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Commercially Similar Paths (Motion 47)

Commercially Similar Paths (Motion 47). NAESB OS Presentation July 22-24, 2014 BPA Presenting. Motion 47 – Evaluation. The current language of Motion 47 significantly restricts BPA’s ability to conduct P&C. Other TP’s have expressed similar concerns.

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Commercially Similar Paths (Motion 47)

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  1. Commercially Similar Paths(Motion 47) NAESB OS Presentation July 22-24, 2014 BPA Presenting

  2. Motion 47 – Evaluation • The current language of Motion 47 significantly restricts BPA’s ability to conduct P&C. • Other TP’s have expressed similar concerns. • The OS has provided two hours to review Motion 47 and potential modifications.

  3. Motion 47 – Current Language Motion 47 has two parts: • A potential Defender must provide relief on all of the flowgates where AFC is not available for the Challenger. • The capacity taken away from the Defender shall not be more than 105% (rounded to the nearest MW) of the capacity made available to the Challenger. • The purpose was to guard against a defender having to give up a disproportionate amount of capacity compared to what the Challenger would gain. For instance, a Defender should not have to give up 100 MW of capacity in order to give the Challenger 10 MW.

  4. Motion 47 – Proposal Overview • Leave Part 1 as is • Has a lesser impact than Part 2 of the motion. • Modify Part 2 • Has the most impact on BPA’s ability to conduct P&C. • Significantly limits ability to identify Defenders.

  5. Motion 47 – Part 2

  6. Motion 47 – Part 2 The capacity taken away from the Defender shall not be more than 105% (rounded to the nearest MW) of the capacity made available to the Challenger. Concerns: • The 105% rule, if implemented on BPA’s flowgate-based system, significantly restricts the TP’s ability to identify Defenders for the preemption and competition process. • Does not permit a TP’s discretion of preempting 5 MWs from a Defender to provide 4 MWs of relief needed by the Challenger. • Significant restriction of P&C is not consistent with FERC policy.

  7. Suggested Modification for Part 2 • Retain 105% Rule. • Permit the TP to develop a MW margin in which if the Defender loss is within that margin, it is deemed a valid Defender. • The margin is defined as the maximum difference in MW between what can be taken from a Defender over and above what is awarded to the Challenger. • The margin applies if the Defender loss is greater than 105% rule. Rationale: • Provides TP with ability to structure a Defender qualification based on its system characteristics and business principles. • Permits a TP to decide whether a valid loss of 5 MW to grant 4 MW, or such, is permissible on its system.

  8. Proposed New Motion • NEW MOTION - A potential Defender must provide relief on all of the flowgates where AFC* is not available for the Challenger. The maximum MW difference between what will be taken from a Defender over and above what can be awarded to the Challenger is the greater of 105% (rounded to the nearest MW) or a discretionary MW limit if set by the TP. • Same concept applies for ATC*.

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