Elective Transmission Upgrade Process Improvements Design

1. Elective Transmission Upgrade Process Improvements Design September 23, 2014 Monica Gonzalez Senior regulatory counsel Rich Kowalski Director, transmission strategy & services Transmission Committee Meeting

2. Purpose of Today’s Presentation • At the RC/TC Summer Meeting, the ISO discussed the objective and scope of the Elective Transmission Upgrade Process Enhancement Project (ETU Project) and provided background necessary to establish a common understanding about the existing rules to facilitate the ETU Project discussions. • With that common understanding established, today, we are presenting the ETU Project design that will form the basis for the revisions to the Open Access Transmission Tariff (OATT).

3. Presentation Contents • What the ETU Project Will Do • Basic Rules for the ETU Project Design • Refine the ETU Definition • New OATT ETU Schedule • Interconnection Process Comparison • ETU Interconnection Services • Additional Design Elements Related to CNIIS* • ETU Operation in ISO Markets • Queue Position Rules • Transition Rules • Summary • Next Steps * Capacity Network Import Interconnection Service

4. What the ETU Project Will Do • The ETU Project will replace the current OATT Section II.47.5 ETU process with a new schedule for ETUs • The new ETU schedule will: • Follow a framework similar to that in Schedule 22 - Large Generator Interconnection Procedures/Agreement (LGIP/A) for ETUs • Stop the constant “free-fall” of ETUs by creating new requirements and obligations so ETUs can establish and maintain a meaningful Queue Position • Define interconnection service rights for certain ETUs comparable to those available to generators

5. Basic Rules for the ETU Project Design • The ETU Project relies on the ISO Tariff structure that is already in place • The fundamental structure of the ISO Markets, Transmission Service, & Operations will remain unchanged • ETUs will be treated in the same manner as similarly-situated transmission facilities and will need to fit within one of the following categories: • Pool Transmission Facility (PTF) • Merchant Transmission Facility (MTF) • Other Transmission Facility (OTF) • PTF, OTF and MTF facilities will be operated the same as they are today: • Physical priority rights will not be recognized over PTF and internal transmission facilities • Scheduling of External Transactions will remain the same for existing ties

6. Refine the ETU Definition • The ETU Project will clarify the definition of ETU and create two categories of ETUs: internal and external

7. New OATT ETU Schedule • The ETU Project will create a new OATT schedule for the interconnection of ETUs using Schedule 22 as its framework • Rules will parallel those of the large generator interconnection process, with a few exceptions (introduced in this presentation) • The new ETU schedule will: • Apply to the proposed interconnection of and modifications to transmission facilities interconnecting to the PTF • Have the same discipline as for generators under Schedule 22 interconnection procedures • Establishmeaningful Queue Positions with ability to progress through and complete the interconnection process • ETUs will continue to be eligible to request Incremental Auction Revenue Rights (IARRs) and Capacity Transfer Rights (CTRs) under existing Tariff provisions

8. Interconnection Process Comparison *Internal ETU IRs between PTF & Non-PTF will require a concurrent application to the applicable PTO through their Schedule 21 process for the Non-PTF connection. External ETU IRs will require a request to the other control area through their applicable process.

9. Interconnection Process Comparison - continued * *Changes will be required to Schedules 22/23 such that earlier queued generators and ETUs are respected **A Facilities Study is required unless an Engineering & Procurement Agreement is pursued

10. Interconnection Process Comparison - continued

11. ETU Interconnection Services • For certain ETU types, the ETU schedule will define ETU-specific interconnection services similar to the services available to generators: • Network Import Interconnection Service (NIIS): Comparable to a generator’s Network Resource Interconnection Service for energy • Capacity Network Import Interconnection Service (CNIIS): Comparable to a generator’s Capacity Network Resource Interconnection Service (CNRIS) for capacity & energy • ETU CNIIS and NIIS structure is comparable to generator CNRIS and NRIS, except that: • CNIIS and NIIS are assigned to the ETU, not a generator • ETU must complete interconnection process milestones & achieve commercial operation to receive NIIS • ETU must complete interconnection process &FCM-specific milestones & achieve commercial operation to receive CNIIS

12. ETU Interconnection Services - continued • NIIS and CNIIS will be available to External ETUs that are controllable MTF & OTF (importing direction) • Capabilities will be maintained, similar to generators • NIIS and CNIIS are not available for: • Internal ETUs - Internal ETUs can facilitate an associated internal generator’s realization of CNRIS and NRIS through the generator interconnection process • External ETUs (export direction) – External ETU can facilitate a capacity export “backed” by the CNRC of “de-listed” internal generators from New England to another control area under the existing FCM rules • External ETUs that are PTF or not controllable – Private and public capacity service rights cannot be distinguished from each other

13. Additional Design Elements Related to CNIIS • External ETUs eligible to request CNIIS will be: • Subject to CNR Group Study • Afforded the opportunity to request long lead treatment at the time of the interconnection request • This structure allows an ETU with a long-lead construction schedule to be considered existing for study purposes before CNIIS is secured • Rules for ETU long lead treatment will parallel the existing design for generators (e.g., deposits, CPS monitoring & other requirements) • Incorporated into the existing FCM conditional qualification provisions under the Tariff

14. ETU Operation in ISO Markets • Consistent with the basic design rules, ETUs will be operated by the ISOas follows: • Internal ETUs – without recognition of physical priority rights and consistent with capabilities to facilitate Security Constrained Economic Dispatch • External ETUs (PTF or non-controllable OTF/MTF) – without recognition of physical priority rights and consistent with capabilities to facilitate Security Constrained Economic Dispatch • External ETUs (controllable OTF/MTF) – with recognition of physical rights for use of the transmission facility consistent with the corresponding OATT schedule approved by FERC and consistent with Security Constrained Economic Dispatch

15. Queue Position Rules • The new ETU schedule will include Queue Position (QP) rules that will determine study order and cost allocation, as is the case for generators, under the existing single queue construct. • With the ability to establish meaningful QP, Internal ETUs will be able to facilitate an associated internal generator(s) realization of CNRIS and NRIS in the generator interconnection process. • When the Internal ETU and the associated generator are at different QPs, the QP of the Internal ETU will be used to determine the order in which the ETU and the associated generator(s) is (are) included in the CNR Group Study only, as follows: • A generator that is not associated with an ETU will be studied in its respective queue order • A generator and its associated ETU will be studied at the lower of the generator’s or its associated ETU’s queue position

16. Queue Position Rules - Example

17. Transition Rules • Currently, ETUs that are pending in the queue do not have a firm Queue Position; therefore, transition rules are necessary to address how pending ETUs will establish a meaningful QP. • QP adjustments for pending ETU requests will be made on the Effective Date of the ETU Project (as requested in the filing) revisions based on progress: • ETUs with I.3.9 approval will be given a: • New QP based on the date of their I.3.9 Approval Letter; and • Separate additional QP placeholder, located at the bottom of the queue in relative queue order, for the ETU to submit a new ETU IR for CNIIS • ETUs without I.3.9 approval will be: • Assigned a meaningful QP at the bottom of the queue (below the separate additional QP placeholder for ETUs with I.3.9 approval) and in relative queue order based on their System Impact Study Agreement (SISA) execution status and study status (active vs. inactive) • Following QP adjustments, studies may need to be updated to reflect the revised queue

18. Illustration of Transition Rules FUTURE CURRENT Earlier queued ETUs with I.3.9 approval Studies may need to be updated to reflect the revised queue New QP based date of I.3.9 Approval Letter ETUs w/o I.3.9 approval: Executed SISA/inactive study ETUs with I.3.9 approval CNIIS IR Placeholder ETUs w/o I.3.9 approval: Without executed SISA ETUs w/o I.3.9 approval: Executed SISA/activestudy ETUs with I.3.9 approval: Placeholder for CNIIS IR Queue bottom ETUs w/o I.3.9 approval: Executed SISA/activestudy All ETUs w/o I.3.9 approval will be assigned a new meaningful QP at bottom of queue in relative queue order & re-ordered based on process progress ETUs w/o I.3.9 approval: Executed SISA/inactive study Later queued ETUs w/o I.3.9 approval: Without executed SISA

19. Transition Rules - continued • After the ETU Project Effective Date , ETUs will have a 60-day transition period to meet specific requirements or will be withdrawn from the queue

20. Summary • The ETU Project will: • Create a new ETU schedule to the ISO OATT that sets out a process similar to that established for generator interconnections • Create new ETU requirements & obligations that allow for ETUs to receive & maintain meaningful Queue Positions • Extend new defined CNIIS & NIIS to eligible ETUs pursuant to completed interconnection requests • Questions on the ETU OATT design should be directed to: • Rich Kowalski at rkowalski@iso-ne.com • Monica Gonzalez at mgonzalez@iso-ne.com

21. Next Steps • Transmission Committee • October, November - Address feed back on the ETU OATT design and present OATT changes • December – TC vote • ISO Tariff conforming revisions to support ETU Project • Reliability Committee – October, November, December • Market Rule 1, Section III.12 – FCM-related • Markets Committee – October, November, December • Market Rule 1, Section III.13 – FCM-related • Budget & Finance Committee – TBD • Tariff Section IV and Financial Assurance Policy – Financial Assurance and qualification deposit