WELCOME
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Where did the journey begin?
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FERC Order 890 Timeline
• February 2007 FERC issues Order 890
• December 2007 FERC issues Order 890-A
• June 2007 FERC issues Order 890-B
• March 2009 FERC issues Order 890-C
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FERC Order 890 Timeline
• February 2008 Western forms an Order 890 Team
• June 2008 Western forms Tariff Administration Team
(TAT) to implement the Tariff.
• June 2009 Western has public customer meeting on
proposed Tariff.
• September 2009 Western files new Tariff with FERC
• December 1, 2009 Western implements new Tariff
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FERC Order 890 Changes
• Unreserved Use
• Reselling/Reassigning of Transmission
• Ancillary Services (Energy & Generator Imbalance)
• Rollover
• Simultaneous Submission Window
• LGI Procedure & Environmental Agreement
• Network Service
• Conditional Firm
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Unreserved use – Schedule 10
Question: What is unreserved use of transmission service?
 Use of transmission service that is not reserved or is in
excess of reserved capacity
 Non-secured reserved capacity or exceeded firm or nonfirm reserved capacity at any point of receipt or delivery
 OATT doesn’t specify all circumstances that constitute
use of transmission service without a transmission
service reservation
 DSW will go through Rate process. Unreserved use
slides are examples and may change during Rate process.
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Unreserved use
Example Scenario - Point to point
Unreserved Use Applies
NO RESERVATION
Load
Load
PTP
RESERVATION
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If Load > than PTP Reservation,
Unreserved Use Applies
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Unreserved use
Example Scenario - Excess Generation and
Network
If Gen > than PTP Reservation,
Unreserved Use Applies
PTP
RESERVATION
NITS
Load
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If Load > than Forecast, Unreserved
Use DOES NOT Apply
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Unreserved use – Frequency & Penalty
Multiple hours
in one day
• Daily Firm Point-to-Point Service rate
Multiple days
in one week
• Weekly Firm Point-to-Point Service
rate
Multiple weeks
in one month
• Monthly Firm Point-to-Point Service
rate
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Reselling of Transmission
Price of reselling Transmission
Pro Forma FERC 890: Allows for reselling of transmission
at “market rate”. Transmission cap rate is no removed, no
longer restricted the price a customer can sell transmission.
Western Implementation: Western decided not to adopt
this language. The cap will remain in place.
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Reselling of Transmission
Western’s Role as a Financial Mediator
Pro Forma FERC 890: Requires transmission provider to act
as the financing wharehouse for the reseller and third party
purchasing the transmission from the reseller.
Western Implementation: Due to Western’s financial
authority limitation, we couldn’t perform this function.
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Reselling of Transmission
New Agreement for Reselling, called Attachment A-1
Pro Forma FERC 890: New Attachment called A-1 was
created for the sole purpose of reselling/reassigning of
transmission agreements.
Western Implementation: Western will use the new
Attachment A-1 for writing reselling and reassignment
agreements.
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Imbalance Services
Energy Imbalance & Generator Imbalance
Pro Forma FERC 890: Implemented new tiers for Energy
Imbalance. Created new Schedule for Generator Imbalance
Western Implementation: Western decided Energy
Imbalance and Generator Imbalance will be handled through
the each Region’s Rate process.
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Rollover Rights
Change in Rollover Rights
• Existing requirement is a minimum term of one year to have
rollover rights. New minimum requirement requires a
duration of five years for customer to have the option to
exercise rollover rights.
The existing requirement is sixty days notice given to
Western. New requirement is one year notification to
Western.
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Rollover Rights
Change in Rollover Rights (Continued)
• The change in rollover rights can be found in Section 2.2 of
Western’s new Tariff.
• Section 2.2 is applicable when FERC accepts Western’s
Attachment P (Planning Process), until then the current sixty
day notice will be applied.
• When Western’s Attachment P is accepted by FERC a
business practice will be posted explaining how Western will
handle Agreements that expire within one year.
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Simultaneous Submission Window
What is Simultaneous Submission Window?
• FERC Order 890 required TPs who set a “no earlier than”
time limit for TSRs to treat all received within a specified
period of time as having been received simultaneously.
• New provision can be found in Section 13.2.
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Simultaneous Submission Window
Western implementation of Simultaneous Submission
Window
• Only applicable to short term firm point-to-point. NonFirm, Hourly-Secondary, and long-term requests will have
the same evaluation process.
• Western will treat all applicable requests received within
five minutes of window opening as having the same queue
time.
• If there’s not enough capacity to accommodate the requests,
Western will implement a lottery to allocate the capacity.
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Simultaneous Submission Window
Lottery implementation
• Western will implement the lottery giving priority to
requests in the following order:
A. Service Increment
• In order Monthly, Weekly, Daily, and Hourly
B. Duration of the request
C. Pre-Confirmation
• Request that are preconfirmed will have priority over
non-preconfirmed requests.
• Pre-Confirmation
D. Price
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Large Generation Interconnection
Procedure & Environmental Studies
Changes to Large Generation Interconnection
Procedure
• Within 15 calendar days of providing a system impact study
report, an environmental review agreement will be provided
to the customer.
• Environmental review agreement must be executed and
funded by the customer within 30 calendar days .
• If agreement isn’t executed and funded with the required
time, the interconnection request will be deemed withdrawn.
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Network Transmission Service
Changes to Network Transmission Service.
•Attestation of resources is required.
• Minimum term of designating a network resource (DNR).
• Requirements of DNR
• If agreement isn’t executed and funded with the required
time, the interconnection request will be deemed withdrawn.
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Network Transmission Service
Requirements of Designated Network Resources.
• Resource must be owned, leased, or customer purchases
non-interruptible power under executed contracts.
• DSW, CRSP, RMR, and SNR will not require purchases from
a specific generating unit.
For off-system resources, Customer is required to obtain and
demonstrate to Western it either has or is in the process of
obtaining firm transmission from the point where the
Customer takes delivery.
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Network Transmission Service
Requirements of Designated Network Resources
• For Day-Ahead and Real-Time purchases, Western will
reserve the capacity for the length of those purchases.
• Network Resources currently listed in Network Agreements
will remain “Grandfathered”, until expiration of the Network
Resource, expiration of the Network Agreement, or Resource
is undesignated.
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Conditional Firm Transmission Service
What is Conditional Firm?
 Modified form of long-term firm PtP service that includes




less-than-firm service in a defined number of hours of the
year or during defined system conditions. (OATT Section
15.4)
No separate queue
The service can be curtailed solely for reliability reasons
during the defined system conditions or defined number of
hours.
Western will offer either option (considerations)
NERC Priority 6 during “conditional” periods
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Conditional Firm Transmission Service
Conditional Firm Bridge Product
 For customers supporting the construction of upgrades,
the planning redispatch or conditional firm options will
serve as a bridge until upgrades are constructed to remedy
the congested transmission facilities.
 For these customers, the TP must offer planning redispatch
or conditional firm service until the time when the
upgrades are constructed. The conditions or redispatch
applicable to this period must be specified in the service
agreement and are not subject to change.
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Conditional Firm Transmission Service
Conditional Firm
 Western retains the right to perform a biennial assessment
of the conditions to reassess the conditions.
 A customer taking conditional firm service will be first in
the queue for transmission service if a non-conditional
firm service stops taking service.
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Contact Information
 For questions regarding implementation of Order 890,
please contact the TAT member for your Region:
 CRSP: Dave Shelton – (801) 524-4012
 DSWR: John Steward – (602) 605-2774
 RMR: Raymond Vojdani – (970) 461-7379
 SNR: Ira Witherspoon – (916) 353-4659
 UGPR: Steve Sanders – (406) 247-7436
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