Western Implementation of FERC Order 890

1. Western Implementation of FERC Order 890 WELCOME Western Area Power Administration

2. Western Implementation of FERC Order 890 Where did the journey begin? Western Area Power Administration

3. February 2007 FERC issues Order 890 • December 2007 FERC issues Order 890-A • June 2007 FERC issues Order 890-B • March 2009 FERC issues Order 890-C FERC Order 890 Timeline Western Area Power Administration

4. February 2008 Western forms an Order 890 Team • June 2008 Western forms Tariff Administration Team (TAT) to implement the Tariff. • June 2009 Western has public customer meeting on proposed Tariff. • September 2009 Western files new Tariff with FERC • December 1, 2009 Western implements new Tariff FERC Order 890 Timeline Western Area Power Administration

5. Unreserved Use • Reselling/Reassigning of Transmission • Ancillary Services (Energy & Generator Imbalance) • Rollover • Simultaneous Submission Window • LGI Procedure & Environmental Agreement • Network Service • Conditional Firm FERC Order 890 Changes Western Area Power Administration

6. Unreserved use – Schedule 10 Question: What is unreserved use of transmission service? • Use of transmission service that is not reserved or is in excess of reserved capacity • Non-secured reserved capacity or exceeded firm or non-firm reserved capacity at any point of receipt or delivery • OATT doesn’t specify all circumstances that constitute use of transmission service without a transmission service reservation • DSW will go through Rate process. Unreserved use slides are examples and may change during Rate process. Western Area Power Administration

7. Unreserved use Example Scenario - Point to point Unreserved Use Applies 1 Load NO RESERVATION 2 If Load > than PTP Reservation, Unreserved Use Applies Load PTP RESERVATION Western Area Power Administration

8. Unreserved use Example Scenario - Excess Generation and Network 3 If Gen > than PTP Reservation, Unreserved Use Applies PTP RESERVATION 4 If Load > than Forecast, Unreserved Use DOES NOT Apply Load NITS Western Area Power Administration

9. Daily Firm Point-to-Point Service rate • Multiple hours in one day Unreserved use – Frequency & Penalty • Weekly Firm Point-to-Point Service rate • Multiple days in one week • Monthly Firm Point-to-Point Service rate • Multiple weeks in one month Western Area Power Administration

10. Reselling of Transmission Price of reselling Transmission Pro Forma FERC 890: Allows for reselling of transmission at “market rate”. Transmission cap rate is no removed, no longer restricted the price a customer can sell transmission. Western Implementation: Western decided not to adopt this language. The cap will remain in place. Western Area Power Administration

11. Reselling of Transmission Western’s Role as a Financial Mediator Pro Forma FERC 890: Requires transmission provider to act as the financing wharehouse for the reseller and third party purchasing the transmission from the reseller. Western Implementation: Due to Western’s financial authority limitation, we couldn’t perform this function. Western Area Power Administration

12. Reselling of Transmission New Agreement for Reselling, called Attachment A-1 Pro Forma FERC 890: New Attachment called A-1 was created for the sole purpose of reselling/reassigning of transmission agreements. Western Implementation: Western will use the new Attachment A-1 for writing reselling and reassignment agreements. Western Area Power Administration

13. Imbalance Services Energy Imbalance & Generator Imbalance Pro Forma FERC 890: Implemented new tiers for Energy Imbalance. Created new Schedule for Generator Imbalance Western Implementation: Western decided Energy Imbalance and Generator Imbalance will be handled through the each Region’s Rate process. Western Area Power Administration

14. Rollover Rights • Change in Rollover Rights • Existing requirement is a minimum term of one year to have rollover rights. New minimum requirement requires a duration of five years for customer to have the option to exercise rollover rights. • The existing requirement is sixty days notice given to Western. New requirement is one year notification to Western. Western Area Power Administration

15. Rollover Rights • Change in Rollover Rights (Continued) • The change in rollover rights can be found in Section 2.2 of Western’s new Tariff. • Section 2.2 is applicable when FERC accepts Western’s Attachment P (Planning Process), until then the current sixty day notice will be applied. • When Western’s Attachment P is accepted by FERC a business practice will be posted explaining how Western will handle Agreements that expire within one year. Western Area Power Administration

16. Simultaneous Submission Window • What is Simultaneous Submission Window? • FERC Order 890 required TPs who set a “no earlier than” time limit for TSRs to treat all received within a specified period of time as having been received simultaneously. • New provision can be found in Section 13.2. Western Area Power Administration

17. Simultaneous Submission Window • Western implementation of Simultaneous Submission Window • Only applicable to short term firm point-to-point. Non-Firm, Hourly-Secondary, and long-term requests will have the same evaluation process. • Western will treat all applicable requests received within five minutes of window opening as having the same queue time. • If there’s not enough capacity to accommodate the requests, Western will implement a lottery to allocate the capacity. Western Area Power Administration

18. Simultaneous Submission Window • Lottery implementation • Western will implement the lottery giving priority to requests in the following order: • A. Service Increment • In order Monthly, Weekly, Daily, and Hourly • B. Duration of the request • C. Pre-Confirmation • Request that are preconfirmed will have priority over non-preconfirmed requests. • Pre-Confirmation • D. Price Western Area Power Administration

19. Large Generation Interconnection Procedure & Environmental Studies • Changes to Large Generation Interconnection Procedure • Within 15 calendar days of providing a system impact study report, an environmental review agreement will be provided to the customer. • Environmental review agreement must be executed and funded by the customer within 30 calendar days . • If agreement isn’t executed and funded with the required time, the interconnection request will be deemed withdrawn. Western Area Power Administration

20. Network Transmission Service • Changes to Network Transmission Service. • Attestation of resources is required. • Minimum term of designating a network resource (DNR). • Requirements of DNR • If agreement isn’t executed and funded with the required time, the interconnection request will be deemed withdrawn. Western Area Power Administration

21. Network Transmission Service • Requirements of Designated Network Resources. • Resource must be owned, leased, or customer purchases non-interruptible power under executed contracts. • DSW, CRSP, RMR, and SNR will not require purchases from a specific generating unit. • For off-system resources, Customer is required to obtain and demonstrate to Western it either has or is in the process of obtaining firm transmission from the point where the Customer takes delivery. Western Area Power Administration

22. Network Transmission Service • Requirements of Designated Network Resources • For Day-Ahead and Real-Time purchases, Western will reserve the capacity for the length of those purchases. • Network Resources currently listed in Network Agreements will remain “Grandfathered”, until expiration of the Network Resource, expiration of the Network Agreement, or Resource is undesignated. Western Area Power Administration

23. Conditional Firm Transmission Service What is Conditional Firm? • Modified form of long-term firm PtP service that includes less-than-firm service in a defined number of hours of the year or during defined system conditions. (OATT Section 15.4) • No separate queue • The service can be curtailed solely for reliability reasons during the defined system conditions or defined number of hours. • Western will offer either option (considerations) • NERC Priority 6 during “conditional” periods Western Area Power Administration

24. Conditional Firm Transmission Service • Conditional Firm Bridge Product • For customers supporting the construction of upgrades, the planning redispatch or conditional firm options will serve as a bridge until upgrades are constructed to remedy the congested transmission facilities. • For these customers, the TP must offer planning redispatch or conditional firm service until the time when the upgrades are constructed. The conditions or redispatch applicable to this period must be specified in the service agreement and are not subject to change. Western Area Power Administration

25. Conditional Firm Transmission Service • Conditional Firm • Western retains the right to perform a biennial assessment of the conditions to reassess the conditions. • A customer taking conditional firm service will be first in the queue for transmission service if a non-conditional firm service stops taking service. Western Area Power Administration

26. Contact Information • For questions regarding implementation of Order 890, please contact the TAT member for your Region: • CRSP: Dave Shelton – (801) 524-4012 • DSWR: John Steward – (602) 605-2774 • RMR: Raymond Vojdani – (970) 461-7379 • SNR: Ira Witherspoon – (916) 353-4659 • UGPR: Steve Sanders – (406) 247-7436 Western Area Power Administration