Long-Term Partial Service Remainders

1. Long-Term Partial Service Remainders Transmission Tariff Issues Workshop #2 March 15, 2011

2. Definition of “Partial Service” • OATT §19.7 Partial Interim Service: If the Transmission Provider determines that it will not have adequate transfer capability to satisfy the full amount of a Completed Application for Firm Point-To-Point Transmission Service, the Transmission Provider nonetheless shall be obligated to offer and provide the portion of the requested Firm Point-To-Point Transmission Service that can be accommodated without addition of any facilities and through redispatch. • BPA Transmission Services business practices defines “Partial Service” as: Firm Point-to-Point (PTP) Transmission Service for a portion of the capacity requested and/or a portion of the term requested.

3. Issue: Partial Service Remainders • Issue 7 as presented on February 9, 2011 in BPA’s Tariff Current Issues Paper: Customers sought and BPA created a unique process for customers receiving partial quantity offers for transmission service. Where BPA makes a partial offer and the customer accepts it, the customer typically submits a remainder request for the rest of its desired service. BPA keeps that remainder request in the same queue position as the original request. This technique is also often used in conjunction with conditional firm transmission as a placeholder request until new firm transmission becomes available. The approach makes effective use of existing transmission capacity and encourages development of resources such as wind generation and minimizes costs.

4. FERC Guidance Relating to Remainders • Footnote 300, Order 890 Notice of Proposed Rulemaking (NOPR) • BPA submitted a detailed comment regarding remainders in its comments to the Order 890 Notice of Inquiry. BPA pointed out that the NAESB Standards and Communication Protocols (S&CP) did not allow for remainders at that time. BPA asked for clarification on this point. • FERC responded to BPA’s comment in Footnote 300 of the Order 890 NOPR: In response to Bonneville, the Commission clarifies that a customer does not lose its queue position for its original request when it accepts a counteroffer for less service than originally requested. • Additionally, in a case involving BPA and the Port of Westward (110 FERC P 61,001 (2005)), FERC stated that the remaining portion of a transmission service request submitted by the Port of Westward that BPA could not offer service to on a partial basis under OATT Section 19.7 should remain in BPA’s queue. 110 FERC P 61,001 at p. 37. Once the capacity became available, FERC instructed BPA to amend its service agreement with the Port of Westward to provide for the remaining portion of service not provided in the partial offer. Id. FERC did not elaborate on how BPA was to amend the service agreement. • Though FERC seems to be clear that the remaining (or unoffered) portion of a customer’s request should remain in the queue, it has approved revised versions of the NAESB S&CP’s on several occasions since the Order 890 NOPR was published and has not required NAESB to change its business practices on this point. • As a result, BPA is unclear on FERC’s position concerning its use of remainders.

5. S&CP Process Diagram

6. Example • A customer submits TSR #1234 for 100 MW for 5 years • BPA cannot presently offer full service, so a Counteroffer is made of 75 MW for 5 years • The customer Confirms TSR #1234 and submits TSR #1245 for 25 MW for 5 years • BPA overrides the queue time of #1245 to match the queue time of #1234 • Final state: • #1234 is CONFIRMED • #1245 is in STUDY As far as BPA is aware, no other Transmission Provider allows the unoffered remainder request to retain the queue time of the original request.