Attachment K Business Practice –NorthWestern Energy
NWE Local Transmission Planning
Attachment K Business Practice
If there is any difference between this Business Practice and the Tariff, the Tariff is correct.
Don Bauer
Transmission Eng. – Planning & Capacity West Manager
Phone: (406) 497-3542
Effective Date: After FERC approval
From: FERC Order 1000 – October 2012 Filing
FERC Order 1000 – September 16,2013 Compliance Filing
To: ______
Table of Contents
Preamble
Introduction
Principle 1 – Coordination
FERC Order Requirement Summary
Coordination, Generally
NWE Stakeholder Coordination
NWE OASIS Website
Stakeholder Involvement Simplified
NWE Contact Information
Comparable Stakeholder Involvement
Types of Planning Meetings
Meeting Information
Announcements and Communications:
Coordination of Study Results From Local Transmission Plan, Interconnection Studies, Transmission Service and Economic Congestion Studies
Regional/Interconnection wide Coordination
Principle 2 – Openness
FERC Order Requirement Summary
NWE’s Open Planning Process
Public Meetings
Standards of Conduct and Critical Energy Information
Confidentiality
Regional and Interconnection wide Planning
Principle 3 – Transparency
FERC Order Requirement Summary
Technical Analyses Transparency
Consistent Application
Data Access
Opportunity For Review and Comment
Replication of Planning Studies
Regional/Interconnection wide Transparency
Principle 4 - Information Exchange
FERC Order Requirement Summary
Information Request
Schedule
Procedure For Data Submission
Data Use In Planning Process
Confidentiality
Customer Responsibility
Principle 5 – Comparability
FERC Order Requirement Summary
Ensuring Comparability
Principle 6 - Dispute Resolution
FERC Order Requirement Summary
NWE Dispute Resolution
Regional and Interconnection wide Dispute Resolution
Principle 7 – Regional Participation
FERC Order Requirement Summary
Regional Participation
Regional Plan and Data Coordination
Interconnection wide Participation
NWE and Regional Planning Process Differences
Simultaneous Plan Feasibility
Principle 8 - Economic Congestion Studies
FERC Order Requirement Summary
High-Priority Study Requests
Requesting A High-Priority Local Economic Congestion Study
Valid NWE Request
Economic Congestion Study Classification
Number of NWE High-Priority Studies
Prioritizing NWE Local Economic Study Requests
Clustering Study Requests
NWE Local Economic Congestion Study
Customer’s Obligation To Share Data
NWE Obligation
Cost to Conduct NWE’s Two High Priority Local Economic Congestion Studies
NWE Local Economic Congestion Study Timeline and Process
Additional Local Economic Congestion Studies
Process for Additional Economic Congestion Studies
Regional Economic Congestion Study Coordination
Economic Congestion Study Posting
Principle 9 - Cost Allocation for New Projects
FERC Order Requirement Summary
Projects Not Covered Under Existing Cost Allocation Rules
NWE Cost Allocation Methodology Projects Outside the OATT
Regional and Interregional Cost Allocation
Recovery of Planning Costs
Preamble
The Federal Energy Regulatory Commission (FERC) issued its Order No. 890 on February 16, 2007 (Order). The Order provided amendments to the regulations and the pro forma Open Access Transmission Tariff (OATT) adopted in Orders 888 and 889. The Order became effective May 14, 2007, which is 60 days following the date the Order was published in the Federal Register. One objective of the Order is to limit undue discrimination in planning the transmission system by requiring coordinated, open, and transparent transmission planning on both a local and interconnection wide level and by involving stakeholders in the early stages of transmission planning. FERC outlined the need for reform in transmission planning through Order No. 890.
Accordingly, each public utility transmission provider is required to submit, as part of a compliance filing, a proposal for a planning process that complies with the planning principles and other requirements in the Order. The Order requires a more inclusive transmission planning process incorporating the following nine principles: (1) Coordination, (2) Openness, (3) Transparency, (4) Information exchange, (5) Comparability, (6) Dispute resolution, (7) Regional participation, (8) Economic planning studies, and (9) Cost allocation for new projects. This Business Practice provides a discussion on these 9 principles.
In 2011, FERC issued Order 1000 amending their Order 890 regional planning requirements requiring each transmission provider participate in a regional transmission planning process that produces a Regional Transmission Plan by complying with Order No. 890 transmission planning principles of coordination, openness, transparency, information exchange, comparability, dispute resolution and economic planning. This Order also requires each public utility transmission provider to consider transmission needs driven by public policy requirements established by state or federal laws or regulations in its local and regional transmission planning processes and evaluate potential solutions to meet those needs. The order does not prohibit including additional public policy requirements that go beyond state or federal laws or regulations. FERC declined to specify which public policy requirements must be considered or included in the plan. The planning process must provide stakeholders with an opportunity to provide input on needs driven by public policy requirements.
The URL address to access NWE’s Attachment K and the various documents and business practices discussed in this document are identified in
Introduction
NorthWestern Energy (“NWE”), with input from stakeholders, developed the nine principles of NWE’s Attachment K Business Practice (“Business Practice”). This Business Practice and its supporting documents and business practices can be obtained on NWE’s OASIS website by following the URL address identified in
The NWE local transmission system provides regulated electric transmission services to approximately 295,000 electric customers. Figure 1, below, provides a graphical overview of NWE’s transmission system. NWE’s electric transmission system consists of over 7,000 miles of transmission lines and associated terminal facilities. This system, with voltage levels ranging from 50,000 to 500,000 volts, serves an area of 97,540 square miles, which is equivalent to two-thirds of Montana. The system has interconnections to five major transmission systems[1] located in the Western Electricity Coordinating Council (WECC) area and Mid-Continent Area Power Pool (MAPP) region through WAPA’s DC interconnection. NWE is registered as a Balancing Authority, Planning Authority and Transmission Planner. NWE does not currently own generation used to serve retail customer load.
The URL address to the various documents and business practices discussed in this document and in NWE Attachment K are identified in
Figure 1: NWE Local Transmission System
The following Attachment K Business Practice was developed in collaboration with interested stakeholders in an open, transparent forum.
Principle 1 – Coordination
FERC Order Requirement Summary
The Commission Determination is found within paragraphs 451 – 454 of the Order. The Coordination principle requires appropriate lines of communications among transmission providers, transmission-providing neighbors, State authorities, customers, and other stakeholders. Transmission providers are allowed to craft coordination requirements that work for those providers, their customers and stakeholders.
Coordination, Generally
NWE’s Local Transmission Plan (or LTP), also referred to as Local Transmission System Plan (LTSP), will be coordinated in two ways. First, during the development stage of the Local Transmission Plan NWE will have an open public process to allow two-way communication with stakeholders and interested parties. Second, NWE’s Local Transmission Plan will be coordinated with its regional planning entity - the Northern Tier Transmission Group’s (“NTTG”), other regional planning entities and the Western Electricity Coordinating Council’s (“WECC”) interconnectionwide planning entity. See the URL address for the NTTG“Transmission Planning Guidance Document” and other documents and business practices identified in
NWE Stakeholder Coordination
NWE’s local transmission plan planning coordination is an open public process that allows and promotes customers, interconnected neighbors, regulatory and state bodies and other stakeholder participation in a coordinated nondiscriminatory process for local transmission plan development. To accomplish this coordination, NWE will have an open meeting policy and a transparent process that will afford stakeholders an opportunity to regularly meet with NWE and to provide input on content, methodology, process and other elements used in the development of NWE’s transmission plan. Furthermore, NWE has a permanent planning committee called the Transmission Advisory Committee (“TRANSAC”) that will be involved in developing the local transmission plan.
NWE OASIS Website
NWE’s OASIS website can be accessed through the URL address identified in
Stakeholder Involvement Simplified
To simplify stakeholder involvement and understanding of NWE’s planning process, NWE has an area on NWE’s OASIS website dedicated to transmission planning. The URL addresses for this website area can be found in On this website, stakeholders can learn about NWE planning activities including:
- Past meeting information and minutes,
- Future meeting announcements,
- Review NWE calendar of events and the study cycle,
- Review reports and meeting material, and
- Obtain NWE contact information.
A list of Frequently Asked Questions is also posted on NWE OASIS website to simplify stakeholder understanding of NWE’s local area planning process. NWE’s OASIS website can be accessed through the URL address identified in
NWE Contact Information
Interested parties can provide comment or contact NWE directly by following the directions provided in the “How To Contact Transmission Planning” folder on NWE’s OASIS website. NWE’s OASIS website can be accessed through the URL address identified in
Comparable Stakeholder Involvement
NWE will make its stakeholder meetings open to the public, except when Standards of Conduct (SOC) concerns require portions of the meeting to be closed to some participants. NWE’s open process will allow participation by stakeholders, including, but not limited to, the Montana Public Service Commission, the Montana Consumer Council, transmission customers (network and point-to-point), existing generator owners, new project developers, cooperatives, interconnecting utilities, the Governor’s Office, transmission-providing neighbors and other stakeholders.
Types of Planning Meetings
NWE will have two types of planning meetings to involve stakeholders in the planning process and to facilitate and coordinate stakeholder input and involvement in NWE local transmission plan planning. These planning meetings are the Transmission Advisory Committee (“TRANSAC”) meetings and Open Public meetings.
TRANSAC Meeting: TRANSAC will be engaged in the various stages of developing NWE’s local transmission plan. Access to TRANSAC Charter can be achieved through the URL address identified in The purpose of this advisory committee will be to provide input to NWE on its local transmission plan. TRANSAC will not make decisions or implement the plan. The ultimate responsibility for the transmission plan will remain with NWE.
TRANSAC membership is open to anyone and will be established through self-nomination. If the membership is either too small or too large, NWE will work with the committee to determine whether adjusting the size is appropriate and, if so, what mechanism should be used to accomplish the adjustment. NWE will encourage membership from neighboring transmission providers, affected state authorities, regulators, customers and other stakeholders.
All TRANSAC meetings will be open to the public and will allow open and transparent dialogue on all aspects of the transmission plan to the maximum extent allowed without violating Standards of Conduct (“SOC”) information and Critical Energy Infrastructure Information (“CEII”). Members on this committee will be encouraged to be involved in each meeting and to be actively engaged in the process.
TRANSAC is a stand-alone committee that will provide input only into NWE’s transmission plan. TRANSAC may determine that it needs to form a sub-committee to address a specific issue or task. Participation on this sub-committee will be open to anyone. The responsibilities of the sub-committee and its structure will be determined by TRANSAC. If a sub-committee is to be formed, NWE will consult with TRANSAC before formation and an announcement of the formation of the sub-committee, its responsibilities and who to contact for more information or to join will be posted on the Transmission Planning portion of NWE’s OASIS website.
Open Public Meeting: NWE will hold open public meetings to allow a two-way communication on NWE’s transmission plan. Open public meetings will be scheduled by TRANSAC.
Meeting Information
The number of meetings, scope, notice requirements, and the format for these two types of meetings is described below.
Number of Meetings:
TRANSAC: TRANSAC will meet regularly in an open forum. NWE will encourage TRANSAC to meet as often as needed to provide meaningful input into NWE’s transmission plan development. NWE would anticipate that TRANSAC will meet at least quarterly.
Open Public Meeting: NWE will work with TRANSAC to schedule and hold open public meetings that will be designed to communicate information about its transmission plan and to receive input on its transmission plan. TRANSAC may adjust the number of public meetings as needed, but NWE anticipates one or two meetings per year.
Scope of Meetings:
The meetings will be open to discuss non-confidential aspects of transmission planning activities including, but not limited to methodology, study inputs, criteria, and study process and results. The intent is to provide a forum that allows stakeholders to have meaningful input into NWE’s transmission plan development. Dissemination of market sensitive information or critical infrastructure information must follow FERC Standards Of Conduct (SOC) requirements and CEII requirements.
Notice:
TRANSAC: There will be two forms of meeting notice: (1) A list of participants (name, organization, phone and email) will be maintained and notice for each meeting will be provided to prior participants by email; (2) Notice of a TRANSAC meeting will be posted on NWE’s OASIS website no later than fourteen (14) calendar days prior to the meeting and the available meeting material will be distributed at least two (2) business days prior to the meeting. Any additional meeting material presented during the TRANSAC meeting will be posted on NWE’s OASIS website. The Transmission Planning section of NWE’s OASIS website will include a calendar of events and study cycle” (“Calendar”) document. Access to this calendar can be achieved through the URL address identified in
Open Public Meeting: NWE will use, as appropriate, three forms of meeting notice: (1) A list of participants (name, organization, phone and email) from prior open public meetings will be maintained and meeting notices will be provided to prior participants by email or by mail if email is not available; (2) Local media (radio, newspaper, etc) may be used as appropriate to announce the open public meetings; (3) Notice of an open public meeting will be posted on NWE’s OASIS website at least thirty (30) calendar days prior to the meeting.
Format:
NWE will retain a neutral moderator to help plan and moderate the meetings. These meetings will be designed to provide opportunities for information exchange about NWE’s transmission plans, methodology and processes. Notes taken at the meetings and other information from the meetings will be posted on NWE’s OASIS website.
TRANSAC: TRANSAC meetings will be held either face-to-face or by conference call. The face-to-face meetings will also include a phone connection and a web conference service for those who cannot attend in person.
Open Public Meeting: The Open Public Meeting will be a face-to-face meeting between NWE and the public.
Announcements and Communications:
Announcements and communications will be posted under the Transmission Planning folders on NWE’s OASIS website. Information regarding NWE public meetings will be posted and emailed to interested parties as described under the Notice discussion above.
Coordination of Study Results From Local Transmission Plan, Interconnection Studies, Transmission Service and Economic CongestionStudies
The Local Transmission Plan study (for retail load service), Interconnection study, Transmission Service study and the Economic Congestion study (for customer economiccongestion studyrequest described below) are distinct and separate studies. They examine the transmission system for different purposes and from different perspectives (reliability evaluation vs. economic dispatch evaluation). Even though these studies are distinct and separate, the applicable study results from each study will be made available to the other study for considerationSee Figure 2: Sharing System and Economic Congestion Study Results.
Figure 2: Sharing System and Economic CongestionStudy Results
NWE, in consultation with TRANSAC, will determine the proposed new projects to evaluate or re-evaluate in the development of the LTP.
Any project included in the prior LTP will be subject to reevaluation in NWE’s planning process if construction contracts have not been awarded prior to the beginning of the biennial planning cycle.
Proposed new interconnection (i.e., generation resource, transmission project, or new large load) or request for transmission service may be coordinated into the Local Transmission Plan during Q1 and Q5 if 1) there is a signed agreement in place, or 2) it is included in the WECC base case, or 3) TRANSAC requests including it in the Local Transmission Plan.
Regional/Interconnection wide Coordination
NWE is a member and actively engaged in the Northern Tier Transmission Group (“NTTG”), which is a permanent planning committee. NWE will coordinate its biannual transmission plan with NTTG and with other planning entities as required. NTTG has participation of state commissions, including the Montana PSC. NTTG will coordinate its planning proposals with WECC and other regional planning entities(e.g., ColumbiaGrid, WestConnect,CAISO.). NTTG is an open stakeholder process that has formal stakeholder meetings. Addition information can be found on the NTTG website at or on NWE’s OASIS website through the URL address identified in
Principle 2 – Openness
FERC Order Requirement Summary
The Commission Determination is found within paragraph 460 of the Order. The Openness principle requires that Transmission planning meetings are open to all affected parties, including all transmission and interconnection customers, state commissions and other stakeholders. If subgroups are used, the overall transmission plan and planning process must remain open.