WASN Operations Business Procedure OASIS COVER PAGE

Transcription

1 No. COVER PAGE This page will be removed when final document is posted Western Area Power Administration Sierra Nevada Region () Business Practice/ covering Sierra Nevada Regional procedures is being updated. This document was posted to provide customers the opportunity to comment on the proposed changes on 9/15/2016. No comments were received during the 10 day comment period. Document will now posted to Pending BP s folder. Planned Posting - 9/26/2016 to 10/03/2016 to cover the 5 day posting requirement The only change to this document is in section , which deals with financial return for losses on CVP transmission. The changes concern financial settlement of loss paybacks removing WAPA s cost component and to add clarity to the pricing. Page 1 of 24

2 No. 1. PURPOSE 1.1. This Business () sets forth the current business procedures and timing requirements for Western Area Power Administration s (Western) Open Access Transmission Tariff (OATT) transmission service, non-oatt transmission service contracts, and any Party with contractual transmission capacity rights on Western transmission facilities (Party) in Western s Sierra Nevada Region (). All business procedures listed are considered current unless otherwise noted. establishes requirements for the transmission reservation, service, or transmission capacity rights and energy scheduling processes. The following Transmission systems are included under these requirements and processes: CVP Central Valley Project Transmission, 500-kV, 230-kV, 115-kV, 69- kv, 60-kV COTP s transmission capacity rights on the California-Oregon Transmission Project, 500-kV PACI s transmission capacity rights on the Pacific AC Intertie, 500-kV 1.2. s share of Path 15 transmission capacity is under California Independent System Operator (CAISO) control and is managed in accordance with the CAISO Tariff If any business procedure or timing requirement listed herein conflicts with Western s OATT, a non-oatt transmission service contract, or a Party s contractual transmission capacity rights, the OATT, non-oatt transmission service contract, or a Party s contractual transmission capacity rights, respectively shall apply s transmission service rates are established under existing federal ratemaking rules through an open administrative process. s approved rates are posted at: in the Current Rates and Losses folder All electronic-tag (E-tag) loss accounting and payback schedules shall comply with Western Electricity Coordinating Council (WECC) Business Practices and Standards, North American Electric Reliability Corporation (NERC) Standards and tagging procedures, and Western s OATT, or as set forth in the terms and Page 2 of 24

3 No. conditions of a non-oatt transmission service or a Party s transmission capacity right contract. 2. APPLIES TO: 2.1. Transmission Customers (under OATT and non-oatt contracts) 2.2. transmission capacity rights holders under contract 2.3. Settlements 2.4. Transmission Scheduling and Security Dispatchers (TSS) 3. SYSTEMS INVOLVED 3.1. Electronic Tagging System and WebTrans 3.2. OATI 4. ACCEPTANCE OF REQUESTS 4.1. For short-term transmission service requests, will accept transmission service requests when there is Available Transfer Capability (ATC) available, contingent on system conditions For long-term transmission service requests, a system impact study may be required to determine if ATC is available. 5. LIMITATIONS ON QUANTITY OF REQUESTS 5.1. The quantity of requests are limited as follows: CVP, COTP or PACI Transmission Requests : will refuse eight (8) or more requests for the same posted path submitted by the same transmission requestor within any one (1) clock hour. Requests include any request that is submitted, regardless of state that the request may be in or become Monthly Non-firm Requests: For the first twelve (12) hours of the request timing window (00:00:00 Pacific Prevailing Time [PPT] to 12:00:00 PPT, 60 calendar days prior to the start of service), only one(1) request per posted path will be allowed per customer each clock hour. If more than one request by the same customer for service is submitted during this time frame all Page 3 of 24

4 No. requests for that clock hour will be refused. This practice only applies to the first 12 hours of the request-timing window. After the 12 hours have passed, the practice of refusing 8 or more requests, as stated above, will apply. Requests include any request that is submitted, regardless of state the request may be in or become. 6. UNAUTHORIZED USE OF TRANSMISSION 6.1. Unauthorized use is defined as unscheduled or untagged use of Western s transmission system and any affiliated ancillary service, exceeding reserved capacity at any point of delivery or receipt. Unauthorized use may also include a Transmission Customer s or Party s failure to curtail transmission when requested or required through the curtailment of a tagged transaction If a Transmission Customer (including the transmission provider for third- Party sales) or Party engages in unauthorized use of -managed transmission systems, the Transmission Customer or Party will be charged in accordance with the effective Unauthorized Use of Transmission Rate Schedule at the time of the unauthorized use Unreserved Use Penalties will not apply to Transmission Customers or a Party as a result of action taken to support reliability at the direction of Western. 7. SCHEDULING PATHS 7.1. Transaction schedules must be tagged from the same POR/POD combination as identified in the confirmed Open Access Same-time Information System () reservation or contract Transaction schedules that do not match POR/POD as identified in or contract will not be allowed and the E-tag will be denied Secondary delivery points (transmission redirects) may be granted as provided in the OATT. 8. CONSTRAINED PATHS 8.1. is one of many transmission owners of the California Oregon Intertie (COI) including the California-Oregon Project (COTP) and the Pacific AC Intertie (PACI). COI is a constrained path and the California ISO acts as the Page 4 of 24

5 No. Path Operator (Path 66) while and others manage their share of the COI transmission capacity The COI is a WECC qualified path for control of unscheduled flow. Transactions taking place across the COI are subject to the WECC unscheduled flow mitigation procedures and to the inter-regional Operating Transfer Capabilities (OTC) violation mitigations that may result in reduction of transmission capability and/or scheduled transactions on a day-ahead, hour-ahead, or real-time basis. 9. COI PATH 66 SHARE OF COTP & PACI 9.1. ATC on s share of the COTP and PACI will be posted on the Path 66 may become overloaded as a result of unscheduled flow or reduction of ATC due to circuit or equipment outages. Coordinated phase shifter operation and/or schedule reductions may be required on the qualified paths. The dispatcher may determine that current system conditions are such that the anticipated transaction schedule(s) cannot be implemented, and adjustments to the existing transaction schedules may be required consistent with Western s OATT. 10. CVP TRANSMISSION CVP ATC will be posted on the. A portion of the CVP transmission in the greater Sacramento area is constrained and subject to cuts by an automatic Remedial Action Scheme (RAS) throughout the entire year, especially during the summer peak load periods. 11. EXPANDED OATT TRANSMISSION SERVICE Redirect: Redirect is available on all firm reservations. Redirect requests shall be submitted as Secondary Hourly service requests from an Alternate POR/POD Partial : If cannot accommodate a customer s request in its entirety for lack of ATC, will Counteroffer transmission service for the capacity that is available. Page 5 of 24

6 No. 12. TRANSMISSION REAL POWER LOSSES Transmission losses will be assessed for all real-time and prescheduled transactions on transmission facilities managed by as follows: Import Transaction: Transactions that show the source as a Balancing Authority outside of Sub-Balancing Authority and a sink in Sub-Balancing Authority Export Transaction: Transactions that show the source as Sub- Balancing Authority and the sink as another Balancing Authority Wheeled-Through Transactions: Transactions that flow through the entire Sub- Balancing Authority for which Sub-Balancing Authority is an intermediary system /Transmission Provider and the transaction neither originates nor sinks within the Sub-Balancing Authority Loss Factors are as follows: CVP 500-kV losses are established by contract CVP 230-kV losses = 1.6% CVP 115-kV and 69-kV losses are established by contract Losses through transformers are established by contract PACI Losses are assessed in accordance with the the CAISO Tariff The above provisions may not apply if there are pre-existing contractual arrangements or other specified methods to assess losses. 13. TRANSMISSION REAL POWER LOSSES: CALCULATION AND SETTLEMENT Losses will be assessed against all real-time and prescheduled transactions on transmission facilities managed by, with the exception of pseudo ties has determined that Transmission Customers or parties with transmission capacity rights on s transmission system (Party) will settle transmission losses through either a return of in-kind energy or through a financial settlement, unless otherwise agreed to in writing. The Page 6 of 24

7 No. Transmission Customer or Party and must agree on which method will be used for settling transmission losses. Additionally, the Transmission Customer or Party can change the method used to settle losses on an annual basis. The Transmission Customer or Party must contact Settlement department via at indicating their preference if they want to change the option used. This request would be implemented annually and be effective for the upcoming October and remain in effect until the following September For return of in-kind energy Transmission Customers or Party have the option of scheduling the energy concurrently but not more than1 week in arrears, unless otherwise required under other agreements and contracts The calculation and settlement of the loss obligations incurred by the Transmission Customer are managed as outlined below Transmission Real Power Losses for a Party or Customers Taking Transmission must either: Return in-kind energy to settle their transmission loss obligations with not more than seven (7) days in arrears; or through a loss payback schedule concurrently in the same hour unless otherwise required under other agreements and contracts; or For the Transmission Customers or Party choosing to settle financially, the Transmission Customer or Party shall pay for such losses at the greater of the price consistent with a monthly average of the CAISO s hourly Mmarket Cclearing Pprice (LMP)at the NP15 trading hub (TH_NP15_GEN-APND) locational market price (LMP) in the month at the time the loss is incurred or Western s calculated cost based on prior year Base Resource revenue requirement ($) divided by Base Resource energy (MWh). For any month(s) that the monthly average LMP is negative, no credit is given Loss Account Calculation: Western Settlements will retrieve each transmission customer s usage from WebTrans the next business day. The settlements group will validate the calculations and checkout balance(s) with the Transmission Customer each business day or as agreed to with the customer. Page 7 of 24

8 No All loss payback schedules for using CVP and COTP transmission will require a separately identified loss payback e-tag Loss calculations are based upon the sum of the absolute values of the entire Transmission Customer s final hourly scheduled energy multiplied by the applicable loss factor. will not net schedule for loss accounting purposes Losses will be calculated hourly to three decimal places, but settlement values will be on a daily basis COTP losses will be calculated and settled in seasonal peak periods as defined in section 16 below CVP losses will continue to be calculated and settled in on peak and off peak periods For Transmission Customers or Party choosing to pay losses through return of in-kind energy, the loss payback shall be scheduled after-the-fact not more than seven (7) days in arrears, in the same like period, unless otherwise required under other agreements and contracts Loss calculation period totals for loss payback resulting in less than a whole MW will be carried forward to the following like period. (i.e. truncated values will be carried forward to the next like period) COTP loss calculations seasonal peak period totals resulting in less than a whole MW will be carried forward to the following like period For Transmission Customers or Party choosing to pay COTP loss obligations through return of in-kind energy, the loss payback will be settled not more than one week in arrears clearing balances, with the Seasonal adjustment factors not holding over balances Season-to-Season Losses accumulated while going from one season to another (Summer Season vs. Winter Season) will be settled in the same hours using the 7 day payback schedule CVP loss calculations on and off peak period totals resulting in less than a whole MW will be carried forward to the following like period. Page 8 of 24

9 No Absolute value total Peak periods will be carried forward from month to month If the Transmission Customer or Party has opted to pay losses through return of in-kind energy, and such COTP and/or CVP loss balances due Western are not settled within seven (7) days during the same energy period. Western shall bill the Transmission Customer or Party and the Transmission Customer or Party shall pay one and one-half (1.5) times the CAISO hourly market clearing price for the unreturned energy or actual replacement energy if procured by Western and any other related costs incurred by Western unless Western and the Transmission Customer or Party mutually agree to another loss payback settlement arrangement Loss calculation will be based upon the sum of the absolute values of the entire Transmission Customer s or Party s final hourly scheduled transactions multiplied by the applicable loss factor For CVP Transmission transactions that are settled as energy-inkind, the loss obligation will be calculated hourly, but truncated on a daily basis for the total daily On-Peak period and the total daily Off-Peak Period, with truncated values being carried to the next like period For COTP Transmission transactions that are settled as energy-inkind, the loss obligation will be calculated hourly using the seasonal adjustment factors outlined in Section 16 of this business procedure. 14. Energy Return for Transmission Losses Transactions Deficient Energy Return: When the loss obligation is underpaid: Western shall bill the Transmission Customer or Party and the Transmission Customer or Party shall pay one and one-half (1.5) times the CAISO hourly market clearing price for the unreturned energy or actual replacement energy if procured by Western and any other related costs incurred by Western unless Western and the Transmission Customer agree to another loss payback settlement arrangement Surplus Energy Return: If the Transmission Customer s or Party s loss return energy is overpaid, the overpaid amount of energy is deemed lost to the Transmission Customer or Party and no credit is given. No financial compensation or energy return will be provided by for overpayment of loss obligations. There should be no condition beyond the control of the Page 9 of 24

10 No. Transmission Customer or Party that results in overpayment. The Transmission Customer or Party is entirely in control of knowing how much energy they schedule and calculating and scheduling to repay for losses. 15. Delivery Points For Transmission Losses Scheduled losses can be delivered to any POR or POD as mutually agreed by and the Transmission Customer or Party. 16. COTP Loss Accounting Loss Accounting Factor (LAF) The LAF types for COTP are determined by specific time of day and season as illustrated below (times indicated below are real-time and not Hour Ending): SUMMER SEASON (MAY 1 through OCTOBER 31) MONDAY THROUGH FRIDAY EXCEPT HOLIDAYS* SATURDAY, SUNDAY, and HOLIDAYS COTP LOSS FACTORS (%) PEAK NOON to 6:00PM N/A 3.8% 8:00AM to NOON N/A PARTIAL PEAK 2.5% 6:00PM to 9:00PM N/A OFF PEAK 9:00PM to 1:00AM 5:00AM to 8:00AM 5:00AM to 1:00AM 1.4% SUPER OFF PEAK 1:00AM to 5:00AM 1:00AM to 5:00AM 1.4% Page 10 of 24

11 No. WINTER SEASON (NOVEMBER 1 through APRIL30) MONDAY THROUGH FRIDAY EXCEPT HOLIDAYS SATURDAY, SUNDAY, and HOLIDAYS COTP LOSS FACTORS (%) PEAK N/A N/A N/A PARTIAL PEAK 8:00AM to 9:00PM N/A 2.3% OFF PEAK SUPER OFF PEAK 9:00PM to 1:00AM 5:00AM to 8:00AM 1:00AM to 5:00AM 5:00AM to 1:00AM 1:00AM to 5:00AM 1.6% 1.6% COTP Loss Payback All loss paypack schedules for using COTP transmission will require a separately identified loss payback e-tag. will not net schedule for loss accounting purposes Loss payback will be the product of the Transmission Customer s final hourly scheduled energy times the LAF. will not net schedule for loss accounting purposes. 17. CVP Loss Accounting Loss Accounting Factor (LAF) The LAF for CVP 230 kv transmission is 1.60% Losses for special arrangements across a bus or transformer are established via contractual arrangement Wheeling energy across a Western bus without a change in voltage will not incur a charge for losses. Page 11 of 24

12 No Loss Payback All loss payback schedules for using CVP transmission will require a separately identified loss payback e-tag Pseudo tie arrangements will require a loss payback schedule based upon actual metered flow with whole numbers using Western numbers unless agreed to otherwise Decimal places on actual metered flow will be truncated and carried forward to the next like period Loss payback profiles will be the product of the Transmission Customer s or Party s hourly scheduled energy, actual energy flow for pseudo ties and the LAF. 18. NON-FIRM REQUESTS ATC for Non-Firm reservations on CVP will be posted on All Non-firm Transmission Requests shall be pre-confirmed To maximize transmission usage, Non-Firm service on the CVP transmission system may be offered if/when the offered service will not violate the Sacramento Area operating nomogram No exceptions will be allowed for operational problems originating at the customer s site Some Real-Time Hourly requests may be refused for insufficient ATC based on system conditions Non-Firm reservations will be curtailed using the pro-rata method. 19. FIRM TRANSMISSION REQUESTS All requests for Short-Term Firm Transmission must be made through the. Page 12 of 24

13 No All Short-Term Firm Transmission Requests (term of less than one year) shall be pre-confirmed with an Enabling transmission service contract All requests for Long-Term Firm Transmission must be made in accordance with the OATT All Long-Term Firm Transmission requests will initially be placed in STUDY mode The non-refundable processing fee must be received by in accordance with Section 17 or 29 and other applicable sections of the OATT Information required for a complete application, is set forth in Section 17 and 29 and other applicable sections of the OATT. The Transmission Application form is available at under General Information A Agreement will be tendered to the Transmission Customer upon satisfying the requirements of the OATT Firm reservations will be curtailed using a pro-rata method. 20. Conditional Firm Transmission Conditional Firm ( CFS ): A form of long term firm PTP service that is offered when the TSP does not have long term firm available transfer capability ( ATC ) to meet the request. CFS includes less than firm service defined by a lower curtailment priority in either a defined number of hours in a year or during predefined system conditions (Order No and 912). CFS does not preclude the TSP s obligation to offer other forms of partial interim service (i.e., partial MW offers, partial duration offers, or a combination of the two). The TSP is obligated to make a partial offer of firm service if possible. The remainder can then be studied to determine whether a CFS offer is possible if the customer desires a CFS SIS. 21. PRE-CONFIRMED TRANSMISSION REQUESTS Transmission customers are prohibited from withdrawing pre-confirmed nonfirm and short-term firm point-to-point transmission service requests prior to when the transmission customer is offered service or a system impact study. Page 13 of 24

14 No TSS Dispatchers may invalidate a pre-confirmed request at the request of the transmission customer following submittal of the request, in the event the transmission customer makes an inadvertent error in submitting its request Please refer to the Western common business practice at BP-Annulments-Version pdf 22. ENERGY SCHEDULES Per WECC approved business practices, an approved transaction tag must accompany all pre-scheduled non-real-time energy transactions. If there is no valid tag, the schedule will not be implemented Tags for real-time energy transactions shall be submitted in accordance with NERC Standards. 23. Rollover Requests Any existing Long-Term customer that wishes to exercise its reservation priority must make an application for its new service term in accordance with OATT procedures. Notification to exercise a right of first refusal for Long-term Firm transmission under Section 2.2 of OATT must be received by the Transmission Provider no less than sixty days (60 days) prior to the date an existing Long-term contract ends and the commencement of the new service. In addition, the request to exercise roll over rights on should be made by selecting Request Type of Renewal. 22. ANCILLARY SERVICES RATES Scheduling, System Control and Dispatch : This service is required to schedule the movement of power through, out of, within, or into the Sub-Balancing Authority. This service can be provided only by the Transmission Provider where the transmission facilities are located. The Transmission Providers charges for Scheduling, System Control and Dispatch s are included in the transmission rates Reactive Supply and Voltage Support (VAR Support): Page 14 of 24

15 No In order to maintain transmission voltages on the Transmission Provider s transmission facilities within acceptable limits, generation facilities under the control of the transmission provider or the Transmission operator are operated to produce or absorb reactive power. Thus, the Transmission Customer must purchase this service from the Transmission Provider. The cost for VAR Support is included in the power rates. 23. CYBER SECURITY CONTROL: The IT (N2000) organization administers Cyber Security. The SCADA system is designated as Mission Critical and as a result has the most stringent cyber security controls applied. All access to the SCADA system is controlled by placing terminals behind secure card-key access doors in a control center that is staffed continually The webtrans, webtrader, e-tag, and computer programs require a secure digital certificate to access the program. These programs are remotely hosted from the Open Access Technology International (OATi) offices in Minneapolis, Minnesota and require access through digital certificates. OATi provides a fully secured and redundant computer center with full data backups The After the Fact Settelements group verifies the actual transmission usage with each Transmission Customer before return energy can be scheduled. The Transmission Customers confirm the values and if there is a discrepancy, it is investigated and corrected. 24. SUBSEQUENT PROCESS FLOW: Transmission loss obligations are returned through a loss return schedule which shall be scheduled after-the-fact one week in arrears, in the same energy profile unless otherwise agreed to by the parties annually and set forth for implementation the first day of October. 25. CONTINGENCY PROCESS: There is no viable contingency process for this item. Page 15 of 24

16 No. 26. TERMS OF SERVICE ATTACHMENTS Attachments are continued on next page Page 16 of 24

17 No. FIRM TRANSMISSION SERVICE REQUESTS TRANSMISSION REQUESTS RESPONSE TIME DISPLACE/ SUPERSEDE Type Term Curtailment Priority No Later Than No Earlier Than Provider Evaluation Time Limit System Impact Study Customer Confirmation Time Limit after ACCEPTED or COUNTEROFFER No Later Than Right of First Refusal Network 1-10 Years 7 (60) Initial Month 10-Years (30) (60) (15) N/A N/A Firm Pointto-Point Fixed Monthly ( Month) 1-11 Months 7 (14) Start Of 120 days Prior To (30) 1 (60) 4 1-Month Prior To Commencement Of 24-Hours Firm Pointto-Point Fixed Weekly 1-4 Weeks 7 (2) Business 60 days Prior To (30) 1 (60) 48 Hours 1-Week Commencement Of 24-Hours Page 17 of 24

18 No. Firm Pointto-Point Fixed Daily ( Day) Day 30 days Prior To (30) 1 (30) <24 Hrs Min 2 >24 Hrs 2 24 Hrs 1-Day Commencement Of 24-Hours Or Up To 1-Day schedule Start, Whichever Is Less Firm Pointto-Point (Fixed Hourly) 1-24 Hrs Within One Day 7 30-Mins 0600 (6) Prior to 30-Minutes or As Soon As Practicable N/A <1 Hrs 2-5 Min. 1>24 Hrs 2 5 Min. 24 Hrs 2 > - 10 Min Day Prior To Immediately On Notification Network From Non- Designated Resources Based On Network Reservation Day As Soon As Practicable (1) Business Day N/A Optional 1000 Day Prior N/A 1. Subject to expedited time requirements of Section 17.1 of the pro forma tariff. Transmission Providers should make best efforts to respond within 72 hours, or prior to the scheduling deadline, whichever is earlier. 2. Time QUEUED prior to start of service. Less than (<), Greater than (>). Example: <24 Hrs Request submitted within 24 hours prior to the start of service. Page 18 of 24

19 No. NON-FIRM TRANSMISSION SERVICE REQUESTS TRANSMISSION REQUESTS RESPONSE TIME DISPLACE/SUPERSEDE Type Term Curtailment Priority No Later Than No Earlier Than Provider Evaluation Time Limit System Impact Study Customer Confirmation Time Limit after ACCEPTED or COUNTEROFFER No Later Than Right of First Refusal 1 (Fixed Monthly) 1- Month Day Non- Firm Pointto-Point 60-2-Calender N/A 24 Hours 1400 Day 24-Hours Or 1400 Prior To Schedule Start Whichever Is Less Non- Firm Pointto-Point (Fixed Weekly) 1-4 Weeks Day (14) 4 Hours or As Soon as Practicable N/A 24 Hours 1400 Day 24-Hours Or 1400 Prior To Schedule Start Whichever Is Less Non- Firm Point- (Fixed Daily) 1-6 days Day (2) 30-Minutes or As Soon as N/A 120 Minutes 1400 Day 24-Hours Or 1400 Prior To Schedule Start Whichever Is Less Page 19 of 24

20 No. to-point Practicable Non- Firm Pointto-Point (Fixed Hourly) 1-24 Hrs Within One Day 2 30-Mins 0900 Day Prior to 30-Minutes or As Soon As Practicable N/A <1 Hrs 2-5 Min. 1>24 Hrs 2 5 Min. 24 Hrs 2 > - 10 Min Day Immediately On Notification 1. The right of first refusal applies only with respect to requests for service that are being preempted by competing, longer-term requests for non-firm point-to-point transmission service. 2. Time QUEUED prior to start of service. Less than (<), Greater than (>). Example: <1 Hrs Request submitted within 1 hour prior to the start of service. Page 20 of 24

21 No. DOCUMENT CONTROL Version # Revision Date Details of Revision Page Number Paragraph Number Reason 0 N.A. Original Document Conformed to Internal Controls Standard, Document Control page added Document rewrite to include COTP loss factors and loss payback procedures. Removed obsolete language All Pages All Pages Header All Paragraphs Added fields for Revision date and revision # Set document with outline numbering Changed reference to MORC & 6 Combined BP with Transmission Loss BP and added CVP loss accounting details Page 21 of 24

22 No. Version # Revision Date Details of Revision Page Number Paragraph Number Reason & 7, 9 13 & 14, 17 Clarified most of the sub-sections in section 13, removed section 14.3 and added pseudo tie language into section 17, based upon questions from customers & & Removed Point-to-Point (PTP) designation, since losses are returned for PTP and NITS. Clarified deficient payback results Added section to clarify loss responsibility on a bus Removed reference to sliding service from charts No version change Corrected non-firm fixed hourly No Earlier Than timing Attempted to clarify a loss paypay back question 5 10, 11 18, 19 Added clarifying language for order of curtailments Page 22 of 24

23 No. Version # Revision Date Details of Revision Page Number Paragraph Number Reason Unreserved use penalty changed from 150% to 200 % in 10/1/11 rate filing Added new section for conditional firm Corrected customer charges Updated link to current transmission rates Adjusted loss payback requirement language Removed unnecessary language Reworded COTP Loss payback language Clarified CVP transmission language Replaced LIFO curtailment with Pro-Rata Corrected link to Minor correction Included reference to Western Common BP 8 All Numerous wording changes throughout document, not changing meaning or procedure 6 13 Added financial settlement as a loss return option Page 23 of 24

24 No. Version # Revision Date Details of Revision Page Number Paragraph Number Reason Updated timing table to include Firm Hourly Transmission All 6 All Updates to entire BP - Most of the changes do not change the meaning or intent, they are just for clarification and clean up. The change to section concerning financial settlement of loss paybacks was changed to correct a potential issue xx The change to section concerning financial settlement of loss paybacks to remove WAPA s cost component and to add clarity to the pricing. Page 24 of 24