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EIM Entities Presentation on Transmission Elements of EDAM Design Feb 11-12, 2020 1 Pream eamble The EIM Entities are a diverse group differently situated based upon geography, resource portfolios, and jurisdictional status, among other


  1. EIM Entities Presentation on Transmission Elements of EDAM Design Feb 11-12, 2020 1

  2. Pream eamble  The EIM Entities are a diverse group differently situated based upon geography, resource portfolios, and jurisdictional status, among other potential differentiating factors.  Some EIM Entities may not have yet formulated individual positions on specific market design issues. Therefore, while this presentation represents a consensus view, it may not necessarily represent the ultimate position of any individual EIM Entity.  Some EIM Entities may choose to offer their own individual contributions where appropriate, either in comments or throughout the stakeholder process. 2

  3. Agen enda  Overview and Principles  Western OATT Environment vs. CAISO Transmission  EIM Transmission  Sources of EDAM Transmission Capacity  Seams and Third-party Transmission Customer Issues  Other Considerations  Losses  BA vs TSP Modeling  Operational and Commercial Seams  Tariff Structure and Rate Change Rights 3

  4. Overview and Principles 4

  5. Overview of of Prese esentation Design must be mindful of differences of Transmission Design concepts presented Providers among the EIM entity community • Informed by experience in the EIM • System topology • Guided by EDAM principles • Transmission cost recovery document • Interactions with third-party transmission customers • Modeling of Joint-owned transmission • Jurisdiction 5

  6. Key y Princi ciples • OATT Administration (modified to facilitate EDAM) Planning and Operational Control • Transmission and Balancing Authority Operations Unchanged • Transmission planning and siting remains with utilities and regulators No Materially Significant • Balance cost and benefits of transmission including recovery of Cost Shifts transmission costs and compensation for transmission utilization Transmission Should • Transmission charge/hurdle rate imposed should not impede EDAM Facilitate Market efficiency Activity • Bi-lateral purchases and sales Reasonably Compatible with Existing Market • Reserve Sharing Groups Transactions • Respect long-term transmission ownership/rights Congestion Rent • Transmission Customers contributing transmission should receive Revenue proportionate congestion rents 6

  7. Open Access Transmission Tariff (OATT) Environment 7

  8. FE FERC OATT FERC’s Order No. 888 required all public utilities that own, operate or control The FERC pro-forma tariff defines: interstate transmission facilities to: • Offer network and point-to-point transmission • Process for requesting transmission service; service and ancillary service to eligible • Rates, terms, and conditions for service; customers; • Required ancillary services and rates for those • Take transmission service for their own use services; under the same terms and conditions; • Studies conducted to determine the availability • Functionally separate transmission and power of transmission and interconnection service; marketing functions; • Priorities among competing transmission service • Adopt an electronic transmission system requests, including rights of first refusal; information network; and • Curtailment priorities; and • Have on file with FERC an Open Access • Provisions dealing with billing and payment, Transmission Tariff creditworthiness, force majeure, liability, and indemnification 8

  9. OATT Ser Service ce Network Integration Point-To-Point Transmission Available Transfer Capability Transmission Service (NITS) Service (PTP) (ATC) • Firm transmission utilized by • Capacity based reservation • ATC is the transfer capability a Designated Network from a specified point of remaining on a transmission Resource (DNR) receipt to a specified point provider’s transmission of delivery on a transmission system that is available for • Transmission rate based on providers system further commercial activity load ratio share over and above already • Varies in length of service • Allows for secondary committed uses term (Long-Term or Short- network (non-firm) Term) and firmness (Firm or • Firm – unreserved by a utilization for non-DNR with non-firm) customer priority over other non-firm service • Transmission charged on • Non-firm – reserved but reserved capacity not scheduled for that timeframe • Methodology for calculating ATC typically found in OATT Attachment C 9

  10. Com ompari rison of of OATT to o CAISO Provision OATT CAISO Tariff Products Network and (Firm and Non-firm) Point-to Point Schedule delivery (economic, not firm physical, rights) Rate Structure Single provider - charges based on posted OATT rates High voltage (200 kV and above) single-system (combined and vary based on form of transmission services revenue requirements of all participating transmission procured by Transmission Customer, often offered in owners); hourly, daily, monthly and annual increments and firmness/quality Low voltage zonal rates based on utility-specific costs Network – load ratio share Currently a volumetric rate ($/MWh); proposal to move to Point-to-point based on capacity reservation ½ volumetric and ½ demand CAISO loads are charged TAC Exports and MSS Loads are charged WAC Firm Network transmission service is firm when Network Firm PTP rights only for “grandfathered” pre -existing Transmission Load is supplied from Designated Network Resources transmission contracts on PTOs’ systems Rights (DNR) Priority to inject or withdrawal based on economic bids, If there is ATC available, firm PTP transmission can be system constraints and other factors (e.g., RMR for supply) procured Firmness of exports protected through “supporting resource” in CAISO (i.e., supply tied to export not already committed to an internal CAISO RA obligation) 10

  11. Com ompari rison of of OATT to o CAISO (con ontinued) Provision OATT CAISO Tariff Congestion Expectation is that absent an outage or de-rate there Collected through Locational Marginal Price (LMP) [LMP = Management will be sufficient transmission capacity to system marginal energy + marginal congestion + marginal accommodate NITS and Firm PTP without any loss] redispatch charge. Load can be hedged through Congestion Revenue Rights Non-Firm PTP may be subject to curtailment, not redispatch with an associated congestion charge. Transmission Average system losses based on stated rate Marginal losses charged though LMP [LMP = system Losses marginal energy + marginal congestion + marginal loss] Curtailment Based on “firmness” of rights used by transmission Based on economic bids/Self-Schedules based on priority Priority customer assigned in Tariff (i.e., “penalty factors” – assigned numeric values to schedules. The higher the value, the firmer) Wheeling If PTP wheeling moves through multiple balancing Single WAC for exports from anywhere within the CAISO authorities/transmission service providers, rates are (except EIM exports). Will see additional pancaked charge “pancaked” (i.e., cumulative). Dependent on PTP from an OATT transmission service provider beyond CAISO reservation not import/export of energy in the BA. boundary. 11

  12. Transm smissi sion Ser Service ce Regu egulatory ry Diversi sity Investor Owned Utility Municipal or Public Utility Power Marketing Provincial Utility District Administration • • • • Provides transmission Various organic statutes Various organic statutes Organizational service under a FERC- that create/govern the that create/govern the separation between approved OATT utility utility operational and • • • Rates and OATT Very limited FERC Various oversight by marketing functions • changes approved by regulation and no DOE and Congress Limited FERC regulation • • FERC in publicly FERC-approved OATT Limited FERC regulation Marketing organization • • notified dockets under Various mechanisms for Maintain OATT but is the EIM Entity and the FPA memorializing terms none are approved by does not provide • Non-interstate business and conditions of FERC transmission service • regulated by a state transmission service Various rules for • regulatory body Various local changing OATT terms governance and and conditions regulatory schemes 12

  13. EIM Transmission 13

  14. EIM Tran ansmissi sion EI Interchange Rights Holder – previously reserved transmission donated by Transmission Customers Sources of EIM Transmission Available Transfer Capacity – Unreserved or unscheduled transmission identified by the EIM Entity transmission provider Energy Transfer System Resources (ETSRs) are defined in each EIM BAA to anchor the Energy Transfer schedules from that BAA to other BAAs in the EIM Area for tracking, tagging, and settlement There is no charge for transmission usage in the EIM 14

  15. Aver erage EI EIM Tran ansfer r Limits s Q3 Q3 20 2019 19 15

  16. Sources of EDAM Transmission Capacity 16

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