Loading...
HomeMy WebLinkAbout2025-05-16 RTO Agenda128868497.1 0084203-00001 RAILBELT TRANSMISSION ORGANIZATION (RTO) GOVERNANCE COMMITTEE AGENDA May 16, 2025 9:00 AM Alaska Energy Authority Conference Room To participate dial 1-888-585-9008 and use code 212-753-619# 1. CALL TO ORDER 2. ROLL CALL (for Committee members) 3. PUBLIC ROLL CALL (for all others present) 4. AGENDA APPROVAL 5. PUBLIC COMMENTS 6. APPROVAL OF THE MEETING MINUTES –May 2, 2025 7. OLD BUSINESS A. Working Group Update – Daniel Heckman B. RTO Certificate Filing and OATT Filing – Tina Grovier 8. NEW BUSINESS A. Presentation on HB307 Requirements for the Backbone Transmission System B. Draft Backbone Transmission System Policy C. Composition of the Backbone Transmission System for the Alaska Railbelt D. Presentation on HB307 OATT Requirements & Proposed Changes to FERC Pro Forma OATT E. Presentation on Revenue Mechanism 9. EXECUTIVE SESSION – (Bylaws Section 5.12.3) To discuss matters, the immediate knowledge of which could have an adverse effect on the finances or legal position of the RTO, the Committee or Authority, or that are confidential under state, federal, or local law. 10. MEMBERS COMMENTS 11. NEXT MEETING DATE – May 28, 2025, 9:00 am 12. ADJOURNMENT __________________________________________________________________________ RTO Minutes 5/02/25 Page 1 of 3 RAILBELT TRANSMISSION ORGANIZATION (RTO) MEETING MINUTES May 2, 2025 Alaska Energy Authority Conference Room 1. CALL TO ORDER Vice Chair Million, GVEA, called the Railbelt Transmission Organization Governance Committee meeting to order at 11:30 a.m. A quorum was established. 2. ROLL CALL (for Committee members) Travis Million (Golden Valley Electric Association [GVEA]); Jon Sinclair (Matanuska Electric Association [MEA]); Brad Janorschke (Homer Electric Association [HEA]); Brian Hickey (City of Seward); Arthur Miller (Chugach Electric Association [CEA]); Curtis Thayer (Alaska Energy Authority [AEA]); and Ed Jenkin (Railbelt Reliability Counsel [RRC]). 3. PUBLIC ROLL CALL (for all others present) Fernanda Conrad (Accu-Type Depositions); Karen Bell, Jennifer Bertolini, Mark Billingsley, William Price (AEA); Matt Clarkson (CEA); Kody George (City of Seward); Dan Bishop, Daniel Heckman (GVEA); Larry Jorgensen, Sarah Lambe, Jessica Spuhler (HEA); Tony Zellers (MEA); Carl Monroe (Munro Advisors, LLC); Andrew Jensen (Office of the Governor); Bernie Smith (Public); and Tina Grovier (Stoel Rives, RTO). 4. AGENDA APPROVAL MOTION: A motion was made by Mr. Thayer to approve the agenda. Motion seconded by Mr. Hickey. A roll call was taken, and the motion to approve the agenda passed unanimously. 5. PUBLIC COMMENTS There were no public comments. 6. APPROVAL OF THE MEETING MINUTES – April 18, 2025 MOTION: A motion was made by Mr. Hickey to approve the Meeting Minutes of April 18, 2025. Motion seconded by Mr. Thayer. A roll call was taken, and the motion to approve the Minutes of April 18, 2025 passed unanimously. __________________________________________________________________________ RTO Minutes 5/02/25 Page 2 of 3 7. OLD BUSINESS A. Working Group Update Daniel Heckman, GVEA, provided the RTO Working Group update. Mr. Heckman noted that the Working Group has been focused and busy with their tasks assigned at the previous Governance Committee meeting. The majority of the tasks will be discussed later in today’s meeting. Mr. Heckman indicated that the utilities’ Chief Financial Officers (CFO) and regulatory personnel are working with the RTO’s consultant Carl Monroe, Munro Advisors, on developing a cost allocation approach with the Annual Transmission Revenue Requirement (ATRR). The initial plan may be brought before the Governance Committee at the May 16, 2025, meeting for feedback. Mr. Heckman discussed that if there is alignment around the path forward that could result in a process that would be part of the Open Action Transmission Tariff (OATT) that is due on July 1, 2025. The Working Group continues its work and effort with a steady cadence. There were no comments or questions. B. RTO Certificate Filing and OATT Filing Tina Grovier, Stoel Rives, and Counsel to the RTO, provided the update on the RTO Certificate Filing and the OATT Filing. Ms. Grovier discussed that since the previous RTO meeting, there have been no new filings with the Regulatory Commission of Alaska in the application docket and there have been no new orders issued. Ms. Grovier indicated that she has no information to add to Mr. Heckman’s report regarding the backbone transmission system (BTS), the OATT, and the ATRR. However, she does have related matters to discuss in executive session, the immediate knowledge of which could have an adverse effect on the legal position and/or financial position of the RTO and/or the Committee members. There were no comments or questions. MOTION: A motion was made by Mr. Hickey to enter Executive Session to discuss matters the immediate knowledge of which could have an adverse effect on the finances or legal position of the RTO, the Committee, or Authority, or that are confidential under state, federal, or local law. Motion seconded by Mr. Sinclair. A roll call was taken, and the motion to enter into Executive Session passed, with Mr. Thayer voting no. 8. EXECUTIVE SESSION – 11:40 am. (Bylaws Section 5.12.3) To discuss matters with an attorney for the Committee, the immediate knowledge of which could have an adverse effect on the finances or legal position of the Committee or Authority. The RTO Governance Committee reconvened its regular meeting at 4:26 p.m. Vice Chair Million advised that the RTO did not take any formal action on matters discussed while in Executive Session, except as authorized in the Bylaws 5.12.2., to give directions to an attorney or negotiator regarding the handling of a specific legal matter or pending negotiation. 9. NEW BUSINESS __________________________________________________________________________ RTO Minutes 5/02/25 Page 3 of 3 Vice Chair Million stated that the recommended draft BTS policy will be posted publicly on Monday, and will be discussed further at the next RTO meeting. 10. MEMBERS’ COMMENTS Mr. Janorschke expressed appreciation for the work and effort of Ms. Grovier, Mr. Monroe, and the Working Group. Mr. Sinclair echoed the comments of appreciation for the work and efforts during this timeline. Mr. Hickey echoed the previous comments of appreciation. Mr. Jenkin expressed appreciation for the ongoing work efforts, specifically the work by the CFOs to develop a cost allocation manual. Mr. Thayer thanked everyone for the meeting and expressed appreciation for understanding the need for a public session. There will be many public documents to review next week that will provide a glimpse of some of the challenges the RTO faces. Mr. Miller echoed the previous comments. He reiterated appreciation for the Working Group for their efforts and progress. Vice Chair Million echoed the previous comments. He noted the impressive efforts of the Working Group. He understands there is much work remaining, and he is confident it will be completed. 11. NEXT MEETING DATE – May 16, 2025 The next meeting date is May 16, 2025. Vice Chair Million noted it will be a long meeting, including multiple presentations and discussions within the public setting. 12. ADJOURNMENT There being no further business for the committee, the meeting adjourned at 4:30 p.m. ________________________________ Travis Million, Acting Chair _________________________________ Curtis W. Thayer, Secretary Backbone Transmission System Railbelt Transmission Organization What is the Backbone Transmission System? •AS 44.83.710(a)-“The transmission organization shall hold and administer a commission-approved nondiscriminatory open access transmission tariff for the backbone transmission system” •AS 44.83.720(1)-“‘backbone transmission system’ means the transmission assets in the Railbelt that facilitate the transmission of electrical power under the standards established by the Federal Energy Regulatory Commission” What is the Backbone Transmission System? 1.Transmission Assets 2.In the Railbelt 3.Facilitate transmission of electrical power 4.Under Federal Energy Regulatory Commission (FERC) standards Backbone Transmission System Policy •Purpose of Proposed Policy: Describe the standards and their application by the RTO when determining what Transmission Assets qualify to be in the Backbone Transmission System that will be used for transmission service under the RTO’s nondiscriminatory Open Access Transmission Tariff (OATT). What are the FERC standards? •Transmission Assets •7-Factor Test •Used to determine if an asset should be categorized as distribution. If the asset fails the test, it can be categorized as transmission •Integration with the Transmission Network •Mansfield Test •Used to determine if an asset shows “any degree of integration” with the backbone transmission system •Fact-specific test and application •In Railbelt •May need to make Alaska-specific adjustments when applying FERC/Lower 48 standards to Alaska Railbelt What are the FERC standards? •Transmission Assets •7-Factor Test 1.Local distribution facilities are normally in close proximity to retail customers; 2.Local distribution facilities are primarily radial in character; 3.Power flows into local distribution systems; it rarely, if ever, flows out; 4.When power enters a local distribution system, it is not reconsigned or transported onto some other market; 5.Power entering a local distribution system is consumed in a comparatively restricted geographical area; 6.Meters are based at the transmission/local interface to measure flows into the local distribution system; and 7.Local distribution systems will be of reduced voltage. Source: Promoting Wholesale Competition Through Open Access Non-Discriminatory Transmission Services by Public Utilities; Recovery of Stranded Costs by Public Utilities and Transmitting Utilities, Order No. 888, 61 Fed. Reg. 21,540 (May 10, 1996) (full cite on last slide) What are the FERC standards? •Mansfield Test 1.Whether the facilities are radial, or whether they loop back into the transmission system; 2.Whether energy flows only in one direction, from the transmission system to the customer over the facilities, or in both directions, from the transmission system to the customer, and from the customer to the transmission system; 3.Whether the transmission provider is able to provide transmission service to itself or other transmission customers . . . over the facilities in question; 4.Whether the facilities provide benefits to the transmission grid in terms of capability or reliability, and whether the facilities can be relied on for coordinated operation of the grid; and 5.Whether an outage on the facilities would affect the transmission system. Source: Mansfield Mun. Elec. Dep’t v. New Eng. Power Co., Opinion No. 454, 97 FERC 61,134 (Nov. 7, 2001), reh'g denied, 98 FERC ¶ 61,115 (Feb 1, 2002). How do the Standards Generally Apply? •Both FERC standards and any Alaska-specific applications of those standards will be fact specific and fact intensive •Application is to a wide range of lines across multiple Railbelt entities •Need to ensure standards will allow OATT to meet additional provisions of HB307:•Remove impediments to competition in wholesale bulk power market (710(b))•Pool BTS costs and allocate them through certificated load-serving entities on a coincident peak, load ratio share, or combination of both (710(c)(1))•Account for congestion on the BTS (710(c)(2)(B))•Account for disruptions that result in isolation for more than 24 hours (710(c)(2)(C)) •Account for costs to own and operate the BTS (710(c)(2)(D))•Pass BTS costs to directly and transparently to the Railbelt utilities’ customers (710(d)) Committee Considerations •Are there Alaska-specific adjustments that need to be made to the application of the FERC standards related to the BTS in the Alaska Railbelt? •Which transmission assets in the Alaska Railbelt qualify to be in the Backbone Transmission System in compliance with HB307? BTS Recommendation Process •The Technical Working Group was tasked with recommending to the Governance Committee which facilities fit the statutory BTS definition. •Two Tests •7-Factor Test •Evaluates line segments using seven principles. •If four or more principles are answered “yes,” the line segment is classified as distribution and is excluded from BTS recommendation. •Mansfield Test •Line segments not classified as distribution were evaluated for integration under five principles. •If three or more principles are answered “yes”, the line segment is included in the BTS recommendation –deemed to be integrated and therefore part of the BTS. BTS Recommendation Process •Results •127 line segments evaluated •7-Factor Test •29 segments unanimously classified as distribution and therefore excluded from the BTS. •Mansfield Test •98 segments were evaluated, with 86 unanimously recommended for inclusion in the BTS. •Remaining 12 lines were not unanimous –ultimately 11 were recommended for inclusion in the BTS, one was recommended for exclusion. •Non-line segment assets not yet to recommendation stage but some possible recommendations have been discussed (including one in draft BTS Policy). List of Line Segments Contested and Recommendation FAC_ID 7-Factor Removal?Is Facility Transmission (Mansfield)? MEA00010 No Yes MEA00011 No Yes MEA00014 No Yes MEA00016 No Yes MEA00017 No Yes SES001 No Yes SES002 No Yes CEA0001 No Yes CEA0002 No Yes CEA0003 No Yes CEA0005 No Yes CEA0025 No No Other References •Alaska House Bill 307 •Alaska Statutes 44.83.700-720 •Promoting Wholesale Competition Through Open Access Non-Discriminatory Transmission Services by Public Utilities; Recovery of Stranded Costs by Public Utilities and Transmitting Utilities, Order No. 888, 61 Fed. Reg. 21,540 (May 10, 1996), FERC Stats. & Regs. ¶ 31,036, at 31,771 (1996) (cross-reference at 75 FERC ¶ 61,080), order on reh’g, Order No. 888-A, 62 Fed. Reg. 12,274 (Mar. 14, 1997), FERC Stats. & Regs. ¶ 31,048 (1997) (cross-reference at 76 FERC ¶ 61,220), order on reh’g, Order No. 888-B, 81 FERC ¶ 61,248 (1997), order on reh’g, Order No. 888-C, 82 FERC ¶ 61,046 (1998), aff’d in relevant part sub nom. Transmission Access Policy Study Group v. FERC, 225 F.3d 667 (D.C. Cir. 2000), aff’d sub nom. New York v. FERC, 535 U.S. 1 (2002). 1 RAILBELT TRANSMISSION ORGANIZATION Policy ___ Date:______________ BACKBONE TRANSMISSION SYSTEM The purpose of this Policy is to describe the standard to be applied by the Railbelt Transmission Organization (RTO) when determining what Transmission Facilities will be included in the Backbone Transmission System used for transmission service under the RTO’s Open Access Transmission Tariff (OATT). This policy recognizes the need for a Railbelt Backbone Transmission System OATT “to remove impediments to competition in the wholesale bullk power marketplace in the state.”1 The Backbone Transmission System is defined as “the transmission assets in the Railbelt that facilitate the transmission of electrical power under the standards established by the Federal Energy Regulatory Commission[ FERC].”2 This integrated subset of Transmission Facilities will support wholesale bulk power transactions across the Railbelt.3 “Any degree of integration” into the Backbone Transmission System supports “rolled-in” cost recovery for that Transmission Facility through the Backbone Transmission System OATT.4 The Federal Energy Regulatory Commission’s (FERC) five-factor Mansfield test is used to determine whether “any degree of integration” exists.5 While a positive showing of integration on all five factors is not necessary for inclusion, a negative showing of integration on all five factors requires exclusion from the Backbone Transmission System.6 1 AS 44.83.710(b). 2 AS 44.83.720(1). 3 AS 44.83.710(b). “The transmission organization shall file with the commission a nondiscriminatory open access transmission tariff consistent with [FERC] standards to remove impediments to competition in the wholesale bulk power marketplace in the state. 4 Ne. Tex. Elec. Coop., Inc. 108 FERC 61,084, at P48 (2004) (“On the question of how to determine whether a facility is a network facility, the Commission has stated that a showing of any degree of integration is sufficient.”); see also Tri-State Generation & Transmission Ass'n, Inc., 184 FERC 61,099 (2023) (“[T]he any-degree-of-integration test and the Mansfield factors are the Commission’s standard tools. . . .”). 5 Mansfield Mun. Elec. Dep’t v. New Eng. Power Co., Opinion No. 454, 97 FERC 61,134 (2001); Duke Energy Carolinas, LLC, 168 FERC 61,190, at P4 (2019). 6 Ne. Tex. Elec. Coop., Inc. 108 FERC 61,084, at P48 (2004) (“It is still our policy, as it has been for many years, to prohibit the direct assignment of network facilities. Due to the integrated nature of the transmission network, network facilities benefit all network users. It does not matter whether the facilities were installed to meet a particular customer's request for service… The five-factor Mansfield Test was used to determine whether the radial lines at issue exhibited any degree of integration. Thus, the lines’ negative showing with respect to all five factors established there were ‘exceptional circumstances’ that merited direct assignment of their costs. In this proceeding, Trial 2 The five Mansfield factors to be considered when determining whether a facility is integrated with, and thereby part of, the Backbone Transmission System are: 1. Whether the facilities are radial, or whether they loop back into the transmission system; 2. Whether energy flows only in one direction, from the transmission system to the customer over the facilities, or in both directions, from the transmission system to the customer, and from the customer to the transmission system; 3. Whether the transmission provider is able to provide transmission service to itself or other transmission customers . . . over the facilities in question; 4. Whether the facilities provide benefits to the transmission grid in terms of capability or reliability, and whether the facilities can be relied on for coordinated operation of the grid; and, 5. Whether an outage on the facilities would affect the transmission system.7 The RTO’s determination of whether a Transmission Facility exhibits by a preponderance of the evidence “any degree of integration” with the Backbone Transmission System shall be based on the specific factual circumstances evaluated at the time.8 This Policy is intended to provide flexibility for a transmission owner to argue the appropriate application of the Mansfield test in the Alaska Railbelt. A Transmission Facility will be evaluated when it is added and may be re-evaluated for inclusion or exclusion in or from the Backbone Transmission System if significantly upgraded or modified. For purposes of this Policy, the phrase “Transmission Facility” means (1) any electric transmission equipment that is operating at a voltage level of 69kV or greater that is not primarily used in local distribution as determined to be transmission by the application of the seven factor test from FERC Order No. 888; and (2) any controls equipment and facilities functionally allocated to transmission that are necessary to control and protect an electric transmission line that operates at a voltage level of at least 69 kV. Pursuant to FERC Order No. 888, the following seven factors indicate that a facility is a local distribution facility, rather than a transmission facility: 1. local distribution facilities are normally in close proximity to retail customers; Staff and SWEPCO would have us require that facilities meet all five parts of the Staff Test to merit rolled-in treatment. This contradicts the Commission's policy that costs should be rolled in when any degree of integration has been shown.”). 7 Mansfield Mun. Elec. Dep’t v. New Eng. Power Co., Opinion No. 454, 97 FERC 61,134 (2001). Although not required, de-ration is the general “effect” the RTO would expect to see for a positive showing of integration on the fifth Mansfield factor. 8 Duke Energy Carolinas, LLC, 168 FERC 61,190, at P18 (2019) (“Based on the evidence submitted in this proceeding, DEC has not demonstrated that the costs of the Arlington Tap Line should be directly assigned, and, in contrast, the record demonstrates that the Arlington Tap Line passes the ‘any degree of integration’ test by satisfying at least one of the Mansfield criteria, thereby requiring rolled-in rate treatment.”). 3 2. local distribution facilities are primarily radial in character; 3. power flows into local distribution systems; it rarely, if ever, flows out; 4. when power enters a local distribution system, it is not reconsigned or transported on to some other market; 5. power entering a local distribution system is consumed in a comparatively restricted geographical area; 6. meters are based at the transmission/local interface to measure flows into the local distribution system; and 7. local distribution systems will be of reduced voltage.9 9 Promoting Wholesale Competition Through Open Access Non-Discriminatory Transmission Services by Public Utilities; Recovery of Stranded Costs by Public Utilities and Transmitting Utilities, Order No. 888, 61 Fed. Reg. 21,540 (May 10, 1996), FERC Stats. & Regs. ¶ 31,036, at 31,771 (1996) (cross-reference at 75 FERC ¶ 61,080), order on reh’g, Order No. 888-A, 62 Fed. Reg. 12,274 (Mar. 14, 1997), FERC Stats. & Regs. ¶ 31,048 (1997) (cross-reference at 76 FERC ¶ 61,220), order on reh’g, Order No. 888B, 81 FERC ¶ 61,248 (1997), order on reh’g, Order No. 888-C, 82 FERC ¶ 61,046 (1998), aff’d in relevant part sub nom. Transmission Access Policy Study Group v. FERC, 225 F.3d 667 (D.C. Cir. 2000), aff’d sub nom. New York v. FERC, 535 U.S. 1 (2002). Alaska Railbelt Transmission Organization (RTO)Facilities Recommended to be Included in BTSMansfield Test EvaluationFAC_IDFrom Bus / To Bus VoltageIs Facility Transmission per Mansfield? Pass Principle 1? Pass Principle 2? Pass Principle 3? Pass Principle 4? Pass Principle 5?MEA0001 115Yes Yes Yes Yes No YesMEA0002 115Yes No Yes Yes No YesMEA0003 115Yes No Yes Yes No YesMEA00010 115Yes Yes Yes Yes No YesMEA00011 115Yes Yes Yes Yes No YesMEA00014 115Yes Yes No Yes No YesMEA00016 115Yes Yes Yes Yes No YesMEA00017 115Yes Yes Yes Yes No YesMEA00018 115Yes Yes No Yes Yes YesMEA00020 115Yes Yes No Yes Yes NoMEA00021 115Yes Yes No Yes Yes NoMEA00027 138Yes Yes No Yes Yes YesGVEA0001 138Yes Yes Yes Yes Yes YesGVEA0002 138Yes Yes No Yes Yes YesGVEA0003 138Yes Yes No Yes Yes YesGVEA0005 138Yes Yes No Yes Yes NoGVEA0006 138Yes Yes Yes Yes Yes YesGVEA0007 138Yes Yes Yes Yes Yes YesGVEA0008 138Yes Yes No Yes Yes YesGVEA0009 138Yes No Yes Yes Yes YesGVEA0014 138Yes Yes Yes Yes Yes YesGVEA0015 138Yes Yes Yes Yes Yes YesGVEA0017 69Yes Yes Yes Yes Yes YesGVEA0018 69Yes Yes No Yes Yes NoGVEA0020 69Yes Yes No Yes Yes YesGVEA0022 69Yes Yes Yes Yes Yes YesGVEA0023 69Yes Yes Yes Yes Yes YesGVEA0024 69Yes Yes Yes Yes Yes YesGVEA0026 69Yes Yes No Yes Yes YesGVEA0027 69Yes Yes No Yes Yes YesGVEA0028 69Yes Yes No Yes Yes Yes1 of 4 Alaska Railbelt Transmission Organization (RTO)Facilities Recommended to be Included in BTSMansfield Test EvaluationFAC_IDFrom Bus / To Bus VoltageIs Facility Transmission per Mansfield? Pass Principle 1? Pass Principle 2? Pass Principle 3? Pass Principle 4? Pass Principle 5?GVEA0029 69Yes Yes Yes Yes Yes YesGVEA0030 69Yes Yes Yes Yes Yes YesGVEA0034 69Yes Yes No Yes Yes YesGVEA0035 69Yes Yes No Yes Yes YesGVEA0036 69Yes Yes No Yes Yes YesGVEA0037 69Yes Yes No Yes Yes YesGVEA0038 69Yes Yes Yes Yes Yes YesGVEA0039 69Yes Yes Yes Yes Yes YesGVEA0041 69Yes Yes No Yes Yes YesGVEA0042 69Yes Yes Yes Yes Yes YesHEA001 115Yes Yes Yes Yes Yes YesHEA002 115Yes Yes Yes Yes Yes YesHEA003 115Yes Yes Yes Yes Yes YesHEA004 115Yes Yes Yes Yes Yes YesHEA005 115Yes Yes Yes Yes Yes YesHEA006 115Yes Yes Yes Yes Yes YesHEA007 115Yes Yes Yes Yes Yes YesHEA008 115Yes Yes Yes Yes Yes YesHEA009 115Yes Yes Yes Yes Yes YesHEA010 115Yes Yes Yes Yes Yes YesHEA011 115Yes Yes Yes Yes Yes YesAEA0001 138Yes No No Yes Yes YesAEA0002 115Yes No No Yes Yes YesAEA0003 115Yes No No Yes Yes YesSES001 115Yes No Yes Yes No YesSES002 69Yes No Yes Yes No YesCEA0001 138Yes Yes Yes Yes No YesCEA0002 230Yes Yes Yes Yes No Yes2 of 4 Alaska Railbelt Transmission Organization (RTO)Facilities Recommended to be Included in BTSMansfield Test EvaluationFAC_IDFrom Bus / To Bus VoltageIs Facility Transmission per Mansfield? Pass Principle 1? Pass Principle 2? Pass Principle 3? Pass Principle 4? Pass Principle 5?CEA0003 230Yes Yes Yes Yes No YesCEA0004 230Yes Yes No Yes Yes YesCEA0005 138Yes Yes No Yes No YesCEA0006 138Yes Yes No Yes No YesCEA0007 138Yes Yes No Yes No YesCEA0008 138Yes Yes No Yes No YesCEA0011 230Yes Yes Yes Yes Yes YesCEA0012 115Yes Yes Yes Yes No YesCEA0013 115Yes Yes Yes Yes No YesCEA0014 230Yes Yes Yes Yes No YesCEA0015 115Yes Yes No Yes No YesCEA0016 138Yes Yes Yes Yes No YesCEA0017 138Yes Yes No Yes No YesCEA0018 115Yes Yes No Yes Yes YesCEA0019 115Yes Yes No Yes Yes YesCEA0020 115Yes Yes No Yes Yes YesCEA0021 115Yes Yes No Yes Yes YesCEA0022 115Yes Yes No Yes Yes YesCEA0023 115Yes Yes No Yes Yes YesCEA0024 115Yes Yes No Yes Yes YesCEA0026 138Yes Yes No Yes No YesCEA0027 138Yes Yes Yes Yes No YesCEA0028 138Yes Yes No Yes No YesCEA0029 115Yes Yes Yes Yes No YesCEA0030 115Yes Yes No Yes No YesCEA0031 115Yes Yes Yes Yes No YesCEA0032 115Yes Yes Yes Yes No YesCEA0033 115Yes Yes Yes Yes No YesCEA0034 115Yes Yes No Yes No YesCEA0035 115Yes Yes No Yes No YesCEA0036 115Yes Yes Yes Yes No YesCEA0037 115Yes Yes No Yes No Yes3 of 4 Alaska Railbelt Transmission Organization (RTO)Facilities Recommended to be Included in BTSMansfield Test EvaluationFAC_IDFrom Bus / To Bus VoltageIs Facility Transmission per Mansfield? Pass Principle 1? Pass Principle 2? Pass Principle 3? Pass Principle 4? Pass Principle 5?CEA0038 115Yes Yes No Yes No YesCEA0039 115Yes Yes No Yes No YesCEA0040 115Yes Yes No Yes No YesCEA0041 115Yes Yes No Yes No YesCEA0042 115Yes Yes No Yes No YesCEA0043 115Yes Yes No Yes No Yes4 of 4 Alaska Railbelt Transmission Organization (RTO)Facilities Recommended to be Excluded from BTSFERC Seven Factor Test (SFT) EvaluationFAC_IDFrom Bus / To BusVoltageFacility Excluded because Distribution per 7-Factor7-FactorPass Principle 1? Pass Principle 2? Pass Principle 3? Pass Principle 4? Pass Principle 5? Pass Principle 6? Pass Principle 7?MEA0004 115Yes Yes Yes No Yes Yes Yes NoMEA0005 115Yes Yes Yes No Yes Yes Yes NoMEA0006 115Yes Yes Yes No Yes Yes Yes NoMEA0007 115Yes Yes Yes No Yes Yes Yes NoMEA0008 115Yes Yes Yes No Yes Yes Yes NoMEA0009 115Yes Yes Yes No Yes Yes Yes NoMEA00012 115Yes Yes Yes No Yes Yes Yes NoMEA00013 115Yes Yes Yes No Yes Yes Yes NoMEA00015 115Yes Yes Yes No Yes No Yes NoMEA00019 115Yes Yes Yes No Yes Yes Yes NoMEA00022 115Yes Yes Yes No Yes Yes Yes NoMEA00023 115Yes Yes Yes No Yes No Yes NoMEA00024 115Yes Yes Yes No Yes Yes Yes NoMEA00025 115Yes Yes Yes No Yes No Yes NoMEA00026 115Yes Yes Yes No Yes Yes Yes NoGVEA0004 138Yes Yes Yes No Yes Yes Yes NoGVEA0010 138Yes Yes Yes No No Yes Yes NoGVEA0011 138Yes Yes Yes No Yes Yes Yes NoGVEA0012 138Yes Yes Yes No Yes Yes Yes NoGVEA0013 138Yes Yes Yes No Yes Yes Yes NoGVEA0016 69Yes Yes Yes No Yes Yes Yes NoGVEA0019 69Yes Yes Yes No Yes Yes Yes NoGVEA0021 69Yes Yes Yes No Yes Yes Yes NoGVEA0025 69Yes Yes Yes No Yes No Yes NoGVEA0031 69Yes Yes Yes No Yes No Yes NoGVEA0032 69Yes Yes Yes No Yes Yes Yes NoGVEA0033 69Yes Yes Yes No Yes No Yes NoGVEA0040 69Yes Yes Yes No Yes Yes Yes No1 of 2 Alaska Railbelt Transmission Organization (RTO)Facilities Recommended to be Excluded from BTSFERC Seven Factor Test (SFT) EvaluationFAC_IDFrom Bus / To BusVoltageFacility Excluded because Distribution per 7-Factor7-FactorPass Principle 1? Pass Principle 2? Pass Principle 3? Pass Principle 4? Pass Principle 5? Pass Principle 6? Pass Principle 7?SES 003 69Yes YES YES Yes Yes Yes Yes NoMansfield Test EvaluationFAC_IDFrom Bus / To Bus VoltageIs Facility Transmission per Mansfield?Mansfield Pass Principle 1? Pass Principle 2? Pass Principle 3? Pass Principle 4? Pass Principle 5?CEA0025 69No No No No No No2 of 2 Intro to OATT, Proposed Deletions, and Other Changes Being Considered RTO Governance Comm –05/16/2025 Carl Monroe –Munro Advisors, LLC Alaska HB307 (2024) •AS 44.83.700 –(a) The Railbelt Transmission Organization is created for the purpose of establishing an open access transmission tariff that •(1) provides for recovery of transmission costs and related ancillary services; and •(2) replaces wholesale charges assessed by unit by each utility in the Railbelt with a new mechanism that fairly recovers and equitably allocates the costs of operating the backbone transmission system. •AS 44.83.710 –(a) The transmission organization shall hold and administer a commission-approved nondiscriminatory open access transmission tariff for the backbone transmission system. –(b) The transmission organization shall file with the commission a nondiscriminatory open access transmission tariff consistent with Federal Energy Regulatory Commission standards to remove impediments to competition in the wholesale bulk power marketplace in the state. If the transmission organization does not file a nondiscriminatory open access transmission tariff with the commission on or before July 1, 2025, the commission shall, after notice and opportunity for public comment, establish a nondiscriminatory open access transmission tariff consistent with this section. Alaska HB307 (2024) •AS 44.83.710 –(c) The nondiscriminatory open access transmission tariff must, as approved by the commission, •(1) pool backbone transmission system costs and allocate those costs through certificated load-serving entities on a coincident peak or load ratio share basis, or a combination of both; •(2) account for –(A) required backbone transmission system ancillary services; –(B) backbone transmission system congestion; –(C) disruptions to the backbone transmission system that result in the isolation of one geographical area of the backbone transmission system from another for more than 24 hours; and –(D) costs to own and operate the backbone transmission system, as established by the commission or by contract, including transmission costs associated with the Bradley Lake hydroelectric project. Background on FERC’s Open Access Transmission Standard •On April 24, 1996, the Federal Energy Regulatory Commission (FERC) issued Order No. 888 which required public utilities to provide open access transmission service on a comparable basis to the transmission service they provide themselves –Required all public utilities that own, control or operate facilities used for transmitting electric energy in interstate commerce to file open access non-discriminatory transmission tariffs that contain minimum terms and conditions of non-discriminatory service. –Permits public utilities and transmitting utilities to seek recovery of legitimate, prudent and verifiable stranded costs associated with providing open access and transmission services. •FERC's goal was to remove impediments to competition in the wholesale bulk power marketplace and to bring more efficient, lower-cost power to the Nation's electricity consumers. Source: History of OATT Reform | Federal Energy Regulatory Commission How do HB307 & the FERC OATT Work Together? •Prefiled testimony with the RCA proposed starting with the FERC’s Order 888 Open Access Transmission Tariff (OATT) and committed to describing major deletions, changes, and additions the RTO makes. •Latest version of the FERC Pro Forma OATT is dated December 16, 2021. Overview •This is a review of the significant changes currently under consideration in the three categories below and the rationale for the changes (OATT is still a work in progress) –Proposed Deletions –Proposed Modifications –Proposed Additions Proposed Deletions •Part II –Point to Point Service (Pt-to-Pt) –FERC’s purpose for Pt-to-Pt service was to allow market delivery between OATTs. FERC’s intentions were to isolate Network Integration Transmission Service (NITS) to be used between generation and load for a Network Customer and then Pt-to-Pt for other moves of energy between specific points on the transmission system. –Currently in AK regional tariffs, Pt-to-Pt is only used for imports, exports, and thru transactions between other tariffs. The Railbelt has no external connections that could use Pt-to-Pt service. –The removal of Pt-to-Pt service and requiring use of NITS eliminates wheeling that would be needed between Railbelt service areas and reduces the cost of tariff service. –Pt-to-Pt service is very intense in administration and provisions and would be costly for no qualified reason to provide the service. Proposed Deletions (cont) •Native Load Service –Original purpose for Native Load service was for all service under the OATT to be bound by all the non-rate terms and conditions of the OATT, including the transmission owner’s load (called Native Load). –FERC also would review the rates that Native Load and NITS would pay to ensure that the rates were non-discriminatory. –In all the regional OATTs, the Native Load had restrictions to only use the local transmission owner’s transmission system and require Pt-to-Pt as stated in the previous slide. –To meet HB307, the removal of Native Load provides all load access to the full Backbone Transmission System (BTS) because all load is under NITS. Proposed Deletions (cont) •Studies, Transmission Analysis, Planning Requirements –Based on the RRC’s statutory duties and HB307 not placing these responsibilities on the RTO, all the requirements in the FERC OATT are proposed to be directed to the Transmission Owners (TO). –FERC OATTs required the tariff to cover both planning and implementation of those plans to ensure NITS is maintained reliably, but also any requested changes to NITS would be studied, even if modifications to the transmission system were required to make it available. –It is anticipated that as the RRC modifies its tariff to include the IRP and other transmission standards, the RTO tariff will need to be coordinated with those changes and the TO tariffs too. –This would delete Attachment K -Planning as well as any FERC Order 1920 requirements. Proposed Deletions (cont) •Operational Requirements –Based on HB307 not authorizing the RTO to be responsible for operations, all the requirements in the FERC OATT and the reliability standards are the Transmission Owners (TO). –FERC OATTs required that the tariff cover operational requirements to ensure all transmission service is treated non-discriminatorily. –FERC assumed that the NERC functions were provided by the tariff operator. –This meets HB307’s intent to have the administration of the OATT provided by the RTO, but operational requirements remain as they are today. –Would remove need for a Network Operating Committee (any needed groups can be formed under the Governance Committee) and for a Network Operating Agreement (but may require that of the TO). Proposed Deletions (cont) •Regulatory Filings –To be covered under other sections when required. –For instance, changes in Service Agreements, change of tariff rate terms, etc. •OATT Attachments –Deleting any attachments no longer needed based on the deletions to the tariff. Proposed Modifications •Customer Definition –FERC Order 888 defined: •1.12 Eligible Customer: (i) Any electric utility (including the Transmission Provider and any power marketer), Federal power marketing agency, or any person generating electric energy for sale for resale is an Eligible Customer under the Tariff. Electric energy sold or produced by such entity may be electric energy produced in the United States, Canada or Mexico. However, with respect to transmission service that the Commission is prohibited from ordering by Section 212(h) of the Federal Power Act, such entity is eligible only if the service is provided pursuant to a state requirement that the Transmission Provider offer the unbundled transmission service, or pursuant to a voluntary offer of such service by the Transmission Provider. (ii) Any retail customer taking unbundled transmission service pursuant to a state requirement that the Transmission Provider offer the transmission service, or pursuant to a voluntary offer of such service by the Transmission Provider, is an Eligible Customer under the Tariff –Considering this definition: •2.15 Eligible Customer: Any public utility or other person generating electric energy for resale of at least one (1) megawatt that holds a Certificate of Public Convenience and Necessity for electrical service from the Commission or that is exempt from Commission regulation under AS 42.05.711 or federal law.–Change proposed based on Alaska unique legal and regulatory requirements Proposed Modifications (cont) •Ancillary Services –HB307 AS 44.83.710 (c)(2)(A) requires the OATT to account for required backbone transmission system ancillary services. –FERC required OATTs to provide ancillary services if the customer didn’t self provide or obtain otherwise. –The RTO, as many of the original regional OATTs, does not have the ability to provide Ancillary Services. –We are considering having the current ancillary service providers provide or validate that the customer can self-provide or obtain otherwise. –Two of the Ancillary Services are required to be provided by the current ancillary service providers, Schedule 1 -Scheduling, System Control and Dispatch Service and Schedule 2 -Reactive Supply and Voltage Control from Generation or Other Sources Service. Proposed Modifications (cont) •Responsibility Designee in OATT –HB307 does not grant the RTO all the same duties as FERC’s Transmission Provider (TP) in the lower 48. –FERC Order 888 used the term TP for the administrator but included other functions that coordinated operations and planning activities in and with the OATT. –To avoid any confusion about the duties and functions of the functions of the RTO, the RTO WG is considering using the term Transmission Service Administrator instead of TP. Proposed Modifications (cont) •Posting Requirements –Although HB307 did not specify any posting requirements, the FERC OATT required an OASIS posting system to ensure that the tariff operations were transparent to all but also protected sensitive information. –With the removal of Pt-to-Pt service and other requirements, any posting required by the OATT can be provided on the RTO’s website (hosted by AEA). Proposed Modifications (cont) •Local Furnishing Bonds –Considering changes by Seward to protect their Tax-Exempt Bonds requirements. •Charges for Specific RTO activities –FERC OATT has charges specifically for studies, etc. –The only considered additional charge by the RTO might be to assess if any changes to the transmission system are determined to be BTS changes. Proposed Modifications (cont) •Part III NITS (now Part II) –Significant changes to reflect subjects already covered with deletions and modification. –One additional modification is to have any changes requested by a customer be addressed first to the TO affected with the RTO informed. –The TO will provide any studies, analysis, or requirements that would need to be included in the customer Service Agreement. Proposed Modifications (cont) •Congestion –HB307 AS 44.83.710 (c)(2)(B) requires the OATT to account for backbone transmission system congestion. –Considering proposing to modify the operational provisions to direct the procedures and relief to the TOs or Balancing Authorities. •Disruptions that Isolate Area –HB307 AS 44.83.710 (c)(2)(C) requires the OATT to account for disruptions to the backbone transmission system that result in the isolation of one geographical area of the backbone transmission system from another for more than 24 hours. –Considering modifying the billing provisions for disruptions more than a period of time, for instance a week. –To execute this (if accepted by the Committee) may mean the isolated area is excluded from the RTO transmission charge for the period isolated but be charged its local ATRR. The other Network Customers would not include the isolated area in their charge. Proposed Additions •Introduction –Considering whether the OATT needs an introduction to the tariff to orient the reader to the tariff and its purpose. •RTO Tariff rates for Transmission Service –HB307 requires aggregating the BTS transmission expenses of the TOs to be paid by the Railbelt utilities (and then passed on pursuant to AS 44.83.710(d)). Rates should be specified in the OATT, just like FERC. –First, TOs are doing ATTR review for consistency and financial analysis of rate designs. –May consider additional Attachments to the OATT to describe the process from gathering ATRRs from the TOs to calculation of the Network Customer rate, and the distribution of revenue to the TOs, like a cost allocation manual. Proposed Additions •Transition Period –Considering any requirements that might be needed for a transition period and terms that would change if there were one. •New Transmission upgrades, modification, etc. –Just starting consideration of how new transmission might be incorporated in the development of rates. Committee Considerations •What Alaska-specific adjustments need to be made to the FERC Pro Forma OATT to adapt it for the Alaska Railbelt? •How to make the RTO OATT comply with Alaska Statutes 44.83.700-720 (open access, nondiscriminatory, etc.) and any other statutory standards applicable to its mandate. Revenue Mechanism IntroductionRailbelt Transmission Organization Alaska HB307 (2024)•AS 44.83.700•(a) The Railbelt Transmission Organization is created for the purpose of establishing an open access transmission tariff that •(1) provides for recovery of transmission costs and related ancillary services; and •(2) replaces wholesale chargesassessed by unit by each utility in the Railbelt with a new mechanism that fairly recovers and equitably allocates the costs of operating the backbone transmission system. Alaska HB307 (2024)•AS 44.83.710•(c) The nondiscriminatory open access transmission tariff must, as approved by the commission,•(1) pool backbone transmission system costs and allocate those costs through certificated load-serving entitieson a coincident peak or load ratio share basis, or a combination of both; •(2) account for •(A) required backbone transmission system ancillary services; •(B) backbone transmission system congestion;•(C) disruptions to the backbone transmission system that result in the isolation of one geographical area of the backbone transmission system from another for more than 24 hours; and•(D) costs to own and operate the backbone transmission system, as established by the commissionor by contract,including transmission costs associated with the Bradley Lake hydroelectric project. •(d) A Railbelt utility shall pass the commission-approved transmission costs directly and transparently to the utility's customers. What must the revenue mechanism accomplish?•Replace wholesale charges assessed by unit by each utility.•Pool backbone transmission system (BTS) costs.•Fairly recover and equitably allocate BTS costs.•Allocate BTS costs through certificated load-serving entities on a coincident peak or load ratio share basis, or a combination of both.•Account for •required BTS ancillary services; •BTS congestion;•disruptions to the BTS that result in the isolation of one geographical area of the backbone transmission system from another for more than 24 hours; and•costs to own and operate the BTS, as established by the commission or by contract, including transmission costs associated with the Bradley Lake hydroelectric project. How do Alaska Statutes Generally Apply?•AS 44.83.700-710 establish the parameters for the revenue mechanism•AS 44.83.710(a) – the open access tariff must be nondiscriminatory•RCA Standard - AS 42.05.381 “Rates to be Just and Reasonable”•AS 44.83.710(c)(2)(D) Account for costs to own and operate the BTS, as established by the commission or by contract•Pre-filed testimony in U-24-026 states the RTO will take transmission costs in each Railbelt utility, specifically through expressed annual transmission revenue requirements (ATRRs) and accumulate those into an RTO ATRR. •Railbelt utilities are working on creating a BTS ATRR for purposes of AS 44.83.710•Ratemaking principle – Cost Causer (and/or beneficiary) = Cost Payer•AEA collects rates in accordance with established contracts•AS 44.83.090 “Power Contracts and the RCA”•AS 44.83.710(c)(2)(A) Account for BTS ancillary services•Railbelt utilities have existing approved rates for ancillary services Committee Considerations•How should rates established by existing agreements be accounted for in the OATT?•How should BTS costs be allocated – coincident peak, load ratio share, or a combination of both?•How should the limited facilities and benefits provided be handled in the revenue mechanism?•How will the revenue mechanism address disruptions and congestion?•How will the revenue mechanism address the RCA requirements of nondiscriminatory, just and reasonable rates?•How often will RTO rates need to be updated?