OASIS Business Practice –NorthWestern Energy’s Local Attachment K
OASIS Attachment K Business Practice
FERC Order 890
NWE Local Transmission Planning
Attachment K
If there is any difference between this Business Practice and the Tariff, the Tariff is correct.
SUBMISSION OF COMMENTS
NorthWestern Energy will consider written comments from stakeholders on the this Attachment K Business Practice. Written comments may be emailed or faxed to NorthWestern Energy as follows:
John Leland
Electric Transmission Planning Manager
NorthWestern Energy
Fax: (406) 497-3393
Effective Date
From: December 7, 2007
To: ______
Table of Contents
Preamble 8
Introduction 9
Principle 1 – Coordination 11
FERC Order Requirement Summary 11
Coordination, Generally 11
NWE Stakeholder Coordination 11
NWE OASIS Website 11
Stakeholder Involvement Simplified 11
NWE Contact Information 12
Comparable Stakeholder Involvement 12
Types of Planning Meetings 12
Meeting Information 13
Announcements and Communications: 14
Coordination of Study Results From Local Transmission Plan, Generation Interconnection Studies, Planning and Economic Studies 14
Sub-Regional/Regional Coordination 15
Principle 2 – Openness 16
FERC Order Requirement Summary 16
NWE’s Open Planning Process 16
Public Meetings 16
Standards of Conduct and Critical Energy Information 16
Confidentiality 16
Sub-Regional and Regional Planning 17
Principle 3 – Transparency 18
FERC Order Requirement Summary 18
Technical Analyses Transparency 18
Consistent Application 19
Data Access 19
Opportunity For Review and Comment 19
Replication of Planning Studies 19
Sub-Regional/Regional Transparency 20
Principle 4 - Information Exchange 21
FERC Order Requirement Summary 21
Information Request 21
Schedule 22
Procedure For Data Submission 22
Data Use In Planning Process 22
Confidentiality 22
Customer Responsibility 23
Principle 5 – Comparability 24
FERC Order Requirement Summary 24
Ensuring Comparability 24
Principle 6 - Dispute Resolution 25
FERC Order Requirement Summary 25
NWE Dispute Resolution 25
Sub-Regional and Regional Dispute Resolution 26
Principle 7 - Regional Participation 27
FERC Order Requirement Summary 27
Sub-Regional Participation 27
Sub-Regional Plan and Data Coordination 28
Regional Participation 28
NWE and Sub-Regional Planning Process Differences 28
Simultaneous Plan Feasibility 29
Principle 8 - Economic Planning Studies 30
FERC Order Requirement Summary 30
High-Priority Study Requests 31
Requesting A High-Priority Economic Planning Study 31
Valid NWE Request 31
Economic Planning Study Classification 31
Number of NWE High-Priority Studies 31
Prioritizing NWE Economic Study Requests 31
Clustering Study Requests 32
NWE Economic Planning Study 33
Customer’s Obligation To Share Data 34
NWE Obligation 34
Cost to Conduct NWE’s Two High Priority Economic Studies 34
NWE Economic Planning Study Timeline and Process 35
Additional Local Economic Studies 36
Process for Additional Economic Planning Studies 36
Sub-Regional Economic Study Coordination 37
Economic Planning Study Posting 37
Principle 9 - Cost Allocation for New Projects 38
FERC Order Requirement Summary 38
Projects Not Covered Under Existing Cost Allocation Rules 38
NWE Cost Allocation Methodology Projects Outside the OATT 39
Sub-Regional and Regional Cost Allocation 40
Recovery of Planning Costs 41
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 regional 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.
The URL address to access NWE’s Attachment K and the various documents and business practices discussed in this document are identified in http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
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 at “http:/www.oatioasis.com/NWMT/Transmission Planning/”.the URL address identified in http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
The NWE local transmission system provides regulated electric transmission services to approximately 295,000 electric customers. Figure 1Figure 1Figure 1Figure 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 http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
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 system plantransmission plan (or LTP) will be coordinated in two ways. First, during the development stage of the local transmission system plantransmission 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 the Northern Tier Transmission Group’s (“NTTG”) sub-regional planning and the Western Electricity Coordinating Council’s (“WECC”) regional planning organizations. See the URL address for “Transmission Planning Guidance Document” and other documents and business practices identified in http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
NWE Stakeholder Coordination
NWE’s local transmission system plantransmission 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 system plantransmission 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 system plantransmission plan.
NWE OASIS Website
NWE’s OASIS website can be accessed through is http:/www.oatioasis.com/NWMT/Transmission Planningthe/. URL address identified in http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Stakeholder Involvement Simplified
To simplify stakeholder involvement and understanding of NWE’s planning process, NWE Transmission Planning has an area on NWE’s OASIS website dedicated to Transmission Planningtransmission planning . The URL addresses for this website area can be found in http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc. 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 http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
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 http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
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), generators, cooperatives, interconnecting utilities, the Governors 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 system plantransmission 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 system plantransmission plan. The Access to TRANSAC Charter can be is posted on NWE’s websiteachieved through the URL address identified in http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc. The purpose of this advisory committee will be to provide input to NWE on its local transmission system plantransmission 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 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 Critical Energy Infrastructure Information (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 “Calendarcalendar of eEvents and sStudy cCycle” (“Calendar”) document. Access to this calendar can be achieved through the URL address identified in http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Open Public Meeting: : There 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.