes changes. R06002 completed and approved by the WEQ EC on 5-9-06.

Ongoing BPS

iii) Complete version 1 TLR business practices.

Status: Dependent on successful completion of NERC efforts – 1(d)(i).

2nd Q, 2007 BPS

e) Determine any needed NAESB action in support of the Interchange Distribution Calculator (IDC) and develop any necessary standards.


4th Q, 2007 BPS

f) Develop jointly with NERC a Joint NERC/NAESB Operating training manual.

Status: Not Started. Dependent on completion of version 1 TLR BPs, 1(d)(i).

2nd Q, 2007 BPS





Page 2 of 7



2 Develop business practice standards in support of the FERC RM05-25-000 and RM05-17-000 (OATT Reform)

a) Develop version 1 business practice standards to better coordinate the use of the transmission system among neighboring transmission providers. Such business practice standards would be based on recommendations from NERC's Long Term ATC/AFC Task Force and would involve revised procedures for the ATC calculation and/or revised protocols as determined by the final order.

Status: Underway using joint standards development process with NERC. Request R050004 was expanded to include the OATT NOPR items (NOPR, Docket Nos. RM05-25-000 and RM05-17-000, “Preventing Undue Discrimination and Preference in Transmission Services”, issued May 19, 2006).

2007 BPS/ESS

b) Develop the needed business practices as companion to the NERC standards for ATC related efforts.

TBD BPS/ESS

i) Develop standards to support existing Request No. R05004.

Status: Underway

TBD BPS/ESS

ii) Develop the needed business practices to support NERC efforts (MOD 001-MOD 009, FAC 12/13).

Status: Underway

TBD BPS/ESS

c) Develop version 1 business practice standards to support transparency reporting and related functions that may be required as a result of the final order.


TBD BPS/ESS

3 Develop business practices standards to improve the current operation of the wholesale electric market and develop and maintain business practice and communication standards for OASIS and Electronic Scheduling

a) Develop and/or maintain business practice standards as needed for OASIS and electronic scheduling. Specific items to address include:

i) Develop OASIS S&CP changes to support OASIS business practices:

1) Implementation of S&CP changes to support "relinquish" mechanism to complement non-firm redirects (R04006C1).

Status: Complete – approved by the WEQ EC on 2-6-07.

1st Q, 2007 ESS/ITS

2) Implementation of S&CP changes to support Standards of Conduct business practices.

Status: Complete – approved by the WEQ EC on 2-6-07.

1st Q, 2007 ESS/ITS





Page 3 of 7



ii) Network Services: Determine and develop needed business practice standards or other support is needed to support use of OASIS for Network Service transactions (R04006E).

Status: Underway.

3rd Q, 2007 ESS/ITS

iii) Registry: Determine and develop needed business practice standards to support the registry functions currently supported by NERC (R04037).

Status: Underway.

3rd Q, 2007 JISWG

iv) Identify e-Tag enhancements to support business practices (including e-Tag specification changes) (R05018).

Status: Underway.

3rd Q, 2007 JISWG

v) Document procedures used to implement the displacement/interruption terms of the Pro Forma tariff (R05019).

Status: Not Started.(Related to request R05004)

4th Q, 2007 ESS/ITS

vi) Make incremental enhancements to OASIS as an outgrowth of the NAESB March 29, 2005 conference on the future of OASIS (R05026).

Status: Underway. Scoping statement completed by SRS and to be considered by the WEQ EC for assignment.

TBD Not Assigned

vii) Respond to issues in FERC Order No. 676 (Docket No. RM05-5-000) – NAESB WEQ Standards 001 9.7, (paragraph 51 of the order).

Status: Underway – see item 7 in provisional items. Delayed awaiting rulemaking on OATT NOPR.

Delayed ESS/ITS

b) Develop and/or maintain standard communication protocols and cyber-security business practices as needed.

i) Address the surety assessment findings on NAESB PKI standards.

Status: Complete, will be provided as a response to the U.S. DoE upon completion by the WGQ for their response to the findings.

1st Q, 2007 JISWG

ii) Develop PKI standards for OASIS.


2nd Q, 2007 ESS

iii) Develop PKI Standards for e-tagging.

Status: Underway.

2nd Q, 2007 JISWG

iv) Develop enhanced Electric Industry Registry (EIR), (R06027)

Status: Underway.

3rd Q, 2007 JISWG

c) Develop needed business practice standards for organization/company codes for NAESB standards – and address current issues on the use of DUNs numbers.

3rd Q, 2007 NAESB Staff with WEQ support





Page 4 of 7



Status: Underway.

4 Review and develop business practices standards as applicable to address seams issues

a) Review and evaluate entries in existing Seams Catalog and identify possible business practices development.

Status: Underway.

2nd Q, 2007 Seams

b) Develop business practice standards as identified from the review of the seams catalog.

Status: Underway.

TBD To be assigned

5 Review and develop business practices standards to support e-Tariff program

Develop business practices as needed to support the e-Tariff program including submittal of tariffs and metadata. (Docket No RM05-1-000)

Status: Underway.

3rd Q, 2007 Joint WEQ/WGQ e-Tariff Subcommittee





Page 5 of 7

NORTH AMERICAN ENERGY STANDARDS BOARD 2007 WEQ Annual Plan – Approved by the Board of Directors on December 14, 2006

Proposed Changes from the WEQ EC on 2-6-07

PROVISIONAL ITEMS

1 Develop and or modify business practices related to support of NERC effort on the NERC Resources and Transmission Adequacy and Inadvertent Interchange Data Standards BAL-006 revisions.

2 Develop business practice standards as requested by the regional and state advisory groups.

3 Using the NERC Interconnected Operations Services reference document (March 2002, version 1.1) as a guide and starting point, develop business practices as necessary for ancillary services and/or interconnected operating services transactions.

4 Develop business practice standards as related to the Effectiveness Study of Competitive Wholesale Markets (Congressional Mandate), Electric Energy Market Competition Task Force, Docket No. AD05-17-000, issued by the FERC on October 13, 2005.

5 Develop and or modify business practices as requested by FERC related to gas-electric coordination issues in Docket No. RM05-5-001, "Standards for business practices for Interstate Natural Gas Pipelines", "Standards for Business Practices for Public Utilities," issued October 25, 2006 and related order on inquiry, "Order Instituting Inquiries into Gas-Electric Coordination Issues," also issued on October 25, 2006.

6 Develop and/or maintain business practice standards to support gas-electric interdependencies

• Respond to requests as received that are related to Docket No. RM05-28-000.

• Respond directives related to the conclusions of the NAESB reports submitted in Docket No. RM05-28-000.

7 Develop business practices as needed to support NAESB Retail Electric Quadrant efforts on demand side management and energy efficiency programs.





Page 6 of 7

NAESB WEQ EC and Subcommittee Leadership: Executive Committee: Kathy York (WEQ EC Chair) and Clay Norris (WEQ EC Vice Chair)

Standards Review Subcommittee: Raj Rana, Narinder Saini Seams Subcommittee: Robert Schwermann Business Practices Subcommittee & Task Forces: Kathy York & Jim Busbin Electronic Scheduling Subcommittee/Information Technology Subcommittee & Task Forces: Paul Sorenson, J.T. Wood • Joint Interchange Scheduling Working Group (JISWG): Bob Harshbarger e-Tariff Joint WEQ/WGQ Subcommittee (e-Tariff): To be named

Wholesale Electric Quadrant Executive Committee (WEQ EC)

Standards Review Subcommittee (SRS)

Seams Subcommittee

Business Practices Subcommittee (BPS)

Electronic Scheduling Subcommittee (ESS)

Information Technology Subcommittee (ITS)

Joint Interchange Scheduling Working Group (JISWG)

Scoping

Task Forces & Working Groups

Development

E-Tariff Joint WEQ/WGQ Subcommittee





Page 7 of 7

End Notes: 1 Dates in the completion column are by end of the quarter for completion by the assigned committee. The dates do not necessarily mean that the standards are fully staffed so as to be implementable by the industry, and/or ratified by membership. If one item is completed earlier than planned, another item can begin earlier and possibly complete earlier than planned. There are no begin dates on the plan. 2 The assignments are abbreviated. The abbreviations and committee structure can be found at the end of the annual plan document.





TAB 13

Request to the Drafting Collaborative

• The WEQ EC proposed changes to the drafting collaborative are included. The WEQ Leadership has asked that

the WEQ EC provide a more detailed reasoning for the request to make the proposed changes.

• The materials in Tab 13 correspond to agenda item 7 for the WEQ EC agenda.


From: Rae Mcquade Sent: Tuesday, February 27, 2007 10:30 AM Subject: Request to the NAESB Drafting Collaborative Regarding Restriction Against Holding Concurrent Seats on the WEQ Board and WEQ EC

Dear WEQ Board, WEQ EC, and Posting for Interested Parties,

At the February Wholesale Electric Quadrant Executive Committee Meeting, there was a unanimous vote to request that the WEQ Board and the Drafting Collaborative review the WEQ Procedures and consider removal of the restriction against a NAESB WEQ member holding both a WEQ Board and WEQ EC seat concurrently, (this would assume that they were duly elected to both seats). I have taken the liberty to begin a redline of the procedures to that effect and have attached the draft procedures for your consideration. If you are interested in participating in the Drafting Collaborative where this item will be considered, please let our office know and we will add you to the distribution list. A conference call will be set up shortly to discuss the redlined language and determine if there is support to go forward. For reference, this item will also be discussed at the upcoming WEQ leadership meeting on March 21 and the Board meeting on March 22.

With Best Regards,

Rae

Rae McQuade, President, NAESB 1301 Fannin, Suite 2350, Houston, Texas 77002 713-356-0060 (phone), 713-356-0067 (fax), 281-830-7406 (cell), www.naesb.org <http://www.naesb.org/> (web)


North American Energy Standards Board Wholesale Electric Quadrant Procedures

As Amended and Approved by the NAESB WEQ Membership – February 2, 2007PUT NEW DATE HERE

WEQ Quadrant Procedures as Approved February 2, 2007 PUT DATE HERE -- Page 1 of 13

1 Definitions 1.1 Definitions Included In NAESB Bylaws

All capitalized terms, if not defined in Section 1.2, shall have the same definitions as specified in the Bylaws or Certificate of Incorporation (Certificate) of NAESB. 5

1.2 Definitions for the Purposes of this Exhibit A “Entity” - an individual, partnership, firm, corporation or organization who is a Member of the

WEQ. B “IOU” - an investor owned entity with substantial business interest in owning and/or operating any

two of the following three asset categories --- generation, transmission, distribution. 10 C “Segment Membership” - the Segment Members collectively. D “Segment Procedures” - the procedures that may be attached to this document as exhibits for each

of the Segments, as amended. E “Services” - providers of services to participants in the wholesale electric industry, which would

include, but not be limited to, software providers, consultants and other Entities not otherwise 15 considered to be a Transmission, Generation, Marketer/Broker, Distribution/Load-Serving Entity or End-User.

F “Sub-Segment” - the allocation of Board and EC seats as shown on Attachment A. G “Sub-Segment Principles” - the principles described in Section 2.4 of these Procedures. H “Sunrise” - Sub-Segments may be revisited at any time, but no later than three (3) years from 20

WEQ formation approval by the NAESB Board. . I “WEQ” - the Wholesale Electric Quadrant. J “WEQ Designated Alternates” - the group of WEQ Memberships selected by each WEQ

Membership Segment’s Sub-Segment to serve in the stead of WEQ EC Members who are unable to attend EC meetings. 25

K “WEQ EC” - the Executive Committee of the WEQ. L “WEQ Membership” - the Voting Members of the WEQ collectively. M “WEQ Segment” - one of six (6) equal Membership Segments of the NAESB WEQ, representing

the following functions that exist in the operation of the wholesale electric industry: Transmission; Generation; Marketers/Brokers; Distribution/Load Serving Entities; End 30 User, Independent Grid Operators/Planners.

2 Purpose, Scope, Activities and Policies 2.1 Purpose, Scope and Activities

A Purpose The purpose of the WEQ of NAESB is to propose, evaluate and adopt voluntary Standards that 35 apply to business practice Standards, Model Business Practices and communication protocols including, but not limited to, electronic data interchange (“EDI”) record formats. All Standards shall be designed to promote more competitive, efficient and reliable wholesale electric service.

B Scope and Activities The WEQ is concerned with activities necessary or desirable to achieve the objectives and 40 purposes of the commercial aspects of the wholesale electric industry, and are appropriate to the operation of the wholesale electric market. The WEQ will work closely with other NAESB Quadrants to strive for consistency where proposed business practice Standards, Model Business Practices and communication protocols affect those other Quadrants. 45





2.2 Policies The WEQ shall comply with the policies and procedures specified in the Bylaws and Certificate of

NAESB. 2.3 Segment Organization and Description

The WEQ shall be composed of six Segments: (1) Transmission, (2) Generation, (3) 50 Marketers/Brokers, (4) Distribution/Load Serving Entities, (5) End Users and (6) Independent Grid Operators/Planners. Each prospective Member of the WEQ shall declare the Segment(s), and if applicable, the Sub-Segment, with which they have a legitimate business interest and are to be identified. A Transmission 55 Any Entity engaged in the activity of owning, operating or controlling bulk electric transmission

facilities in North America. B Generation Any Entity engaged in the activity of owning and/or operating wholesale electric generation

facilities in North America. 60 C Marketers/Brokers Any Entity engaged in the activity of buying and selling wholesale electric power in North

America on a physical or financial basis. D Distribution/Load-Serving Entities Any Entity engaged in the activity of electric power sales and/or delivery to end use customers in 65

North America, or any Entity designated to represent a distribution utility. E End Users Any Entity in North America that is an end use consumer of electricity, engages in electricity

regulation, or represents customer interests, or any Entity designated to represent an end user. F Independent Grid Operators/Planners 70 Any Entity in North America authorized by an appropriate governmental authority to operate as a

regional transmission organization, independent system operator, independent tariff administrator or independent planning entity and which does not have a business or financial interest in any other WEQ segment

2.4 Sub-Segment Principles 75 The WEQ shall use the following principles to develop Sub-Segments for each Segment. These principles shall continue to be used for future Sub-Segment development. Sunrise rules will apply to the Sub-Segments. Changes to Sub-Segments require a 75% affirmative vote of the WEQ Membership from that Segment of which that Sub-Segment is a part and a 67% affirmative vote of the WEQ Membership as a whole. In both cases, the percentages are calculated based on those members 80 who return ballots. Appeals of the changes to Sub-Segments should be addressed b y the aggrieved Sub-Segment to the NAESB Office. The appeals will be considered by the NAESB Board of Directors members who represent the WEQ, and will be resolved through a 75% affirmative vote of the NAESB Board of Directors members representing the WEQ, and a minimum 40% affirmative vote of each of the NAESB Board of Directors members representing the WEQ for each of the WEQ Segments. As 85 noted earlier, the percentages are calculated based on those members who vote. The Segment organization will operate under the following Sub-Segment Principles: A No single business interest can by itself pass a Standard. B All appropriate interests are represented. C No Sub-Segment may alone block action. 90 D Creation of any new segment requires sub-segment definitions within 9 months after segment

population.





2.5 Sub-Segment Organization See Attachment A. Attachment A “Procedural Elements” are not intended to conflict with the WEQ 95 Quadrant Procedures. As of February 2, 2007, the Sub-Segments and seats held on the Board of Directors and Executive Committee per Segment are:

Transmission: Sub-segments: Muni/Coop Number of Seats: 1 Fed/State/Provincial 1 IOU 2 100 ITC 2 At Large 1

Generation: Muni/Coop 1 Fed/State/Provincial 1 IOU 2 105 Merchant 2 At Large 1

Marketers/Brokers: Muni/Coop 1 Fed/State/Provincial 1 Non- IOU Affiliated 2 110 IOU Affiliated 2

At Large 1

Distribution/Load Serving Entities: Muni/Coop 2 IOU 2 Competitive Retailer 1 115 (not available to muni/coop, IOU or IOU affiliates) Other 1 (not available to muni/coop, IOU or IOU affiliates) At Large 1

End Users: End Use (also in another segment) 1 120 Regulator 1 Residential/Commercial 1 Large Industrial (not in other segments) 2 End Use (Self Generation) 1 At Large 1 125

Independent Grid Operators/Planners 7

3 Reserved

4 Reserved

5 Members 130 5.1 Voting Members A Membership

Membership and voting rights in the WEQ shall be open to any person or legal Entity that: 1 Has an active, significant business interest in the wholesale electric market or is the

representative or Agent of such a person or Entity, and 135 2 Is current in payment of its membership dues. B Multiple Memberships Per Quadrant

Memberships in multiple Segments of the WEQ are permissible for any Entity, provided each membership is filed and declared with NAESB, the Entity meets the membership requirements of





each Segment joined, membership dues are paid for each Segment and different company 140 personnel are used for each Segment’s activities.

C Segment and Sub-Segment Qualification Upon joining the NAESB WEQ, the Voting Member must identify a Segment and within that Segment, only one Sub-Segment, in accordance with Section 2.3 and the Sub-Segment allocation shown in Attachment A, that it feels most closely aligns with its business interest. 145 If membership in the Segment is challenged, participation by this Voting Member can be barred by a 67% affirmative vote of that Segment. If a Voting Member is disallowed, the Voting Member has 60 days to appeal the decision to the Board of Directors, and upon receipt of the appeal, the Board of Directors will take action within 60 days. If the Voting Member does not appeal the disallowal or if the Board of Directors upholds the disallowal action in the case of an 150 appeal, reselection of Segment and Sub-Segment will be required. In the case of an appeal, the Voting Member will remain a Voting Member in the Segment, and Sub-Segment, pending the resolution of the appeal by the Board of Directors. If membership in the Sub-Segment is challenged, participation by this Voting Member can be barred by a 67% affirmative vote of that Sub-Segment. If a Voting Member is disallowed, the 155 Voting Member has 60 days to appeal the decision to the Board of Directors, and upon receipt of the appeal, the Board of Directors will take action within 60 days. If the Voting Member does not appeal the disallowal or if the Board of Directors upholds the disallowal action in the case of an appeal, reselection of Segment and Sub-Segment will be required. In the case of an appeal, the Voting Member will remain a Voting Member in the Segment and Sub-Segment pending the 160 resolution of the appeal by the Board of Directors.

D Multiple Corporate Memberships An Entity may join and vote in all Segments for which it is qualified and for which its membership dues are current. Multiple companies under common control within a corporate organization that desire to become Voting Members must join individually. Members cannot 165 extend their WEQ Membership to their parent company, affiliates, or subsidiaries.

6 Meetings of the Members All meetings held in association with the NAESB organization, or the WEQ, are open to any interested Entity and will be held in accordance with the NAESB Operating Procedures. From time to time, there may be joint meetings of the WEQ with other Quadrants within NAESB, and Segments may meet jointly to transact Quadrant 170 business. Only the EC, Board and the WEQ Membership ratification processes are limited to Voting Members.

7 Board 7.1 Board Representation

The membership of each WEQ Sub-Segment shall elect representatives to the Board from its Sub-Segment in accordance with the NAESB Bylaws, Certificate, and these WEQ Procedures. 175

7.2 Qualifications of Board Members A Eligibility To be eligible to serve as a NAESB Board Member from the WEQ, a nominee must: 1 Have a working knowledge of the NAESB process, 2 Be willing to commit the time and resources necessary, 180 3 Have the authority to fulfill the obligations as a Board representative, 4 Be willing to meet the minimum threshold of participation and attendance established in the

NAESB Bylaws, Section 9.7(f), and any other applicable provisions, as set forth in the NAESB Bylaws and

5 Be a Voting Member or a partner, an officer, an employee or an agent of a Voting Member of 185 the WEQ.





B One Member, One Seat Per Segment No two Board Members from the same or affiliated companies can be elected to the Board from the same Segment.

C One Office Per Member RepresentativeRESERVED 190 No Board Member elected from the WEQ may hold both a Board seat and an EC seat concurrently in the WEQ or any other NAESB Quadrant. If a WEQ EC Member is elected as a Board Member from the WEQ, the WEQ EC seat is vacated immediately upon the EC Member’s assumption of the Board position.

7.3 Number and Election of Board Members 195 A Number of Board Members

The WEQ shall elect forty-two (42) Board Members. Each Segment of the WEQ will elect seven (7) Board Members, in accordance with the Sub-Segment allocation shown in Attachment A of the WEQ Procedures. Vacant seats are subject to Section 7.5 C of these WEQ Procedures.

B Election of Board Members 200 Nominations for and election of Board Members will be in accordance with the Sub-Segment allocation shown in Attachment A. Only Voting Members of the particular Sub-Segment for which the Board seat is being sought are allowed to vote in this process.

C Board Election Procedures In preparation for any election of Board Members, other than initial Board Members: 205

1 Nominations may be made at or prior to the close of the WEQ nomination period by any appropriate Sub-Segment Member by submitting the candidate names to the NAESB Office in accordance with the NAESB Operating Procedures.

2 All Board nominees shall meet the personal and membership eligibility requirements set out in these WEQ Procedures. NAESB shall confirm that a nominee meets the Board eligibility 210 requirements.

3 All eligible nominees shall state in writing their willingness to accept the responsibility of serving as a Board Member, prior to the submission of their names to the Sub-Segment WEQ Membership at the election.

4 The WEQ Board nomination period shall end two weeks prior to the commencement of the 215 election period. This deadline may be extended. All nominations will be in writing or by electronic communications.

5 Any WEQ Sub-Segment Voting Member who is current in the payment of its membership dues is eligible to one vote per open Sub-Segment seat. The ballot shall contain the names of all eligible nominees 220

6 The candidates receiving the greatest number of votes shall be elected. 7 In the event of a tie, a runoff election will be held to resolve the tie. In the event of another

tie, the candidate chosen by lot will be announced as the newly elected Board member. The NAESB Office will conduct the lottery required to resolve the tie.

D Timing of Elections 225 The election of Board Members shall occur concurrently for all Segments of the WEQ. 7.4 Term of Office A Terms

Initially, Board Members shall be elected for two-year terms, with half of the terms expiring in alternating years. All subsequent elections for other than filling vacancies during a term, are for 230 two year terms.

B Limit on Number of Terms of Office Board Members from the WEQ may run for re-election without restriction on the number of terms held.





C Change of Affiliation 235 In the event that a WEQ Board Member changes member or company affiliation, the Board seat will become vacant and open for re-election as prescribed in Section 7.5 of these WEQ Procedures.

7.5 Vacancies A A person shall cease to be a member of the Board upon (1) the Board Member’s resignation, 240

removal, or death; (2) term expiration; or (3) the resignation or lapse, through a delinquency in payment of the membership dues, of the Segment Membership of the Entity that the Board Member represents. A vacancy shall be filled for the remainder of that term in accordance with Section 7.5 B & C of these WEQ Procedures.

B In the event that a Board Member resigns or otherwise vacates a seat, and less than 90 days remain 245 in the term of office, the Board seat will remain vacant until the next election period.

C If any seat on the Board becomes vacant and more than 90 days remain in the term of that seat, the respective Sub-Segment will conduct nominations and elections to fill that seat.

1. If the seat is vacant after ninety (90) days, that seat will be designated an “At Large” seat and the Segment will hold elections to fill that seat conforming to the Sub-Segment Principles. 250

2. If the seat is vacant after 180 days, the voting rights of that “At Large” seat will be suspended and the Segment will be expected to re-organize with new Sub-Segments consistent with the seven (7) Board seats, seven (7) EC seats, and Sub-Segment Principles. The new sub-segmentation will become effective on approval by 75% of the Segment and then 67% of the WEQ Membership. The percentage will be based on those members voting. The Segment 255 will then conduct elections for its Board and EC members with the rights of the Board Members effective under the new Sub-Segment designations.

3. If, after 270 days of the original vacancy, the Segment is unable to develop new Sub-Segments, an affirmative vote of 67% of the WEQ Membership is needed within the next ninety (90) days to develop and approve the new Sub-Segments for the Segment consistent 260 with the Sub-Segment Principles. New Segment elections will be conducted as outlined above.

4. At any time during the vacancy of the seat, the Sub-Segment in question elects a Board member to fill the vacancy, no further Sub-Segment actions are necessary.

7.6 Reserved 265 7.7 Resignation of Members of the Board

A Member of the Board may resign his or her position by submitting a letter to the Secretary of NAESB with a copy to the Board Chair stating that he or she is resigning and giving the effective date of the resignation.

8 Election of WEQ Board Vice Chair 270 8.1 Eligibility

Any Board member who is a member of the WEQ may be nominated for the WEQ Board Vice Chair position.

8.2 Election Process After a two week process where Board members can nominate, (including self-nomination), the 275 NAESB office will run an election for the office of the WEQ Board Vice Chair and the candidate receiving the most votes from among the WEQ Board members will be announced as the WEQ Board Vice Chair. The WEQ Board Vice Chair may run for re-election at the conclusion of his/her term.

8.3 Term The WEQ Board Vice Chair will remain in office until the earlier of: the conclusion of the two year 280 term, or he/she no longer holds a Board seat.





9 Reserved.

10 Executive Committee 10.1 EC Representation

The membership of each WEQ Sub-Segment shall elect representatives to the EC from its Sub-285 Segment in accordance with the NAESB Bylaws, Certificate, and these WEQ Procedures.

10.2 Qualifications of EC Members A Eligibility To be eligible to serve as a NAESB EC Member from the WEQ, a nominee must:

1 Have a working knowledge of the NAESB process 290 2 Be willing to commit the time and resources necessary, 3 Have the authority to fulfill the obligations as an EC representative,

4 Be willing to meet the minimum threshold of participation and attendance established in the NAESB Bylaws, Section 10.4(j), and any other applicable provisions, as set forth in the NAESB Bylaws and 295

5 Be a Voting Member, or a partner, an officer, employee or an agent of a Voting Member of the WEQ.

B One Member, One Seat Per Segment No two EC Members from the same or affiliated Entities can be elected to the EC from the same Segment. 300

C One Office Per Member RepresentativeReserved No EC Member elected from the WEQ may hold both a Board seat and an EC seat concurrently in the WEQ or any other NAESB Quadrant. If a WEQ EC Member is elected as a Board Member from the WEQ, the WEQ EC seat is vacated immediately upon the EC Member’s assumption of the Board position. 305

10.3 Number and Election of EC Members A Number of EC Members

The WEQ shall elect forty-two (42) EC Members. Each Segment of the WEQ will elect seven (7) EC Members, in accordance to the Sub-Segment allocation shown in Attachment A of the WEQ Procedures. Vacant seats are subject to Section 10.5 C of these WEQ Procedures. 310

B Election of EC Members Nominations for and election of all EC Members will be in accordance with the Sub-Segment allocation shown in Attachment A. Only Voting Members of the particular Sub-Segment for which the EC seat is being sought are allowed to vote in this process.

C Election Procedures 315 In preparation for any election of EC Members:

1 Nominations may be made at or prior to the close of the WEQ nomination period by any appropriate Sub-Segment Member by submitting the candidate names to the NAESB Office in accordance with the NAESB Operating Procedures

2 All EC nominees shall meet the personal and membership eligibility requirements set out in 320 these WEQ Procedures. NAESB shall confirm that a nominee meets the EC eligibility requirements

3 All eligible nominees shall state in writing their willingness to accept the responsibility of serving as an EC Member, prior to the submission of their names to the Sub-Segment WEQ Membership at the election. 325





4 The WEQ EC nomination period shall end two weeks prior to the commencement of the election period. This deadline may be extended. All nominations shall be in writing or electronically communicated.

5 Any WEQ Sub-Segment Voting Member who is current in the payment of its membership dues is eligible to vote per open Sub-Segment seat. The ballot shall contain the names of all 330 eligible nominees.

6 The candidates receiving the greatest number of votes shall be elected. 7 In the event of a tie, a runoff election will be held to resolve the tie. In the event of another

tie, the candidate chosen by lot will be announced as the newly elected EC member. The NAESB Office will conduct the lottery required to resolve the tie. 335

D Timing of Elections The election of EC Members shall occur concurrently for all Segments of the WEQ.

E Officers of the WEQ EC The WEQ EC shall elect a vice chair of the EC, and may elect a second vice chair who shall serve for a period of one (1) calendar year. The Vice Chair, and in his or her absence the Second Vice 340 Chair, shall preside over the meetings of the WEQ EC.

1 Eligibility Any EC member who is a member of the WEQ quadrant may be nominated for the WEQ EC Vice Chair position or Second Vice Chair position. It is encouraged but not required that the WEQ EC Vice Chair position and Second Vice Chair represent different segments of the 345 WEQ.

2 Election Process After a two week nomination process where WEQ EC members can nominate including self-nomination, the NAESB office will run an election and the candidates receiving the most votes from among the WEQ EC members will be announced the as the officers of the WEQ EC. 350

10.4 Term of Office A Terms

Initially, EC Members shall be elected for two-year terms, with half of the terms expiring in alternating years. All subsequent elections for other than filing vacancies during a term, are for two years. 355

B Limit on Number of Terms of Office EC Members from the WEQ may run for re-election without restriction on the number of terms

held, provided that the position of the EC Vice Chair and Second Vice Chair shall have a term limit of one year each.

C Change of Affiliation 360 In the event that the EC Member changes member or company affiliation, the EC seat will become

vacant and open for re-election as prescribed Section 10.5 of these WEQ Procedures. 10.5 Vacancies

A A person shall cease to be a member of the EC upon (1) the EC Member’s resignation, removal, or death; (2) term expiration; or (3) the resignation or lapse, through a delinquency in payment of the 365 membership dues, of the Segment Membership of the Entity that the EC Member represents. A vacancy shall be filled for the remainder of that term in accordance with Sections 10.5B & C of these WEQ Procedures.

B In the event that an EC Member resigns or otherwise vacates a seat with less than 90 days remaining in the term of office, the EC seat will remain vacant until the next election period and 370 the respective Sub-Segments Designated Alternate will serve until a new EC Member is elected.

C If any seat on the EC becomes vacant and more than 90 days remain in the term of that seat, the respective Sub-Segment will conduct nominations and elections to fill that seat.





1. If, after ninety (90) days the seat is still vacant, that seat will be designated an “At Large” seat and the Segment will hold elections to fill that seat conforming to the Sub-Segment Principles. 375

2. If, after 180 days of the vacancy, that seat is still vacant, the voting rights of the “At Large” seat will be suspended and the Segment will be expected to re-organize with new Sub-Segments consistent with the seven (7) EC seats, seven (7) Board seats, and Sub-Segment Principles. The new sub-segmentation will become effective on approval by 75% of the Segment and then 67% of the WEQ Membership. The percentage will be based on those 380 members voting. The Segment will then conduct elections for its Board and EC members with the rights of the Board Members and EC Members effective under the new Sub-Segment designations.

3. If, after 270 days of the original vacancy, the Segment is unable to develop new Sub-Segments, an affirmative vote of 67% of the WEQ Membership is needed within the next 90 385 days to develop and approve the new Sub-Segments for the Segment consistent with the Sub-Segment Principles.

4. At any time during the vacancy of the seat, the Sub-Segment in question elects a Board member to fill the vacancy, no further Sub-Segment actions are necessary.

10.6 Reserved 390 10.7 Resignation of Members of the EC

A Member of the WEQ EC may resign his or her position by submitting a letter to the Secretary of NAESB with a copy to the WEQ EC Vice-chair stating that he or she is resigning and giving the effective date of the resignation.

10.8 Designated Alternates 395 Each Segment’s Sub-Segment of the WEQ may develop and approve a list of individuals to serve as Designated Alternates and will give such list to the NAESB office in accordance with the NAESB Bylaws.

A Authority Persons presenting themselves at an EC meeting as Designated Alternates will be accepted as a 400 participant provided that: 1 No two EC Members and Designated Alternates from the same Voting Member can represent

a Segment at an EC meeting. 2 He or she has been designated to attend by an absent EC Member from his/her Segment’s Sub-

Segment. 405 3 The WEQ EC Member from that Segment either indicates to the NAESB Office, EC Chair or

Vice Chair that the EC Member will be absent, or is in fact absent and remains absent, and 4 The name of the Designated Alternate is on a list of approved Designated Alternates selected

by the appropriate Sub-Segment Membership according to these WEQ Procedures, and is on file with the NAESB Office. 410

B Election of Designated Alternates Each Sub-Segment may select Designated Alternates. In selecting Designated Alternate, the items below should be followed: 1 EC representative of Sub-Segment submits the list to NAESB office. 2 Alternates are members or agents of members of NAESB in good standing. 415 3 Alternates may not be presiding EC representatives (in any Segment or Sub-Segment) in the

WEQ. 4 The Sub-Segment may provide a list that is considered approved if no objection from the Sub-

Segment is raised. If objection is raised and not accommodated by the EC member providing the list, a vote of the Sub-Segment members is taken to approve the list with a 67% 420 affirmative vote of those Sub-Segment members required for approval.

5 Alternates List may be revised.





10.9 EC Meetings A WEQ EC Meetings

1 WEQ EC meetings shall be held at times and locations determined by the EC Vice Chair or 425 Second Vice Chair of the WEQ EC. The capability to participate by telephone is required for all WEQ EC meetings.

2 The NAESB Office shall record the minutes of EC meetings. B Notices

The NAESB Office shall post advance meeting notices and agendas on the NAESB website and 430 transmit same in writing, by facsimile, e-mail, or other electronic means to all WEQ EC Members. Unless under extreme circumstances, meeting notices shall provide at least 10 days notice of the meeting.

C Voting 1 The WEQ EC shall practice Balanced Voting and record voting results. 435 2 Each WEQ EC Member may participate and vote in EC meetings by notational ballot. Every

notational ballot shall be executed in writing by the WEQ EC Member or by his or her duly authorized attorney in fact and filed with the Secretary of NAESB. The notational ballot may be mailed, sent via facsimile or sent via electronic mail to the NAESB Office.

3 Notational voting shall be permitted in accordance with the NAESB Bylaws, Section 10.4 440 (k)(i-iii).

D Joint EC Meetings In the event that the EC of the WEQ meets jointly with an EC of another NAESB Quadrant, the choice of Quadrant EC Vice Chair presiding over the joint meeting will be determined by the precedence established in the order of rotation of EC Vice Chairs as specified in the NAESB 445 Bylaws.

10.10 EC Subcommittees & Task Forces A Establishing Subcommittees & Task Forces

The EC of the WEQ shall set up its own subcommittees and task forces to deal with WEQ-specific issues for standards development as described in the WEQ Annual Plan. The WEQ EC chair may 450 assign or solicit volunteers from the EC to co-chair the subcommittee or task force. The subcommittees and task forces will proceed in accordance with the relevant NAESB Operating Practices.

B Meeting Minutes In the event that an individual from the NAESB Office is unavailable to take minutes, the Chair of 455 any subcommittee / task force meeting will designate an individual to take minutes and forward them to the NAESB Office.

C Reporting Each WEQ EC subcommittee or task force will report to the EC at no less than quarterly intervals, on a schedule to be defined by the EC for as long as the subcommittee or task force continues to 460 exist.

11 Reserved

12 Reserved

13 Reserved

14 Reserved 465

15 Reserved





16 Reserved

17 Reserved

18 Amendments

18.1 Any interested party may request a change to the WEQ Procedures by forwarding a request in writing 470 to the NAESB Office.

18.2 The WEQ Procedures Drafting Collaborative Task Force is charged with drafting amendments to the quadrant procedures. The changes will be reviewed by NAESB Counsel to ensure that the amendments are not inconsistent with the organization’s certificate and bylaws. After such assessment, the procedures will be reviewed for adoption by the WEQ membership. The NAESB 475 Office will forward proposed amendments with a notational ballot to all WEQ Board members. The notational balloting period shall be 30 days. For the amendments to be adopted, 75% affirmative vote of the WEQ Board members with a minimum of 40% affirmative vote from each segment will be required. After the WEQ Board vote is taken and passes, the amendments must also be ratified by WEQ membership. For the amendments to be ratified, a minimum of 75% of the WEQ members 480 returning ballots should vote affirmatively.

18.3 The foregoing notwithstanding, any actions taken under Section(s) 2.4, 7.5, or 10.5c of the WEQ Procedures shall be approved only in accordance with the provisions set forth in those Section(s); once so approved, such actions shall not be subject to, or require, any other or additional consideration under Section 18 of the WEQ Procedures. 485

19 Reserved





Attachment A

NAESB WHOLESALE ELECTRIC QUADRANT 490

The NAESB Wholesale Electric Quadrant will be composed of six segments. Each segment will have seven seats on the Board of Directors and the Executive Committee. The organization for the segments is shown below: • Transmission: Any entity engaged in the activity of owning, operating or controlling bulk electric transmission

facilities in North America. 495 Sub-segments: Muni/Coop Number of Seats: 1

Fed/State/Provincial 1 IOU 2 ITC 2 At Large 1 500

• Generation: Any entity engaged in the activity of owning and/or operating wholesale electric generation facilities in North America. Sub-segments: Muni/Coop Number of Seats: 1

Fed/State/Provincial 1 IOU 2 505 Merchant 2 At Large 1

• Marketers/Brokers: Any entity engaged in the activity of buying and selling wholesale electric power in North America on a physical or financial basis. Sub-segments: Muni/Coop Number of Seats: 1 510

Fed/State/provincial 1 Not IOU affiliated 2 IOU Affiliated 2 At Large 1

• Distribution/Load Serving Entities: Any entity engaged in the activity of electric power sales and/or delivery 515 to end use customers in North America, or any entity designated to represent a distribution utility. Sub-segments: Muni/Coop Number of Seats: 2

IOU 2 Competitive Retailer 1

(not available to muni/coop, IOU or IOU affiliates) 520 Other 1

(not available to muni/coop, IOU or IOU affiliates) At Large 1

• End Users: Any entity in North America that is an end use consumer of electricity, engages in electricity regulation, or represents customer interests, or any entity designated to represent an end user. 525 Sub-segments: End Use (also in another segment) Number of Seats: 1

Regulator 1 Residential/Commercial 1 Large Industrial (not in other segments) 2 End Use (Self Generation) 1 530 At Large 1

• Independent Grid Operators/Planners: Any entity in North America authorized by an appropriate governmental authority to operate as a regional transmission organization, independent system operator, independent tariff administrator or independent planning entity and which does not have a business or financial interest in any other WEQ segment. 535

Sub-segments: None defined at this time 7





Definitions:

• IOU Definition: An investor owned entity who has substantial business interest in owning and/or operating any two of the following three asset categories --- generation, transmission, distribution.

• At Large Definition: The At Large sub-segment within each segment is intended for regional reliability 540 organizations, consultants, service companies, information services and software companies, law firms, and other such organizations that are not specifically encompassed in the other sub-segments for a given segment, and excludes the ISOs, RTOs and other independent grid operators and planners.

Procedural Elements: 545 1. Entities may participate in multiple segments within WEQ. 2. “Sunrise.” Sub-segment principles will continue. Sub-segments may be revisited at any time, but no later than

three years. Changes to sub-segments require 75% affirmative from with segment, subject to other minimum 550 participation and deadline requirements.

3. Fixed Annual Payment. All WEQ participants will pay a fixed annual payment. Annual payment should provide

for required budget to administer the process to develop Standards. Exceptions must be approved by the NAESB Board. 555

4. Sub-segment population. NAESB WEQ will establish minimum number for populating sub-segments within a

segment, including a deadline for such population. 5. Consultants. Contract consultants may be considered as an option for Standards drafting, contingent on 560

identification of need and availability of sufficient funding. 6. Segment Blocking. If at any time a segment acts to block the adoption of any standard during an EC vote on

such standard, the blocking action shall be referred to the WEQ board members. Following such referral, the WEQ board members may request that the EC members of the segment explain the rationale for their votes. 565


north american energy standards board · 2019-09-30 · for quadrant: wholesale electric quadrant...

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