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Intertie Managment Commitee Meetings 07-09-2013 5
H Dale LLC Box 60173 Fairbanks,AK 99706 907-322-9228 Henri@HDaleLLC.com July 7,2013 H Dale LLC was retained in part to review the Railbelt Operating and Reliability Standards and provide written comments.This document provides the written comments.Of particular importance to AEA is its role as a Generator Owner (Bradley Lake),a Transmission Owner (the Alaska Intertie),and its participation within various committees of the above assets.The State also owns for the time being the HCCP coal plant and has an interest in ensuring that the Standards are not discriminatory. |had participated as Chairman of the RRC (the Railbelt Reliability Committee)for most of its existence. This is the committee that drafted these standards,primarily using NERC standards as a reference.| retired in March of 2013 and am not aware of what may have transpired within the committee for the last few months.My understanding is that the meetings have been limited.As such,when | reference something as being post March,there is a possibility that the new language has not been vetted by the utilities or by the RRC. Many of the GM's had concerns that the rules of the road were tied into agreements for the operation and maintenance of a single asset.To split the reliability aspects off from the AIA,and to take a modern look at aligning ourselves with current NERC standards,they had a group of their people form the RRC.The RRC (under various names)was first proposed as being an IOC subcommittee,but was almost immediately determined that it should be ad-hoc so as to allow the participation of non-lOC participants as well as allowing the two members of AEGT to voice their opinions independently.After a few years,the GM's were rightly concerned about an ad-hoc group that didn't particularly report to anyone,and put it under ARCTEC.It's not clear from the Standards to who and how the RRC now reports,but according to the Standards,the governing body is now the IMC for all reliability issues in the Railbelt.AEA may have concerns about this.1n particular,the IMC in the ARAIA (Amended and Restated Alaska Intertie Agreement)was set up to be an asset manager for the Alaska Intertie. Although it clearly allows the IMC to create reliability rules and levy sanctions,such language is almost always limited to users of the intertie and reliability rules for the Intertie (for example,8.6.1 and definition #48 "Reliability Standards”).Much of the proposed standards have little effect on the reliability of the Intertie itself.One important exception where the ARAIA delves away from the intertie is in the WHEREAS's which recognizes the requirement to adopt the old Addendum #1 as being required for "reliable operation of the Intertie and the interconnected Railbelt electrical system”and another in section 3.3 which requires adherence to the standards if you connect to a participant or users system.Of course,as long as it's not prohibited;anything that the parties agree to among themselves and agree to unanimously,is ultimately binding.The problem is how binding is it to a non-user or a minority party of a non-unanimous motion if the motion was not within the intents of the ARAIA. Similar questions arise within the Standards themselves.When the RRC drafted much of the language, the term "Railbelt Utilities'was often used as we were working largely to consensus.But what if a 1 utility dissented?Is the product still of the Railbelt Utilities?Section 120 of both the Generation Interconnect Standard and the Transmission Interconnect Standards have post March language that the IMC IS the Reliability Coordinator for the Railbelt Grid (color for emphasis).By whose authority were they put in that role?Further,the IMC is the "representative”body of the Railbelt Utilities with respect to Grid planning and Operations.Are they representative if there is a dissenting or a new utility?This has always been the thorny question,and the RRC wrote the standards assuming it would be taken care of higher up.We also see "The power to grant such interconnection authorization is delegated to the Intertie Management Committee”.f it's delegated,it begs the question -by who? |don't believe that the IMC is the right body due to the many limitations in the ARAIA (although I'm not proposing anything else at this time).The Standards require the IMC to react in a timely manner to a wide variety of issues.Presumably the IMC will delegate much of it,but for a group that meets quarterly,this will be a significant increase in activity.The RRC had always expected that the Standards would also have some sort of legal review prior to adoption since the expertise of most of the RRC members was in Engineering and Operations.I'm not aware any such review has been undertaken. The following are comments on the Standards in page number order.Many of the comments are editing and typos (which is not what |was tasked with,and not what |looked for),but as |came across them looking for other issues |thought it best to capture them along with the comments.They can be fixed ina new edition.Issues of greater importance will be highlighted. Introduction (grandfather paragraph got deleted,so no page number):The grandfather clause for units that were in late stages of planning got deleted post March.Reasoning was given that they would likely pass the interconnect requirements anyways.I'm not aware the RRC did such research. There are spinning reserve requirements for new units prior to commercialization that those who recently got their units commercialized didn't have to follow not to mention requirements to review plans and drawings.HCCP is one that has been deleted,although presumably it won't be a State asset by the time it goes on line. Table of Contents:This was set up as appendices with alphabet names.|have concerns that as new standards are adopted,the IMC will either have to re-sequence the existing alphabet labels,or add the new standards at the end which could put them out of a logical order. AKBAL-005 R12.1 and AKBAL-006 R3:CEA is currently filing an OATT with the RCA where they require all metering (within and at their boundaries)to be CEA meters.They are also requiring a reciprocity clause such that everyone else must have a similar OATT (and presumably those utilities would have their own meters at their own boundaries).This violates this AKBAL standard which requires common metering equipment at boundaries. AKBAL-006 R4 last paragraph:Typo,reference to AKBAL-006 1D1-1.2 should likely be AKBAL-006 E1-1.2. AKFAC-001 R1.3:Requires End User facility connection requirements.The document appears to have been removed post March.AEA needs to discuss among itself what the possibility of an end user (think large mine)that's not in anyone's service territory.Would such an entity be allowed to connect 2 without being a member to any particular utility?If so,this document would be necessary.May also be necessary even if it were part of a utilities service territory if it were so large that it could affect the reliability of other utilities. AKFAC-002 B R1.4:When the RRC modified the original NERC language,we removed the reference to TPL 001,002,and 003 since we didn't expect to be adopting those anytime soon.Post March,those Standards have been included,so it would be appropriate to reinstate the reference to those Standards here. AKRES-001 R2.3:|would add "and approved by the IMC”or other such group at the end of this. (The paragraph has to do with setting the SRB via engineering studies.We wouldn't want dueling studies being used}. AKRES-001 RS.4:Requires carving out room for a Capacity Benefit Margin.This is new post March and likely has to do with Kenai transfer limits.I'm not particularly fond of the name (why use the word "Benefit”)but making room makes some sense.This is significant and needs to be vetted. Ultimately,it lowers the usable transfer capability of the Kenai tie which affects Bradley Lake Transfers. CEA needs to state what this margin is (size in MW)that they want to reserve to themselves. Apparently there is also supposed to be a document (Capacity Benefit Margin Implementation Document),but it wasn't included in the Standards. AKRES-001 R5.5:Refers to itself.Probably a typo and was intended for R5.4. AKRES-001 R5.6:This is the umbrella language which was a very controversial issue for the RRC. It was finally compromised to allow the total lease of a unit,but post March now includes shares of a unit. AKRES-001 R6.1:Yet another post March Margin that will reduce transfer capability on certain transmission lines,in particular the Kenai line.This may be in addition to that mentioned above in AKRES-001 R5.4.Needs to be vetted as it could significantly reduce Bradley Lake transfer capabilities. AKRES-001 R7.1:Here and several other places,a term Largest Single Generating Contingency is used.But the definitions section uses the term Largest Single Generation Contingency.Need to do global searches to make sure the two terms are used consistently. AKRES-001 R7.1:Excludes RAS applications.If a RAS is designed to be quick enough,not sure of any good reasons to exclude them.It is likely that the Watana turbines combined with a BESS will ultimately be required,but this would seem to exclude counting the benefit of that. AKRES-001 R7.4:Awkward sentence "or an entity install new generation”. AKRES-001 R7.6:Clumsy sentence structure. AKRES-001 R7.7:Need to clarify that the 120 MW value is what is subject to change by the IMC. MUD is the delta between the new large unit and the 120 MW value. AKRES-001 R7.8:"obligated entity”is a defined term and should be capitalized. AKRES-001 R7.8:MUD should be MUDe. AKRES-001 R7.8:lower case "i”should denote "All Interconnected Entities”.(ie Other Interconnected Entities +the Obligated Entity e). AKRES-001 M8:"Absent a specifically appointed Compliance Monitor ...”Strange thing to say. Why not just make the IMC the Compliance Monitor in the entities matrix (which is how its checked off already). AKTPL-001 B R1 and AKTPL-002 B R1 and AKTPL-003 B Ri:As a newly minted consultant |would have to admit that you can never have too many studies.Seriously,these two standards are requiring every two years a battery of studies over a several year forecast.The last couple of years have been very busy for the Railbelt,but historically,not many units or lines are built in any given decade.Also, may want to give some thought to who pays for all these studies,the entities that wheel on the Intertie? Also keep in mind that a whole slew of studies are required whenever someone files application to interconnect a generator or a transmission line in the interconnect standards. AKTPL-002 A 3 and AKTPL-003 A 3 last paragraphs:"Further system operators”is clumsy. AKTPL-002 A 4.3 and 4.4:These are not NERC defined entities.In general,the RRC tried to use NERC terminology so that as new standards were adopted,the body of interpretation and language was already out there nationwide. AKTPL-002 B R1:"The loss of no single element of the BES should result in the loss of firm load or firm transfers”.The current form of the Intertie violates this (Cantwell and Stevens)and most of the Railbelt Utilities have lines that would violate it also.This is a planning requirement,so no penalties, but it does require corrective plans be crafted biannually. AKTPL-003 A 4.3 and 4.4:Same terms as above. AKVAR-001 B R9:AEA's Healy SVS would violate this requirement (that SVS is a critical unit and must be in service). The Entity Matrix:There are errors throughout.All the entities have to declare what they volunteer to participate in,and be aware of what they are required to do via being an Obligated Entity. The ARAIA gives AEA veto power over any proposed standards.There probably isn't a NERC entity in the matrix that fits those powers. The Definitions:The RRC (at the CEA's representatives'insistence)went through the Standards and vetted each defined term from the Standards with its corresponding definition in the NERC Glossary.We renamed it AK_Glossary_of_Terms,changing definitions as required and adding an approval date.Any other terms were left alone as they would define the national interpretation,but wasn't necessarily vetted to work with the Railbelt.The definitions that are currently attached to the standards (and contains various post March defined terms)does not appear to be based on the one the RRC left off with. The Sanctions Matrix:This was mostly a place holder for the RRC.Not much though went into it other than to make the sanctions get bigger as the level got worse or the infractions were repeated.At least for those who "sign up for it”,we can fine ourselves as much as we please,but as the utilities are all mostly regulated,it's a different question if the RCA will allow us to pay those fines out of rates.It was the intent of the RRC to waive fines for the first year or so (but still report the violations)to get a better understanding of where we needed to improve.Presumably,if a bad apple is deemed to be in violation,they will contest it,and at some point,some group will need to rule on this.If the bad apple also is an IMC participant,will the normal voting rules prevail?Dispute resolution in this context has not been given any thought.Since it's under the auspices of the IMC,do the IMC dispute resolution language prevail? Exhibit D -Railbelt Reliability Planning Guidelines:A lower frequency of 58.8 Hz is probably a fact of life,but I'm not sure that we should "plan”to allow ourselves to go down that far.It is part of our existing ASCC guides. Exhibit E:FMUS stood for Fairbanks Municipal Utilities Systems.Also,should have the various utility engineering folks vet Table 1.Aspects of it doesn't quite seem right to me. {interconnection Standards for Railbelt Generation 210:Typo top of page 7 "mayl”. Interconnection Standards for Railbelt Generation 230,step 2,B f:|have some concerns with this section.The "proof”of acquisition of ancillary services is rather premature as this is part of the application,construction could take years,and section 120 page 5 merely requires them to have the agreements in place prior to physical interconnection.Could also be somewhat discriminatory since a utility building a generator wouldn't necessarily (and probably wouldn't)do any of the agreements mentioned,so this is pointed particularly at IPP's.One would expect an IPP to want to have those agreements figured out on their own prior to dumping tens to hundreds of millions into a project. Interconnection Standards for Railbelt Generation Section 3:Need to be careful here.This sections discusses the consequences for failing to meet the requirements,and these consequences don't appear to have any correlation with the sanctions matrix.The two sections were written independently. Interconnection Standards for Railbelt Generation 351 last sentence:Typo,missing an "of”. Interconnection Standards for Railbelt Generation 352:Clean up last sentence to "...shall meet the required quality of response as set forth by the IMC.” Interconnection Standards for Railbelt Generation 360:Typo,should be "...Category B and probable Category C...”. Interconnection Standards for Railbelt Generation 524:Drop the "(fiber optic)”from the second bullet. We shouldn't be specifying the type of technology to be used,just the results we want. Interconnection Standards for Railbelt Transmission 120:In the 3 paragraph,typo "will Producer will” should be "Provider will”. Interconnection Standards for Railbelt Transmission 220:In the 2™paragraph,typo "generation” should be "transmission”. Interconnection Standards for Railbelt Transmission 230,step 2 B f:Same concern about having certain contracts finished during the application process for transmission as was noted above for the generation process. Interconnection Standardsfor Railbelt Transmission Section 3:Need to be careful here also.This sections discusses the consequences for failing to meet the requirements,and these consequences don't appear to have any correlation with the sanctions matrix.The two sections were written independently. Interconnection Standards for Railbelt Transmission:Inconsistent indentation in this document. Particularly noticeable in the 370/380 area. Interconnection Standards for Railbelt Transmission 524:Drop the "(fiber optic)”from the second bullet.We shouldn't be specifying the type of technology to be used,just the results we want. Interconnection Standards for Railbelt Transmission Glossary:Drop the first definition of "Provider”at the top of the page.The correct one towards the bottom should remain. INTERTIE MANAGEMENT COMMITTEE Resolution No.13-1 WHEREAS,Section 3.1 of the Amended and Restated Alaska Intertie Agreement provides that the Intertie Management Committee ("IMC”)shall determine Reserve Capacity and Operating Reserves for the Intertie,and the IMC has the authority to adopt operating policies and procedures,reliability standards,and enforcement mechanisms,for the Intertie. WHEREAS,on November 18,2011,the Intertie Management Committee ("IMC”)approved Resolution 11-1 which resolved that all then-currently existing contracts,customs,and operating policies and procedures associated with the Alaska Intertie and recognized by the Alaska Energy Authority ("AEA”)and the Intertie Operating Committee ("IOC”)were to remain in effect and be maintained by the IMC until such time as the IMC expressly addresses such contracts and operating policies and procedures relating to the operation of the Alaska Intertie (Intertie). WHEREAS,on September 13,2012,the IMC formally addressed and establish the Reserve Capacity and Operating Reserve responsibilities for all users of the Intertie by adopting Exhibit H of the Amended and Restated Alaska Intertie Agreement,but Exhibit H is a 1985 document that does not reflect the current configuration of the Railbelt system nor current operating protocols. WHEREAS,it is in the best interests of the Railbelt system to establish operating standards and reliability criteria applicable to the entire interconnected Railbelt system,and to have those standards and criteria apply to the Intertie,rather than to adopt standards and criteria solely for the Intertie. WHEREAS,the only entity that has established reliability criteria for the interconnected Railbelt system is the Alaska System Coordinating Council (ASCC)that has been defunct for 15 years. WHEREAS,in 2005 the Railbelt Utilities formed the "Ad-Hoc Railbelt Reliability Committee ("RRC”),to work with the Alaska Energy Authority ("AEA)in an open public process to review the substantial NERC operating,reserve capacity,and reliability standards,and to adapt those standards to meet Railbelt conditions and practices. WHEREAS,the RRC-prepared the "Intertie Management Committee's Railbelt Operating and Reliability Standards,updated June 7,2013.” WHEREAS,the IMC is the entity with authority to adopt policies,criteria and standards for the Intertie related to reserve capacity,operating reserves,operating policies,reliability,and enforcement mechanisms. WHEREAS,the IMC is willing to work with other interested parties to establish and implement Railbelt wide policies,criteria and standards related to reserve capacity,operating reserves, operating policies,reliability,and enforcement mechanisms. Page 1 of 2--IMC Resolution 13-1 INTERTIE MANAGEMENT COMMITTEE Resolution No.13-1 (Continued) WHEREAS,the purpose of this Resolution No.13-1 is to adopt the "Intertie Management Committee's Railbelt Operating and Reliability Standards,updated June 7,2013”as a guideline for the IMC working with other interested parties to establish and implement Railbelt wide policies,criteria and standards related to reserve capacity,operating reserves,operating policies,reliability,and enforcement mechanisms. WHEREAS,to ensure that the Intertie and the Railbelt system have the same criteria and standards applied related to reserve capacity,operating reserves,operating policies,reliability, and enforcement mechanisms,this Resolution shall sunset on [***date***]unless extended by the IMC to allow for monitoring of progress,and the "sanctions”enforcement mechanisms shall not become effective until separately approved by the IMC. BE IT RESOLVED THAT the "Intertie Management Committee's Railbelt Operating and Reliability Standards,updated June 7,2013.”prepared by the RRC is hereby accepted as the Reserve Capacity and Operating Reserves for the Intertie,Exhibit H of the Amended and Restated Alaska Intertie Agreement,and is accepted as the operating policies and procedures, reliability standards,and enforcement mechanisms,for the Intertie,with two modifications. First,this resolution shall sunset on [***date***]unless extended by the IMC to enable the IMC to monitor progress on establishing Railbelt system wide standards and criteria and ensure uniformity with Intertie standards and criteria.If the sunset is implemented, the currently existing Exhibit H and standards and criteria for reserve capacity,operating reserves,operating policies,reliability,and enforcement mechanisms shall become effective. Second,the "sanctions”portions of the enforcement mechanisms in the "Intertie Management Committee's Railbelt Operating and Reliability Standards,updated June 7, 2013”shall not become effective until separately approved by the IMC. BE IT FURTHER RESOLVED THAT this resolution and the "Intertie Management Committee's Railbelt Operating and Reliability Standards,updated June 7,2013.”prepared by the RRC shall be submitted as an informational filing to the Regulatory Commission of Alaska (RCA). The Secretary hereby certifies that this is a true and correct copy of Resolution No.13-1 and Resolution No.13-1 was approved by the IMC on July 9,2013. Bradley Evans,Chairman Gene Therriault,Secretary Page 2 of 2-IMC Resolution 13-1 JNTERTIE MANAGEMENT COMMITTEE __---{Formatted:Font:12 pt Resolution No.13-1 Background-OnWHEREAS,Section 3.1 of the Amended and Restated Alaska Intertie Agreement provides that the Intertie Management Committee ("IMC”)shall determine Reserve Capacity and Operating Reserves for the Intertie,and the IMC has the authority to adopt operating policies and procedures,reliability standards,and enforcement mechanisms,for the Intertie. WHEREAS,on November 18,2011,the Intertie Management Committee ("IMC”)approved Resolution 11-1 which resolved that all then-currently existing contracts,customs,and operating policies and procedures associated with the Alaska Intertie and recognized by the Alaska Energy Authority ("AEA”)and the Intertie Operating Committee ("IOC”)were to remain in effect and be maintained by the IMC until such time as the IMC expressly addresses such contracts and operating policies and procedures relating to the operation of the Alaska Intertie (intertie). __----{Formatted:Font:11 pt criteria document dated Apsl IWHEREAS.,on September 13,2012,the Railbelt Reliability Committee +RRG)IMC formally addressed and establish the Reserve Capacity and Operating Reserve responsibilities for all users of the Intertie- Amended and Restated Alaska Intertie AgreementWHEREAS,by adopting Exh ibit H of the WHEREAS -the-current,but Exhibit H is a 1985 document that does not reflect thecurrent system-configuration erof the Railbelt system nor current operating protocols-ard,. WHEREAS WHEREAS,it is in the best interests of the Railbelt system to establish operating standards and reliability criteria applicable to the entire interconnected Railbelt system,rather than to adopt standards and criteria solely for the Intertie. Page1 of 2 -IMC Resolution 13-1 WHEREAS,the only entity establishingthat has established reliability criteria for the interconnected Railbelt system is the Alaska System Coordinating Council (ASCC)that has been defunct for 15 years;-and,, WHEREAS,in 2005 the Railbeit Utilities formed the "Ad-Hoc Railbelt Reliability Committee ('RRC'),to work with the Alaska Energy Authority ("AEA)in an open public process to review the substantial NERC operating,reserve capacity,and reliability standards,and to adapt those standards to meet Raitbelt conditions and practices. WHEREAS,the RRC-prepared the "Intertie Management Committee's Railbelt Operating and Reliability Standards,updated June 7,2013.” WHEREAS,the IMCis the entity inthein dmmaiintaine,repairs and improves the-syetem and.with authority to0 adopt policies,criteria and standards for the Intertie related to reserve capacity,operating reserves,operating policies, reliability,and enforcement mechanisms. WHEREAS,the IMC is fit-willing to work with other interested parties to establish and ablete undertakeimplement Railbelt wide policies,criteria and effectively nplishstandards related to reserve capacity,operating reserves,operating policies,reliability,and enforcement mechanisms. WHEREAS,the tasks-identified inpurpose of this Resolution No.13-1 is to adopt the aforementioned clause."Intertie Management Committee's Railbe!t Operating and Reliability Standards,updated June 7,2013"as a guideline for the IMC working with other interested parties to establish and implement Railbelt wide policies,criteria and standards related to reserve capacity,operating reserves,operating policies,reliability,and enforcement mechanisms. WHEREAS.to ensure that the Intertie and the Railbelt system have the same criteria and standards applied related to reserve capacity,operating reserves,operating policies,reliabilit and enforcement mechanisms,this Resolution shail sunset on [***date***]unless extended by the IMC to allow for monitoring of progress,and the "sanctions”enforcement mechanisms shall not become effective until separately approved by the IMC. JNTERTIE MANAGEMENT COMMITTEE __---{Formatted:Font:12 pt Resolution No.13-1 (Continued) Page 2 of 2 -IMC Resolution 13-1 BE IT RESOLVED THAT the systers-retiability "Intertie Management Committee's Railbelt Operating and reserve-criteria-decumentdatedApril4,2042 ReliabilityStandards,updated June 7,2013.”prepared by the RRCis hereby accepted as the Reserve Capacity and Operating Reserves for the Intertie,Exhibit H of the Amended and Restated Alaska Intertie Agreement-and,,and is accepted as the operating policies and procedures,reliability standards,and enforcement mechanisms,for the Intertie,with two modifications. First,this resolution shall sunset on [***date***]unless extended by the IMC to enable the IMC to monitor progress on establishing Railbelt system wide standards and criteria and ensure uniformity with Intertie standards and criteria.If the sunset.is implemented, the currently existing Exhibit H and standards and criteria for reserve capacity,operating reserves,operating policies,reliability,and enforcement mechanisms shall become effective. Second,the "sanctions”portions of the enforcement mechanisms in the "Intertie Management Committee's Railbelt Operating and Reliability Standards,updated June 7, 2013”shall not become effective until separately approved by the IMC. BE IT FURTHER RESOLVED THAT this resolution and the aferementioned-cystem_reliability and-+esenve-criteria-decument'Intertie Management Committee's Railbelt Operating and Reliability Standards,updated June 7,2013.”prepared by the RRC_shall be submitted as an informational filing to the Regulatory Commission of Alaska (RCA). The Secretary hereby certifies that this is a true and correct copy of Resolution No.43-1 and that Resolution No.13-1 was approved by the IMC on July 9,2013. Print Name Chairman Gene Therriault,Secretary Page 3 of 2 -IMC Resolution 13-1 ALASKA INTERTIE MANAGEMENT COMMITTEE List of Representatives Representative Alternate Utility Brad Evans Burke Wick Chugach Electric Association Chairman 5601 Electron Drive Anchorage,Alaska 99518 Phone:563-7494 Fax:762-4514 Brad Evans@chugachelectric.com Burke Wick@chugachelectric.com James Posey Jeff Warner Anchorage Municipal Light &Power Vice Chairman 1200 East First Avenue Anchorage,Alaska 99501 Phone:279-7671 Fax:263-5204 PoseyJM@muni.org WarnerJA@muni.org Gene Therriault Sara Fisher-Goad Alaska Energy Authority Secretary/Treasurer 813 West Northern Lights Boulevard Anchorage,Alaska 99503 Phone:771-3000 Fax:771-3044 gtherriault@aidea.org sfishergoad@aidea.org Cory Borgeson Allen Gray Golden Valley Electric Association P.O.Box 71249 Fairbanks,Alaska 99707-1249 Phone:452-1151 Fax:458-5951 cborgeson@gvea.com ajg@@qvea.com Evan "Joe”Griffith Don Zoerb Matanuska Electric Association P.O.Box 2929 (163 Industrial Way) Palmer,Alaska 99645-2929 Phone:689-9211 Fax:689-9368 joe.qriffith@mea.coop don.zoerb@mea.coop Kirk Gibson McDowell Rackner &Gibson PC 419 SW 11"Street,Suite 400 Portland,Oregon 97205 Phone:(503)290-3626 Fax:(503)595-3928 Kirk@med-law.com Revised Date:May 22,2013 July 2,2013 IMC, Attached are draft open access rules (OA)for the Alaska Intertie and following the NERC methodology, the associated reliability standards AAMOD-001-01,028-01,029-01,030-01 covering the requirements for the calculation Available Transfer Capability under Open Access Rules (OARs) The attached draft rules for open access on the Alaska Intertie were adapted from the pro-forma open access transmission tariff (OATT)of the Federal Energy Regulatory Commission (FERC)(FERC order 888), as well as language in Chugach's OATT currently before the RCA.Chugach's OATT also follows the FERC Pro-forma tariff format modified to some degree to reflect the unique nature of the Alaskan interconnection. From a practical perspective "Alaska Intertie”is a component in a "series connection”of components which facilitate the transfer of energy and capacity from the Kenai-Anchorage-Mat-Su areas to the Fairbanks and central region and vice versa.The Alaska Intertie includes the facilities beginning at Chugach's 230kV bus at Teeland Substation;traversing a small section of Alaska Energy Authority's (AEA) line,the Leased MEA 115 Section to Douglas and the 345 kV AEA-owned intertie section and terminating | at Golden Valley Electric Association's (GVEA)Healy 138 kV bus and including static var compensators (SVCs)at Teeland,Healy and Gold Hill (See Exhibit E of the Amended and Restated Alaska Intertie Agreement).Entities wishing to move power from the "Southern Group”to the "Northern Group”(the predominant direction of Power flow currently)or vice versa,must at a minimum traverse three systems to transfer Energy and Capacity;namely Chugach's,the AEA's,and GVEA's.Currently,GVEA has an open access tariff on file with the Regulatory Commission of Alaska (RCA)and Chugach has an open access tariff before the RCA.Both the Chugach and GVEA tariffs have reservations for transfer of energy and capacity to native loads.The scheduling boundary between the Northern and Southern Groups is Douglas substation located near Willow.Municipal Light and Power is the southern area controller while GVEA is the northern area controller.Under the AIA both groups have Minimum Intertie Transfer Capability Rights (MITCR)in their respective Import directions based on the Total Transfer Capability of the intertie.Currently total MITCR is 80 MW in each direction,as determined by powerflow and a transient stability analysis completed in accordance with the relevant reliability guidelines. Figure 1 below is Douglas-BIB Hourly MW reading for the 12-months ending June 1.2013.Figure 2 shows the Available Capacity during that same period of time. Figure 1 Douglas Breaker B1B Mwgawatts --Douglas B18 (MW) om ATC 5/1/2013 0:00 6/1/2013 0:004/1/2013 0:002/1/2013 0:00 3/1/2013 0:001/1/2013 0:0011/1/20120:00 12/1/2012 0:0010/1/2012 0:009/1/2012 0:00 T /2012 0:007/1/2012 0:00 i 70 10 0 6/1/2012 0:00 10 Date/Time 6/8/2012 22:00 6/16/2012 21:00 6/24/2012 20:00 7/2/2012 19:00 7/10/2012 18:00 7/18/2012 17:00 7/26/2012 16:00 8/3/2012 15:00 8/11/2012 14:00 8/19/2012 13:00 8/27/2012 12:00 9/4/2012 11:00 9/12/2012 10:00 9/20/2012 9:00 9/28/2012 8:00 10/6/2012 7:00 10/14/2012 6:00 10/22/2012 5:00 10/30/2012 4:00 11/7/2012 2:00 11/15/2012 1:00 11/23/2012 11/30/2012 23:00 12/8/2012 22:00 12/16/2012 21:00 12/24/2012 20:00 1/1/2013 19:00 1/9/2013 18:00 1/17/2013 17:00 1/25/2013 16:00 2/2/2013 15:00 2/10/2013 14:00 2/18/2013 13:00 2/26/2013 12:00 3/6/2013 11:00 3/14/2013 11:00 3/22/2013 10:00 3/30/2013 9:00 4/7/2013 8:00 4/15/2013 7:00 4/23/2013 6:00 5/1/2013 5:00 5/9/2013 4:00 5/17/2013 3:00 5/25/2013 2:00 0806o1V8JNOHAqAqioedesa1q49}U]ajqejleayZaun3i4 The Figures above reflect that utilization of Northern MITCR (Imports to the Fairbanks Area)stood at approximately 56%and the Southern MITCR at 0%. One of the fundamental issues related to open access is the treatment of pre-existing transmission capacity rights.Generally speaking throughout the Lower 48,as a part of a broader move to competitive markets,FERC 888 recognized pre-existing transmission rights although in some cases,recognition of these rights is designed to "sunset”as markets develop and mature.Generally,the sunset of pre- existing capacity rights is contingent on the implementation of iSO/RTO structures and the development of robust forward looking markets for energy and capacity and ancillary services as well as hedging markets for congestion management.Further,competitive markets of this nature require real time pricing transparency in the form of Open Access Same Time information Systems (OASIS)(FERC Order 889). Due to the very limited transfer capacity between the Northern and Southern Groups and the single path nature of the interconnection,and the limited number of potential participants'robust markets of this nature are well beyond the foreseeable horizon of energy transfers within the Railbelt.Further, implementation of a true OASIS would require an ISO/RTO structure and significant investment in technology system care and feeding. Consistent with FERC practice,the attached draft OA rules establish fixed capacity rights (based on MITCR allocation at the time of OA adoption)for the Legacy Utility Participants (LUP). The draft OA rules utilize the "Rated Path Methodology (RPM)”for calculation of Available Transfer Capability (ATC).Rated Path Methodology is the most commonly used methodology in most of the lower 48 with the exception of the Southeastern US and make the most sense for less densely interconnected regions.The RPM calculates ATC as follows: ATC=(TTC-CBM-TRM_ETC+Postbacks+Counterflows) e TTC-Total Transfer Capability,the more conservative of the thermal or stability limit for the line. o Inthe case of the Alaska Intertie 80 MW as measured at Douglas e CBM-Capacity Benefit Margin (during emergencies),the amount of operating and non-operating reserve with priority rights over the line to be used only during periods of emergency.In the case of the Alaska Intertie o The Largest Single Contingency (LSC)less Northern area spin plus non-operating reserves for Northward flowing CBM o And LSC less Southern area spin plus non-operating reserves for southerly flowing CBM e TRM-Transmission Reliability Margin,a reservation of capacity based on operator experience to account for variations in forecast versus actual for loads,unit capacity,temperature etc. o Inthe case of the Intertie this is 3-5 MW e ETC -Existing Transmission Commitments,pre-existing transmission capacity and wheeling rights. o Inthe case of the Intertie these are ="Pre-existing transmission capacity rights granted to the LUPs base on MITCR at the time of conversion to OAR. «Existing OAR Firm and Non-firm commitments in priority ranking e Postbacks.These are formal recognition of the intention not to utilize transmission capacity in an ETC. o For example on the Alaska Intertie this would be the situation if GVEA's initial capacity allocation were scheduling 80 MW from hour ending 12:00 to hour ending 19:00 and only 20 MW north for hours ending 20:00 to hour ending 24:00.From 20:00 to 24:00,GVEA has made a 60MW postback from their ETC of 80 MW. e Counterflows.Flows that are scheduled counter to the predominate flow of energy and capacity o For example on the Alaska Intertie,if GVEA were scheduling 80 MW north out of Douglas and the US Army was scheduling 20 MW south out of Healy,net flow north is 60 MW.The Counterflow allows another 20 MW to be scheduled north. The draft OA rule formally recognizes and requires accounting of Postbacks and Counterflows and facilitates distribution of these rights to LUP's and Non-LUPs. In terms of practical effect,the OATR's will facilitate full use of the line during periods when the pre- existing capacity rights and OAR ETC's are not fully utilized.It should be recognized that since the intertie is a single link in a three or more link chain from the Southern to Northern systems,capacity may or may not be available North or South of the Intertie proper. Finally,the OAR's present a clear path for entities wishing to expand the transmission system or to increase transfer capacity on the intertie to do so while preserving the pre-existing rights of the LUP's. The OARs contemplate establishment of a pre-existing congestion revenue rights as a method to preserve these transfer rights as the system grows more complex. 11.COMMON TRANSMISSION SERVICE PROVISIONS 11.1 11.2 General These terms are applicable to all Eligible Customers and Transmission Customers transmitting capacity and energy on Transmission Provider's Transmission System.If an Eligible Customer or Transmission Customer is part of some other transmission services arrangement in which the Transmission Provider is involved,those terms and conditions will govern where applicable. Definitions Relating to Transmission Service (a) (b) (c) (d) (e) (f) (g) (h) Ancillary Services:Those services necessary to support the transmission of capacity and energy from resources to loads while maintaining reliable operation of the Transmission Provider's Transmission System in accordance with Good Utility Practice. Application For Transmission Service:A written request for transmission service by an Eligible Customer in a form approved by Transmission Provider pursuant to the provisions of the these Rules. Commission:The Regulatory Commission of Alaska. Completed Application For Transmission Service:An Application For Transmission Service that satisfies all of the information and other requirements of these rules,including any required deposit. Counterflows:As defined in Rule 13.2. Curtailment:A reduction in the scheduled capacity or energy delivery of an Interchange Transaction.Such a reduction in firm or non-firm transmission service made by the Transmission Provider in response to a transmission capacity shortage due to system reliability issues or other emergency conditions. . Delivering Party:The entity supplying capacity and energy to be transmitted at Point(s)of Receipt. Designated Agent:Any entity,or person,that performs actions or functions on behalf of the Transmission Provider,an Eligible Customer,or the Transmission Customer required under these Rules. Direct Assignment Facilities:Facilities or portions of facilities that are constructed by the Transmission Provider for the sole use and/or benefit of a particular Transmission Customer requesting service under the Interconnection Standards for Railbelt Transmission and or Generation and Page I of 52 GQ) (k) (1) (m) (n) (0) (p) (q) End User Interconnection Standards.Direct Assignment Facilities shall be specified in the Service Agreement that governs service to the Transmission Customer. Eligible Customer:Any electric utility (including the Transmission Provider)or any person generating electric energy for resale that holds a Certificate of Public Convenience and Necessity from the Commission is an Eligible Customer under these Rules. Facilities Study:An engineering study conducted in accordance with the methodologies outlined in the Interconnection Standards for Railbelt Transmission and or Generation and End User Interconnection Standards by the Transmission Provider,or its designee,to determine the required modifications to the Transmission Provider's Transmission System, including the cost and scheduled completion date for such modifications, that will be required to provide the requested transmission service.The cost of any Facilities Study is the responsibility of the requesting party. Firm Point-To-Point Transmission Service:Transmission Service under these rules that is reserved and/or scheduled between Douglas and Healy substations pursuant these rules. Good Utility Practice:Any of the practices,methods and acts engaged in or approved bya significant portion of the electric utility industry during the relevant time period,or any of the practices,methods and acts which, in the exercise of reasonable judgment in light of the facts known at the time the decision was made,could have been expected to accomplish the desired result at a reasonable cost consistent with good business practices, reliability,safety and expedition.Good Utility Practice is not intended to be limited to the optimum practice,method,or act to the exclusion of all others,but rather to be acceptable practices,methods,or acts generally accepted in the region. Intertie_Management Committee (IMC):The Intertie Management Committee established by the Amended and Restated Alaska Intertie Agreement dated November 18,2011. Intertie Utility Participant(s):As defined in the Amended and Restated Alaska Intertie Agreement dated November 18,2011. Interruption:A reduction in non-firm transmission service due to economic reasons pursuant to Rule 12.2(g). Legacy Utility Participant:The Intertie Utility Participant under the Amended and Restated Alaska Intertie Agreement dated November 18, 2011 who receive preexisting capacity rights upon adoption of these open access Rules. Page 2 of 52 (r) (s) (t) (u) (v) (w) (x) (y) (z) Long-Term Firm Point-To-Point Transmission Service:Firm Point-To- Point Transmission Service with a term of one (1)year or more. Native Load Customers:The wholesale and retail power customers of the Transmission Provider (or their load serving entities)on whose behalf the Transmission Provider,by statute,franchise,regulatory requirement,or contract,has undertaken a priority obligation to construct and operate the Transmission Provider's system to meet the reliable electric needs of such customers. Network Upgrades:Facilities or a portion of facilities that are added or upgraded by the Transmission Provider to the Transmission System in order to accommodate Eligible Customer's transmission service request in accordance with the Interconnection Standards for Railbelt Transmission and or Generation and End User Interconnection Standards. Non-Firm _Point-To-Point Transmission Service:Point-To-Point Transmission Service under these rules that is reserved and scheduled on an as-available basis and is subject to Curtailment or Interruption as set forth in Rule 12.2(g)of these rules.Non-Firm Point-To-Point Transmission Service is available on a stand-alone basis for a period ranging from one hour to one month. Parties:The Transmission Provider and the Transmission Customer receiving service pursuant to Rules 11 and 12. Point(s)of Delivery:Point(s)on the Transmission Provider's Transmission System where capacity and energy transmitted by the Transmission Provider will be made available to the Receiving Party under Rule 12 of these rules.The Point(s)of Delivery shall be specified in the Service Agreement for Firm Point-To-Point Transmission Service -see Appendix E-1 and E-2. Point(s)of Receipt:Point(s)of interconnection on the Transmission Provider's Transmission System where capacity and energy will be made available to the Transmission Provider by the Delivering Party under Rule 12 of these rules.The Point(s)of Receipt shall be specified in the Service Agreement for Firm Point-To-Point Transmission Service -see Appendix E-land E-2. Point-To-Point Transmission Service:The reservation and transmission of capacity and energy on either a firm or non-firm basis from the Point(s)of Receipt to the Point(s)of Delivery under Rule 12 of these Rules. Putbacks:As defined in Rule 13.1. Page 3 of 52 (aa) (bb) (cc) (dd) (ce) (ff) (gg) (hh) (ii) Gi) Real_Power Losses:A Real Power Loss is the normal loss of energy during transmission. Receiving Party:The entity receiving the capacity and energy transmitted by the Transmission Provider to Point(s)of Delivery. Reseller:The entity receiving rights under a Service Agreement as more fully described in Rule 12.11. Reserved Capacity:The amount of capacity and energy that the Transmission Provider agrees to transfer for the Transmission Customer over the Transmission Provider's Transmission System between the Point(s)of Receipt and the Point(s)of Delivery.Reserved Capacity shall be expressed in terms of whole megawatts on a sixty (60)minute interval (commencing on the clock hour)basis. Service Agreement for Point-to-Point_Transmission Service ("Service Agreement"):For purposes of Rule 11 and Rule,the initial agreement and any amendments or supplements thereto entered into by the Transmission Customer and the Transmission Provider for service under these Rules. See Appendix E-land Appendix E-3. Service Commencement Date:The date the Transmission Provider begins to provide service pursuant to the terms of an executed Service Agreement, or the date the Transmission Provider begins to provide service in accordance with these Rules. Shed_or Shedding:The systematic reduction of system demand by temporarily decreasing load in response to transmission system or area capacity shortages,system instability,or voltage control considerations, also known as under frequency loadshed when operating below 59.0 Hz and Shed In Lieu of Spin (SILOS)between 59.0 and 60 Hz. Shed in Lieu of Spin:[to be defined] Short-Term Firm Point-To-Point Transmission Service:Firm Point-To- Point Transmission Service with a term of less than one (1)year. System Impact Study:An assessment by the Transmission Provider,or its designee,of (i)the adequacy of the Transmission System to accommodate a request for Firm Point-To-Point Transmission Service and (ii)whether any additional costs may be incurred in order to provide transmission service.The cost of any System Impact Study is the responsibility of the requesting entity and must be performed in accordance with the Interconnection Standards for Railbelt Transmission and or Generation and End User Interconnection Standards. Page 4 of 52 11.3 11.4 11.5 (kk)Third-Party Sale:Any sale for resale to a power purchaser. (11)Transmission Customer:Any Eligible Customer (or its Designated Agent) that is deemed qualified under the Interconnection Standards for Railbelt Transmission and or Generation and End User Interconnection Standards that executes a Service Agreement with the Transmission Provider.This term is used in the Rule 11 Common Transmission Service Provisions to include customers receiving transmission service under Rule 12 of these rules. (mm)Transmission Provider:Intertie Management Committee. (nn)Transmission Service:Point-To-Point Transmission Service provided under Rule 12 of these Rules. (oo)Transmission System:The facilities owned,controlled or operated by the Transmission Provider that are used to provide transmission service under Rule 12 of these Rules. (pp)Under-Frequency Load Shed:[to be defined] (qq)Working Day:Monday through Friday,excluding public holidays recognized by the Commission and the State of Alaska,Alaska Energy Authority. Initial Allocation of Available Transfer Capability For purposes of determining whether existing capability on the Transmission Provider's Transmission System is adequate to accommodate a request for firm service under these Rules,all completed applications for new firm transmission service received during the initial sixty (60)day period commencing with the effective date of these Rules will be deemed to have been filed simultaneously.A lottery system conducted by the Intertie Management Committee IMC shall be used to assign priorities for completed applications filed simultaneously.All completed applications for firm transmission service received after the initial sixty (60)day period shall be assigned a priority pursuant to Rule 12.1(b).It should be noted that currently all firm capacity on the Alaska Intertie is committed to the current (legacy)Intertie Utility Participants (LUPs)through pre- existing capacity rights.To the extent that Postbacks and Counterflows make firm service available,the capacity will be allocated as above. This section intentionally blank Ancillary Services Ancillary Services are required with transmission service to maintain reliability within and among the portion(s)of the service territories area affected by the Page 5 of §2 transmission service requested by Transmission Customer.The Transmission Provider is required to offer,and the Transmission Customer is required to purchase,the following Ancillary Services:(i)Scheduling,System Control and Dispatch (Rate Schedule T-1),(ii)Reactive Supply and Voltage Control from Generation Sources (Rate Schedule T-2),(iii)Regulation and Frequency Response (Rate Schedule T-3),(iv)Energy Imbalance (Rate Schedule T-4),(v) Operating Reserve -Spinning Reserve Service (Rate Schedule T-5),and (vi) Operating Reserve -Supplemental Reserve Service (Rate Schedule T-6). In order to insure adequate Operating Reserves (spinning)and Non-Operating Reserves (supplemental)and to fairly distribute responsibility for these reserves, the original provider of the energy and/or capacity whether acting as the Transmission Customer or as energy provider to the Transmission Customer shall be responsible for meeting the reserve obligations as described in Exhibit H of the Amended and Restated Alaska Intertie Agreement. The IMC as Transmission provider will contract for and obtain for provision to the Transmission Customer services not provided by the assets of the Alaska Intertie project.The Transmission Customer is required to acquire these Ancillary Services from the Transmission Provider.The Transmission Customer may not decline the Transmission Provider's offer of these Ancillary Services and instead self-supply or supply these Ancillary services from a third party unless the Transmission Customer demonstrates,to the Transmission Provider's satisfaction,that it can provide,or it has acquired,the additional Ancillary Services from another source acceptable to Transmission Provider.In this case, the Transmission Customer must identify in its Application For Transmission Service how it will satisfy this obligation,including which Ancillary Services it will purchase from the Transmission Provider.In all cases,Scheduling,System Control and Dispatch services and Reactive Supply and Voltage Control from Generation and other VAR Sources services must be provided directly by the Transmission Provider. A Transmission Customer that exceeds its firm reserved capacity at any Point of Receipt or Point of Delivery or an Eligible Customer that uses Transmission Service at a Point of Receipt or Point of Delivery that it has not reserved is required to pay for all of the Ancillary Services identified in this Rule that were provided by the Transmission Provider associated with the unreserved service. The Transmission Customer or Eligible Customer will pay for Ancillary Services in accordance with the provisions of Rule 12.1(g)in the case of firm service and Rule 12.2(e)in the case of non-firm service. The specific Ancillary Services,prices and/or compensation methods are described on the Schedules that are attached to and made a part of these Transmission rules.The Ancillary Services are: (a)Scheduling:System Control and Dispatch Service.The rates and/or Page 6 of 52 11.6 11.7 methodology are described in Rate Schedule T-1. (b)Reactive Supply and Voltage Control from Generation Sources Service: The rates and/or methodology are described in Rate Schedule T-2. (c)Regulation and Frequency Response _Service:The rates and/or methodology are described in Rate Schedule T-3. (d)Energy Imbalance Service:The rates and/or methodology are described in Rate Schedule T-4. (e)Operating Reserve _-Spinning Reserve Service:The rates and/or methodology are described in Rate Schedule T-5. (f)Operating Reserve _-Supplemental Reserve Service:The rates and/or methodology are described in Rate Schedule T-6. Reciproci A Transmission Customer receiving transmission service under these rules agrees to provide comparable transmission service that it is capable of providing to the each member or any combination of members of the IMC on similar terms and conditions over facilities used for the transmission of electric energy owned, controlled or operated by the Transmission Customer and over facilities used for the transmission of electric energy owned,controlled or operated by the Transmission Customer's corporate affiliates. This reciprocity requirement applies not only to the Transmission Customer that obtains transmission service under these Rules,but also to all parties to a transaction that involves the use of transmission service under these Rules, including the power seller,buyer and any intermediary,such as a power marketer. This reciprocity requirement also applies to any Eligible Customer that owns controls or operates transmission facilities that uses an intermediary,such as a power marketer,to request transmission service under these Rules.If the Transmission Customer does not own,control or operate transmission facilities,it must include in its Application a sworn statement of one of its duly authorized officers or other representatives that the purpose of its Application is not to assist an Eligible Customer to avoid the requirements of this provision. Billing and Payment (a)Billing Procedure:Within a reasonable time after the first day of each month,the Transmission Provider shall submit an invoice to the Transmission Customer for the charges for all services furnished under these Rules during the preceding month.The Transmission Customer will be billed each month for the charges in the transmission rate schedules Page 7 of 52 11.8 11.9 (a) (b) (c) governing Ancillary Services and Reserved Capacity using the monthly rate or one-twelfth (1/12)of the yearly rate accordingly.The invoice shall be paid by the Transmission Customer within twenty (20)calendar days of receipt.All payments shall be made in immediately available funds payable to the Alaska Energy Authority on behalf of the IMC acting as the Transmission Provider.If day 20 falls on a weekend or holiday,payment is to be made on the next business day. Interest_on Unpaid Balances:Interest on any unpaid amounts (including amounts placed in escrow)shall be calculated in accordance with Commission regulations.Interest on delinquent amounts shall be calculated from the due date of the bill to the date of payment.Bills will be increased 1 percent per month on amounts unpaid after 20 calendar days from the date the bill is rendered,not to exceed the regulations under AS 45.45.010(a).When payments are made by mail,bills shall be considered as having been paid on the date of receipt by the Transmission Provider. Customer Default:In the event the Transmission Customer fails,for any reason other than a billing dispute as described below,to make payment to the Transmission Provider on or before the due date as described above, and such failure of payment is not corrected within thirty (30)calendar days after the Transmission Provider notifies the Transmission Customer to cure such failure,a default by the Transmission Customer shall be deemed to exist.Upon the occurrence of a default,the Transmission Provider may immediately terminate Transmission Service under these Rules until the default is cured. In the event of a billing dispute between the Transmission Provider and the. Transmission Customer,the Transmission Provider will continue to provide service under the Service Agreement as long as the Transmission Customer (i)continues to make all payments not in dispute,and (ii)pays into an independent escrow account an amount equal to the portion of the invoice in dispute,pending resolution of such dispute.If the Transmission Customer fails to meet these two requirements for continuation of service during a billing dispute,then the Transmission Provider may provide notice to the Transmission customer of its intention to terminate transmission service in thirty (30)days. This section intentionally left blank Force Majeure and Indemnification Force Majeure:With respect to transmission services provided in accordance with the provisions of Rule 11 and Rule 12 of these Rules,an event of Force Majeure means any act of God,labor disturbance,act of the public enemy,war,insurrection,riot,fire,storm or flood,explosion, Page 8 of 52 11.10 11.11 breakage or accident to machinery or equipment,any Curtailment,order, regulation or restriction imposed by governmental military or lawfully established civilian authorities,or any other cause beyond a party's control. A Force Majeure event does not include an act of negligence or intentional wrongdoing.Neither the Transmission Provider nor the Transmission Customer will be considered in default as to any obligation under these Rules if prevented from fulfilling the obligation due to an event of Force Majeure.However,a Party whose performance under these Rules is in any way hindered by an event of Force Majeure shall make all reasonable efforts to perform its obligations under these Rules. (b)Indemnification:The Transmission Customer shall at all times indemnify, defend,and save the Transmission Provider harmless from,any and all damages,losses,claims,including claims and actions relating to injury to or death of any person or damage to property,demands,suits,recoveries, costs and expenses,court costs,attorney fees,and all other obligations by or to third parties,arising out of or resulting from the Transmission Provider's performance of its obligations under these Rules on behalf of. the Transmission Customer,except in cases of gross negligence or intentional wrongdoing by the Transmission Provider. Creditworthiness For the purpose of determining the ability of the Transmission Customer to meet its obligations related to service hereunder,the Transmission Provider may require reasonable credit review procedures.This review shall be made in accordance with standard commercial practices used by the Transmission Provider.In addition,the Transmission Provider may require the Transmission Customer to provide and maintain in effect during the term of the Service Agreement,an unconditional and irrevocable letter of credit as security to meet its responsibilities and obligations under these Rules,or an alternative form of security proposed by the Transmission Customer and acceptable to the Transmission Provider and consistent with commercial practices established by the Uniform Commercial Code,that would serve to protect the Transmission Provider against the risk of non-payment. Dispute Resolution Procedures A Transmission Customer who believes that the Transmission Provider has violated these rules or the Service Agreement may submit the matter for review under the following complaint procedure. Step 1:The Transmission Customer should report the complaint to the designated to the substance of each complaint in a timely manner.If a representative of Transmission Provider is unable to resolve a complaint,the employee will refer the matter to the Chairman of the IMC,who will make every effort to resolve the Page 9 of §2 12. matter. Step 2:If the Transmission Customer disagrees with the Transmission Provider's resolution of the complaint,the Transmission Customer may set out the complaint in writing and address it to the Executive Director of the Alaska Energy Authority.The Executive Director and department of Law will attempt to mediate the dispute within the confines of the Amended and Restate Alaska Intertie Agreement. Moreover,if the Transmission Customer does not receive a timely response to a complaint during the dispute resolution process outlined herein,the Transmission Customer may appeal directly to the AEA Executive Director. POINT-TO-POINT TRANSMISSION SERVICE The Transmission Provider will provide Firm Point-To-Point Transmission Service and Non-Firm Point-to-Point Transmission Service pursuant to the applicable terms and conditions of these rules.Point-To-Point Transmission Service is for the receipt of capacity and energy at designated Point(s)of Receipt and the transfer of such capacity and energy to designated Point(s)of Delivery.As set forth in this Rule 12,Point-To-Point Transmission Service transactions may give rise to several component charges. Because of the pre-existing capacity rights of signatories to the Amended and Restated Alaska Intertie Agreement,the availability of point to point transmission service will be a function of Postbacks and Counterflows.Duration and nature of service will be contingent upon the duration and nature of the Postbacks and Counterflows. 12.1 Nature of Firm Point-To-Point Transmission Service (a)Term:The minimum term of Firm Point-To-Point Transmission Service shall be one (1)day.The term shall be specified in the Service Agreement. The term of Short-Term Firm Point-To-Point Transmission Service shall be expressed in days,weeks,and/or months. (b)Reservation Priority: i,Long-Term Firm Point-To-Point Transmission Service shall be available on a first-come,first-served basis i.e.,in the chronological sequence in which each Transmission Customer has reserved service subject to pre-existing capacity rights of signatories to the Amended and Restated Alaska Intertie Agreement; ti.Reservations for Short-Term Firm Point-To-Point Transmission Service will be conditional based upon the length of the Postbacks and Counterflows and the length of the requested transaction as follows:If the Postbacks and Counterflows are recallable and Page 10 of 52 (c) subsequently recalled or the transmission system becomes oversubscribed,requests for longer term service shall preempt requests for shorter-term service up to the following conditional reservation deadlines: °one (1)day before the commencement of daily service (i.e. service with a term of less than a week); e one (1)week before the commencement of weekly service (i.e. service with a term of less than a month);and e one (1)month before the commencement of monthly service (i.e.service with a term equal to or greater than a month). Preemption of shorter-term service,if any,shall take place sequentially beginning with preemption of the most recent request for shorter-term service.Before the conditional reservation deadline,if available transmission capability is insufficient to satisfy all Applications for Transmission Service,an Eligible Customer with a reservation for shorter term service has the right of first refusal to match any longer term reservation before losing its reservation priority.A longer term competing request for Short-Term Firm Point-To-Point Transmission Service will be granted if the Eligible Customer with the right of first refusal does not agree to match the competing request within twenty-four (24)hours (or earlier at Transmission Provider's discretion if necessary to comply with the scheduling deadlines)from being notified by the Transmission Provider of a longer-term competing request for Short-Term Firm Point- To-Point Transmission Service.When a longer duration request preempts multiple shorter duration reservations,the shorter duration reservations shall have simultaneous opportunities to exercise the right of first refusal. Duration and time of response will be used to determine the order by which the multiple shorter duration reservations will be able to exercise the right of first refusal.After the conditional reservation deadline,service will commence pursuant to the terms of Rule 12 of these rules. iii.Firm Point-To-Point Transmission Service will always have a reservation priority over Non-Firm Point-To-Point Transmission Service under these rules.All Long-Term Firm Point-To-Point Transmission Service,should it become available,will be subject to priority to MITCR allocations in effect on the date these OAT rules were incorporated into the agreement. Use of Firm Transmission Service by the members of the IMC:The Utility Participants of the AIA will be subject to the rates,terms and conditions of these rules when making Third-Party Sales except in that Ancillary Services (with the exception of Dispatch Scheduling and Voltage Page 11 of 52 (d) (e) (f) Support)may be provided by the AIA member utility. Firm Point-To-Point Service Agreements:The Transmission Provider shall offer a standard form Service Agreement (See Appendix E-1)for Firm Point-To-Point Transmission Service to an Eligible Customer when it submits a Completed Application For Transmission Service in accordance with these Rules.An Eligible Customer that uses Transmission Service at a Point of Receipt or Point of Delivery that it has not reserved and that has not executed a Service Agreement will be deemed,for purposes of assessing any appropriate charges and penalties,to have executed the applicable Service Agreement. Transmission Customer Obligations for Facility Additions or Re-dispatch Costs:In cases where the Transmission Provider determines that the Transmission System is not capable of providing Firm Point-To-Point Transmission Service without exceeding the Available Transfer Capability, the Transmission Provider will only be obligated to expand or upgrade its Transmission System pursuant to the terms of Rule 12.7 and in accordance with the Applicable Railbelt Reliability Standards and the Interconnection Standards for Railbelt Transmission and or Generation and End User Interconnection Standards.The Transmission Customer must agree to compensate the Transmission Provider for any necessary transmission facility additions pursuant to the terms of Rule 12.7 and these standards. To the extent the Transmission Provider can relieve any system constraint more economically by re-dispatching the Transmission Provider's resources than through constructing System Upgrades;it may do so, provided that the Eligible Customer agrees to compensate the Transmission Provider pursuant to the terms of Rule 12.7.Any re-dispatch, System Upgrade or Direct Assignment Facilities costs to be charged to the Transmission Customer on an incremental basis under these rules will be specified in the Service Agreement prior to initiating service. Curtailment of Firm Transmission Service:In the event that a Curtailment on the Transmission Provider's Transmission System,or a portion thereof, is required to maintain reliable operation of such system Curtailments will be made on a non-discriminatory basis to the transaction(s)that effectively relieve the constraint.If multiple transactions require Curtailment,to the extent practicable and consistent with Good Utility Practice,the Transmission Provider will curtail service to Transmission Customers taking Firm Point-To-Point Transmission Service on a basis subordinate only to the curtailment of service to the Transmission Provider's Native Load Customers (IMC member's).All Curtailments under these Rules will be made on a non-discriminatory basis,however: Page 12 of 52 (g) °Non-Firm Point-To-Point Transmission Service shall be subordinate to Firm Transmission Service and service to the Transmission Provider's Native Load Customers;and e Non-Firm Point-To-Point Transmission Service for which re- dispatch costs will not be paid shall be subordinate to Non-Firm Point-To-Point Transmission Service for which re-dispatch costs will be paid. When the Transmission Provider determines that an electrical or system emergency exists on its Transmission System and implements emergency procedures to curtail firm transmission service,the Transmission Customer shall make the required reductions upon request of the Transmission Provider.In some instance these reduction may be automated.Automated curtailment procedures will be outlined in detail in the Service Agreement prior to scheduling.However,the Transmission Provider reserves the right to initiate Curtailment,in whole or in part,any Firm Point-To-Point Transmission Service provided under these rules when,in the Transmission Provider's sole discretion,an emergency or other unforeseen condition impairs or degrades the reliability of its Transmission System.The Transmission Provider will notify all affected Transmission Customers in a timely manner of any scheduled Curtailments. Classification of Firm Transmission Service: i.The Transmission Customer taking Firm Point-To-Point Transmission Service may request a modification of the Point(s)of Receipt or Point(s)of Delivery on a firm basis pursuant to the terms of Rule 12.10.The Transmission Customer may purchase transmission service to make sales of capacity and energy from multiple generating units that are on the Transmission Provider's Transmission System.For such a purchase of transmission service, the resources will be designated as multiple Points of Receipt,unless the multiple generating units are at the same generating facility in which case the units would be treated as a single Point of Receipt. ii.|The Transmission Provider shall provide deliveries of capacity and energy on a firm basis from the Point(s)of Receipt to the Point(s)of Delivery.Each Point of Receipt at which firm transfer capability is reserved by the Transmission Customer shall be set forth in the Service Agreement for Long-Term Firm Point-To-Point Transmission Service along with a corresponding capacity reservation associated with each Point of Receipt.Points of Receipt and corresponding capacity reservations shall be as mutually agreed upon by the Parties for Short-Term Firm Point-To-Point Transmission.Each Point of Delivery at which firm transfer capacity Page 13 of 52 is reserved by the Transmission Customer shall be set forth in the Service Agreement for Long-Term Firm Point-To-Point Transmission Service along with a corresponding capacity reservation associated with each Point of Delivery.Points of Delivery and corresponding capacity reservations shall be as mutually agreed upon by the Parties for Short-Term Firm Point-To- Point Transmission.The greater of either (1)the sum of the capacity reservations at the Point(s)of Receipt,or (2)the sum of the capacity reservations at the Point(s)of Delivery shall be the Transmission Customer's Reserved Capacity.The Transmission Customer will be billed for its Reserved Capacity under the terms of Rate Schedule T- 7. The Transmission Customer may not exceed its firm capacity reserved at each Point of Receipt and each Point of Delivery.In the event the Transmission Customer (including Third Party Sales by the Transmission Provider)exceeds its firm capacity reserved at any Point of Receipt or Point of Delivery or uses Transmission Service at a Point of Receipt or Point of Delivery that it has not reserved,the Transmission Customer shall pay a penalty equal to twice the rate set forth in Rate Schedule T-7 as follows: e The unreserved use penalty for a single hour of unreserved use shall be based on the rate for daily Firm Point-To-Point Transmission Service. e If there is more than one assessment for a given duration (e.g., daily)for the Transmission Customer,the penalty shall be based on the next longest duration (e.g.,weekly). e The unreserved penalty charge for multiple instances of unreserved use (i.e.,more than one hour)within a day shall be based on the daily rate Firm Point-To-Point Transmission Service. e The unreserved penalty charge for multiple instances of unreserved use isolated to one calendar week shall be based on the charge for weekly Firm Point-To-Point Transmission Service. e The unreserved use penalty charge for multiple instances of unreserved use during more than one week during a calendar month shall be based on the charge for monthly Firm Point-To- Point Transmission Service. The Transmission Customer shall additionally pay for Ancillary Services Page 14 of §2 h) associated with the unreserved service.This penalty payment for Ancillary Services shall be based on twice the rate set forth in Rate Schedules T-1, T-2,T-3,T-4,T-5 and T-6,multiplied by the penalty basis set out in the immediately-preceding list (i.e.a daily,weekly or monthly basis as appropriate). As an alternative to the above penalties,the Transmission Provider,in its sole discretion,may accept payment in kind on a MW per MW basis Scheduling of Firm Point-To-Point Transmission Service:Notice of Postbacks and Counterflows in excess of one day,making available Firm Point to Point service will be posted not later than 5:00 pm of second working day prior to the schedule date.The Transmission Customer's Firm Point-To-Point Transmission Service must be submitted to the Transmission Provider no later than 10:00 a.m.of the Working Day prior to commencement of such service.Schedules submitted after 10:00 a.m. may be accommodated,if practicable.Hour-to-hour schedules of any capacity and energy that is to be delivered must be stated in increments of 1,000 kW per hour.Transmission Customers with multiple requests for transmission service at a Point of Receipt,each of which is underl,000 kW per hour,may consolidate their service requests at a common Point of Receipt into units of 1,000 kW per hour for scheduling and billing purposes.To the extent practicable,scheduling changes will be permitted up to twenty (20)minutes before the start of the next clock hour provided that the Delivering Party and Receiving Party also agree to the schedule modification.Hour by hour Postbacks and Counterflows may occur within this time frame as well.The Transmission Provider will furnish to the Delivering Party's system operator,hour-to-hour schedules equal to those furnished by the Receiving Party (unless reduced for losses)and shall deliver the capacity and energy provided by such schedules.Should the Transmission Customer,Delivering Party or Receiving Party revise or terminate any schedule,such party shall immediately notify the Transmission Provider,and the Transmission Provider shall have the right to adjust,in its sole discretion,the schedule for capacity and energy to be received and to be delivered,as well as to add these termination to the hour by hour Postbacks. 12.2 Nature of Non-Firm Point-To-Point Transmission Service (a)Term:Non-Firm Point-To-Point Transmission Service will be available for periods ranging from one (1)hour to one (1)month subject to corresponding Postbacks and Counterflows.However,a Purchaser of Non- Firm Point-To-Point Transmission Service will be entitled to reserve a sequential term of service (such as a sequential monthly term without having to wait for the initial term to expire before requesting another monthly term)so that the total time period for which the reservation Page 15 of 52 (b) (c) (d) (e) applies is greater than one month,subject to the requirements of Rule 12.6(c). Reservation Priority:Subject to availability of suitable Postbacks and Counterflows,Non-Firm Point-To-Point Transmission Service shall be available from transfer capability in excess of that needed for pre-existing capacity rights of Native Load Customers,reliable service to Native Load Customers and other Transmission Customers taking Long-Term and Short-Term Firm Point-To-Point Transmission Service.A higher priority will be assigned in the first instance to requests or reservations with a longer duration of service.In the event the Transmission System is constrained,competing requests of equal duration will be prioritized based on the highest price offered by the Eligible Customer for the Transmission Service.Eligible Customers that have already reserved shorter term service have the right of first refusal to match the term and price of any longer term request before being preempted.A longer term competing request for Non-Firm Point-To-Point Transmission Service will preempt that of the Eligible Customer with the right of first refusal if that Eligible Customer does not agree to match the competing request within 24 hours (or earlier if necessary to comply with the scheduling deadlines provided in Rule 12.2(f))after notification by the Transmission Provider.Non-Firm Point- To-Point Transmission Service over secondary Point(s)of Receipt and Point(s)of Delivery will have the lowest reservation priority under these rules. Use of Non-Firm Transmission Service by the Transmission Provider:The Transmission Provider will be subject to the rates,terms and conditions of these rules when making Third-Party Sales. Non-Firm Transmission Service Agreements:The Transmission Provider shall offer a standard form Service Agreement (see Appendix E-3)for Non-Firm Point-To-Point Transmission Service to an eligible Customer when it submits a Completed Application For Transmission Service in accordance with these rules. Classification of Non-Firm Transmission Service:Subject to appropriate Postbacks and Counterflows,Non-Firm Point-To-Point Transmission Service shall be offered under terms and conditions contained in these rules.The Transmission Provider undertakes no obligation under these rules to plan its Transmission System in order to have sufficient capacity for Non-Firm Point-To-Point Transmission Service.Parties requesting Non-Firm Point-To-Point Transmission Service for the transmission of firm power do so with the full realization that such service is subject to availability and to Curtailment or Interruption under the terms of these rules.The Transmission Provider shall specify the rate treatment and all related terms and conditions applicable in the event that a Transmission Page 16 of52 (f) (g) Customer (including Third-Party Sales by the Transmission Provider) exceeds its non-firm capacity reservation.Non-Firm Point-To-Point Transmission Service shall include transmission of energy on an hourly basis and transmission of scheduled short-term capacity and energy on a daily,weekly or monthly basis,but not to exceed one month's reservation for any one Application,under Rate Schedule T-8. In the event the Transmission Customer (including Third Party Sales by the Transmission Provider)exceeds its non-firm capability reserved at any Point of Receipt or Point of Delivery,the Transmission Customer shall pay the rate set forth in Rate Schedule T-8 for the delivery period (.e., monthly,weekly,daily or hourly)for which the Transmission Customer is reserving capacity multiplied by an adjusted reserved capacity (for pricing purposes only)equal to the highest level used by the Transmission Customer at such Point of Receipt or Point of Delivery as integrated over a 60 minute period.The Transmission Customer shall additionally pay for Ancillary Services on the basis of this adjusted reserved capacity level, multiplied by the rates set forth in Rate Schedules T-1,T-2,T-3,T-4,T-5 and T-6. Scheduling of Non-Firm Point-To-Point Transmission Service:Postbacks and Counterflows in excess of one day shall be posted by 5:00pm of the second day prior to scheduled service.Schedules for Non-Firm Point-To- Point Transmission Service must be submitted to the Transmission Provider no later than 10:00 a.m.of the day prior to the commencement of such service.Schedules submitted after 10:00 a.m.will be accommodated, if practicable.Hour-to-hour schedules of energy that is to be delivered must be stated in increments of 1,000 kW per hour.Transmission Customers with multiple requests for Transmission Service at a Point of Receipt,each of which is under 1,000 kW per hour,may consolidate their schedules at a common Point of Receipt into units of 1,000 kW per hour. To the extent practicable,scheduling changes will be permitted up to thirty (30)minutes before the start of the next clock hour provided that the Delivering Party and Receiving Party also agree to the schedule modification.The Transmission Provider will furnish to the Delivering Party's system operator,hour-to-hour schedules equal to those furnished by the Receiving Party and shall deliver the capacity and energy provided by such schedules.Should the Transmission Customer,Delivering Party or Receiving Party revise or terminate any schedule,such party shail immediately notify the Transmission Provider,and the Transmission Provider shall have the right to adjust accordingly the schedule for capacity and energy to be received and to be delivered. Curtailment_or Interruption of Non-Firm_Point-To-Point Transmission Service:The Transmission Provider reserves the right to Curtail,in whole or in part,Non-Firm Point-To-Point Transmission Service provided under Page 17 of 52 these rules for reliability reasons when an emergency or other unforeseen condition threatens to impair or degrade the reliability of the Transmission System or the systems directly and indirectly interconnected with Transmission Provider's Transmission System.Transmission Provider may elect to implement such Curtailments pursuant to the transmission loading relief procedures.The Transmission Provider reserves the right to Interrupt,in whole or in part,Non-Firm Point-To-Point Transmission Service provided under these rules for economic reasons in order to (1) accommodate in the event that the Postbacks are recalled (2)Counterflows are cancelled or interrupted for some reason and situation will impede the delivery of service to Native Load Customers or firm service (3)a request for Firm Transmission Service,(4)a request for Non-Firm Point-To-Point Transmission Service of greater duration,or (5)a request for Non-Firm Point-To-Point Transmission Service of equal duration with a higher price. The Transmission Provider also will discontinue or reduce service to the Transmission Customer to the extent that deliveries for transmission are discontinued or reduced at the Point(s)of Receipt.Where required, Curtailments or Interruptions will be made on a nondiscriminatory basis to the transaction(s)that effectively relieve the constraint,however,Non- Firm Point-To-Point Transmission Service shall be subordinate to Firm Transmission Service and Non-Firm Point-To-Point Transmission Service for which redispatch costs will not be paid shall be subordinate to Non- Firm Point-To-Point Transmission Service for which redispatch costs will be paid.If multiple transactions require Curtailment or Interruption,to the extent practicable and consistent with Good Utility Practice,Curtailments or Interruptions will be made to transactions of the shortest term Non-Firm Point-To-Point Transmission Service over secondary Point(s)of Receipt and Point(s)of Delivery will have a lower priority than any Non-Firm Point-To-Point Transmission Service under these rules.The Transmission Provider will provide advance notice of Curtailment or Interruption where such notice can be provided consistent with Good Utility Practice. 12.3 Service Availability (a) (b) General Conditions:The Transmission Provider will provide Firm and Non-Firm Point-To-Point Transmission Service over,on,or across its Transmission System to any Transmission Customer that has met the requirements of Rule 12.4. Determination of Available Transmission Capability:|Transmission Provider's methodology for assessing Available Transmission Capability is the "Rated System Path Methodology”as required in Reliability Standard AKMOD-001-01and more fully described in Appendix E-4 and Reliability Standard AKMOD-028-01 .In the event sufficient transmission capability may not exist to accommodate a service request for Long-Term Firm Point-To-Point Transmission Service,the Transmission Provider will Page 18 of 52 12.4 (c) (d) (e) respond by performing a System Impact Study as more fully described in the Interconnection Standards for Railbelt Transmission and or Generation and End User Interconnection Standards.See Appendix E-5. Obligation to Provide Transmission Service that Requires Expansion or Modification of the Transmission System:If the Transmission Provider determines that it cannot accommodate a Completed Application for Long- Term Firm Point-To-Point Transmission Service because of insufficient capability on its Transmission System,the Transmission Provider will use due diligence to redispatch its own resources or to expand or modify its Transmission System to provide the requested Firm Transmission Service, provided the Transmission Customer agrees to compensate the Transmission Provider for all such costs incurred to accommodate Transmission Customer's request pursuant to the terms of these rules .The Transmission Provider will conform to Good Utility Practice and the applicable Railbelt Reliability and Interconnection Standards in determining the need for new facilities and in the design and construction of such facilities.The obligation applies only to those facilities that the Transmission Provider has the right to expand or modify.With the expansion of the system,the Legacy Utility Participants will retain pre- existing capacity rights on the improved system.A system recognizing these pre-existing capacity nghts will be put in place to compensate and make whole the Utility Participants in the event of congestion on the improved system. Deferral of Service:The Transmission Provider may defer providing service until it completes construction of new transmission facilities or upgrades needed to provide Firm Point-To-Point Transmission Service whenever the Transmission Provider determines that providing the requested service would,without such new facilities or upgrades,impair or degrade reliability to any existing firm services. Real Power Loss (Losses):Real Power Losses are associated with all transmission service and must be supplied by Transmission Customer.The Transmission Provider is not obligated to provide for Real Power Losses. The Transmission Customer is responsible for replacing losses associated with all transmission service as calculated by the Transmission Provider. Losses will be allocated based on system loading.For loss calculation purposes,capacity is allocated as determined by the IMC. Transmission Customer Responsibilities (a)Conditions Required of Transmission Customers:Point-To-Point Transmission Service shall be provided by the Transmission Provider only if the following conditions are satisfied by the Transmission Customer: Page 19 of 52 12.5. ii. ili. iv. Vi. Vii. The Transmission Customer has pending a Completed Application For Transmission Service; The Transmission Customer meets the creditworthiness criteria set forth in Rule 11.10; The Transmission Customer will have arrangements in place for any other transmission service necessary to effect the delivery from the generating source to the Transmission Provider prior to the time service under Rule 12 of these rules commences; The Transmission Customer agrees to pay for any facilities constructed and chargeable to such Transmission Customer under Rule 12 of these rules,whether or not the Transmission Customer takes service for the full term of its reservation; The Transmission Customer has executed a Service Agreement;and The Transmission Customer (and/or its energy supplier)has agreed, in writing,to be bound by operating policies,procedures;and reliability standards adopted pursuant to Section 8.6.1 of the Amended and Restated Alaska Intertie Agreement dated November 18,2011 and to operate in accordance with Exhibit H (and its corresponding reserve Reliability Standard AKRES-001)of that same agreement (pertaining to Reserve Capacity and Operating Reserve Responsibility). Transmission _Customer__Responsibility for _'Third-Party Arrangements:Any scheduling arrangements that may be required by other persons or electric systems shall be the responsibility of the Transmission Customer requesting service.The Transmission Customer shall provide,unless waived by the Transmission Provider, notification to the Transmission Provider identifying such systems and authorizing them to schedule the capacity and energy to be transmitted by the Transmission Provider pursuant to Rule 12 of these Rules on behalf of the Receiving Party at the Point of Delivery or the Delivering Party at the Point of Receipt.However,to the extent practicable,the Transmission Provider will undertake reasonable efforts to assist the Transmission Customer in making such arrangements,including without limitation,providing any information or data required by such other electric system pursuant to Good Utility Practice. Procedures for Arranging Firm Point-To-Point Transmission Service (a)Application: Page 20 of 52 (b) ii. iil. A request for Firm Point-To-Point Transmission Service for periods of one year or longer must contain a completed Application For Transmission Service to: Intertie Management Committee c/o Alaska Energy Authority 813 West Northern Lights Boulevard Anchorage,Alaska 99503 The Application For Transmission Service for firm service must be received by the Intertie Management Committee at least sixty (60) days in advance of the calendar month in which transmission service is to commence.The Transmission Provider will consider requests for such firm service on shorter notice when feasible.Requests for firm service for periods of less than one year may be subject to expedited procedures that shall be negotiated between the Parties within the time constraints provided in Rule 12.5(e).The Transmission Provider will provide a time-stamped record for establishing the priority of Applications. Requests for monthly service shall be submitted no earlier than eleven (11)months before the requested service is to commence. All Firm Point-To-Point Transmission Service requests should be submitted by entering the information on an Application For Transmission Service. Completed Application For Transmission Service: ii. iii. iv. The location of the generating facility (or facilities)supplying the capacity and energy and the location of the load ultimately served by the capacity and energy transmitted.The Transmission Provider will treat this information as confidential until after the transmission transaction has begun except to the extent that disclosure of this information is required by these rules,by regulatory or judicial order, for reliability purposes pursuant to Good Utility Practice; A description of the supply characteristics of the capacity and energy to be delivered; An estimate of the capacity and energy expected to be delivered to the Receiving Party; 'The Service Commencement Date and the term of the requested transmission service;and the transmission capacity requested for Page 21 of §2 (c) (d) each Point of Receipt and each Point of Delivery on the Transmission Provider's Transmission System;customers may combine their requests for service in order to satisfy the minimum transmission capacity requirement. This information set forth in Rule 12.5(b)shall be kept confidential until after the transmission transaction has begun at the request of the Transmission Customer except to the extent that disclosure of this information is required by these rules,by regulatory or judicial order,or for reliability purposes pursuant to Good Utility Practice. Deposit:A Completed Application For Transmission Service also shall include a deposit of either one month's charge for Reserved Capacity for transmission service request of one (1)year or greater,or the full charge for Reserved Capacity for transmission service requests of less than one (1) year.However,the Transmission Provider may waive the deposit requirement if the Applicant meets the creditworthiness requirements for Transmission Customers as described in Rule 11.10.If the Application is rejected by the Transmission Provider because it does not meet the conditions for service as set forth herein,or in the case of requests for service arising in connection with losing bidders in a Request For Proposals (RFP),said deposit shall be returned with interest less any reasonable costs incurred by the Transmission Provider in connection with the review of the losing bidder's Application For Transmission Service. The deposit also will be returned with interest less any reasonable costs incurred by the Transmission Provider if the Transmission Provider is unable to complete new facilities needed to provide the service.If an Application For Transmission Service is withdrawn or the Eligible Customer decides not to enter into a Service Agreement for Firm Point-To- Point Transmission Service,the deposit shall be refunded in full,with interest,less reasonable costs incurred by the Transmission Provider to the extent such costs have not already been recovered by the Transmission Provider from the Eligible Customer.If requested,the Transmission Provider will provide to the Eligible Customer a complete accounting of all costs deducted from the refunded deposit.If a Service Agreement for Firm Point-To-Point Transmission Service is executed,the deposit,with interest, will be returned to the Transmission Customer upon expiration or termination of the Service Agreement for Firm Point-To-Point Transmission Service.Applicable interest shall be computed and shall be calculated from the day the deposit check is credited to the Transmission Provider's account. Notice of Deficient Application For Transmission Service:If an Application For Transmission Service fails to meet the requirements of these rules,the Transmission Provider shall notify the entity requesting service within fifteen (15)days of receipt of the reasons for such failure. Page 22 of 52 (e) (f) (g) The Transmission Provider will attempt to remedy minor deficiencies in the Application For Transmission Service through informal communications with the Eligible Customer.If such efforts are undertaken and are unsuccessful,the Transmission Provider shall return the Application For Transmission Service,along with any deposit,with interest.Upon receipt of a new or revised Application For Transmission Service that fully complies with the requirements of Rule 12 of the rules, the Eligible Customer shall be assigned a priority consistent with the date of the new,refiled,or revised Application For Transmission Service. Response_to a Completed Application For Transmission Service: Following receipt of a Completed Application For Transmission Service, the Transmission Provider shall make a determination of available transmission capability as required in Rule 12.7.The Transmission Provider shall notify the Eligible Customer as soon as practicable,but not later than thirty (30)days after the date of receipt of a Completed Application either (i)if it will be able to provide service without performing a System Impact Study or (ii)if such a study is needed to evaluate the impact of the Application pursuant to Rule 12.7.Responses by the Transmission Provider shall be made as soon as practicable to all completed applications,and the timing of such responses shall be made on a nondiscriminatory basis. Execution of Service Agreement:Whenever the Transmission Provider determines that a System Impact Study is not required and that the service can be provided,it shall notify the Eligible Customer as soon as practicable but no later than thirty (30)days after receipt of the Completed Application For Transmission Service.Where a System Impact Study is required,the provisions of Rule 12.7(a)will govern the execution of a Service Agreement.Failure of an Eligible Customer to execute and return the Service Agreement within fifteen (15)days after it is tendered by the Transmission Provider may be deemed a withdrawal and termination of the Application For Transmission Service and any deposit submitted shall be refunded with interest.Nothing herein limits the right of an Eligible Customer to file another Application after its Application For Transmission Service is deemed withdrawn or terminated under this Rule. Extensions for Commencement of Service:The Transmission Customer can obtain up to a one-year extension for the commencement of service. The Transmission Customer may postpone service by paying a non- refundable annual reservation fee equal to one (1)month's charge for Firm Transmission Service for each month of the requested extension within fifteen (15)days of notifying the Transmission Provider of its interest to extend commencement of service.If during any extension for the commencement of service an Eligible Customer submits a Completed Application For Transmission Service,and such request can be satisfied Page 23 of 52 only by releasing all or part of the Transmission Customer's Reserved Capacity,the original Reserved Capacity will be released unless within thirty (30)days,the original Transmission Customer agrees to pay the Firm Point-To-Point transmission rate for its Reserved Capacity concurrent with the new Service Commencement Date.In the event the Transmission Customer elects to release the Reserved Capacity,the reservation fees or portions thereof previously paid will be forfeited. 12.6 Procedures for Arranging Non-Firm Point-To-Point Transmission Service (a)Application:Eligible Customers seeking Non-Firm Point-To-Point (b) Transmission Service must submit a completed Application For Transmission Service to the Transmission Provider. Completed Application For Transmission Service:A Completed Application For Transmission Service shal]provide all of the information included in the Application For Transmission Service form,including,but not limited to,the following: i.The identity,address,telephone number,email address,and facsimile number of the entity requesting service; ii.A statement that the entity requesting service is,or will be upon commencement of service,an Eligible Customer under these rules; iii.The location of the Point(s)of Receipt and Point(s)of Delivery and the identities of the Delivering Parties and the Receiving Parties; iv.The maximum amount of capacity requested at each Point of Receipt and Point of Delivery;and v.The proposed dates and hours for initiating and terminating transmission service hereunder. vi."Request Valid Until Date and Time.This date and time is the latest date and time that the Transmission Customer is willing to receive service and in no case shall be later than one-hour before the scheduled transaction.Transmission Provider will attempt to schedule service up to this point in time the event of short lead time Postbacks or Counterflows. In addition to the information specified above,when required to properly evaluate system conditions,the Transmission Provider also may ask the Transmission Customer to provide the following: vii.The electrical location of the initial source of the power to be Page 24 of 52 (c) (d) transmitted pursuant to the Transmission Customer's request for service;and vill.The electrical location of the ultimate load. ix.Modeling information as required by the applicable Railbelt Interconnection Standards. This information set forth in Rules 12.6(b)(6)and 12.6(b)(7)shall be kept confidential at the request of the Transmission Customer until after the transmission transaction has begun except to the extent that disclosure of this information is required by these rules,by regulatory or judicial order, or for reliability purposes pursuant to Good Utility Practice. Reservation of Non-Firm Point-To-Point Transmission Service:Requests © for monthly service shall be submitted no earlier than sixty (60)days before service is to commence,requests for weekly service shall be submitted no earlier than fourteen (14)days before service is to commence, requests for daily service shall be submitted no earlier than three (3)days before service is to commence,and requests for hourly service shall be submitted no earlier than two (2)days before service is to commence. Requests for service received later than 2:00 p.m.prior to the day service is scheduled to commence will be accommodated if practicable. Determination of Available Transfer Capability:Following receipt of a tendered schedule the Transmission Provider will make a determination on a non-discriminatory basis of available transfer capability pursuant to Rule 11.2.Such determination shall be made as soon as reasonably practicable after receipt.The Transmission Providers will revisit the determination up to the earlier of the "Request Valid until Date and Time”or one-hour before the scheduled transaction.The Transmission Provider will attempt to schedule service up to this point in time in the event of short lead time Postbacks or Counterflows. 12.7 Additional Study Procedures For Firm Point-To-Point Transmission Service Requests (a)Notice of Need for System Impact Study:After receiving a request for service,the Transmission Provider shall determine on a non-discriminatory basis whether a System Impact Study is needed.A general description of the Transmission Provider's methodology for completing a System Impact Study is provided in Appendix E-5 and the applicable Railbelt Interconnection Standards.If the Transmission Provider determines that a System Impact Study is necessary to accommodate the requested service,it shall so inform the Eligible Customer,as soon as practicable.In such cases,the Transmission Provider shall within thirty (30)days of receipt of Page 25 of 52 (b) (c) a Completed Application,tender a System Impact Study Agreement pursuant to which the Eligible Customer shall agree to reimburse the Transmission Provider for performing the required System Impact Study. For a service request to remain a Completed Application For Transmission Service,the Eligible Customer shall execute the System Impact Study Agreement and return it to the Transmission Provider within fifteen (15) days.If the Eligible Customer elects not to execute the System Impact Study Agreement,its application shall be deemed withdrawn and its deposit shall be returned with interest. System Impact Study Agreement and Cost Reimbursement: i.Subject to the applicable Railbelt Interconnection Standard terms and conditions,the System Impact Study Agreement will clearly specify the Transmission Provider's estimate of the actual cost,including any consulting fees and a reasonable allocation of the Transmission Provider's overhead costs related to the study,and time for completion of the System Impact Study.The charge shall not exceed the actual]cost of the study.In performing the System Impact Study, the Transmission Provider shall rely,to the extent reasonably practicable,on existing transmission planning studies.The Eligible Customer will not be assessed a charge for such existing studies; however,the Eligible Customer will be responsible for all costs and charges associated with any modifications to existing planning studies that are reasonably necessary to evaluate the impact of the Eligible Customer's request for service on the Transmission System. In accordance with the applicable Railbelt Interconnection Standards, the Eligible customer will be responsible for providing field tested modeling data for assets the Eligible customer intends to install to make or cause to be made the transfers of energy and capacity under consideration. ii.If in response to multiple Eligible Customers requesting service in relation to the same competitive solicitation,a single System Impact Study is sufficient for the Transmission Provider to accommodate the requests for service,the costs of that study shall be prorated among the Eligible Customers by the amount of Reserved Capacity each Eligible Customer is requesting. System Impact Study Procedures:Upon receipt of an executed System Impact Study Agreement,the Transmission Provider will use due diligence to complete the required System Impact Study within the timeframes indicated in the applicable Railbelt Interconnection Standard.The System Impact Study shall identify any system constraints and re-dispatch options (including an estimate of the number of hours of re-dispatch that may be Page 26 of 52 (d) required to accommodate the request for transmission service,and a preliminary estimate of the cost of re-dispatch),additional Direct Assignment Facilities or System Upgrades required to provide the requested service.In the event that the Transmission Provider is unable to complete the required System Impact Study within such time period,it shall so notify the Eligible Customer and provide an estimated completion date along with an explanation of the reasons why additional time is required to complete the required studies.A copy of the completed System Impact Study and related work papers shall be made available to the Eligible Customer(s).The Transmission Provider will use the same due diligence in completing the System Impact Study for an Eligible Customer as it uses when completing studies for itself.The Transmission Provider shall notify the Eligible Customer immediately upon completion of the System Impact Study if the Transmission System will be adequate to accommodate all or part of a request for service or that no costs are likely to be incurred for new transmission facilities or upgrades.In order for a request to remain a Completed Application,within fifteen (15)days of completion of the System Impact Study,the Eligible Customer must execute a Service Agreement or the Application For Transmission Service shall be deemed terminated and withdrawn. Facilities Study Procedures:If a System Impact Study indicates that additions or upgrades to the Transmission System are needed to supply the Eligible Customer's service request,the Transmission Provider,within thirty (30)days of the completion of the System Impact Study,shall tender to the Eligible Customer a Facilities Study Agreement pursuant to which the Eligible Customer shall agree to reimburse the Transmission Provider for performing the required Facilities Study.For a service request to remain a Completed Application For Transmission Service,the Eligible Customer shall execute the Facilities Study Agreement and return it to the Transmission Provider within fifteen (15)days.If the Eligible Customer elects not to execute the Facilities Study Agreement,its Application For Transmission Service shall be deemed withdrawn and its deposit shall be returned with interest.Upon receipt of an executed Facilities Study Agreement,the Transmission Provider will use due diligence to complete the required Facilities Study within the time periods identified in the applicable Railbelt Interconnection Standard.If the Transmission Provider is unable to complete the Facilities Study in the allotted time period,the Transmission Provider shall notify the Transmission Customer and provide an estimate of the time needed to reach a final determination along with an explanation of the reasons that additional time is required to complete the study.When completed,the Facilities Study will include a good faith estimate of (i)the cost of Direct Assignment Facilities to be charged to the Transmission Customer,(ii)the Transmission Customer's appropriate share of the cost of any required Network Upgrades as determined pursuant to the provisions of Rule 12 of these Rules,and (iii)the time Page 27 of 52 (c) (f) (g) (h) required to complete such construction and initiate the requested service. The Transmission Customer shall provide the Transmission Provider with a letter of credit or other reasonable form of security acceptable to the Transmission Provider equivalent to the costs of new facilities or upgrades consistent with commercial practices as established by the Uniform Commercial Code.The Transmission Customer shall have thirty (30)days to execute a Service Agreement and provide the appropriate amount of security in a form satisfactory to Transmission Provider or the request will no longer be a Completed Application For Transmission Service and shall be deemed terminated and withdrawn. Facilities Study Modifications:Any change in design arising from inability to site or construct facilities as proposed will require development of a revised good faith estimate.New good faith estimates also will be required in the event of new statutory or regulatory requirements that are effective before the completion of construction or other circumstances beyond the reasonable control of the Transmission Provider that significantly affect the final cost of new facilities or upgrades to be charged to the Transmission Customer pursuant to the provisions of Rule 12 of these rules. Due Diligence in Completing New Facilities:The Transmission Provider shall use due diligence to add necessary facilities or upgrade its Transmission System within a reasonable time.The Transmission Provider will not upgrade its existing or planned Transmission System in order to provide the requested Firm Point-To-Point Transmission Service if doing so would impair system reliability or otherwise impair or degrade existing firm service. Partial Interim Service:If the Transmission Provider determines that it will not have adequate transfer capability to satisfy the full amount of a Completed Application For Transmission Service,the Transmission Provider nonetheless shall be obligated to offer and provide the portion of the requested Firm Point-To-Point Transmission Service that can be accommodated without addition of any facilities and through re-dispatch. However,the Transmission Provider shall not be obligated to provide the incremental amount of requested Firm Point-To-Point Transmission Service that requires the addition of facilities or upgrades to the Transmission System until such facilities or upgrades have been placed in service. Expedited Procedures for New Facilities:In lieu of the procedures set forth above,the Eligible Customer shall have the option to expedite the process by requesting the Transmission Provider to tender at one time, together with the results of required studies,an "Expedited Service Agreement"pursuant to which the Eligible Customer would agree to Page 28 of 52 compensate the Transmission Provider for all costs incurred pursuant to the terms of these rules.In order to exercise this option,the Eligible Customer shall request in writing an expedited Service Agreement covering all of the above-specified items within thirty (30)days of receiving the results of the System Impact Study identifying needed facility additions or upgrades or costs incurred in providing the requested service.While the Transmission Provider agrees to provide the Eligible Customer with its best estimate of the new facility costs and other charges that may be incurred,such estimate shall not be binding and the Eligible Customer must agree in writing to compensate the Transmission Provider for all costs incurred pursuant to the provisions of these Rules.The Eligible Customer shall execute and return such an Expedited Service Agreement within fifteen (15)days of its receipt or the Eligible Customer's request for service will cease to be a Completed Application For Transmission Service and will be deemed withdrawn and terminated. 12.8 Procedures _if The Transmission Provider is Unable to Complete New Transmission Facilities for Firm Point-To-Point Transmission Service (a) (b) Delays in Construction of New Facilities:If any event occurs that will materially affect the time for completion of new facilities,or the ability to complete them,the Transmission Provider shall as soon as practicable notify the Transmission Customer.In such circumstances,the Transmission Provider shall within thirty (30)days of notifying the Transmission Customer of such delays,convene a technical meeting with the Transmission Customer to evaluate the alternatives available to the Transmission Customer.The Transmission Provider also shall make available to the Transmission Customer studies and work papers related to the delay,including all information that is in the possession of the Transmission Provider that is reasonably needed by the Transmission Customer to evaluate any alternatives. Alternatives to the Original Facility Additions:When the review process of Rule 12.7 determines that one or more alternatives exist to the originally planned construction project,the Transmission Provider shall present such alternatives for consideration by the Transmission Customer.If,upon review of any alternatives,the Transmission Customer desires to maintain its Completed Application For Transmission Service subject to construction of the alternative facilities,it may request the Transmission provider to submit a revised Service Agreement for Firm Point-To-Point Transmission Service.If the alternative approach solely involves Non- Firm Point-To-Point Transmission Service,the Transmission Provider shall promptly tender a Service Agreement for Non-Firm Point-To-Point Transmission Service providing for the service.In the event the Transmission Provider concludes that no reasonable alternative exists and the Transmission Customer disagrees,the Transmission Customer may Page 29 of 52 (c) seek relief under the dispute resolution procedures pursuant to Rule 11.11 or it may refer the dispute to the Executive Director of the Alaska Energy Authority to pursue a negotiated resolution with the IMC. Refund Obligation for Unfinished Facility Additions:If the Transmission Provider and the Transmission Customer mutually agree that no other reasonable alternatives exist and the requested service cannot be provided out of existing capability under the conditions of Rule 12 of these Rules, the obligation to provide the requested Firm Point-To-Point Transmission Service shall terminate and any deposit made by the Transmission Customer shall be returned with interest.However,the Transmission Customer shall be responsible for all prudently incurred costs by the Transmission Provider through the time construction was suspended.The Transmission Provider may offset such costs against any deposit. 12.9 Provisions Relating to Transmission Construction and Services on the Systems of Other Utilities (a) (b) Responsibility for Third-Party System Additions:The Transmission Provider shall not be responsible for.making arrangements for any necessary engineering,permitting,and construction of transmission or distribution facilities on the system(s)of any other entity or for obtaining any regulatory approval for such facilities.The Transmission Provider will undertake reasonable efforts to assist the Transmission Customer in obtaining such arrangements,including without limitation,providing any information or data required by such other electric system pursuant to Good Utility Practice. Coordination of Third-Party System Additions:In circumstances where the need for transmission facilities or upgrades is identified pursuant to the provisions of Rule 12 of these rules,and if such upgrades further require the addition of transmission facilities on other systems,the Transmission Provider shall have the right to coordinate construction on its own system with the construction required by others.The Transmission Provider,after consultation with the Transmission Customer and representatives of such other systems,may defer construction of its new transmission facilities,if the new transmission facilities on another system cannot be completed in a timely manner.The Transmission Provider shall notify the Transmission Customer in writing of the basis for any decision to defer construction and the specific problems which must be resolved before it will initiate or resume construction of new facilities.Within sixty (60)days of receiving written notification by the Transmission Provider of its intent to defer construction pursuant to this Rule,the Transmission Customer may challenge the decision in accordance with the dispute resolution procedures pursuant to Rule 11.11,or it may refer the dispute directly to the Executive Director of the Alaska Energy Authority to pursue a negotiated resolution Page 30 of 52 12.10 with the IMC. Modification Of Point(s)of Receipt or Point(s)of Delivery (a) (b) Modifications On a Non-Firm Basis:The Transmission Customer taking Firm Point-To-Point Transmission Service may request the Transmission Provider to provide transmission service on a non-firm basis over Receipt and Delivery Points other than those specified in the Service Agreement ("Secondary Receipt and Delivery Points'),in amounts not to exceed its firm capacity reservation,without incurring an additional Non-Firm Point- To-Point Transmission Service charge or executing a new Service Agreement,subject to the following conditions. i.Service provided over Secondary Receipt and Delivery Points will be non-firm only,on an as-available basis and will not displace any firm or non-firm service reserved or scheduled by third-parties under these Rules or by the Transmission Provider on behalf of its Native Load Customers. ii.The sum of all Firm and non-firm Point-To-Point Transmission Service provided to the Transmission Customer at any time pursuant to this Rule shall not exceed the Reserved Capacity in the relevant Service Agreement under which such services are provided. iii.The Transmission Customer shall retain its right to schedule Firm Point-To-Point Transmission Service at the Receipt and Delivery Points specified in the relevant Service Agreement in the amount of its original capacity reservation. iv.Service over Secondary Receipt and Delivery Points on a non-firm basis shall not require the filing of an Application for Non-Firm Point-To-Point Transmission Service under these Rules.However, all other requirements of these rules (except as to transmission rates) shall apply to transmission service on a non-firm basis over Secondary Receipt and Delivery Points. Modifications on a Firm Basis:Any request by a Transmission Customer to modify Point(s)of Receipt and Point(s)of Delivery on a firm basis shall be treated as a new request for service in accordance with Rule 12.5 hereof, except that such Transmission Customer shall not be obligated to pay any additional deposit if the capacity reservation does not exceed the amount reserved in the existing Service Agreement.While such new request is pending,the Transmission Customer shall retain its priority for service at the existing firm Points of Receipt and Points of Delivery specified in its Service Agreement. Page 31 of 52 12.11 Sale or Assignment of Transmission Service (a) (b) Procedures for Assignment_or Transfer of Service:A Transmission Customer may sell,assign,or transfer all or a portion of its rights under its Service Agreement,but only to another Eligible Customer (the Assignee). The Transmission Customer that sells,assigns,or transfers its rights under its Service Agreement is hereafter referred to as the Reseller. Compensation to the Reseller shall not exceed the higher of (i)the original rate paid by the Reseller,(ii)the Transmission Provider's maximum rate as determined by the IMC,or (iii)the Reseller's opportunity cost capped at the Transmission Provider's cost of expansion.The Assignee must execute a service agreement with the Transmission Provider governing reassignments of transmission service prior to the date on which the reassigned service commences.If the Assignee does not request any change in the Point(s)of Receipt or the Point(s)of Delivery,or a change in any other term or condition set forth in the original Service Agreement,the Assignee will receive the same services as did the Reseller and the priority of service for the Assignee will be the same as that of the Reseller.A Reseller shall notify the Transmission Provider as soon as possible after any assignment or transfer of service occurs but in any event,notification must be provided prior to any provision of service to the Assignee.The Assignee will be subject to all terms and conditions of these rules.If the Assignee requests a change in service,the reservation priority of service will be determined by the Transmission Provider pursuant to Rule 12.1. Limitations _on_Assignment_or Transfer_of Service:If the Assignee requests a change in the Point(s)of Receipt or Point(s)of Delivery,or a change in any other specifications set forth in the original Service Agreement,the Transmission Provider will consent to such change subject to the provisions of these Rules,provided that the change will not impair the operation and reliability of the Transmission Provider's generation, transmission,or distribution systems.The Assignee shall compensate the Transmission Provider for performing any System Impact Study needed to evaluate the capability of the Transmission System to accommodate the proposed change and any additional costs resulting from such change.The Reseller shall remain liable for the performance of all obligations under the Service Agreement,except as specifically agreed to by the Parties through an amendment to the Service Agreement agreed to by the Transmission Provider. 12.12 Metering and Power Factor Correction at Receipt and Delivery Point(s) (a)Transmission Customer Obligations:|Unless otherwise agreed,the Transmission Provider shall be responsible for installing and maintaining metering and communications equipment to accurately account for the capacity and energy being transmitted under Rule 12 of these rules.Such Page 32 of 52 12.13 12.14 equipment shall remain the property of the Transmission Provider. (b)Meter Location:The Transmission Provider's meter(s)shall be located at each interconnection point (points of receipt and delivery)of energy and demand on the Transmission System. (c)Power Factor:Unless otherwise agreed,the Transmission Customer is required to maintain a power factor within the same range as the Transmission Provider pursuant to Good Utility Practices.The power factor requirements are specified in the Service Agreement where applicable. Compensation for Transmission Service Rates for Firm and Non-Firm Point-To-Point Transmission Service are provided in the Schedules included in these rules.See Firm Point-To-Point Transmission Service (Schedule T-7)and Non-Firm Point-To-Point Transmission Service (Schedule T-8).The Transmission Provider shall use Rule 12 of these rules to govern its Third-Party Sales where applicable.The Transmission Provider shall account for such use at the applicable rates. Compensation for New Facilities and Re-dispatch Costs Whenever a System Impact Study performed by the Transmission Provider in connection with the provision of Firm Point-To-Point Transmission Service identifies the need for new facilities,the Transmission Customer shall be responsible for all such costs.Whenever a System Impact Study performed by the Transmission Provider identifies capacity constraints that may be relieved more economically by re-dispatching the Transmission Provider's resources than by building new facilities or upgrading existing facilities to eliminate such constraints,the Transmission Customer shall be responsible for the re-dispatch costs. 13.POSTBACKS &COUNTERFLOWS 13.1 Postbacks and Counterflows allow for maximum usage of intertie assets.Both increase the result of the Available Transfer Capability (ATC)calculation in the Rated Path Availability Methodology of ATC calculation. Postbacks (a)Postbacks are the committed return of transmission capacity by a transmission capacity holder for a specified period of time.These commitments may be recallable or non-recallable commitments to make capacity available.Recallable commitments result in the availability of Page 33 of 52 Non-Firm Point-to-Point capacity and Non-recallable commitments result in the availability of Firm Point-to-point capacity for the time specified in the Postback. (b)Subject to and in accordance with Good Utility Practice,capacity holders (whether Legacy Utility Participants or Users who have acquired capacity through facility construction)are required to postback unused capacity as soon as it is reasonably certain to be available and no later than 2:00p of the day preceding the day the capacity will be available. (c)Postbacks may be made as recallable and converted to non-recallable as availability becomes more certain. 13.2 Counterflows (a)Counterflows are scheduled power flows in opposition to the predominant flow of power on the intertie,which result in an increase in ATC.Due to the nature of the Counterflows,capacity made available by Counterflows can only result in the availability of Non-Firm Capacity Point-to-Point capacity. Page 34 of §2 RATE SCHEDULE T-1 Scheduling,System Control and Dispatch Service This service is required to schedule the movement of power through a Transmission Provider's Transmission System.The charges for Scheduling,System Control and Dispatch Service are to be based on the rates set forth below: Scheduling,System Control, and Dispatch Service Rate $xxxxper hour of Reserved Capacity in kW OR $xxxxx per day of Reserved Capacity in kW OR $xxxxxx per week of Reserved Capacity in kW OR $xxxxxx per month of Reserved Capacity in kW OR $xxxxxx per year of Reserved Capacity in kW Page 35 of 52 RATE SCHEDULE T-2 Reactive Supply and Voltage Control from Generation and VAR Sources Service In order to maintain transmission voltages on the Transmission Provider's transmission facilities within the limits identified in the applicable Railbelt Reliability Standards,generation facilities and Static VAR Compensators use (or absorb)reactive power.Thus,Reactive Supply and Voltage Control from Generation and VAR Sources Service must be provided for each transaction on the Transmission Provider's transmission facilities.The amount of Reactive Supply and Voltage Control from Generation Sources Service that must be supplied with respect to the Transmission Customer's transaction will be determined based on the reactive power support necessary to maintain transmission voltages within limits that are generally accepted in the region and consistently adhered to by the Transmission Provider. The charges for such service will be based on the rates set forth below: $xxxx per hour of ReservedReactiveSupplyand=Capacity inkWVoltageControl]Rate OR $xxxxx per day of Reserved Capacity in kW OR $xxxxx per week of Reserved Capacity in kW OR $xxxxx per month of Reserved Capacity in kW OR $xxxxx per year of Reserved Capacity in kW Page 36 of 52 RATE SCHEDULE T-3 Regulation and Frequency Response Service Regulation and Frequency Response Service is necessary to provide for the continuous balancing of resources (generation and interchange)with load and for maintaining scheduled Interconnection frequency at sixty cycles per second (60 Hz).Regulation and Frequency Response Service is accomplished by committing on-line generation whose output is raised or lowered (predominantly through the use of automatic generating control equipment)as necessary to follow the moment-by-moment changes in load.The obligation to maintain the balance between resources and load within the Standards set out in the Applicable Railbelt Reliability Standards lies with the Load Balancing Authority (LBA).The Transmission Provider is required to provide these services to the LBA in an amount sufficient to cover the transfers scheduled by the Transmission Provider and not otherwise accounted for by the LBA.The amount of and charges for Regulation and Frequency Response Service are set forth below. Regulation and Frequency Response Service: $XXXXX per hour of Reserved Capacity in kW or $XXXXX per day of Reserved Capacity in kW or $XXXXX per week of Reserved Capacity in kW or $XXXXX per month of Reserved Capacity in kW or $XXXXX per year of Reserved Capacity in kW. Page 37 of 52 RATE SCHEDULE T-4 Energy Imbalance Service Energy Imbalance Service is provided when a difference occurs between the scheduled and the actual delivery of energy through the Transmission Provider's Transmission System over a single hour. The Transmission Provider shall establish a deviation band of +/-1.5 percent (with a minimum of 1 MW)of the scheduled transaction to be applied hourly to any energy imbalance that occurs as a result of the Transmission Customer's scheduled transaction(s).Parties will attempt to eliminate energy imbalances within the limits of the deviation band within next appropriate (on - peak or off peak)inadvertent payback period scheduled by the receiving area controller off the Transmission Provider.If an energy imbalance is not corrected within thirty (30)days or a reasonable period of time that is generally accepted by the Transmission Provider,the Transmission Customer will compensate the Transmission Provider for such service at the rate set forth below for energy imbalances outside the deviation band.Energy imbalances outside the deviation band will be subject to charges to be specified by the Transmission Provider.The charges for Energy Imbalance Service are set forth below. 1.For an energy imbalance within the deviation band there is no charge for Energy Imbalance Service;however,hourly energy associated with imbalances (positive or negative)shall be zeroed out,in like time periods,at the earliest practicable time.The time to zero out such energy shall not exceed thirty (30)days.The customer may elect to financially settle hourly energy imbalances within the deviation band,as follows:(i)hourly negative energy imbalances within the deviation band will be settled at 100 percent of the Transmission Provider's average cost of power for the hour in which the deviation occurred,plus 2 mills/kWh;and (11)hourly positive energy imbalances within the deviation band will be settled at 100 percent of the Transmission Provider's average cost for the hour in which the deviation occurred,minus 2 mills/kWh.The customer may elect this option on a monthly basis,by providing at least ten (10)days'written notice to the Transmission Provider prior to the start of the month. 2.For an energy imbalance,for any hour of the day,outside the deviation band the charge for the Energy Imbalance Service shall be: (a)The Transmission Customer shall pay the Transmission Provider the higher of 100 mills per kilowatt-hour or 110 percent of the Transmission Provider's incremental costs for that hour for a negative deviation energy imbalance.The Transmission Provider's incremental cost for these hourly negative Energy Imbalances will be 100 percent of the generation cost with the highest incremental cost of power at the time of imbalance for the hour in which the deviation occurred,plus 2 mills/k Wh. (b)The Transmission Provider shall pay the Transmission Customer 90 Page 38 of 52 percent of the Transmission Provider's decremental costs for that hour for a positive deviation energy imbalance.The Transmission Provider's decremental cost for these hourly positive Energy Imbalances will be 100 percent of the average cost of power for the hour in which the deviation occurred,minus 2 mills/kWh. In the event an hourly rate is not available or ceases publication,a suitable replacement index will be used for pricing the incremental/decremental costs of in-band and out-of-band imbalance energy. Notwithstanding the above provisions,the transmission provider,in its sole discretion,may waive the requirements of this Rate Schedule T-4 and accept payment in kind on a MW per MW basis. Page 39 of52 RATE SCHEDULE T-5 Operating Reserve -Spinning Reserve Service Spinning Reserve Service is needed to serve load immediately in the event of a system contingency.Spinning Reserve Service may be provided by generating units that are on-line and loaded at less than maximum output or by an IMC approved Shed in Lieu of Spin system acting on the transmission customers load.The amount of and charges for Spinning Reserve Service provided by a generating unit will be 110%of the difference of the average cost of the unit providing the spin at its merit EDC control point,less the average cost of the Unit at its dispatch point. Page 40 of 52 RATE SCHEDULE T-6 Operating Reserve -Supplemental Reserve Service Supplemental Reserve Service is needed to serve load in the event of a system contingency; however,it is not available immediately to serve load but rather within a short period of time. Supplemental Reserve Service may be provided by generating units that are on-line but unloaded,by quick-start generation or by interruptible load.Compensation shall be at the rate charged the Transmission Provider plus 10%. Page 41 of 52 RATE SCHEDULE T-7 Long-Term Firm and Short-Term Firm Point-To-Point Transmission Service The Transmission Customer shall compensate the Transmission Provider each month for Reserved Capacity and energy usage at the rate calculated by the Intertie Management Committee -Operating Committee (IMC-OC)as defined in Section 7 of the Amended and Restated Alaska Intertie Agreement (as amended to incorporate these rules). These rates are calculated annually based on projected usage of the line and upon allocated capacity;with 83.5%of anticipated annual costs being covered by energy charges and 16.5% being covered by capacity charges.A true up to reflect actual usage of the line and actual costs incurred (or committed)at the fiscal year's end (June 30).Legacy participants and other Transmission Customers are either credited or billed accordingly in order to zero annual carryover. The Transmission Customer shall pay the average of the capacity charges on a per Mwh basis capacity reserved basis,and the calculated energy component for Kwh delivered. The rates and rules governing charges and discounts stated above shall not apply to re-sales of transmission service,compensation for which shall be governed by Rule 12.11(a)of these rules. Page 42 of 52 RATE SCHEDULE T-8 Non-Firm Point-To-Point Transmission Service The Alaska Intertie is operated as a cost-based asset.Therefore,the Transmission Customer shall compensate the Transmission Provider for Non-Firm Point-To-Point Transmission Service at a rate equal to the Firm Service rate (Rate Schedule T-7). Page 43 of 52 E-I:Sample Service Agreement For Alaska Intertie Firm Point-To-Point Transmission Service 1. 7. This Service Agreement,dated as of,is entered into by and between Intertie Management Committee,(the Transmission Provider), and ("Transmission Customer”). The Transmission Customer has been determined by the Transmission Provider to have a Completed Application For Transmission Service for firm service under these rules. The Transmission Customer has provided to the Transmission Provider an Application deposit in accordance with the provisions of Rule 12.5(c)of these tules. Service under this agreement shall commence on the later of (I)the requested service commencement date,or (2)the date on which construction of any Direct Assignment Facilities and/or System Upgrades are completed,or (3)such other date as it is permitted to become effective by the Commission.Service under this agreement shall terminate on such date as mutually agreed upon by the parties. The Transmission Provider agrees to provide and the Transmission Customer agrees to take and pay for Firm Point-To-Point Transmission Service in accordance with the provisions of these rules and this Service Agreement. Any notice or request made to or by either Party regarding this Service Agreement shall be made to the representative of the other Party as indicated below: Transmission Provider: Intertie Management Committee. c/o Alaska Energy Authority Attn:IMC Chairman 813 Northern Lights Blvd Anchorage,Alaska 99503 Transmission Customer: These rules are incorporated herein and made a part hereof. Page 44 of 52 IN WITNESS WHEREOF,the Parties have caused this Service Agreement to be executed by their respective authorized officials. Transmission Provider: By: Name Title Date Transmission Customer: By: Name Title Date Page 45 of 52 E-2:Sample Attachment To Service Agreement For Firm Point-To-Point Transmission Service Specifications For Firm Point-To-Point Transmission Service 1.Term of Transaction: 2.Start Date: 3.Termination Date: 4.Description of capacity and energy to be transmitted by Transmission Provider:___ 5.Point(s)of Receipt: 6.Delivering Party: 7.Point(s)of Delivery: 8.Receiving Party: 9.Maximum amount of capacity and energy to be transmitted (Reserved Capacity): 10.Designation of party(ies)subject to reciprocal service obligation: 11.Name(s)of any other Systems providing transmission service: 12.Service under this Agreement may be subject to some combination of the charges detailed below.(The appropriate charges for individual transactions will be determined in accordance with the terms and conditions of these Rules.) 13.Transmission Charge: 14.System Impact and/or Facilities Study Charge(s): 15.Direct Assignment Facilities Charge: 16.Ancillary Services Charges: Page 46 of 52 17.Latest date and time request is valid for: Page 47 of 52 E-3:Sample Service Agreement For Non-Firm Point-To-Point Transmission Service 1.This Service Agreement,dated as of,is entered into by and between the Intertie Management Committee (the Transmission Provider),and © ("Transmission Customer"). The Transmission Customer has been determined by the Transmission Provider to be a Transmission Customer under Rule 12 of these Rules and has filed a Completed Application For Transmission Service for non-firm service in accordance with these Rules. Service under this Agreement shall be provided by the Transmission Provider upon request by an authorized representative of the Transmission Customer. The Transmission Customer agrees to supply information the Transmission Provider deems reasonably necessary in accordance with Good Utility Practice in order for it to provide the requested service. The Transmission Provider agrees to provide and the Transmission Customer agrees to take and pay for Non-Firm Point-To-Point Transmission Service in accordance with the provisions of Rule 12 of these Rules and this Service Agreement. Any notice or request made to or by either Party regarding this Service Agreement shall be made to the representative of the other Party as indicated below: Transmission Provider: Intertie Management Committee. c/o Alaska Energy Authority Attn:IMC Chairman 813 Northern Lights Blvd Anchorage,Alaska 99503 Transmission Customer: These Rules are incorporated herein and made a part hereof. Page 48 of 52 IN WITNESS WHEREOPF,the Parties have caused this Service Agreement to be executed by their respective authorized officials. Transmission Provider: By: Name Title Transmission Customer: By: Date Name Title Date Page 49 of 52 Available Transfer Capability Implementation Document The Transmission Provider will routinely review and assess the Available Transfer Capability (ATC)of the Intertie using the "Rated System Path Methodology”. ATC is a measure of the transfer capability remaining in the physical transmission network for further commercial activity over and above already committed uses.It is defined as Total Transfer Capability less Existing Transmission Commitments (including retail customer service),less a Capacity Benefit Margin,less a Transmission Reliability Margin,plus Post-backs,plus Counter-flows as applicable. The Total Transfer Limit (TTC)is the amount of electric power that can be moved or transferred reliably from one area to another area of the interconnected transmission systems by way of Alaska Intertie under specified system conditions. In the case of the Alaska Intertie this currently the stability limit of the line as determined by system studies. The Capacity Benefit Margin (CBM)is the amount of firm transmission transfer capability preserved by the transmission provider for Load-Serving Entities (LSEs),whose loads are located on that Transmission Service Provider's system, to enable access by the LSEs to generation from interconnected systems to meet generation reliability requirements.Preservation of CBM for an LSE allows that entity to reduce its installed generating capacity below that which may otherwise have been necessary without interconnections to meet its generation reliability requirements.The transmission transfer capability preserved as CBM is intended to be used by the LSE only in times of emergency generation deficiencies.In the case of the Alaska Intertie the CBM provides the ability to transfer operating (spinning)and non-operating reserves (Supplemental)(as defined in Exhibit H of the amended and restated Alaska Intertie Agreement)either to the Fairbanks area or to the southern systems in the event of a disturbance. Transmission Reliability Margin (TRM)is the amount of transmission transfer capability necessary to provide reasonable assurance that the interconnected transmission network will be secure.TRM accounts for the inherent uncertainty in system conditions and the need for operating flexibility to ensure reliable system operation as system conditions change.The TRM takes into account errors in load forecast,errors in temperature prediction that effect unit capacity and other variation between the day ahead operating plan and actual operations. Existing Firm Transmission Commitments (ETC)are committed uses of a Transmission Service Provider's Transmission system considered when .determining ATC or AFC.These can include pre-existing (pre-OATT) transmission firm or non-firm transmission capacity rights,pre-existing,capacity benefit margin rights,or other commitments to use of a transmission system. Page 50 of 52 e Postbacks are a variable component of the Transmission Provider's selected ATC or AFC calculation methodology that positively impacts ATC or AFC based on a change in status of a transmission service reservation or use of reserved capacity, or other conditions as specified by the Transmission Provider!. e Counterflows are scheduled or actual power flows in the opposite direction to the predominant flow scheduled or actual power which has a positive effect on ATC. The ATC will be determined by the following formula: ATC =(Total Transfer Capability-Capacity Benefit Margin-Transfer Reliability Margin- Existing Transfer Commitments +Postbacks +Counterflows). 1 Based on NAESB Business Practice Standards Version 002.1 Dated March 11,2009 and IMC AK MOD Standard AKMOD-001-01 Available Transmission System Capability Page 51 of 52 E-5:Methodology for Completing a System Impact Study The Transmission Provider will complete a System Impact Study to assess the service requested consistent with Good Utility Practice and as described in the Railbelt Standards for Transmission,Generation and End User Interconnection.Computer models of the system may be used to simulate the behavior of the system under normal and outage conditions.Simulate Production costing and as described in the interconnection standards, the studies will consider different plausible scenarios and operating conditions in accordance with Railbelt Reliability Standards.The kinds of system problems identified will include equipment overloads,voltage concerns,and stability issues. Page 52 of 52 Standard AKMOD-001-01 -Available Transmission System A.Introduction 1. 2. 3. 5. Title:Available Transmission System Capability Number:AKMOD-001-01 Purpose:To ensure that once performing under Open Access conditions, Providers maintain awareness of available transmission system capability and future flows on their own systems as well as those of their neighbors.The determinations and calculations and penalties below are only applicable to paths under Open Access rules and actually in use as Open Access transfer paths (whether contract path or parallel flow path)i.e.Open Access transfers are scheduled. Applicability: 4.1.Transmission Service Provider. 4.2.Transmission Operator. Proposed Effective Date:TBD B.Requirements RI.Each Transmission Operator shall select one of the methodologies listed below for calculating Available Transfer Capability (ATC)or Available Flowgate Capability (AFC)for each ATC Path per time period identified in R2 for those Facilities within its Transmission operating area that under Open access rules are in use for open access transfers: «The Area Interchange Methodology,as described in MOD-028 «The Rated System Path Methodology,as described in MOD-029 s The Flowgate Methodology,as described in MOD-030 Once a path has been established and is actively in use (schedules and flows are occurring)for open access transfers,each Transmission Service Provider shall calculate ATC or AFC values as listed below using the methodology or methodologies selected by its Transmission Operator(s).No ATC/AFC calculations are required until the path is in use by an eligible entity: R2.1.Hourly values for at least the next 48 hours. R2.2.Daily values for at least the next 31 calendar days. R2.3..Monthly values for at least the next 12 months (months 2-13). 1 All ATC Paths do not have to use the same methodology and no particular ATC Path must use the same methodology for all time periods. Standard AKMOD-001-01 -Available Transmission System R3.Subject to R2,Each Transmission Service Provider shall prepare and keep current an Available Transfer Capability Implementation Document (ATCID)that includes,at a minimum,the following information: R3.1.Information describing how the selected methodology (or methodologies)has been implemented,in such detail that,given the same information used by the Transmission Service Provider,the results of the ATC or AFC calculations can be validated. R3.2._A description of the manner in which the Transmission Service Provider will account for Counterflows including: R3.2.1._How confirmed Transmission reservations,expected Interchange and internal Counterflows are addressed in firm and non-firm ATC or AFC calculations. R3.2.2.A rationale for that accounting specified in R3.2. R3.3.The identity of the Transmission Operators and Transmission Service Providers from which the Transmission Service Provider receives data for use in calculating ATC or AFC. R3.4.The identity of the Transmission Service Providers and Transmission Operators to which it provides data for use in calculating transfer or Flowgate capability. R3.5.A description of the allocation processes listed below that are applicable to the Transmission Service Provider: ¢Processes used to allocate transfer or Flowgate capability among multiple lines or sub-paths within a larger ATC Path or Flowgate. ¢Processes used to allocate transfer or Flowgate capabilities among multiple owners or users of an ATC Path or Flowgate. ¢Processes used to allocate transfer or Flowgate capabilities between Transmission Service Providers to address issues such as forward looking congestion management and seams coordination. R3.6.A description of how generation and transmission outages are considered in transfer or Flowgate capability calculations,including: R3.6.1.The criteria used to determine when an outage that is in effect for part of a day impacts a daily calculation. R3.6.2.The criteria used to determine when an outage that is in effect part of a month impacts a monthly calculation. R3.6.3.How outages from other Transmission Service Providers that cannot be mapped to the Transmission model used to calculate transfer or Flowgate capability are addressed. R4.The Transmission Service Provider shall notify the following entities before implementing a new or revised ATCID R4.1..Each Planning Coordinator associated with the Transmission Service Provider's area. R4.2._Each Reliability Coordinator associated with the Transmission Service Standard AKMOD-001-01 -Available Transmission System RS. R6. R7. R8. R9. Provider's area. R4.3._Each Transmission Operator associated with the Transmission Service Provider's area. R4.4.Each Planning Coordinator adjacent to the Transmission Service Provider's area. R4.5.Each Reliability Coordinator adjacent to the Transmission Service Provider's area. R4.6.Each Transmission Service Provider whose area is adjacent to the Transmission Service Provider's area. The Transmission Service Provider shall make available the current ATCID to all of the entities specified in R4. When calculating Total Transfer Capability (TTC)or Total Flowgate Capability (TFC)the Transmission Operator shall use assumptions no more limiting than those used in the planning of operations for the corresponding time period studied, providing such planning of operations has been performed for that time period. When calculating ATC or AFC the Transmission Service Provider shall use assumptions no more limiting than those used in the planning of operations for the corresponding time period studied,providing such planning of operations has been performed for that time period. Each Transmission Service Provider that calculates ATC shall recalculate ATC,at a minimum,on the following frequency,unless none of the calculated values identified in the ATC equation have changed: R8.1._Hourly values,once per hour.Transmission Service Providers are allowed up to 175 hours per calendar year during which calculations are not required to be performed,despite a change in a calculated value identified in the ATC equation. R8.2._Daily values,once per day. R8.3.Monthly values,once per week. Within thirty calendar days of receiving a request by any Transmission Service Provider,Planning Coordinator,Reliability Coordinator,or Transmission Operator for data from the list below solely for use in the requestor's ATC or AFC calculations,each Transmission Service Provider receiving said request shall begin to make the requested data available to the requestor,subject to the conditions specified in R9.1 and R9.2:[Violation Risk Factor:Lower][Time Note that the NorthHorizon:Operations Planning]American Energy . '*es Standards Board (NAESB)Expected generation and Transmission outages,is developing theadditions,and retirements.companion standards that address the posting of ATC information,including ¢Unit commitments and order of dispatch,to include all supporting information -designated network resources and other resources that are even as that described incommittedorhavethelegalobligationtorun,as they are:, ¢Load forecasts. Standard AKMOD-001-01 -Available Transmission System expected to run,in one of the following formats chosen by the data provider -Dispatch Order -Participation Factors -Block Dispatch ¢Aggregated firm capacity set-aside for Network Integration Transmission Service and aggregated non-firm capacity set aside for Network Integration Transmission Service (i.e.Secondary Service). ¢Firm and non-firm Transmission reservations. ¢Aggregated capacity set-aside for Grandfathered obligations ¢Firm roll-over rights. ¢Any firm and non-firm adjustments applied by the Transmission Service Provider to reflect parallel path impacts. ¢Power flow models and underlying assumptions. ¢Contingencies,provided in one or more of the following formats: -A list of Elements -A list of Flowgates -A set of selection criteria that can be applied to the Transmission model used by the Transmission Operator and/or Transmission Service Provider ¢Facility Ratings. e Any other services that impact Existing Transmission Commitments (ETCs). ¢Values of Capacity Benefit Margin (CBM)and Transmission Reliability Margin (TRM)for all ATC Paths or Flowgates. ¢Values of Total Flowgate Capability (TFC)and AFC for any Flowgates considered by the Transmission Service Provider receiving the request when selling Transmission service. ¢Values of TTC and ATC for all ATC Paths for those Transmission Service Providers receiving the request that do not consider Flowgates when selling Transmission Service. *Source and sink identification and mapping to the model. R9.1..The Transmission Service Provider shall make its own current data available, in the format maintained by the Transmission Service Provider,for up to 13 months into the future (subject to confidentiality and security requirements). R9.1.1.If the Transmission Service Provider uses the data requested in its transfer or Flowgate capability calculations,it shall make the data used available Standard AKMOD-001-01 -Available Transmission System R9.1.2.If the Transmission Service Provider does not use the data requested in its transfer or Flowgate capability calculations,but maintains that data,it shall make that data available R9.1.3.Ifthe Transmission Service Provider does not use the data requested in its transfer or Flowgate capability calculations,and does not maintain that data,it shall not be required to make that data available R9.2.__This data shall be made available by the Transmission Provider on the schedule specified by the requestor (but no more frequently than once per hour,unless mutually agreed to by the requester and the provider). C.Measures M1.The Transmission Operator shall provide evidence (such as a calculation,inclusion of the information in the ATCID,or other written documentation)that it has selected one of the specified methodologies per time period in R2 for use in determining Transfer Capabilities of those Facilities for each ATC Path within the Transmission Operator's operating area.(R1). M2.The Transmission Service Provider shall provide ATC or AFC values and identification of the selected methodologies along with other evidence (such as written documentation,processes,or data)to show it calculated ATC or AFC for the following using the selected methodology or methodologies chosen as part of R1 (R2): -There has been at least 48 hours of hourly values calculated at all times.(R2.1) -There has been at least 31 consecutive calendar days of daily values calculated at all times.(R2.2) -There has been at least the next 12 months of monthly values calculated at all times (Months 2-13).(R2.3) M3.The Transmission Service Provider shall provide its current ATCID that contains all the information specified in R3.(R3) M4.The Transmission Service Provider shall provide evidence (such as dated electronic mail messages,mail receipts,or voice recordings)that it has notified the entities specified in R4 before a new or revised ATCID was implemented.(R4) M5.The Transmission Service Provider shall provide evidence (such as a demonstration) that the current ATCID is available to all of the entities specified in R4,as required by RS.(R5) M6.The Transmission Operator shall provide a copy of the assumptions (such as contingencies,loop flow,generation re-dispatch,switching operating guides or data sources for load forecast and facility outages)used to calculate TTC or TFC as well as other evidence (such as copies of operations planning studies,models,supporting information,or data)to show that the assumptions used in determining TTC or TFC are no more limiting than those used in planning of operations for the corresponding time period studied.Alternatively the Transmission Operator may demonstrate that the same load flow cases are used for both TTC or TFC and Operations Planning. Standard AKMOD-001-01 -Available Transmission System M7. M8. M9. When different inputs to the calculations are used because the calculations are performed at different times,such that the most recent information is used in any calculation,a difference in that input data shall not be considered to be a difference in assumptions.(R6) The Transmission Service Provider shall provide a copy of the assumptions (such as contingencies,loop flow,generation re-dispatch,switching operating guides or data sources for load forecast and facility outages)used to calculate ATC or AFC as well as other evidence (such as copies of operations planning studies,models,supporting information,or data)to show that the assumptions used in determining ATC or AFC are no more limiting than those used in planning of operations for the corresponding time period studied.Alternatively the Transmission Service Provider may demonstrate that the same load flow cases are used for both AFC and Operations Planning.When different inputs to the calculations are used because the calculations are performed at different times,such that the most recent information is used in any calculation,a difference in that input data shall not be considered to be a difference in assumptions.(R7) The Transmission Service Provider calculating ATC shall provide evidence (such as logs or data)that it has calculated the hourly,daily,and monthly values on at least the minimum frequencies specified in R8 or provide evidence (such as data, procedures,or software documentation)that the calculated values identified in the ATC equation have not changed.(R8) The Transmission Service Provider shall provide a copy of the dated request,if any, for ATC or AFC data as well as evidence to show it responded to that request (such as logs or data)within thirty calendar days of receiving the request,and the requested data items were made available in accordance with R9.(R9) D.Compliance 1.Compliance Monitoring Process 1.1.Compliance Enforcement Authority IMC -Regional Reliability Entity unless the IMC is the relevant transmission provider,then the Alaska Energy Authority. 1.2.Compliance Monitoring Period and Reset Time Frame Not applicable. 1.3.Data Retention The Transmission Operator and Transmission Service Provider shall keep data or evidence to show compliance as identified below unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation: -The Transmission Operator shall maintain its current selected method(s)for calculating ATC or AFC and any methods in force since last compliance audit period to show compliance with R1. Standard AKMOD-001-01 -Available Transmission System 1.4. 1.5. -The Transmission Service Provider shall maintain evidence to show compliance with R2,R4,R6,R7,and R8 for the most recent calendar year plus the current year. -The Transmission Service Provider shall maintain its current,in force ATCID and any prior versions of the ATCID that were in force since the last compliance audit to show compliance with R3. -The Transmission Service Provider shall maintain evidence to show compliance with R5 for the most recent three calendar years plus the current year. -The Transmission Operator shall maintain evidence to show compliance with R6 for the most recent calendar year plus the current year. -Ifa Transmission Service Provider or Transmission Operator is found non- compliant,it shall keep information related to the non-compliance until found compliant. The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records. Compliance Monitoring and Enforcement Processes: The following processes may be used: -Compliance Audits -Self-Certifications -Spot Checking -Compliance Violation Investigations -Self-Reporting -Complaints Additional Compliance Information None. Standard MOD-001-1a -Available Transmission System Capability Violation Severity Levels R1.N/A N/A N/A The Transmission Operator did not select one of the specified methodologies for each ATC Path per time period identified in R2 for those Facilities within its Transmission operating area. R2. One or more of the following: *The Transmission Service Provider has calculated hourly ATC or AFC values for more than the next 30 hours but less than the next 48 hours. *Has calculated daily ATC or AFC values for more than the next 21 calendar days but Jess than the next 31 calendar days. «Has calculated monthly ATC or AFC values for more than the next 9 months but less than the next 12 months. One or more of the following: =The Transmission Service Provider has calculated hourly ATC or AFC values for more than the next 20 hours but less than the next 31 hours. «Has calculated daily ATC or AFC values for more than the next 14 calendar days but less than the next 22 calendar days. =Has calculated monthly ATC or AFC values for more than the next 6 months but less than the next 10 months. One or more of the following: *®The Transmission Service Provider has calculated hourly ATC or AFC values for more than the next 10 hours but less than the next 21 hours. «Has calculated daily ATC or AFC values for more than the next 7 calendar days but less than the next 15 calendar days. #Has calculated monthly ATC or AFC values for more than the next 3 months but less than the next 7 months. One or more of the following: «The Transmission Service Provider has calculated hourly ATC or AFC values for less than the next 11 hours. *Has calculated daily ATC or AFC values for less than the next 8 calendar days. *Has calculated monthly ATC or AFC values for less than the next 4 months. «Did not use the selected methodology(ies)to calculate R3. The Transmission Service Provider has an ATCID that does not incorporate changes made up to three months ago. The Transmission Service Provider has an ATCID that does not incorporate changes made more than three months but not more than six months ago. The Transmission Service Provider has an ATCID that does not incorporate changes made more than six months but not more than one year ago. OR The Transmission Service Provider has an ATCID,but it does not include one or two of the information items described in R3. The Transmission Service Provider has an ATCID that does not incorporate changes made a year or more ago. OR The Transmission Service Provider does not have an ATCID,or its ATCID does not include three or more of the information items described in R3. Page 8 of 15 Standard MOD-001-1a -Available Transmission System Capability R4,qnamesowerVSLPeaseaeraAgatenTna:The Transmission Service Provider notified one or more of the parties specified in R4 of a new or modified ATCID after,but not more than 30 calendar days after,its implementation. Be eater:Moder The Transmission Service Provider notified one or more of the parties specified in R4 of a new or modified ATCID more than 30,but not more than 60,calendar days after its implementation. Sy nyrayoerwahee eae ee af .-y Y we PPS:"3 ess "oy ."Seaiticesvaa!'Oh VSL ae cerars pecan SevereVSL Rama aaeE The Transmission Service Provider notified one or more of the parties specified in R4 of a new or modified ATCID more than 60,but not more than 90,calendar days after its implementation. The Transmission Service Provider notified one or more of the parties specified in R4 of a new or modified ATCID more than 90 calendar days after its implementation. OR The Transmission Service Provider did not notify one or more of the parties specified in R4 of a new or modified ATCID for more than 90 calendar days after its implementation. RS.N/A N/A N/A The Transmission Service Provider did not make the ATCID available to the parties described in R4. R6. The Transmission Operator determined TTC or TFC using assumptions more limiting than those used in planning of operations for the studied time period for more than zero ATC Paths or Flowgates,but not more than 5%of all ATC Paths or Flowgates or 1 ATC Path or Flowgate (whichever is greater). The Transmission Operator determined TTC or TFC using assumptions more limiting than those used in planning of operations for the studied time period for more than 5%of all ATC Paths or Flowgates or 1 ATC Path or Flowgate (whichever is greater), but not more than 10%of all ATC Paths or Flowgates or 2 ATC Paths or Flowgates (whichever is greater). The Transmission Operator determined TTC or TFC using assumptions more limiting than those used in planning of operations for the studied time period for more than 10%of all ATC Paths or Flowgates or 2 ATC Path or Flowgate (whichever is greater),but not more than 15%of all ATC Paths or Flowgates or 3 ATC Paths or Flowgates (whichever is greater). The Transmission Operator determined TTC or TFC using assumptions more limiting than those used in planning of operations for the studied time period for more than 15%of all ATC Paths or Flowgates or more than 3 ATC Paths or Flowgates (whichever is greater). R7 The Transmission Service Provider determined ATC or AFC using assumptions more limiting than those used in planning of operations for the studied time period for more than zero ATC Paths or Flowgates,but not more The Transmission Service Provider determined ATC or AFC using assumptions more limiting than those used in planning of operations for the studied time period for more than 5%of all ATC Paths or Flowgates or 1 ATC Path The Transmission Service Provider determined ATC or AFC using assumptions more limiting than _those used in planning of operations for the studied time period for more than 10%,of all ATC Paths or Flowgates or 2 ATC The Transmission Service Provider determined ATC or AFC using assumptions more limiting than those used in planning of operations for the studied time period for more than 15%of all ATC Paths or Flowgates or more Page 9 of 15 Standard MOD-001-1a -Available Transmission System Capability oT sa 4 "ke opera..ate ee on Lae OKT ZS or Flowgate (whichever is greater),than 5%of all ATC Paths or Flowgates or 1 ATC Path or Flowgate (whichever is greater). but not more than 10%of all ATC Paths or Flowgates or 2 ATC Paths or Flowgates (whichever is greater). AEN Path or Flowgate (whichever is greater),but not more than 15%of all ATC Paths or Flowgates or 3 ATC Paths or Flowgates (whichever is greater). ee ga Da oe Ae,<1]aaa wey 5 on oat +oe ae A than3ATC Paths or Flowgates (whichever is greater). R8. One or more of the following: *For Hourly,the values described in the ATC equation changed and the Transmission Service provider did not calculate for one or more hours but not more than 15 hours,and was in excess of the 175-hour per year requirement. *®For Daily,the values described in the ATC equation changed and the Transmission Service provider did not calculate for one or more calendar days but not more than 3 calendar days. *For Monthly,the values described in the ATC equation changed and the Transmission Service provider did not calculate for seven or more calendar days,but less than 14 calendar days. One or more of the following: *For Hourly,the values described in the ATC equation changed and the Transmission Service provider did not calculate for more than 15 hours but not more than 20 hours,and was in excess of the 175-hour per year requirement. «For Daily,the values described in the ATC equation changed and the Transmission Service provider did not calculate for more than 3 calendar days but not more than 4 calendar days. *For Monthly,the values described in the ATC equation changed and the Transmission Service provider did not calculate for 14 or more calendar days,but less than 21 calendar days. One or more of the following: «For Hourly,the values described in the ATC equation changed and the Transmission Service provider did not calculate for more than 20 hours but not more than 25 hours,and was in excess of the 175-hour per year requirement. For Daily,the values described in the ATC equation changed and the Transmission Service provider did not calculate for more than 4 calendar days but not more than 5 calendar days. *For Monthly,the values described in the ATC equation changed and the Transmission Service provider did not calculate for 21 or more calendar days,but less than 28 calendar days. One or more of the following: For Hourly,the values described in the ATC equation changed and the Transmission Service provider did not calculate for more than 25 hours,and was in excess of the 175-hour per year requirement. For Daily,the values described in the ATC equation changed and the Transmission Service provider did not calculate for more than 5 calendar days. For Monthly,the values described in the ATC equation changed and the Transmission Service provider did not calculate for 28 or more calendar days. Page 10 of 15 Standard MOD-001-1a -Available Transmission System Capability RO N/A The Transmission Service Provider made the requested data items specified in RQ available to the requesting entities specified within the requirement,per the schedule specified in the request,subject to the limitations specified in R9, available more than 30 calendar days but less than 45 calendar days after receiving a request. The Transmission Service Provider made the requested data items specified in R9 available to the requesting entities specified within the requirement,per the schedule specified in the request,subject to the limitations specified in R9, available 45 calendar days or more but less than 60 calendar days after receiving a request. The Transmission Service Provider did not make the requested data items specified in R9 available to the requesting entities specified within the requirement,per the schedule specified in the request, subject to the limitations specified in RQ,available for 60 calendar days or more after receiving a request. Page 11 of15 Standard MOD-001-1a -Available Transmission System Capability Version History Version Date Action Change Tracking 1 8/26/2008 Adopted by the Board of Trustees la Board approved |Interpretation of R2 and R8 Interpretation (Project 11/05/2009 2009-15) Page 12 of 15 Standard MOD-001-1a -Available Transmission System Capability Appendix 1 Requirement Number and Text of Requirement MOD-001-01 Requirement R2: R2.Each Transmission Service Provider shall calculate ATC or AFC values as listed below using the methodology or methodologies selected by its Transmission Operator(s): R2.1.Hourly values for at least the next 48 hours. R2.2.Daily values for at least the next 31 calendar days. R2.3.Monthly values for at least the next 12 months (months 2-13). MOD-001-01 Requirement R8: R8.Each Transmission Service Provider that calculates ATC shall recalculate ATC at a minimum on the following frequency,unless none of the calculated values identified in the ATC equation have changed: R8.1.Hourly values,once per hour.Transmission Service Providers are allowed up to 175 hours per calendar year during which calculations are not required to be performed, despite a change in a calculated value identified in the ATC equation. R8.2.Daily values,once per day. R8.3.Monthly values,once per week. Question #1 Is the "advisory ATC”used under the NYISO tariff subject to the ATC calculation and recalculation requirements in MOD-001-1 Requirements R2 and R8?If not,is it necessary to document the frequency of "advisory”calculations in the responsible entity's Available Transfer Capability Implementation Document? Response to Question #1 Requirements R2 and R8 of MOD-001-1 are both related to Requirement R1,which defines that ATC methodologies are to be applied to specific "ATC Paths.”The NERC definition of ATC Path is "Any combination of Point of Receipt and Point of Delivery for which ATC is calculated; and any Posted Path.”Based on a review of the language included in this request,the NYISO Open Access Transmission Tariff,and other information posted on the NYISO Web site,it appears that the NYISO does indeed have multiple ATC Paths,which are subject to the calculation and recalculation requirements in Requirements R2 and R8.It appears from reviewing this information that ATC is defined in the NYISO tariff in the same manner in which NERC defines it,making it difficult to conclude that NYISO's "advisory ATC”is not the same as ATC.In addition,it appears that pre-scheduling is permitted on certain external paths,making the calculation of ATC prior to day ahead necessary on those paths. The second part of NYISO's question is only applicable if the first part was answered in the Page 13 of 15 Standard MOD-001-1a -Available Transmission System Capability negative and therefore will not be addressed. Requirement Number and Text of Requirement MOD-029-01 Requirements R5 and R6: RS.When calculating ETC for firm Existing Transmission Commitments (ETCf)for a specified period for an ATC Path,the Transmission Service Provider shall use the algorithm below: ETCre =NL +NITS¢+GFe +PTP¢+ROR¢+OSp Where: NL+is the firm capacity set aside to serve peak Native Load forecast commitments for the time period being calculated,to include losses,and Native Load growth, not otherwise included in Transmission Reliability Margin or Capacity Benefit Margin. NITS,s is the firm capacity reserved for Network Integration Transmission Service serving Load,to include losses,and Load growth,not otherwise included in Transmission Reliability Margin or Capacity Benefit Margin. GFr is the firm capacity set aside for grandfathered Transmission Service and contracts for energy and/or Transmission Service,where executed prior to the effective date of a Transmission Service Provider's Open Access Transmission Tariff or "safe harbor tariff.” PTPy is the firm capacity reserved for confirmed Point-to-Point Transmission Service. ROR;is the firm capacity reserved for Roll-over rights for contracts granting Transmission Customers the right of first refusal to take or continue to take Transmission Service when the Transmission Customer's Transmission Service contract expires or is eligible for renewal. OS+is the firm capacity reserved for any other service(s),contract(s),or agreement(s)not specified above using Firm Transmission Service as specified in the ATCID. R6.When calculating ETC for non-firm Existing Transmission Commitments (ETCyp)for all time horizons for an ATC Path the Transmission Service Provider shall use the following algorithm: ETCyr =NITSwne +GFyr +PTPne +OSne Where: NITSxyr is the non-firm capacity set aside for Network Integration Transmission Service serving Load (i.e.,secondary service),to include losses,and load growth not otherwise included in Transmission Reliability Margin or Capacity Benefit Margin. GFyr is the non-firm capacity set aside for grandfathered Transmission Service and contracts for energy and/or Transmission Service,where executed prior to the Page 14 of 15 Standard MOD-001-1a -Available Transmission System Capability effective date of a Transmission Service Provider's Open Access Transmission Tariff or "safe harbor tariff.” PTPwr is non-firm capacity reserved for confirmed Point-to-Point Transmission Service. OSnr is the non-firm capacity reserved for any other service(s),contract(s),or agreement(s)not specified above using non-firm transmission service as specified in the ATCID. Question #2 Could OS;in MOD-029-1 Requirement R5 and OSnr in MOD-029-1 Requirement R6 be calculated using Transmission Flow Utilization in the determination of ATC? Response to Question #2 This request for interpretation and the NYISO Open Access Transmission Tariff describe the NYISO's concept of "Transmission Flow Utilization;"however,it is unclear whether or not Native Load,Point-to-Point Transmission Service,Network Integration Transmission Service,or any of the other components explicitly defined in Requirements R5 and R6 are incorporated into "Transmission Flow Utilization."Provided that "Transmission Flow Utilization"does not include Native Load,Point-to-Point Transmission Service,Network Integration Transmission Service,or any of the other components explicitly defined in Requirements R5 and R6,it is appropriate to be included within the "Other Services"term.However,if "Transmission Flow Utilization"does incorporate those components,then simply including "Transmission Flow Utilization"in "Other Service”would be inappropriate. Page 15 of 15 Standard AKMOD-028-01 -Area Interchange A.Introduction 1.Title:Area Interchange Methodology 2.Number:MOD-028-01 3.Purpose:To increase consistency and reliability in the development and documentation of Transfer Capability calculations for short-term use performed by entities using the Area Interchange Methodology to support analysis and system operations. 4.Applicability: 4.1.Each Transmission Operator that uses the Area Interchange Methodology to calculate Total Transfer Capabilities (TTCs)for ATC Paths. 4,2.Each Transmission Service Provider that uses the Area Interchange Methodology to calculate Available Transfer Capabilities (ATCs)for ATC Paths. 5.Proposed Effective Date:TBD B.Requirements R1.Each Transmission Service Provider shall include in its Available Transfer Capability Implementation Document (ATCID),at a minimum,the following information relative to its methodology for determining Total Transfer Capability (TTC): R1.1.Information describing how the selected methodology has been implemented, in such detail that,given the same information used by the Transmission Operator,the results of the TTC calculations can be validated. R1.2.A description of the manner in which the Transmission Operator will account for Interchange Schedules in the calculation of TTC. R1.3.Any contractual obligations for allocation of TTC. R1.4.A description of the manner in which Contingencies are identified for use in the TTC process. R1.5.The following information on how source and sink for transmission service is accounted for in ATC calculations including: R1.5.1.Define if the source used for Available Transfer Capability (ATC) calculations is obtained from the source field or the Point of Receipt (POR)field of the transmission reservation R1.5.2.Define if the sink used for ATC calculations is obtained from the sink field or the Point of Delivery (POD)field of the transmission reservation R1.5.3.The source/sink or POR/POD identification and mapping to the model. Adopted by NERC Board of Trustees:August 26,2008 Page 1 of 15 Standard AKMOD-028-01 -Area Interchange R1.5.4.If the Transmission Service Provider's ATC calculation process involves a grouping of generation,the ATCID must identify how these generators participate in the group. R2.When calculating TTC for ATC Paths,the Transmission Operator shall use a Transmission model that contains all of the following: R2.1.Modeling data and topology of its Reliability Coordinator's area of responsibility.Equivalent representation of radial lines and facilities 35kV or below is allowed. R2.2.Modeling data and topology (or equivalent representation)for immediately adjacent and beyond Reliability Coordination areas. R2.3.Facility Ratings specified by the Generator Owners and Transmission Owners. R3.When calculating TTCs for ATC Paths,the Transmission Operator shall include the following data for the Transmission Service Provider's area.The Transmission Operator shall also include the following data associated with Facilities that are explicitly represented in the Transmission model,as provided by adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed:[Violation Risk Factor:Lower] [Time Horizon:Operations Planning] R3.1.For on-peak and off-peak intra-day and next-day TTCs,use the following (as well as any other values and additional parameters as specified in the ATCID): R3.1.1.Expected generation and Transmission outages,additions,and retirements,included as specified in the ATCID. R3.1.2.Load forecast for the applicable period being calculated. R3.1.3.Unit commitment and dispatch order,to include all designated network resources and other resources that are committed or have the legal obligation to run,(within or out of economic dispatch)as they are expected to run. R3.2.For days two through 31 TTCs and for months two through 13 TTCs,use the following (as well as any other values and internal parameters as specified in the ATCID): R3.2.1.Expected generation and Transmission outages,additions,and Retirements,included as specified in the ATCID. R3.2.2.Daily load forecast for the days two through 31 TTCs being calculated and monthly forecast for months two through 13 months TTCs being calculated. R3.2.3.Unit commitment and dispatch order,to include all designated network resources and other resources that are committed or have the legal obligation to run,(within or out of economic dispatch)as they are expected to run. Adopted by NERC Board of Trustees:August 26,2008 Page 2 of 15 Standard AKMOD-028-01 -Area Interchange R4.When calculating TTCs for ATC Paths,the Transmission Operator shall meet all!of the following conditions:{Violation Risk Factor:Lower][Time Horizon:Operations Planning] R4.1.Use all Contingencies meeting the criteria described in the ATCID. R4.2.Respect any contractual allocations of TTC. R4.3.Include,for each time period,the Firm Transmission Service expected to be scheduled as specified in the ATCID (filtered to reduce or eliminate duplicate impacts from transactions using Transmission service from multiple Transmission Service Providers)for the Transmission Service Provider,all adjacent Transmission Service Providers,and any Transmission Service Providers with which coordination agreements have been executed modeling the source and sink as follows: -Ifthe source,as specified in the ATCID,has been identified in the reservation and it is discretely modeled in the Transmission Service Provider's Transmission model,use the discretely modeled point as the source. -Ifthe source,as specified in the ATCID,has been identified in the reservation and the point can be mapped to an "equivalence”or "aggregate representation”in the Transmission Service Provider's Transmission model,use the modeled equivalence or aggregate as the source. -Ifthe source,as specified in the ATCID,has been identified in the reservation and the point cannot be mapped to a discretely modeled point, an "equivalence,”or an "aggregate representation”in the Transmission Service Provider's Transmission model,use the immediately adjacent Balancing Authority associated with the Transmission Service Provider from which the power is to be received as the source. -Ifthe source,as specified in the ATCID,has not been identified in the reservation,use the immediately adjacent Balancing Authority associated with the Transmission Service Provider from which the power is to be received as the source. -Ifthe sink,as specified in the ATCID,has been identified in the reservation and it is discretely modeled in the Transmission Service Provider's Transmission model,use the discretely modeled point shall as the sink. -Ifthe sink,as specified in the ATCID,has been identified in the reservation and the point can be mapped to an "equivalence”or "aggregate representation”in the Transmission Service Provider's Transmission model,use the modeled equivalence or aggregate as the sink. -Ifthe sink,as specified in the ATCID,has been identified in the reservation and the point cannot be mapped to a discretely modeled point,an "equivalence,”or an "aggregate representation”in the Transmission Service Provider's Transmission model,use the immediately adjacent Adopted by NERC Board of Trustees:August 26,2008 Page 3 of 15 Standard AKMOD-028-01 -Area Interchange Balancing Authority associated with the Transmission Service Provider to which the power is to be delivered as the sink. -Ifthe sink,as specified in the ATCID,has not been identified in the reservation,use the immediately adjacent Balancing Authority associated with the Transmission Service Provider to which the power is being delivered as the sink. R5.Each Transmission Operator shall establish TTC for each ATC Path under an open access and in use as and open access path as defined below: R5.1._At least once within the seven calendar days prior to the specified period for TTCs used in hourly and daily ATC calculations. R5.2.At least once per calendar month for TTCs used in monthly ATC calculations. R5.3.Within 24 hours of the unexpected outage of a 115 kV or higher transmission Facility or a transformer with a High-side voltage of 115 kV or higher for TTCs in effect during the anticipated duration of the outage,provided such outage is expected to last 24 hours or longer. R6.Each Transmission Operator shall establish TTC for each ATC Path using the following process: R6.1.Determine the incremental Transfer Capability for each ATC Path by increasing generation and/or decreasing load within the source Balancing Authority area and decreasing generation and/or increasing load within the sink Balancing Authority area until either: -A System Operating Limit is reached on the Transmission Service Provider's system,or -A SOLis reached on any other adjacent system in the Transmission modelthatisnotonthestudypathandthedistributionfactoris5%or greater'. R6.2.Ifthe limit in step R6.1 cannot be reached by adjusting any combination of load or generation,then set the incremental Transfer Capability by the results of the case where the maximum adjustments were applied. R6.3.Use (as the TTC)the lesser of: - Thesum of the incremental Transfer Capability and the impacts of Firm Transmission Services,as specified in the Transmission Service Provider's ATCID,that were included in the study model,or Thesum of Facility Ratings of all ties comprising the ATC Path. R6.4.For ATC Paths whose capacity uses jointly-owned or allocated Facilities,limit TTC for each Transmission Service Provider so the TTC does not exceed each Transmission Service Provider's contractual rights. 'The Transmission operator may honor distribution factors less than 5%if desired. Adopted by NERC Board of Trustees:August 26,2008 Page 4 of 15 Standard AKMOD-028-01 -Area Interchange R7.The Transmission Operator shall provide the Transmission Service Provider of that ATC Path with the most current value for TTC for that ATC Path no more than: R7.1.One calendar day after its determination for TTCs used in hourly and daily ATC calculations. R7.2.Seven calendar days after its determination for TTCs used in monthly ATC calculations. R8.When calculating Existing Transmission Commitments (ETCs)for firm commitments (ETC,)for all time periods for an ATC Path the Transmission Service Provider shall use the following algorithm: ETC;=NITS¢+GFf +PTPe +ROR¢+OSF Where: NITS,is the firm capacity set aside for Network Integration Transmission Service (including the capacity used to serve bundled load within the Transmission Service Provider's area with external sources and LSE or TSP native load)on ATC Paths that serve as interfaces with other Balancing Authorities. GFr is the firm capacity set aside for Grandfathered Firm Transmission Service and contracts for energy and/or Transmission Service,where executed prior to the effective date of a Transmission Service Provider's Open Access Transmission Tariff or safe harbor tariff on ATC Paths that serve as interfaces with other Balancing Authorities. PTP;is the firm capacity reserved for confirmed Point-to-Point Transmission Service. RORg is the capacity reserved for roll-over rights for Firm Transmission Service contracts granting Transmission Customers the right of first refusal to take or continue to take Transmission Service when the Transmission Customer's Transmission Service contract expires or is eligible for renewal. OS,is the firm capacity reserved for any other service(s),contract(s),or agreement(s)not specified above using Firm Transmission Service,including any other firm adjustments to reflect impacts from other ATC Paths of the Transmission Service Provider as specified in the ATCID. R9.When calculating ETC for non-firm commitments (ETCyp)for all time periods for an ATC Path the Transmission Service Provider shall use the following algorithm: [Violation Risk Factor:Lower][Time Horizon:Operations Planning] ETCyr =NITSwnr +GF nr +PTPyr +OSnr Where: NITS yr is the non-firm capacity set aside for Network Integration Transmission Service (i.e.,secondary service ,including the capacity used to serve bundled load within the Transmission Service Provider's area with external sources and LSE and TSP Native load ) Adopted by NERC Board of Trustees:August 26,2008 Page 5 of 15 Standard AKMOD-028-01 -Area Interchange reserved on ATC Paths that serve as interfaces with other Balancing Authorities. GFyr is the non-firm capacity reserved for Grandfathered Non-Firm Transmission Service and contracts for energy and/or Transmission Service,where executed prior to the effective date of a Transmission Service Provider's Open Access Transmission Tariff or safe harbor tariff on ATC Paths that serve as interfaces with other Balancing Authorities. PTPyr is non-firm capacity reserved for confirmed Point-to-Point Transmission Service. OS yr is the non-firm capacity reserved for any other service(s),contract(s),or agreement(s)not specified above using Non-Firm Transmission Service, including any other firm adjustments to reflect impacts from other ATC Paths of the Transmission Service Provider as specified in the ATCID. R10.When calculating firm ATC for an ATC Path for a specified period,the Transmission Service Provider shall utilize the following algorithm: ATCr =TTC -ETC¢-CBM -TRM +Postbacksy +counterflowsr Where: ATC,is the firm Available Transfer Capability for the ATC Path for that period. TTC is the Total Transfer Capability of the ATC Path for that period. . ETC,is the sum of existing firm Transmission commitments for the ATC Path during that period. CBM is the Capacity Benefit Margin for the ATC Path during that period. TRM is the Transmission Reliability Margin for the ATC Path during that period. Postbacksy are changes to firm or Non-Firm ATC due to a change in the use of Transmission Capacity that is non-recallable. counterflowsf are adjustments to firm ATC as determined by the Transmission Service Provider and specified in the ATCID. R11.When calculating non-firm ATC for a ATC Path for a specified period,the Transmission Service Provider shall use the following algorithm:[Violation Risk Factor:Lower][Time Horizon:Operations Planning] ATCnr =TTC -ETCe -ETCynr -CBMs -TRMy +Postbacksyp +counterflowsyr Where: ATCyr is the non-firm Available Transfer Capability for the ATC Path for that period. TTC is the Total Transfer Capability of the ATC Path for that period. ETC;is the sum of existing firm Transmission commitments for the ATC Path during that period. Adopted by NERC Board of Trustees:August 26,2008 Page 6 of 15 Standard AKMOD-028-01 -Area Interchange ETCyr is the sum of existing non-firm Transmission commitments for the ATC Path during that period. CBMs is the Capacity Benefit Margin for the ATC Path that has been scheduled without a separate reservation during that period. TRMvu is the Transmission Reliability Margin for the ATC Path that has not been released for sale (unreleased)as non-firm capacity by the Transmission Service Provider during that period. Postbacksyr are changes to non-firm ATC due to a change in the use of Transmission Capacity use for that period,that are recallable as defined in Business Practices. counterflowsnr are adjustments to non-firm ATC as determined by the Transmission Service Provider and specified in the ATCID. C.Measures M1. M2. M3. M4. M5. M6. M7. Each Transmission Service Provider shall provide its current ATCID that has the information described in R1 to show compliance with R1.(R1) Each Transmission Operator shall provide evidence including the model used to calculate TTC as well as other evidence (such as Facility Ratings provided by facility owners,written documentation,logs,and data)to show that the modeling requirements in R2 were met.(R2) Each Transmission Operator shall provide evidence,including scheduled outages, facility additions and retirements,(such as written documentation,logs,and data)that the data described in R3 and R4 were included in the determination of TTC as specified in the ATCID.(R3) Each Transmission Operator shall provide the contingencies used in determining TTC and the ATCID as evidence to show that the contingencies described in the ATCID were included in the determination of TTC.(R4) Each Transmission Operator shall provide copies of contracts that contain requirements to allocate TTCs and TTC values to show that any contractual allocations of TTC were respected as required in R4.2.(R4) Each Transmission Operator shall provide evidence (such as copies of coordination agreements,reservations,interchange transactions,or other documentation)to show that firm reservations were used to estimate scheduled interchange,the modeling of scheduled interchange was based on the rules described in R4.3,and that estimated scheduled interchange was included in the determination of TTC.(R4) Each Transmission Operator shall provide evidence (such as logs and data and dated copies of requests from the Transmission Service Provider to establish TTCs at specific intervals)that TTCs have been established at least once in the calendar week prior to the specified period for TTCs used in hourly and daily ATC calculations,at least once per calendar month for TTCs used in monthly ATC calculations,and within 24 hours of the unexpected outage of a 500 kV or higher transmission Facility or a autotransformer with a low-side voltage of 200 kV or higher for TTCs in effect during the anticipated Adopted by NERC Board of Trustees:August 26,2008 Page 7 of 15 Standard AKMOD-028-01 -Area Interchange duration of the outage;provided such outage is expected to last 24 hours or longer in duration per the specifications in R5.(R5) M8.Each Transmission Operator shall provide evidence (such as written documentation) that TTCs have been calculated using the process described in R6.(R6) M9.Each Transmission Operator shall have evidence including a copy of the latest calculated TTC values along with a dated copy of email notices or other equivalent evidence to show that it provided its Transmission Service Provider with the most current values for TTC in accordance with R7.(R7) M10.The Transmission Service Provider shall demonstrate compliance with R8 by recalculating firm ETC for any specific time period as described in (MOD-001 R2), using the algorithm defined in R8 and with data used to calculate the specified value for the designated time period.The data used must meet the requirements specified in MOD-028-1 and the ATCID.To account for differences that may occur when recalculating the value (due to mixing automated and manual processes),any recalculated value that is within +/-15%or 15 MW,whichever is greater,of the originally calculated value,is evidence that the Transmission Service Provider used the algorithm in R8 to calculate its firm ETC.(R8) M11.The Transmission Service Provider shall demonstrate compliance with R9 by recalculating non-firm ETC for any specific time period as described in (MOD-001 R2),using the algorithm defined in R9 and with data used to calculate the specified value for the designated time period.The data used must meet the requirements specified in MOD-028-1 and the ATCID.To account for differences that may occur when recalculating the value (due to mixing automated and manual processes),any recalculated value that is within +/-15%or 15 MW,whichever is greater,of the originally calculated value,is evidence that the Transmission Service Provider used the algorithm in R8 to calculate its non-firm ETC.(R9) M12.Each Transmission Service Provider shall produce the supporting documentation for the processes used to implement the algorithm that calculates firm ATCs,as required in R10.Such documentation must show that only the variables allowed in R10 were used to calculate firm ATCs,and that the processes use the current values for the variables as determined in the requirements or definitions.Note that any variable may legitimately be zero if the value is not applicable or calculated to be zero (such as counterflows, TRM,CBM,etc.).The supporting documentation may be provided in the same form and format as stored by the Transmission Service Provider.(R10) M13.Each Transmission Service Provider shall produce the supporting documentation for the processes used to implement the algorithm that calculates non-firm ATCs,as required in R11.Such documentation must show that only the variables allowed in R11 were used to calculate non-firm ATCs,and that the processes use the current values for the variables as determined in the requirements or definitions.Note that any variable may legitimately be zero if the value is not applicable or calculated to be zero (such as counterflows,TRM,CBM,etc.).The supporting documentation may be provided in the same form and format as stored by the Transmission Service Provider.(R11) Adopted by NERC Board of Trustees:August 26,2008 Page 8 of 15 Standard AKMOD-028-01 -Area Interchange D.Compliance Adopted by NERC Board of Trustees:August 26,2008 Page 9 of 15 Standard AKMOD-028-01 -Area Interchange 1.Compliance Monitoring Process 1.1.Compliance Enforcement Authority IMC Regional Reliability Entity,unless IMC is relevant transmission provider,then Alaska Energy Authority. 1.2.Compliance Monitoring Period and Reset Not applicable. 1.3.Data Retention The Transmission Operator and Transmission Service Provider shall keep data or evidence to show compliance as identified below unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation: -The Transmission Service Provider shall retain its current,in force ATCID and any prior versions of the ATCID that were in force since the last compliance audit to show compliance with R1. -The Transmission Operator shall have its latest model used to calculate TTC and evidence of the previous version to show compliance with R2. -The Transmission Operator shall retain evidence to show compliance with R3 for the most recent 12 months or until the model used to calculate TTC is updated,whichever is longer. -The Transmission Operator shall retain evidence to show compliance with R4,R5,R6 and R7 for the most recent 12 months. -The Transmission Service Provider shall retain evidence to show compliance in calculating hourly values required in R8 and R9 for the most recent 14 days;evidence to show compliance in calculating daily values required in R8 and R9 for the most recent 30 days;and evidence to show compliancein calculating monthly values requiredin R8 and R9 for themostrecent60days. -The Transmission Service Provider shall retain evidence to show compliance with R10 and R11 for the most recent 12 months. -Ifa Transmission Service Provider or Transmission Operator is found non- compliant,it shall keep information related to the non-compliance until found compliant. -The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records. 1.4.Compliance Monitoring and Enforcement Processes: The following processes may be used: -Compliance Audits -Self-Certifications -Spot Checking -Compliance Violation Investigations -Self-Reporting Adopted by NERC Board of Trustees:August 26,2008 Page 10 of 15 Standard AKMOD-028-01 -Area Interchange -Complaints Adopted by NERC Board of Trustees:August 26,2008 Page 11 of 15 Standard AKMOD-028-01 -Area Interchange 1.5.Additional Compliance Information None. Adopted by NERC Board of Trustees:August 26,2008 Page 12 of 15 Standard MOD-028-1 -Area Interchange Methodology 2.Violation Severity Levels OE s >pawns LOVE The Transmission Service Provider has an ATCID but it is missing one of the following: *R14 »R1.2 *R13 »R14 »Rt1.5 (any one or more of its sub-subrequirements) Provider has an ATCID but it is missing two of the following: *R11 *R1.2 *R13 *R14 »R1.5 (any one or more of its sub-subrequirements) Be te at etl st The Transmission Service Provider has an ATCID but it is missing three of the following: *R11 *R12 *R13 »R14 *1.5 (any one or more of its sub-subrequirements) The Transmission Service -ata bye oo} Provider Beeawe, has an ATCID but it is missing more than three of the following: R1.1 R1.2 R1.3 R1.4 R1.5 (any one or more of its sub-subrequirements) R2.The Transmission Operator used one to ten Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. The Transmission Operator used eleven to twenty Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. One or both of the following: e The Transmission Operator used twenty-one to thirty Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. e The Transmission Operator did not use a Transmission model that includes modeling data and topology (or equivalent representation) for one adjacent Reliability Coordinator Area. One or more of the following: e The Transmission Operator used more than thirty Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. The Transmission Operator's model includes equivalent representation of non-radial facilities greater than 161 kV for its own Reliability Coordinator Area. The Transmission Operator did not use a Transmission model that includes modeling data and topology (or equivalent representation)for two or more adjacent Reliability Coordinator Adopted by NERC Board of Trustees:August 26,2008 Page 11 of 15 Standard MOD-028-1 -Area Interchange Methodology pa, Areas. R3.The Transmission Operator did not include in the TTC process one to ten expected generation and Transmission outages, additions or retirements as specified in the ATCID. The Transmission Operator did not include in the TTC process eleven to twenty-five expected generation and Transmission outages,additions or retirements as specified in the ATCID. The Transmission Operator did not include in the TTC process twenty-six to fifty expected generation and Transmission outages,additions or retirements as specified in the ATCID. One or more of the following: e The Transmission Operator did not include in the TTC process more than fifty expected generation and Transmission outages,additions or retirements as specified in the ATCID. e The Transmission Operator did not include the Load forecast or unit commitment in its TTC calculation as described in R3. R4. The Transmission Operator did not model reservations'sources or sinks as described in R5.3 for more than zero reservations, but not more than 5%of all reservations;or 1 reservation, whichever is greater. The Transmission Operator did not model reservations'sources or sinks as described in R5.3 for more than 5%,but not more than 10%of all reservations;or 2 reservations,whichever is greater. The Transmission Operator did not model reservations'sources or sinks as described in R5.3 for more than 10%,but not more than 15%of all reservations;or 3 reservations, whichever is greater. One or more of the following: e The Transmission Operator did not include in the TTC calculation the contingencies that met the criteria described in the ATCID. The Transmission Operator did not respect contractual allocations of TTC. The Transmission Operator did not model reservations'sources or sinks as described in R4.3 for more than 15%of all reservations;or more than 3 reservations,whichever is greater. The Transmission Operator did not use firm reservations to estimate interchange or did not Adopted by NERC Board of Trustees:August 26,2008 Page 12 of 15 Standard MOD-028-1 -Area Interchange Methodology Lore cs -Severe a.t ee ues utilize that estimate in the TTC calculation as described in R4.3. R5.One or more of the following: e The Transmission Operator did not establish TTCs for use in hourly or daily ATCs within 7 calendar days but did establish the values within 10 calendar days e The Transmission Operator did not establish TTCs for use in monthly ATCs during a calendar month but did establish the values within the next consecutive calendar month One or more of the following: e The Transmission Operator did not establish TTCs for use in hourly or daily ATCs in 10 calendar days but did establish the values within 13 calendar days e The Transmission Operator did not establish TTCs for use in monthly ATCs during a two consecutive calendar month period but did establish the values within the third consecutive calendar month One or more of the following: e The Transmission Operator did not establish TTCs for used in hourly or daily ATCs in 13 calendar days but did establish the values within 16 calendar days e The Transmission Operator did not establish TTCs for use in monthly ATCs during a three consecutive calendar month period but did establish the values within the fourth consecutive calendar month One or more of the following: e The Transmission Operator did not establish TTCs for used in hourly or daily ATCs in 16 calendar days e The Transmission Operator did not establish TTCs for use in monthly ATCs during a four or more consecutive calendar month period e The Transmission Operator did not establish TTCs within 24 hrs of the triggers defined in R5.3 R6. N/A N/A N/A The Transmission Operator did not calculate TTCs per the process specified in R6. R7.One or more of the following: e The Transmission Operator provided its Transmission Service Provider with its ATC Path TTCs used in hourly or daily ATC calculations more than one calendar day after their determination,but not been more than two calendar days after their determination. e The Transmission Operator One or more of the following: e The Transmission Operator provided its Transmission Service Provider with its ATC Path TTCs used in hourly or daily ATC calculations more than two calendar days after their determination,but not been more than three calendar days after their determination. e The Transmission Operator One or more of the following: e The Transmission Operator provided its Transmission Service Provider with its ATC Path TTCs used in hourly or daily ATC calculations more than three calendar days after their determination,but not been more than four calendar days after their determination. e The Transmission Operator One or more of the following: e The Transmission Operator provided its Transmission Service Provider with its ATC Path TTCs used in hourly or daily ATC calculations more than four calendar days after their determination. ¢The Transmission Operator did not provide its Transmission Service Provider with its ATC Path TTCs used in hourly or Adopted by NERC Board of Trustees:August 26,2008 Page 13 of 15 Standard MOD-028-1 -Area Interchange Methodology t rely an oar&ay e -«aa "ARIATcsownweataeete has not provided its Transmission Service Provider with its ATC Path TTCs used in monthly ATC calculations more than seven calendar days after their determination,but not more than 14 calendar days since their determination. has not provided its Transmission Service Provider with its ATC Path TTCs used in monthly ATC calculations more than 14 calendar days after their determination,but not been more than 21 calendar days after their determination. by eee Saree ie has not provided its Transmission Service Provider with its ATC Path TTCs used in monthly ATC calculations more than 21 calendar days after their determination,but not been more than 28 calendar days after their determination. daily ATC calc ulations. e The Transmission Operator provided its Transmission Service Provider with its ATC Path TTCs used in monthly ATC calculations more than 28 calendar days after their determination. e The Transmission Operator did not provide its Transmission Service Provider with its ATC Path TTCs used in monthly ATC calculations. R8.For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M10 for the same period,and the absolute value difference was more than 15%of the value calculated in the measure or 15MW, whichever is greater,but not more than 25%of the value calculated in the measure or 25MW,whichever is greater. For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M10 for the same period,and the absolute value difference was more than 25%of the value calculated in the measure or 25MW, whichever is greater,but not more than 35%of the value calculated in the measure or 35MW,whichever is greater. For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M10 for the same period,and the absolute value difference was more than 35%of the value calculated in the measure or 35MW, whichever is greater,but not more than 45%of the value calculated in the measure or 45MW,whichever is greater. For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M10 for the same period,and the absolute value difference was more than 45%of the value calculated in the measure or 45MW,whichever is greater. RQ.For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M11 for the same period,and the absolute value difference was more than 15%of the value calculated in the measure or 15MW, whichever is greater,but not For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M11 for the same period,and the absolute value difference was more than 25%of the value calculated in the measure or 25MW, whichever is greater,but not For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M11 for the same period,and the absolute value difference was more than 35%of the value calculated in the measure or 35MW, whichever is greater,but not For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M11 for the same period,and the absolute value difference was more than 45%of the value calculated in the measure or 45MW,whichever is greater. Adopted by NERC Board of Trustees:August 26,2008 Page 14 of 15 Standard MOD-028-1 -Area Interchange Methodology more than 25%of the value calculated in the measure or 25MW,whichever is greater. more than 35%of the value calculated in the measure or 35MW,whichever is greater... calculated in the measure or 45MW,whichever is greater. R10. The Transmission Service Provider did not use all the elements defined in R10 when determining firm ATC,or used additional elements,for more than zero ATC Paths,but not more than 5%of all ATC Paths or 1 ATC Path (whichever is greater). The Transmission Service Provider did not use all the elements defined in R10 when determining firm ATC,or used additional elements,for more than 5%of all ATC Paths or 1 ATC Path (whichever is greater),but not more than 10% of all ATC Paths or 2 ATC Paths (whichever is greater). The Transmission Service Provider did not use all the elements defined in R10 when determining firm ATC,or used additional elements,for more than 10%of all ATC Paths or 2 ATC Paths (whichever is greater),but not more than 15% of all ATC Paths or 3 ATC Paths (whichever is greater). The Transmission Service Provider did not use all the elements defined in R10 when determining firm ATC, or used additional elements,for more than 15%of all ATC Paths or more than 3 ATC Paths (whichever is greater). R11.The Transmission Service Provider did not use all the elements defined in R11 when determining non-firm ATC,or used additional elements,for more than zero ATC Paths,but not more than 5%of all ATC Paths or 1 ATC Path (whichever is greater). The Transmission Service Provider did not use all the elements defined in R11 when determining non-firm ATC,or used additional elements,for more than 5%of all ATC Paths or 1 ATC Path (whichever is greater),but not more than 10% of all ATC Paths or 2 ATC Paths (whichever is greater). The Transmission Service Provider did not use all the elements defined in R11 when determining non-firm ATC,or used additional elements,for more than 10%of all ATC Paths or 2 ATC Paths (whichever is greater),but not more than 15%of all ATC Paths or 3 ATC Paths (whichever is greater). The Transmission Service Provider did not use all the elements defined in R11 when determining non-firm ATC,or used additional elements, for more than 15%of all ATC Paths or more than 3 ATC Paths (whichever is greater). Adopted by NERC Board of Trustees:August 26,2008 Page 15 of 15 Standard AKMOD-029-01 -Rated System Path A.Introduction 1.'Title:Rated System Path Methodology 2.Number:MOD-029-01 3.Purpose:To increase consistency and reliability in the development and documentation of transfer capability calculations for short-term use performed by entities using the Rated System Path Methodology to support analysis and system operations.The determinations and calculations and penalties below are only applicable to paths under Open Access rules and actually in use as Open Access transfer paths (whether contract path or parallel flow path)i.e.Open Acess transfers are scheduled. 4.Applicability: 4.1.Each Transmission Operator that uses the Rated System Path Methodology to calculate Total Transfer Capabilities (TTCs)for ATC Paths. 4.2.Each Transmission Service Provider that uses the Rated System Path Methodology to calculate Available Transfer Capabilities (ATCs)for ATC Paths. 5.Proposed Effective Date:TBD Requirements R1.When calculating TTCs for ATC Paths,the Transmission Operator shall use a Transmission model which satisfies the following requirements: 'R1.1.The model utilizes data and assumptions consistent with the time period being studied and that meets the following criteria: R1.1.1.Includes at least: R1.1.1.1.The Transmission Operator area.Equivalent representation of radial lines and facilities 34.5 kV or below is allowed. R1.1.1.2.All Transmission Operator areas contiguous with its own Transmission Operator area.(Equivalent representation is allowed.) R1.1.1.3..Any other Transmission Operator area linked to the Transmission Operator's area by joint operating agreement.(Equivalent representation is allowed.) R1.1.2.Models all system Elements as in-service for the assumed initial conditions. R1.1.3.Models all generation (may be either a single generator or multiple generators)that is greater than 10 MVA at the point of interconnection in the studied area or is capable of moving system frequency by .1 Hz in either area interconnected or a typical area islanded situation . R1.1.4.Models phase shifters in non-regulating mode,unless otherwise Page I of 15 Standard AKMOD-029-01 -Rated System Path R1.2. specified in the Available Transfer Capability Implementation Document (ATCID). R1.1.5.Uses Load forecast by Balancing Authority. R1.1.6.Uses Transmission Facility additions and retirements. R1.1.7._Uses Generation Facility additions and retirements. R1.1.8.Uses Special Protection System (SPS)models where currently existing or projected for implementation within the studied time horizon. R1.1.9.Models series compensation for each line at the expected operating level unless specified otherwise in the ATCID. R1.1.10.Includes any other modeling requirements or criteria specified in the ATCID. Uses Facility Ratings as provided by the Transmission Owner and Generator Owner R2.The Transmission Operator shall use the following process to determine TTC: R2.1.Except where otherwise specified within MOD-029-01,adjust base case generation and Load levels within the updated power flow model to determine the TTC (maximum flow or reliability limit)that can be simulated on the ATC Path while at the same time satisfying all planning criteria contingencies as follows: R2.1.1.When modeling normal conditions,all Transmission Elements will be modeled at or below 100%of their continuous rating. R2.1.2..When modeling contingencies the system shall demonstrate transient,dynamic and voltage stability,with no Transmission Element modeled above its Emergency Rating. R2.1.3.Uncontrolled separation shall not occur. .Where it is impossible to actually simulate a reliability-limited flow in a direction counter to prevailing flows (on an alternating current Transmission line),set the TTC for the non-prevailing direction equal to the TTC in the prevailing direction.If the TTC in the prevailing flow direction is dependant on a Special Protection System (SPS),set the TTC for the non-prevailing flow direction equal to the greater of the maximum flow that can be simulated in the non-prevailing flow direction or the maximum TTC that can be achieved in the prevailing flow direction without use of a SPS. .Foran ATC Path whose capacity is limited by contract,set TTC on the ATC Path at the lesser of the maximum allowable contract capacity or the reliability limit as determined by R2.1. .Foran ATC Path whose TTC varies due to simultaneous interaction with one or more other paths,develop a nomogram describing the interaction of the paths and the resulting TTC under specified conditions. .The Transmission Operator shall identify when the TTC for the ATC Path being studied has an adverse impact on the TTC value of any existing path. Page 2 of 15 Standard AKMOD-029-01 -Rated System Path R4. R5. Do this by modeling the flow on the path being studied at its proposed new TTC level simultaneous with the flow on the existing path at its TTC level while at the same time honoring the reliability criteria outlined in R2.1.The Transmission Operator shall include the resolution of this adverse impact in its study report for the ATC Path. R2.6.Where multiple ownership of Transmission rights exists on an ATC Path, allocate TTC of that ATC Path in accordance with the contractual agreement made by the multiple owners of that ATC Path. R2.7.For ATC Paths whose path rating,adjusted for seasonal variance,was established,known and used in operation since January 1,1994,and no action has been taken to have the path rated using a different method,set the TTC at that previously established amount. R2.8.Create a study report that describes the steps above that were undertaken (R2.1 -R2.7),including the contingencies and assumptions used,when determining the TTC and the results of the study.Where three phase fault damping is used to determine stability limits,that report shall also identify the percent used and include justification for use unless specified otherwise in the ATCID. Each Transmission Operator shall establish the TTC at the lesser of the value calculated in R2 or any System Operating Limit (SOL)for that ATC Path.[Violation Risk Factor:Lower][Time Horizon:Operations Planning] Within seven calendar days of the finalization of the study report,the Transmission Operator shall make available to the Transmission Service Provider of the ATC Path, the most current value for TTC and the TTC study report documenting the assumptions used and steps taken in determining the current value for TTC for that ATC Path.[Violation Risk Factor:Lower][Time Horizon:Operations Planning] When calculating ETC for firm Existing Transmission Commitments (ETC)for a specified period for an ATC Path,the Transmission Service Provider shall use the algorithm below:[Violation Risk Factor:Lower][Time Horizon:Operations Planning] ETC =NLp +NITS¢+GFf¢+PTPr +ROR¢+OSrp Where: NL,is the firm capacity set aside to serve peak Native Load forecast commitments for the time period being calculated,to include losses,and Native Load growth,not otherwise included in Transmission Reliability Margin or Capacity Benefit Margin. NITS;is the firm capacity reserved for Network Integration Transmission Service serving Load,to include losses,and Load growth,not otherwise included in Transmission Reliability Margin or Capacity Benefit Margin. GFf is the firm capacity set aside for grandfathered Transmission Service and contracts for energy and/or Transmission Service,where executed prior to the Page 3 of 15 Standard AKMOD-029-01 -Rated System Path effective date of a Transmission Service Provider's Open Access Transmission Tariff or "safe harbor tariff.” PTP;is the firm capacity reserved for confirmed Point-to-Point Transmission Service. ROR;is the firm capacity reserved for Roll-over rights for contracts granting Transmission Customers the right of first refusal to take or continue to take Transmission Service when the Transmission Customer's Transmission Service contract expires or is eligible for renewal. OSs is the firm capacity reserved for any other service(s),contract(s),or agreement(s)not specified above using Firm Transmission Service as specified in the ATCID. R6.When calculating ETC for non-firm Existing Transmission Commitments (ETCyr) for all time horizons for an ATC Path the Transmission Service Provider shall use the following algorithm:[Violation Risk Factor:Lower][Time Horizon: Operations Planning] ETCyr =NITSyg +GF yr +PTPup +OSyne Where: NITSnyr is the non-firm capacity set aside for Network Integration Transmission Service serving Load (i.e.,secondary service),to include losses,and load growth not otherwise included in Transmission Reliability Margin or Capacity Benefit Margin. GFyr is the non-firm capacity set aside for grandfathered Transmission Service and contracts for energy and/or Transmission Service,where executed prior to the effective date of a Transmission Service Provider's Open Access Transmission Tariff or "safe harbor tariff.” PT Pyr is non-firm capacity reserved for confirmed Point-to-Point Transmission Service. OSxr is the non-firm capacity reserved for any other service(s),contract(s),or agreement(s)not specified above using non-firm transmission service as specified in the ATCID. R7.When calculating firm ATC for an ATC Path for a specified period,the Transmission Service Provider shall use the following algorithm:[Violation Risk Factor:Lower][Time Horizon:Operations Planning] ATC =TTC -ETCr--CBM -TRM +Postbacks-+counterflowsF Where ATCy is the firm Available Transfer Capability for the ATC Path for that period. TTC is the Total Transfer Capability of the ATC Path for that period. ETC;is the sum of existing firm commitments for the ATC Path during that period. CBM is the Capacity Benefit Margin for the ATC Path during that period. Page 4 of 15 Standard AKMOD-029-01 -Rated System Path TRM is the Transmission Reliability Margin for the ATC Path during that period. Postbacksr are changes to firm Available Transfer Capability due to a change in the use of Transmission Capacity for that period,that is non-recallable as defined in Business Practices. counterflows,are adjustments to firm Available Transfer Capability as determined by the Transmission Service Provider and specified in their ATCID. R8.When calculating non-firm ATC for an ATC Path for a specified period,the Transmission Service Provider shall use the following algorithm:[Violation Risk Factor:Lower][Time Horizon:Operations Planning] ATCnr =TTC -ETCp-ETCyp -CBMs -TRMy +Postbacksnr +counterflowsnr Where: ATCyr is the non-firm Available Transfer Capability for the ATC Path for that period. TTC is the Total Transfer Capability of the ATC Path for that period. ETC;is the sum of existing firm commitments for the ATC Path during that period. ETCnyys is the sum of existing non-firm commitments for the ATC Path during that period. CBMs is the Capacity Benefit Margin for the ATC Path that has been scheduled during that period. TRMzy is the Transmission Reliability Margin for the ATC Path that has not been released for sale (unreleased)as non-firm capacity by the Transmission Service Provider during that period. Postbacksyr are changes to non-firm Available Transfer Capability due to a change in the use of Transmission capacity for that period,that is recallable as defined in Business Practices. counterflowsyr are adjustments to non-firm Available Transfer Capability as determined by the Transmission Service Provider and specified in its ATCID. Page5 of 15 Standard AKMOD-029-01 -Rated System Path C.Measures M1. M2. M3. M4. MS. M6. M7. Each Transmission Operator that uses the Rated System Path Methodology shall produce any Transmission model it used to calculate TTC for purposes of calculating ATC for each ATC Path,as required in R1,for the time horizon(s)to be examined. (R1) M1.1.Production shall be in the same form and format used by the Transmission Operator to calculate the TTC,as required in R1.(R1) M1.2.The Transmission model produced must include the areas listed in R1.1.1 (or an equivalent representation,as described in the requirement)(R1.1) M1.3.The Transmission model produced must show the use of the modeling parameters stated in R1.1.2 through R1.1.10;except that,no evidence shall be required to prove:1)utilization of a Special Protection System where none was included in the model or 2)that no additions or retirements to the generation or Transmission system occurred.(R1.1.2 through R1.1.10) M1.4.The Transmission Operator must provide evidence that the models used to determine TTC included Facility Ratings as provided by the Transmission Owner and Generator Owner.(R1.2) Each Transmission Operator that uses the Rated System Path Methodology shall produce the ATCID it uses to show where it has described and used additional modeling criteria in its ACTID that are not otherwise included in MOD-29 (R1.1.4, R.1.1.9,and R1.1.10). Each Transmission Operator that uses the Rated System Path Methodology with paths with ratings established prior to January 1,1994 shall provide evidence the path and its rating were established prior to January 1,1994.(R2.7) Each Transmission Operator that uses the Rated System Path Methodology shall produce as evidence the study reports,as required in R.2.8,for each path for which it determined TTC for the period examined.(R2) Each Transmission Operator shall provide evidence that it used the lesser of the calculated TTC or the SOL as the TTC,by producing:1)all values calculated pursuant to R2 for each ATC Path,2)Any corresponding SOLs for those ATC Paths, and 3)the TTC set by the Transmission Operator and given to the Transmission Service Provider for use in R7and R8 for each ATC Path.(R3) Each Transmission Operator shall provide evidence (such as logs or data)that it provided the TTC and its study report to the Transmission Service Provider within seven calendar days of the finalization of the study report.(R4) The Transmission Service Provider shall demonstrate compliance with R5 by recalculating firm ETC for any specific time period as described in (MOD-001 R2), using the algorithm defined in R5 and with data used to calculate the specified value for the designated time period.The data used must meet the requirements specified in MOD-029-1 and the ATCID.To account for differences that may occur when recalculating the value (due to mixing automated and manual processes),any recalculated value that is within +/-15%or 15 MW,whichever is greater,of the Page 6 of 15 Standard AKMOD-029-01 -Rated System Path M8. M9. M10. originally calculated value,is evidence that the Transmission Service Provider used the algorithm in R5 to calculate its firm ETC.(R5) The Transmission Service Provider shall demonstrate compliance with R5 by recalculating non-firm ETC for any specific time period as described in (MOD-001 R2),using the algorithm defined in R6 and with data used to calculate this specified value for the designated time period.The data used must meet the requirements specified in the MOD-029 and the ATCID.To account for differences that may occur when recalculating the value (due to mixing automated and manual processes), any recalculated value that is within +/-15%or 15 MW,whichever is greater,of the originally calculated value,is evidence that the Transmission Service Provider used the algorithm in R6 to calculate its non-firm ETC.(R6) Each Transmission Service Provider shall produce the supporting documentation for the processes used to implement the algorithm that calculates firm ATCs,as required in R7.Such documentation must show that only the variables allowed in R7 were used to calculate firm ATCs,and that the processes use the current values for the variables as determined in the requirements or definitions.Note that any variable may legitimately be zero if the value is not applicable or calculated to be zero (such as counterflows,TRM,CBM,etc...).The supporting documentation may be provided in the same form and format as stored by the Transmission Service Provider. (R7) Each Transmission Service Provider shall produce the supporting documentation for the processes used to implement the algorithm that calculates non-firm ATCs,as required in R8.Such documentation must show that only the variables allowed in R8 were used to calculate non-firm ATCs,and that the processes use the current values for the variables as determined in the requirements or definitions.Note that any variable may legitimately be zero if the value is not applicable or calculated to be zero (such as counterflows,TRM,CBM,etc...).The supporting documentation may be provided in the same form and format as stored by the Transmission Service Provider.(R8) D.Compliance 1.Compliance Monitoring Process 1.1.Compliance Enforcement Authority IMC as Regional Entity unless IMC is transmission provider,then Alaska Energy Authority 1.2.Compliance Monitoring Period and Reset Time Frame Not applicable. 1.3.Data Retention -The Transmission Operator and Transmission Service Provider shall keep data or evidence to show compliance as identified below unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation: -The Transmission Operator shall have its latest models used to determine TTC for R1.(M1)Page 7 of 15 Standard AKMOD-029-01 -Rated System Path 1.4. 1.5. The Transmission Operator shall have the current,in force ATCID(s) provided by its Transmission Service Provider(s)and any prior versions of the ATCID that were in force since the last compliance audit to show compliance with R1.(M2) The Transmission Operator shall retain evidence of any path and its rating that was established prior to January 1,1994.(M3) The Transmission Operator shall retain the latest version and prior version of the TTC study reports to show compliance with R2.(M4) The Transmission Operator shall retain evidence for the most recent three calendar years plus the current year to show compliance with R3 and R4.(M5 and M6) The Transmission Service Provider shall retain evidence to show compliance in calculating hourly values required in R5 and R6 for the most recent 14 days;evidence to show compliance in calculating daily values required in R5 and R6 for the most recent 30 days;and evidence to show compliance in calculating daily values required in R5 and R6 for the most recent sixty days. (M7 and M8) The Transmission Service Provider shall retain evidence for the most recent three calendar years plus the current year to show compliance with R7 and R8. (M9 and M10) If a Transmission Service Provider or Transmission Operator is found non- compliant,it shall keep information related to the non-compliance until found compliant. The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records. Compliance Monitoring and Enforcement Processes: The following processes may be used: Compliance Audits Self-Certifications Spot Checking Compliance Violation Investigations Self-Reporting Complaints Additional Compliance Information None. Page8 of 15 Standard MOD-029-1a -Rated System Path Methodology Violation Severity Levels ar See > 1 |Level 1Masoo The Transmission Operator used a model that met all but one of the modeling requirements specified in R1.1. OR The Transmission Operator utilized one to ten Facility Ratings that were different from those specified by a Transmission Owner or Generation Owner in their Transmission model.(R1.2) The Transmission Operator used a model that met all but two of the modeling requirements specified in R1.1. OR The Transmission Operator utilized eleven to twenty Facility Ratings that were different from those specified by a Transmission Owner or Generation Owner in their Transmission model.(R1.2) Level3 The Transmission Operator used a model that met all but three of the modeling requirements specified in R1.1. OR The Transmission Operator utilized twenty-one to thirty Facility Ratings that were different from those specified by a Transmission Owner or Generation Owner in their Transmission model.(R1.2) Ei reac The Transmission Operator used a model that did not meet four or more of the modeling requirements specified in R1.1. OR The Transmission Operator utilized more than thirty Facility Ratings that were different from those specified by a Transmission Owner or Generation Owner in their Transmission model.(R1.2) R2 One or both of the following: ¢The Transmission Operator did not calculate TTC using one of the items in sub- requirements R2.1-R2.6. ¢The Transmission Operator does not include one required item in the study report required in R2.8. One or both of the following: *The Transmission Operator did not calculate TTC using two of the items in sub- requirements R2.1-R2.6. ¢The Transmission Operator does not include two required items in the study report required in R2.8. One or both of the following: ¢The Transmission Operator did not calculate TTC using three of the items in sub- requirements R2.1-R2.6. ¢The Transmission Operator does not include three required items in the study report required in R2.8. One or more of the following: *«The Transmission Operator did not calculate TTC using four or more of the items in sub- requirements R2.1-R2.6. ¢The Transmission Operator did not apply R2.7. ¢The Transmission Operator does not include four or more required items in the study report required in R2.8 Page 9 of 15 Standard MOD-029-1a -Rated System Path Methodology aR? R3. R4. Slee tdshyBabs(owervstVSLsollme The Transmission Operator did not specify the TTC as the lesser of the TTC calculated using the process described in R2 or any associated SOL for more than zero ATC Paths, BUT,not more than 1%of all ATC Paths or 1 ATC Path (whichever is greater). The Transmission Operator provided the TTC and study report to the Transmission Service Provider more than seven,but not more than 14 calendar days after the report was finalized. The Transmission Operator did not specify the TTC as the lesser of the TTC calculated using the process described in R2 or any associated SOL for more than 1%of all ATC Paths or 1 ATC Path (whichever is greater),BUT not more than 2%of all ATC Paths or 2 ATC Paths (whichever is greater). The Transmission Operator provided the TTC and study report to the Transmission Service Provider more than 14, but not more than 21 calendar days after the report was finalized. The Transmission Operator did not specify the TTC as the lesser of the TTC calculated using the process described in R2 or any associated SOL for more than 2%of all ATC Paths or 2 ATC Paths (whichever is greater),BUT not more than 5%of all ATC Paths or 3 ATC Paths (whichever is greater). The Transmission Operator provided the TTC and study report to the Transmission Service Provider more than 21, but not more than 28 calendar days after the report was finalized. 757%,a inh VSL j pe,a 1HighVS»Hl i Severe VSL The Transmission Operator did not specify the TTC as the lesser of the TTC calculated using the process described in . R2 or any associated SOL,for more than 5%of all ATC Paths or 3 ATC Paths (whichever |isgreater). The Transmission Operator provided the TTC and study report to the Transmission Service Provider more than 28 calendar days after the report was finalized. R5.For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M7 for the same period,and the absolute value difference was more than 15%of the value calculated in the measure or 15MW, whichever is greater,but not more than 25%of the value calculated in the measure or 25MW,whichever is greater. For a specified period,the Transmission Service Provider - calculated a firm ETC with an absolute value different than that calculated in M7 for the same period,and the absolute value difference was more than 25%of the value calculated in the measure or 25MW, whichever is greater,but not more than 35%of the value calculated in the measure or 35MW,whichever is greater. For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M7 for the same period,and the absolute value difference was more than 35%of the value calculated in the measure or 35MW, whichever is greater,but not more than 45%of the value calculated in the measure or 45MW,whichever is greater. For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M7 for the same period,and the absolute value difference was more than 45%of the value calculated in the measure or 45MW, whichever is greater. R6.For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M8 for the same period,and the absolute For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M8 for the same period,and the absolute For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M8 for the same period,and the absolute For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M8 for the same period,and the Page 10 of 15 Standard MOD-029-1a -Rated System Path Methodology value difference was more than 15%of the value calculatedin the measure or 15MW, whichever is greater,but not more than 25%of the value calculated in the measure or 25MW,whichever is greater. wg EN BE a Mme te ae value difference was more than 25%of the value calculated in the measure or 25MW, whichever is greater,but not more than 35%of the value calculated in the measure or 35MW,whichever is greater. value difference was more than 35%of the value calculated in the measure or 35MW, whichever is greater,but not more than 45%of the value calculated in the measure or 45MW,whichever is greater. earsodSeverereVSLabsolutevaluedifference was more than 45%of the value calculated in the measure or 45MW,whichever is greater. R7.The Transmission Service Provider did not use all the elements defined in R7 when determining firm ATC,or used additional elements,for more than zero ATC Paths,but not more than 5%of all ATC Paths or 1 ATC Path (whichever is greater). The Transmission Service Provider did not use all the elements defined in R7 when determining firm ATC,or used additional elements,for more than 5%of all ATC Paths or 1 ATC Path (whichever is greater),but not more than 10%of all ATC Paths or 2 ATC Paths (whichever is greater). The Transmission Service Provider did not use all the elements defined in R7 when determining firm ATC,or used additional elements,for more than 10%of all ATC Paths or 2 ATC Paths (whichever is greater),but not more than 15%of all ATC Paths or 3 ATC Paths (whichever is greater). The Transmission Service Provider did not use all the elements defined in R7 when determining firm ATC,or used additional elements,for more than 15%of all ATC Paths or more than 3 ATC Paths (whichever is greater). R8.The Transmission Service Provider did not use all the elements defined in R8 when determining non-firm ATC,or used additional elements,for more than zero ATC Paths,but not more than 5%of all ATC Paths or 1 ATC Path (whichever is greater). The Transmission Service Provider did not use all the elements defined in R8 when determining non-firm ATC,or used additional elements,for more than 5%of all ATC Paths or 1 ATC Path (whichever is greater),but not more than 10%of all ATC Paths or 2 ATC Paths (whichever is greater). The Transmission Service Provider did not use all the elements defined in R8 when determining non-firm ATC,or used additional elements,for more than 10%of all ATC Paths or 2 ATC Paths (whichever is greater),but not more than 15%of all ATC Paths or 3 ATC Paths (whichever is greater). The Transmission Service Provider did not use all the elements defined in R8 when determining non-firm ATC,or used additional elements,for more than 15%of all ATC Paths or more than 3 ATC Paths (whichever is greater). Page Il of 15 Standard MOD-029-1a -Rated System Path Methodology Version History Version Date Action Change Tracking iv Page 12 of |¥ Standard AKMOD-30-01 -Flowgate Methodology A.Introduction 1.='Title:Flowgate Methodology 2.Number:MOD-030-01 3.Purpose:To increase consistency and reliability in the development and documentation of transfer capability calculations for short-term use performed by entities using the Flowgate Methodology to support analysis and system operations.The determinations and calculations and penalties below are only applicable to paths under Open Access rules and actually in use as Open Access transfer paths (whether contract path or parallel flow path)i.e.Open Access transfers are scheduled. 4.Applicability: 4.1.1 Each Transmission Operator that uses the Flowgate Methodology to support the calculation of Available Flowgate Capabilities (AFCs)on Flowgates. 4.1.2 Each Transmission Service Provider that uses the Flowgate Methodology to calculate AFCs on Flowgates. 5.Proposed Effective Date:TBD Requirements R1.The Transmission Service Provider shall include in its "Available Transfer Capability Implementation Document”(ATCID): R11.The criteria used by the Transmission Operator to identify sets of Transmission Facilities as Flowgates that are to be considered in Available Flowgate Capability (AFC)calculations. R1.2..The following information on how source and sink for transmission service is accounted for in AFC calculations including: R1.2.1. R1.2.2. R1.2.3. R1.2.4. Define if the source used for AFC calculations is obtained from the source field or the Point of Receipt (POR)field of the transmission reservation. Define if the sink used for AFC calculations is obtained from the sink field or the Point of Delivery (POD)field of the transmission reservation. The source/sink or POR/POD identification and mapping to the model. If the Transmission Service Provider's AFC calculation process involves a grouping of generators,the ATCID must identify how these generators participate in the group. R2.The Transmission Operator shall perform the following: R2.1.Include Flowgates used in the AFC process based,at a minimum,on the following criteria: R2.1.1.Results of a first Contingency transfer analysis for ATC Paths internal to a Transmission Operator's system up to the path capability such that at a minimum the first three limiting Elements and their worst associated Contingency combinations with an OTDF of at least 5%and within the Transmission Operator's system are included as Flowgates. R2.1.1.1.Use first Contingency criteria consistent with those first Contingency criteria used in planning of operations for the Page 1 of 19 Standard AKMOD-30-01 -Flowgate Methodology R2.1.2. R2.1.3. R2.1.4. applicable time periods,including use of Special Protection Systems. R2.1.1.2.Only the most limiting element in a series configuration needs to be included as a Flowgate. R2.1.1.3.If any limiting element is kept within its limit for its associated worst Contingency by operating within the limits of another Flowgate,then no new Flowgate needs to be established for such limiting elements or Contingencies. Results of a first Contingency transfer analysis from all adjacent Balancing Authority source and sink (as defined in the ATCID)combinations up to the path capability such that at a minimum the first three limiting Elements and their worst associated Contingency combinations with an Outage Transfer Distribution Factor (OTDF)of at least 5%and within the Transmission Operator's system are included as Flowgates unless the interface between such adjacent Balancing Authorities is accounted for using another ATC methodology. R2.1.2.1.Use first Contingency criteria consistent with those first Contingency criteria used in planning of operations for the applicable time periods,including use of Special Protection Systems. R2.1.2.2.Only the most limiting element in a series configuration needs to be included as a Flowgate. R2.1.2.3.If any limiting element is kept within its limit for its associated worst Contingency by operating within the limits of another Flowgate,then no new Flowgate needs to be established for such limiting elements or Contingencies. Any limiting Element/Contingency combination at least within its Reliability Coordinator's Area that has been subjected to an Interconnection-wide congestion management procedure within the last 12 months,unless the limiting Element/Contingency combination is accounted for using another ATC methodology or was created to address temporary operating conditions. Any limiting Element/Contingency combination within the Transmission model that has been requested to be included by any other Transmission Service Provider using the Flowgate Methodology or Area Interchange Methodology,where: R2.1.4.1.The coordination of the limiting Element/Contingency combination is not already addressed through a different methodology,and -Any generator within the Transmission Service Provider's area has at least a 5%Power Transfer Distribution Factor (PTDF)or Outage Transfer Distribution Factor (OTDF) impact on the Flowgate when delivered to the aggregate load of its own area,or -A transfer from any Balancing Area within the Transmission Service Provider's area to a Balancing Area Page 2 of 19 Standard AKMOD-30-01 -Flowgate Methodology R4. R2.2. R2.3. R2.6. adjacent has at least a 5%PTDF or OTDF impact on the Flowgate. -The Transmission Operator may utilize distribution factors less than 5%if desired. R2.1.4.2.The limiting Element/Contingency combination is included in the requesting Transmission Service Provider's methodology. At a minimum,establish a list of Flowgates by creating,modifying,or deleting Flowgate definitions at least once per calendar year. At a minimum,establish a list of Flowgates by creating,modifying,or deleting Flowgates that have been requested as part of R2.1.4 within thirty calendar days from the request. Establish the TFC of each of the defined Flowgates as equal to: -For thermal limits,the System Operating Limit (SOL)of the Flowgate. -For voltage or stability limits,the flow that will respect the SOL of the Flowgate. At a minimum,establish the TFC once per calendar year. R2.5.1.If notified of a change in the Rating by the Transmission Owner that would affect the TFC of a flowgate used in the AFC process,the TFC should be updated within seven calendar days of the notification. Provide the Transmission Service Provider with the TFCs within seven calendar days of their establishment. The Transmission Operator shall make available to the Transmission Service Provider a Transmission model to determine Available Flowgate Capability (AFC)that meets the following criteria: R3.1. R3.2. R3.3. R3.4. R3.5. Contains generation Facility Ratings,such as generation maximum and minimum output levels,specified by the Generator Owners of the Facilities within the model. Updated at least once per day for AFC calculations for intra-day,next day,and days two through 30. Updated at least once per month for AFC calculations for months two through 13. Contains modeling data and system topology for the Facilities within its Reliability Coordinator's Area.Equivalent representation of radial lines and Facilities161kV or below is allowed. Contains modeling data and system topology (or equivalent representation)for immediately adjacent and beyond Reliability Coordination Areas. When calculating AFCs,the Transmission Service Provider shall represent the impact of Transmission Service as follows: If the source,as specified in the ATCID,has been identified in the reservation and it is discretely modeled in the Transmission Service Provider's Transmission model,use the discretely modeled point as the source. If the source,as specified in the ATCID,has been identified in the reservation and the point can be mapped to an "equivalence”or "aggregate”representation in the Page 3 of 19 Standard AKMOD-30-01 -Flowgate Methodology Transmission Service Provider's Transmission model,use the modeled equivalence or aggregate as the source. If the source,as specified in the ATCID,has been identified in the reservation and the point cannot be mapped to a discretely modeled point or an "equivalence” representation in the Transmission Service Provider's Transmission model,use the immediately adjacent Balancing Authority associated with the Transmission Service Provider from which the power is to be received as the source. If the source,as specified in the ATCID,has not been identified in the reservation use the immediately adjacent Balancing Authority associated with the Transmission Service Provider from which the power is to be received as the source. If the sink,as specified in the ATCID,has been identified in the reservation and it is discretely modeled in the Transmission Service Provider's Transmission model,use the discretely modeled point as the sink. If the sink,as specified in the ATCID,has been identified in the reservation and the point can be mapped to an "equivalence”or "aggregate”representation in the Transmission Service Provider's Transmission model,use the modeled equivalence or aggregate as the sink. If the sink,as specified in the ATCID,has been identified in the reservation and the point cannot be mapped to a discretely modeled point or an "equivalence” representation in the Transmission Service Provider's Transmission model,use the immediately adjacent Balancing Authority associated with the Transmission Service Provider receiving the power as the sink. If the sink,as specified in the ATCID,has not been identified in the reservation use the immediately adjacent Balancing Authority associated with the Transmission Service Provider receiving the power as the sink. R5.When calculating AFCs,the Transmission Service Provider shall: R6. RS.1. RS5.2. R53. Use the models provided by the Transmission Operator. Include in the transmission model expected generation and Transmission outages, additions,and retirements within the scope of the model as specified in the ATCID and in effect during the applicable period of the AFC calculation for the Transmission Service Provider's area,all adjacent Transmission Service Providers, and any Transmission Service Providers with which coordination agreements have been executed. For external Flowgates,identified in R2.1.4,use the AFC provided by the Transmission Service Provider that calculates AFC for that Flowgate. When calculating the impact of ETC for firm commitments (ETC,;)for all time periods for a Flowgate,the Transmission Service Provider shall sum the following: R6.1.The impact of firm Network Integration Transmission Service,including the impacts of generation to load,in the model referenced in R5.2 for the Transmission Service Provider's area,based on: R6.1.1.Load forecast for the time period being calculated,including Native Load and Network Service load Page 4 of 19 Standard AKMOD-30-01 -Flowgate Methodology R6.2. R6.3. R6.4. R6.5. R6.6. R6.7. R6.1.2..Unit commitment and Dispatch Order,to include all designated network resources and other resources that are committed or have the legal obligation to run as specified in the Transmission Service Provider's ATCIDD. The impact of any firm Network Integration Transmission Service,including the impacts of generation to load in the model referenced in R5.2 and has a distribution factor equal to or greater than the percentage'used to curtail in the Interconnection- wide congestion management procedure used by the Transmission Service Provider, for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed based on: R6.2.1.Load forecast for the time period being calculated,including Native Load and Network Service load R6.2.2.Unit commitment and Dispatch Order,to include all designated network resources and other resources that are committed or have the legal obligation to run as specified in the Transmission Service Provider's ATCID. The impact of all confirmed firm Point-to-Point Transmission Service expected to be scheduled,including roll-over rights for Firm Transmission Service contracts,for the Transmission Service Provider's area. The impact of any confirmed firm Point-to-Point Transmission Service expected to be scheduled,filtered to reduce or eliminate duplicate impacts from transactions using Transmission service from multiple Transmission Service Providers,including roll- over rights for Firm Transmission Service contracts having a distribution factor equaltoorgreaterthanthepercentage”used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider,for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. The impact of any Grandfathered firm obligations expected to be scheduled or expected to flow for the Transmission Service Provider's area. The impact of any Grandfathered firm obligations expected to be scheduled or expected to flow that have a distribution factor equal to or greater than the percentage'used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider,for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. The impact of other firm services determined by the Transmission Service Provider. R7.When calculating the impact of ETC for non-firm commitments (ETCyg;)for all time periods for a Flowgate the Transmission Service Provider shall sum: 'A percentage less than that used in the Interconnection-wide congestion management procedure may be utilized. ?A percentage less than that used in the Interconnection-wide congestion management procedure may be utilized. 3 A percentage less than that used in the Interconnection-wide congestion management procedure may be utilized. Page §of 19 Standard AKMOD-30-01 -Flowgate Methodology R7.1.The impact of all confirmed non-firm Point-to-Point Transmission Service expected to be scheduled for the Transmission Service Provider's area. R7.2.The impact of any confirmed non-firm Point-to-Point Transmission Service expected to be scheduled,filtered to reduce or eliminate duplicate impacts from transactions using Transmission service from multiple Transmission Service Providers,that haveadistributionfactorequaltoorgreaterthanthepercentage"used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider,for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. R7.3.The impact of any Grandfathered non-firm obligations expected to be scheduled or expected to flow for the Transmission Service Provider's area. R7.4.The impact of any Grandfathered non-firm obligations expected to be scheduled or expected to flow that have a distribution factor equal to or greater than the percentage'used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider,for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. R7.5.The impact of non-firm Network Integration Transmission Service serving Load within the Transmission Service Provider's area (i.e.,secondary service),to include load growth,and losses not otherwise included in Transmission Reliability Margin or Capacity Benefit Margin. R7.6.The impact of any non-firm Network Integration Transmission Service (secondary service)with a distribution factor equal to or greater than the percentage®used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider,filtered to reduce or eliminate duplicate impacts from transactions using Transmission service from multiple Transmission Service Providers,for all adjacent Transmission Service Providers and any other Transmission Service Providers with which coordination agreements have been executed. R7.7.The impact of other non-firm services determined by the Transmission Service Provider. R8.When calculating firm AFC for a Flowgate for a specified period,the Transmission Service Provider shall use the following algorithm (subject to allocation processes described in the ATCID): AFC,=TFC -ETC,;-CBM;-TRM;+Postbacks,;+counterflows,; Where: *A percentage less than that used in the Interconnection-wide congestion management procedure may be utilized. >A percentage less than that used in the Interconnection-wide congestion management procedure may be utilized. ®A percentage less than that used in the Interconnection-wide congestion management procedure may be utilized. Page 6 of 19 Standard AKMOD-30-01 -Flowgate Methodology TFC is the Total Flowgate Capability of the Flowgate. ETC;,,is the sum of the impacts of existing firm Transmission commitments for the Flowgate during that period. CBM;is the impact of the Capacity Benefit Margin on the Flowgate during that period. TRM,,is the impact of the Transmission Reliability Margin on the Flowgate during that period. Postbacks,;are changes to firm AFC due to a change in the use of Transmission Capacity (non-recallable)for that period,as defined in Business Practices. counterflows,;are adjustments to firm AFC as determined by the Transmission Service Provider and specified in their ATCID. R9.When calculating non-firm AFC for a Flowgate for a specified period,the Transmission Service Provider shall use the following algorithm (subject to allocation processes described in the ATCID):[Violation Risk Factor:To Be Determined][Time Horizon:Operations Planning] AFCyp =TFC -ETCp,-ETCygi -CBMs;-TRMy;+Postbacksyg;+counterflows Where: AF Cyr is the non-firm Available Flowgate Capability for the Flowgate for that period. TFC is the Total Flowgate Capability of the Flowgate. ETC;,;is the sum of the impacts of existing firm Transmission commitments for the Flowgate during that period. ETCyp;is the sum of the impacts of existing non-firm Transmission commitments for the Flowgate during that period. CBM,is the impact of any schedules during that period using Capacity Benefit Margin. TRMjj is the impact on the Flowgate of the Transmission Reliability Margin that has not been released (unreleased)for sale as non-firm capacity by the Transmission Service Provider during that period. Postbacks yr are changes to non-firm Available Flowgate Capability due to a change in the use of Transmission Capacity (recallable)for that period,as defined in Business Practices. counterflowsy,are adjustments to non-firm AFC as determined by the Transmission Service Provider and specified in their ATCID. R10.Each Transmission Service Provider shall recalculate AFC,utilizing the updated models described in R3.2,R3.3,and RS,at a minimum on the following frequency,unless none of the calculated values identified in the AFC equation have changed:[Violation Risk Factor: To Be Determined][Time Horizon:Operations Planning] R10.1.For hourly AFC,once per hour.Transmission Service Providers are allowed up to 175 hours per calendar year during which calculations are not required to be performed,despite a change in a calculated value identified in the AFC equation. R10.2.For daily AFC,once per day. R10.3.For monthly AFC,once per week. Page 7 of 19 Standard AKMOD-30-01 -Flowgate Methodology R11.When converting Flowgate AFCs to ATCs for ATC Paths,the Transmission Service Provider shall convert those values based on the following algorithm:[Violation Risk Factor:To Be Determined)[Time Horizon:Operations Planning] ATC =min(P) P ={PATC,,PATC3,...PATC,} AFC,PATC,= np Where: ATC is the Available Transfer Capability. P is the set of partial Available Transfer Capabilities for all "impacted”Flowgates honored by the Transmission Service Provider;a Flowgate is considered "impacted”by a path if the Distribution Factor for that path is greater than the percentage'used to curtail in the Interconnection-wide congestion management procedure used by the Transmission Service Provider on an OTDF Flowgate or PTDF Flowgate. PATC,is the partial Available Transfer Capability for a path relative to a Flowgate n. AFC,,is the Available Flowgate Capability of a Flowgate n. DF,,is the distribution factor for Flowgate n relative to path p. C.Measures M1. M2. M3. M4. MS. M6. M7. Each Transmission Service Provider shall provide its ATCID and other evidence (such as written documentation)to show that its ATCID contains the criteria used by the Transmission Operator to identify sets of Transmission Facilities as Flowgates and information on how sources and sinks are accounted for in AFC calculations.(R1) The Transmission Operator shall provide evidence (such as studies and working papers)that all Flowgates that meet the criteria described in R2.1 are considered in its AFC calculations. (R2.1) The Transmission Operator shall provide evidence (such as logs)that it updated its list of Flowgates at least once per calendar year.(R2.2) The Transmission Operator shall provide evidence (such as logs and dated requests)that it updated the list of Flowgates within thirty calendar days from a request.(R2.3) The Transmission Operator shall provide evidence (such as data or models)that it determined the TFC for each Flowgate as defined in R2.4.(R2.4) The Transmission Operator shall provide evidence (such as logs)that it established the TFCs for each Flowgate in accordance with the timing defined in R2.5.(R2.5) The Transmission Operator shall provide evidence (such as logs and electronic communication)that it provided the Transmission Service Provider with updated TFCs within seven calendar days of their determination.(R2.6) 7 A percentage less than that used in the Interconnection-wide congestion management procedure may be utilized. Page 8 of 19 Standard AKMOD-30-01 -Flowgate Methodology M8. M9. M10. M11. M12. M13. M14. M15. M16. The Transmission Operator shall provide evidence (such as written documentation,logs, models,and data)that the Transmission model used to determine AFCs contains the information specified in R3.(R3) The Transmission Service Provider shall provide evidence (such as written documentation and data)that the modeling of point-to-point reservations was based on the rules described in R4. (R4) The Transmission Service Provider shall provide evidence including the models received from Transmission Operators and other evidence (such as documentation and data)to show that it used the Transmission Operator's models in calculating AFC.(R5.1) The Transmission Service Provider shall provide evidence (such as written documentation, electronic communications,and data)that all expected generation and Transmission outages, additions,and retirements were included in the AFC calculation as specified in the ATCID. (R5.2) The Transmission Service Provider shall provide evidence (such as logs,electronic communications,and data)that AFCs provided by third parties on external Flowgates were used instead of those calculated by the Transmission Operator.(R5.3) The Transmission Service Provider shall demonstrate compliance with R6 by recalculating firm ETC for any specific time period as described in (MOD-001 R2),using the requirements defined in R6 and with data used to calculate the specified value for the designated time period.The data used must meet the requirements specified in this standard and the ATCID. To account for differences that may occur when recalculating the value (due to mixing automated and manual processes),any recalculated value that is within +/-15%or 15 MW, whichever is greater,of the originally calculated value,is evidence that the Transmission Service Provider used the requirements defined in R6 to calculate its firm ETC.(R6) The Transmission Service Provider shall demonstrate compliance with R7 by recalculating non-firm ETC for any specific time period as described in (MOD-001 R2),using the requirements defined in R7 and with data used to calculate the specified value for the designated time period.The data used must meet the requirements specified in the standard and the ATCID.To account for differences that may occur when recalculating the value (due to mixing automated and manual processes),any recalculated value that is within +/-15%or 15 MW,whichever is greater,of the originally calculated value,is evidence that the Transmission Service Provider used the requirements in R7 to calculate its non-firm ETC. (R7) Each Transmission Service Provider shall produce the supporting documentation for the processes used to implement the algorithm that calculates firm AFCs,as required in R8. Such documentation must show that only the variables allowed in R8 were used to calculate firm AFCs,and that the processes use the current values for the variables as determined in the requirements or definitions.Note that any variable may legitimately be zero if the value is not applicable or calculated to be zero (such as counterflows,TRM,CBM,etc.).The supporting documentation may be provided in the same form and format as stored by the Transmission Service Provider.(R8) Each Transmission Service Provider shall produce the supporting documentation for the processes used to implement the algorithm that calculates non-firm AFCs,as required in R9. Such documentation must show that only the variables allowed in R9 were used to calculate non-firm AFCs,and that the processes use the current values for the variables as determined in the requirements or definitions.Note that any variable may legitimately be zero if the Page 9 of 19 Standard AKMOD-30-01 -Flowgate Methodology M17. MI8. value is not applicable or calculated to be zero (such as counterflows,TRM,CBM,etc.).The supporting documentation may be provided in the same form and format as stored by the Transmission Service Provider.(R9) The Transmission Service Provider shall provide evidence (such as documentation,dated logs,and data)that it calculated AFC on the frequency defined in R10.(R10) The Transmission Service Provider shall provide evidence (such as documentation and data) when converting Flowgate AFCs to ATCs for ATC Paths,it follows the procedure described in R11.(R11) D.Compliance 1.Compliance Monitoring Process 1.1. 1.2. 1.3. 1.4. Compliance Enforcement Authority IMC Regional Reliability Entity unless the IMC is the relevant Transmission provider,then Alaska Energy Authority Compliance Monitoring Period and Reset Time Frame Not applicable. Data Retention The Transmission Operator and Transmission Service Provider shall keep data or evidence to show compliance as identified below unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation: -The Transmission Service Provider shall retain its current,in force ATCID and any prior versions of the ATCID that were in force since the last compliance audit to show compliance with R1. -The Transmission Operator shall have its latest model used to determine flowgates and TFC and evidence of the previous version to show compliance with R2 and R3. -The Transmission Operator shall retain evidence to show compliance with R2.1,R2.3 for the most recent 12 months. -The Transmission Operator shall retain evidence to show compliance with R2.2,R2.4 and R2.5 for the most recent three calendar years plus current year. -The Transmission Service Provider shall retain evidence to show compliance with R4 for 12 months or until the model used to calculate AFC is updated,whichever is longer. -The Transmission Service Provider shall retain evidence to show compliance with RS, R8,R9,R10,and R11 for the most recent calendar year plus current year. -The Transmission Service Provider shall retain evidence to show compliance in calculating hourly values required in R6 and R7 for the most recent 14 days;evidence to show compliance in calculating daily values required in R6 and R7 for the most recent 30 days; and evidence to show compliance in calculating monthly values required in R6 and R7 for the most recent sixty days. -Ifa Transmission Service Provider or Transmission Operator is found non-compliant,it shall keep information related to the non-compliance until found compliant. The Compliance Enforcement Authority shall keep the last audit records and all requested and submitted subsequent audit records. Compliance Monitoring and Enforcement Processes: Page 10 of 19 Standard AKMOD-30-01 -Flowgate Methodology The following processes may be used: Compliance Audits Self-Certifications Spot Checking Compliance Violation Investigations Self-Reporting Complaints 1.5.Additional Compliance Information None. Page 11 of 19 Standard MOD-030-02 -Flowgate Methodology 2.Violation Severity Levels e The Transmission Operator established its list of Flowgates less frequently than once per calendar year, but not more than three months late as described in R2.2. e The Transmission Operator established its list of Flowgates more than thirty days,but not more than sixty days,following a request to create,modify or delete a flowgate as described in R2.3. ¢The Transmission Operator has not updated its Flowgate TFC when notified by the Transmission Owner in more than 7 days,but it has not been more than 14 days e The Transmission Operator did not include a Flowgate in their AFC calculations that met the criteria described in R2.1. e The Transmission Operator established its list of Flowgates more than three months late,but not more than six months late as described in R2.2. e The Transmission Operator established its list of Flowgates more than sixty days,but not more than ninety days,following a request to create,modify or delete a flowgate as described in R2.3. e The Transmission Operator R1.The Transmission Service The Transmission Service The Transmission Service The Transmission Service Provider does not include in its |Provider does not include in its |Provider does not include in its |Provider does not include in its ATCID one or two of the sub-ATCID three of the sub-ATCID the information ATCID the information requirements listed under R1.2,|requirements listed under R1.2,|described in R1.1.described in R1.1 and R1.2 or the sub-requirement is or the sub-requirement is OR (1.2.1,1.2.2.,1.2.3,and 1.2.4 incomplete.incomplete.are missing). The Transmission Service Provider does not include in its ATCID the information described in R1.2 (1.2.1,1.2.2., 4.2.3,and 1.2.4 are missing). R2.One or more of the following:One or more of the following:One or more of the following:One or more of the following: e The Transmission Operator did not include two to five Flowgates in their AFC calculations that met the criteria described in R2.1. e The Transmission Operator established its list of Flowgates more than six months late,but not more than nine months late as described in R2.2. e The Transmission Operator established its list of Flowgates more than ninety days,but not more than 120 days,following a request to create,modify or delete a flowgate as described in R2.3. The Transmission Operator e The Transmission Operator did not include six or more Flowgates in their AFC calculations that met the criteria described in R2.1. e The Transmission Operator established its list of Flowgates more than nine months late as described in R2.2. e The Transmission Operator did not establish its list of internal Flowgates as described in R2.2. e The Transmission Operator established its list of Flowgates more than 120 days following a request to create,modify or delete a flowgate as described in Page 12 of 19 Standard MOD-030-02 -Flowgate Methodology since the notification (RO 5.1) The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs within seven days (one week)of their determination, but is has not been more than 14 days (two weeks) since their determination. 3 ye Moderate siitas=e Pa Sarors ae*.eSSahasnotupdateditsFlowgate TFCs at least once within a calendar year,and it has been not more than 15 months since the last update. The Transmission Operator has not updated its Flowgate TFC when notified by the Transmission Owner in more than 14 days,but it has not been more than 21 days since the notification (R2.5.1) The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs in more than 14 days (two weeks)of their determination,but is has not been more than 21 days (three weeks)since their determination. TFCs at least once within a calendar year,and it has been more than 15 months but not more than 18 months since the last update. The Transmission Operator has not updated its Flowgate TFCs when notified by the Transmission Owner in more than 21 days,but it has not been more than 28 days since the notification (R2.5.1) The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs in more than 21 days (three weeks)of their determination,but is has not been more than 28 days (four weeks)since their determination. The Transmission Operator did not establish its list of external Flowgates following a request to create,modify or delete an external flowgate as described in R2.3. The Transmission Operator did not determine the TFC for a flowgate as described in R2.4. The Transmission Operator has not updated its Flowgate TFCs at least once within a calendar year,and it has been more than 18 months since the last update.(R2.5) The Transmission Operator has not updated its Flowgate TFCs when notified by the Transmission Owner in more than 28 calendar days (R2.5.1) The Transmission Operator has not provided its Transmission Service Provider with its Flowgate TFCs in more than 28 days (4 weeks)of their determination. Page 13 of 19 Standard MOD-030-02 -Flowgate Methodology R3.One or more of the following: e The Transmission Operator used one to ten Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. e The Transmission Operator did not update the model per R3.2 for one or more calendar days but not more than 2 calendar days e The Transmission Operator did not update the model for per R3.3 for one or more months but not more than six weeks One or more of the following: e The Transmission Operator used eleven to twenty Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. e The Transmission Operator did not update the model per R3.2 for more than 2 calendar days but not more than 3 calendar days e The Transmission Operator did not update the model for per R3.3 for more than six weeks but not more than eight weeks One or more of the following: e The Transmission Operator used twenty-one to thirty Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. e The Transmission Operator did not update the model per R3.2 for more than 3 calendar days but not more than 4 calendar days e The Transmission Operator did not update the model for per R3.3 for more than eight weeks but not more than ten weeks One or more of the following: e The Transmission Operator did not update the model per R3.2 for more than 4 calendar days e The Transmission Operator did not update the model for per R3.3 for more than ten weeks e The Transmission Operator used more than thirty Facility Ratings that were different from those specified by a Transmission or Generator Owner in their Transmission model. e The Transmission operator did not include in the Transmission model detailed modeling data and topology for its own Reliability Coordinator area. e The Transmission operator did not include in the Transmission modeling data and topology for immediately adjacent and beyond Reliability Coordinator area. R4.The Transmission Service Provider did not represent the impact of Transmission Service as described in R4 for more than zero,but not more than The Transmission Service Provider did not represent the impact of Transmission Service as described in R4 for more than 5%,but not more than The Transmission Service Provider did not represent the impact of Transmission Service as described in R4 for more than 10%,but not more than The Transmission Service Provider did not represent the impact of Transmission Service as described in R4 for more than 15%of all reservations;or Page 14 of 19 Standard MOD-030-02 -Flowgate Methodology 5%of PT reservations.or more than zero,but not more than 1 reservation,whichever is greater.. dE aieceeme High VSL Sees10%of all reservations:or more than 1,but not more than 2 reservations,whichever is greater.. FT egStSst=<of all reservations;or more than 2,but not more than 3 reservations,whichever is greater.. more than 3 ecervations whicheveris greater.. RS.The Transmission Service Provider did not include in the AFC process one to ten expected generation or Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. The Transmission Service Provider did not include in the AFC process eleven to twenty- five expected generation and Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. The Transmission Service Provider did not include in the AFC process twenty-six to fifty expected generation and Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. One or more of the following: e The Transmission Service Provider did not use the model provided by the Transmission Operator. e The Transmission Service Provider did not include in the AFC process more than fifty expected generation and Transmission outages, additions or retirements within the scope of the model as specified in the ATCID. e The Transmission Service provider did not use AFC provided by a third party. R6.For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M13 for the same period,and the absolute value difference was more than 15%of the value calculated in the measure or 15MW, whichever is greater,but not more than 25%of the value calculated in the measure or For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M13 for the same period,and the absolute value difference was more than 25%of the value calculated in the measure or 25MW, whichever is greater,but not more than 35%of the value calculated in the measure or For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M13 for the same period,and the absolute value difference was more than 35%of the value calculated in the measure or 35MW, whichever is greater,but not more than 45%of the value calculated in the measure or For a specified period,the Transmission Service Provider calculated a firm ETC with an absolute value different than that calculated in M13 for the same period,and the absolute value difference was more than 45%of the value calculated in the measure or 45MW, whichever is greater. Page 15 of 19 Standard MOD-030-02 -Flowgate Methodology Wea oSMW.whichever is greater”BMW whichever isS greater.a5MW.whichever is greater R7.For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M14 for the same period,and the absolute value difference was more than 15%of the value calculated in the measure or 15MW, whichever is greater,but not more than 25%of the value calculated in the measure or 25MW,whichever is greater. For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M14 for the same period,and the absolute value difference was more than 25%of the value calculated in the measure or 25MW, whichever is greater,but not more than 35%of the value calculated in the measure or 35MW,whichever is greater. For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M14 for the same period,and the absolute value difference was more than 35%of the value calculated in the measure or 35MW, whichever is greater,but not more than 45%of the value calculated in the measure or 45MW,whichever is greater. For a specified period,the Transmission Service Provider calculated a non-firm ETC with an absolute value different than that calculated in M14 for the same period,and the absolute value difference was more than 45%of the value calculated in the measure or 45MW, whichever is greater. R8. The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC,or used additional elements,for more than zero Flowgates,but not more than 5%of all Flowgates or 1 Flowgate (whichever is greater). The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC,or used additional elements,for more than 5%of all Flowgates or 1 Flowgates (whichever is greater),but not more than 10%of all Flowgates or 2 Flowgates (whichever is greater). The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC,or used additional elements,for more than 10%of all Flowgates or 2 Flowgates (whichever is greater),but not more than 15%of all Flowgates or 3 Flowgates (whichever is greater). The Transmission Service Provider did not use all the elements defined in R8 when determining firm AFC,or used additional elements,for more than 15%of all Flowgates or more than 3 Flowgates (whichever is greater). RQ.The Transmission Service Provider did not use all the elements defined in R8 when determining non-firm AFC,or used additional elements,for more than zero Flowgates,but The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC,or used additional elements,for more than 5%of all Flowgates The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC,or used additional elements,for more than 10%of all The Transmission Service Provider did not use all the elements defined in R9 when determining non-firm AFC,or used additional elements,for more than 15%of all Page 16 of 19 Standard MOD-030-02 --Flowgate Methodology not more than 5%of all Flowgates or 1 Flowgate (whichever is greater). greater),but not more than 10%of all Flowgates or 2 Flowgates (whichever is greater). Flowgates or 2 Flowgates fh OKaa>ers) (whichever is greater),but not more than 15%of all Flowgates or 3 Flowgates (whichever is greater). So Severe VSL ae Flowgates or more than 3 Flowgates (whichever is greater). R10 One or more of the following: *For Hourly,the values described in the AFC equation changed and the Transmission Service provider did not calculate for one or more hours but not more than 15 hours, and was in excess of the 175-hour per year requirement. »For Daily,the values described in the AFC equation changed and the Transmission Service provider did not calculate for one or more calendar days but not more than 3 calendar days. *For Monthly,the values described in the AFC equation changed and the Transmission Service provider did not calculate for seven or more calendar days,but less than 14 calendar days. One or more of the following: *For Hourly,the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 15 hours but not more than 20 hours, and was in excess of the 175-hour per year requirement. *For Daily,the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 3 calendar days but not more than 4 calendar days. *For Monthly,the values described in the AFC equation changed and the Transmission Service provider did not calculate for 14 or more calendar days,but less than 21 calendar days. One or more of the following: =For Hourly,the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 20 hours but not more than 25 hours, and was in excess of the 175-hour per year requirement. #For Daily,the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 4 calendar days but not more than 5 calendar days. *For Monthly,the values described in the AFC equation changed and the Transmission Service provider did not calculate for 21 or more calendar days,but less than 28 calendar days. One or more of the following: *For Hourly,the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 25 hours, and was in excess of the 175-hour per year requirement. »For Daily,the values described in the AFC equation changed and the Transmission Service provider did not calculate for more than 5 calendar days. *For Monthly,the values described in the AFC equation changed and the Transmission Service provider did not calculate for 28 or more calendar days. Page 17 of 19 ae eae ret we get ss Standard MOD-030-02 -Flowgate Methodology The Transmission Service Provider did not follow theN/A N/A N/A procedure for converting Flowgate AFCs to ATCs described in R11. Page 18 of 19 Standard MOD-030-02 -Flowgate Methodology A.Regional Differences None identified. B.Associated Documents Version History Version Date Action Change Tracking Page 19 of 19 Standard MOD-030-02 -Flowgate Methodology Page 19 of 19