Comments Submitted by R. Kelley, Bonneville Power Administration

Comments submitted by R. Kelley, Bonneville Power Administration

2015 WEQ Annual Plan Item 2.a.i.2 – Develop version 3 business practice standards to better coordinate the use of the transmission system among neighboring transmission providers. Long-Term Firm Rollover Rights Competition (OATT Section 2.2).

Bonneville Power Administration appreciates the opportunity to provide comment on the NAESB Long Term Recommendation. BPA believes that the Recommendation addresses the key principles that provide clarity and support to the industry including:

1. A request to rollover long term capacity triggers the competition (e.g. a defender initiates the competition)
2. The TP must secure an agreement with the challenger prior to the transfer of rollover rights from the defender to the challenger (e.g., the TP is not required to establish a service agreement prior to conducting a competition)
3. The competition is for Transmission Customer rollover requests
4. Rollover requests associated with NITS and PTP customers are addressed
5. If a DNR extension request is a defender and the PTP request is the challenger, the NITS Service Agreement is extended (if necessary)
6. The ‘term of service’ is used in determining whether a competition will be conducted as well as used in the rollover extension (if necessary)
7. ‘One and done’ – meaning that a defender will only be evaluated to defend one time; only one challenger can be identified; and only one competition will be conducted

Additionally, BPA agrees withdifferences in standard language that distinguishes Short Term Competition and Long Term Competition, (e.g., Long Term Competition standards will replace certain terms used in Short Term Competition/Preemption because their meaning and applications are different.) Specifically, BPA agrees with the following:

• ‘Pre-confirmed’ or ‘pre-confirmation’ - a request must be pre-confirmed in order to be a Challenger in STCP but this is not a requirement for the TP in Long Term.
• Right Of First Refusal (ROFR) – applies to the competition matching activity for additional ATC. This term is not used in Long Term because the defenders service extension applies to rollover rights
• ‘Reservation Priority Rights’ is the term used for rollover rights and was chosen because it is consistent with tariff language
• Short Term Competition term ‘Challenger’ and ‘Defender’ terms are replaced with ‘Eligible Customer’ and ‘Incumbent Transmission Customer’ in Long Term Competition respectively.
• Duration has been replaced with ‘term of service’ or ‘minimum term of service’