via electronic filingdec 01, 2014  · december 1, 2014 . via electronic filing . the honorable...

22
December 1, 2014 VIA ELECTRONIC FILING The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Re: Revisions to ISO New England Inc. Open Access Transmission Tariff and Request for Waivers Related to Order No. 676-H; ISO New England Inc., ER15-___-000 Dear Secretary Bose: Pursuant to Section 205 of the Federal Power Act (“FPA”) 1 and Order No. 676-H, 2 ISO New England Inc. (the “ISO”) 3 hereby electronically submits to the Federal Energy Regulatory Commission (“FERC” or “Commission”) this filing to request waiver of, and to incorporate by reference, certain Version 003 Standards for Business Practices and Communication Protocols of the Wholesale Electric Quadrant (“WEQ Standards”) adopted by the North American Energy Standards Board (“NAESB”) and as incorporated by reference into the regulations of the Commission in Order No. 676-H. The ISO’s waiver request includes renewal of waivers previously-granted by the Commission, as the conditions warranting those waivers have not changed, and waiver of certain new standards approved in Order No. 676-H (“Request for Waiver”). The waiver requested herein is consistent with the waivers the Commission granted the ISO with regard to Order Nos. 676, 4 676-C, 5 and 676-E, 6 as well as the Order accepting the 1 16 U.S.C. § 824d (2006 and Supp. II 2009). 2 Standards for Business Practices and Communication Protocols for Public Utilities, Order No. 676-H, 148 FERC ¶ 61,205 (2014), as modified by the Commission’s October 3, 2014 Errata Notice, 149 FERC ¶ 61,014 (2014). 3 Capitalized terms used but not otherwise defined in this filing have the meanings ascribed thereto in the ISO’s Transmission, Markets and Services Tariff (the “ISO Tariff”). Section II of the ISO Tariff contains the Open Access Transmission Tariff (the “ISO OATT”). 4 ISO New England Inc., 117 FERC ¶ 61,195 (2006) (“November 16, 2006 Order”). 5 ISO New England Inc., 125 FERC ¶ 61,201 (2008) (“November 20, 2008 Order”).

Upload: others

Post on 03-Mar-2020

3 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

December 1, 2014

VIA ELECTRONIC FILING The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426

Re: Revisions to ISO New England Inc. Open Access Transmission Tariff and Request for Waivers Related to Order No. 676-H;

ISO New England Inc., ER15-___-000

Dear Secretary Bose:

Pursuant to Section 205 of the Federal Power Act (“FPA”)1 and Order No. 676-H,2 ISO New England Inc. (the “ISO”)3 hereby electronically submits to the Federal Energy Regulatory Commission (“FERC” or “Commission”) this filing to request waiver of, and to incorporate by reference, certain Version 003 Standards for Business Practices and Communication Protocols of the Wholesale Electric Quadrant (“WEQ Standards”) adopted by the North American Energy Standards Board (“NAESB”) and as incorporated by reference into the regulations of the Commission in Order No. 676-H. The ISO’s waiver request includes renewal of waivers previously-granted by the Commission, as the conditions warranting those waivers have not changed, and waiver of certain new standards approved in Order No. 676-H (“Request for Waiver”). The waiver requested herein is consistent with the waivers the Commission granted the ISO with regard to Order Nos. 676,4 676-C,5 and 676-E,6 as well as the Order accepting the

1 16 U.S.C. § 824d (2006 and Supp. II 2009).

2 Standards for Business Practices and Communication Protocols for Public Utilities, Order No. 676-H, 148 FERC ¶ 61,205 (2014), as modified by the Commission’s October 3, 2014 Errata Notice, 149 FERC ¶ 61,014 (2014).

3 Capitalized terms used but not otherwise defined in this filing have the meanings ascribed thereto in the ISO’s Transmission, Markets and Services Tariff (the “ISO Tariff”). Section II of the ISO Tariff contains the Open Access Transmission Tariff (the “ISO OATT”).

4 ISO New England Inc., 117 FERC ¶ 61,195 (2006) (“November 16, 2006 Order”).

5 ISO New England Inc., 125 FERC ¶ 61,201 (2008) (“November 20, 2008 Order”).

Page 2: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

ISO’s compliance filing in response to Order No. 890.7 The revisions to Schedule 24 – Incorporation by Reference of NAESB Standards (“Schedule 24”) of the ISO OATT are also included in this filing to incorporate by reference the Version 003 WEQ Standards for which the ISO does not request waiver (“Schedule 24 Revisions”).

The ISO respectfully requests that the Commission waive compliance requirements for the WEQ Version 003 Standards specified in this filing and accept the Schedule 24 Revisions as proposed in this filing, without modifications or conditions, with an effective date of February 2, 2015.

I. DESCRIPTION OF THE ISO AND COMMUNICATIONS

The ISO is the private, non-profit entity that serves as the regional transmission organization (“RTO”) for New England. The ISO operates the New England bulk power system and administers New England’s organized wholesale electricity market pursuant to the ISO Tariff and operating agreements with transmission owners. In its capacity as an RTO, the ISO has the responsibility to protect the short-term reliability of the New England Control Area and to operate the system according to reliability standards established by the Northeast Power Coordinating Council (“NPCC”) and the North American Electric Reliability Council (“NERC”).

All correspondences and communications in this proceeding should be addressed to the undersigned for the ISO: Monica Gonzalez Senior Regulatory Counsel ISO New England Inc. One Sullivan Road Holyoke, MA 01040-2841 Tel: (413) 535-4178 Fax: (413) 535-4379 E-mail: [email protected]

II. STANDARD OF REVIEW

The Schedule 24 Revisions are being submitted pursuant to Section 205 of the FPA, which “gives a utility the right to file rates and terms for services rendered with its assets.”8 Under Section 205, the Commission “plays ‘an essentially passive and reactive’ role”9 whereby

6 ISO New England Inc., 133 FERC ¶ 61,215 (2010) (“December 16, 2010 Order”); ISO New England Inc., 132 FERC ¶ 61,208 (2010) (“September 7, 2010 Order”).

7 ISO New England Inc., 123 FERC ¶ 61,133 (2008).

8Atlantic City Elec. Co. v. FERC, 295 F.3d 1, 9 (D.C. Cir. 2002).

9Id. at 10 (quoting City of Winnfield v. FERC, 744 F.2d 871, 876 (D.C. Cir 1984).

________________________ (...continued)

Page 3: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

it “can reject [a filing] only if it finds that the changes proposed by the public utility are not “just and reasonable.”10 The Commission limits this inquiry “into whether the rates proposed by a utility are reasonable – and [this inquiry does not] extend to determining whether a proposed rate schedule is more or less reasonable than alternative rate designs.”11 The changes proposed herein “need not be the only reasonable methodology, or even the most accurate.”12 As a result, even if an intervenor or the Commission develops an alternative proposal, the Commission must accept the ISO’s Section 205 filing if it finds that the filing is just and reasonable.13

III. BACKGROUND

A. The ISO OATT’s Regional Transmission Services Differ From Those Described in the Pro Forma OATT

As the ISO explained in its prior requests for waiver of NAESB WEQ standards,14 and as previously acknowledged by the Commission in its orders granting those requests,15 the ISO OATT has several important characteristics that distinguish its regional transmission services16 from those described in the pro forma OATT upon which the WEQ standards are premised. Specifically, the ISO OATT offers two unique “Regional Transmission Services” (i.e., Regional

10Id.

11See ISO New England Inc., 114 FERC ¶ 61,315 at P 33 and n.35 (2005), citing Pub. Serv. Co. of New Mexico v. FERC, 832 F.2d 1201, 1211 (10th Cir. 1987) and City of Bethany v. FERC, 727 F.2d 1131, 1136 (D.C. Cir. 1984) (“City of Bethany”), cert. denied, 469 U.S. 917 (1984).

12Oxy USA, Inc. v. FERC, 64 F.3d 679, 692 (D.C. Cir. 1995).

13Cf. Southern California Edison Co., et al., 73 FERC ¶ 61,219 at 61,608 n. 73 (1995) (“Having found the Plan to be just and reasonable, there is no need to consider in any detail the alternative plans proposed by the Joint Protesters.” (citing City of Bethany, 727 F.2d at 1136)).

14 See Request of ISO New England Inc. for Limited Waiver of NAESB WEQ Standards, Docket No. ER11-2-001 (Oct. 29, 2010); Request of ISO New England Inc. for Waiver of NAESB WEQ Standards, Docket No ER11-1947-000 (Oct, 20, 2010); Request of ISO New England Inc. for Limited Waiver of NAESB WEQ Standards, Docket No. ER10-1749-000 (July 9, 2010, as corrected July 20, 2010) (collectively, “ISO-NE WEQ Version 002 Waiver Request”). See also Request of ISO New England Inc. for Limited Waiver of NAESB WEQ Standards, Docket No. ER08-1606-000 (Sept. 30, 2008) (“ISO-NE WEQ Version 001 Waiver Request”); Request of ISO New England Inc. for Limited Waiver of NAESB WEQ Standards, Docket No. ER06-1094-003 (June 1, 2006) (“ISO-NE WEQ Version 000 Waiver Request”).

15 See December 16, 2010 Order; September 7, 2010 Order; November 20, 2008 Order; November 16, 2006 Order.

16 This waiver request is not intended to include transmission services listed in the ISO OATT involving external ties or internal transmission facilities that are not Pool Transmission Facilities (“PTF”). Such non-PTF transmission services are addressed in Schedule 18 - Merchant Transmission Facilities of the ISO OATT, Schedule 20 - Other Transmission Facilities of the ISO OATT, and Schedule 21 - Local Service of the ISO OATT. The ISO does not provide transmission service over these facilities. The entities that offer service over such non-PTF facilities are responsible for complying with the standards as they apply to the transmission services they offer, including posting the relevant information on their respective transmission provider home pages contained in the ISO’s OASIS.

Page 4: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

Network Service (“RNS”)17 and Through or Out (“TOut”) Service)18 over the Pool Transmission Facilities. These two services reflect significant deviations from the two transmission services described in the pro forma OATT: Point-To-Point Service19 and Network Integration Transmission Service (“NITS”).20 RNS and TOut Service differ from the pro forma OATT in that they: (1) do not require Transmission Customers to acquire advance reservations prior to their use of the PTF; (2) do not have “Firm” vs. “Non-Firm” service characteristics; and (3) are offered as fixed monthly and fixed hourly services, respectively.

Briefly, internal Point-To-Point Service over regional PTF was eliminated from the ISO OATT in 2003 as part of the ISO’s application to become New England’s RTO.21 Although internal Point-To-Point Service had previously been offered as an alternative to RNS, that service was discontinued, because it was “unnecessary and inconsistent” with the Locational Marginal Pricing (“LMP”) system implemented as part of New England’s Standard Market Design (“SMD”).22 The Commission accepted the elimination of internal Point-To-Point Service as a deviation from the pro forma transmission services in its orders approving the joint application of the ISO and New England Transmission Owners to form an RTO.23

As provided under the ISO OATT, RNS allows Network Customers to deliver energy and capacity from Network Resources or market transactions to serve load on any point on the PTF, and without the need to acquire an advance reservation. TOut Service is the ISO’s form of point-to-point transmission service over the PTF that supports the movement of power through the New England Balancing Authority Area from one boundary to another or from any point on the PTF out to a boundary of the New England Balancing Authority Area. TOut Service fundamentally differs from the standardized Point-To-Point Service; it is assigned to Transmission Customers whose TOut transactions in the Real-Time Energy Markets are scheduled by the ISO based on economic merit. A TOut reservation equal to the maximum scheduled flow over the PTF by a TOut transaction in an hour is created after-the-fact by the ISO.

17 ISO Tariff § II.B.

18 ISO Tariff § II.C, excluding §§ II.27 - II.29. Sections II.27-29 govern transmission service over Merchant Transmission Facilities, Local Point-To-Point Service, and Other Transmission Facilities. The ISO is not the transmission provider for these three categories of service.

19 Part II of the pro forma OATT.

20 Part III of the pro forma OATT.

21 See Request for Approval of a Regional Transmission Organization for New England, Transmittal Letter at 115 n.136, Docket No. RT04-2-000 (filed Oct. 31, 2003).

22 Request for Approval of a Regional Transmission Organization for New England, Transmittal Letter at 115 n.136.

23 ISO New England Inc., 106 FERC ¶ 61,280, order on reh’g, 109 FERC ¶ 61,147 (2004) (Docket Nos. RT04-2-000 and ER04-116-000).

Page 5: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

RNS and TOut Service are designed to work in conjunction with the LMP system used to schedule energy transactions in New England Real-Time Energy Market. Under LMP, external energy transactions are scheduled on an hourly basis in the Real-Time Energy Market on an economic merit order basis, with the least-cost energy transactions scheduled first. Regional Network Customers serving Regional Network Load or Market Participants importing energy into, exporting energy out of or moving energy through the New England Balancing Authority Area in the Real-Time Energy Market are able to utilize the PTF in accordance with the RNS and TOut Service provisions. Those external transactions that have been scheduled in the New England Real-Time Energy Market through the LMP scheduling system automatically receive a reservation equal to the maximum scheduled flow over the PTF in the hour, which is created after-the-fact by the ISO.

Another variation from the pro forma OATT is that the ISO OATT does not include Transmission Loading Relief (“TLR”) procedures, as the ISO does not initiate TLR or TLR-like procedures.24 This is because, as the ISO explained when it made its Order No. 890 compliance filing, parallel flows associated with inter-Control Area transactions do not flow through the ISO Control Area in sufficient magnitude to require TLR usage.25 Instead, Section II.44 of the OATT, ISO New England Operating Procedures and ISO New England System Operating Procedures govern scheduling and curtailment of real-time external transactions (and their associated schedules) in New England.26

B. Order Nos. 676, et al. and Waivers Previously Granted by the Commission to the ISO

Issued on April 25, 2006, Order No. 676 incorporated by reference into the Commission’s regulations the Version 000 standards promulgated by NAESB’s WEQ (“WEQ Version 000” standards), and required public utilities to revise their OATTs to include these standards. Order No. 676 provided that public utilities could seek waivers of individual WEQ standards by filing such requests by June 1, 2006. The ISO filed such a request,27 seeking a limited waiver with respect to its offering of Regional Transmission Services. The Commission granted the request because the ISO’s “business model and regional transmission services differ from the business model and transmission services described in the pro forma OATT, on which

24 For clarity, while the ISO does not call TLRs, it responds to TLRs initiated by another entity, which the NAESB process determines as having an impact on the ISO.

25 See ISO New England Inc., Amendments to the ISO New England Inc. Transmission, Markets and Services Tariff in Compliance with Order No. 890, Transmittal Letter at 31 n.74 (explaining why the ISO does not utilize TLRs), available at: http://www.iso-ne.com/regulatory/ferc/filings/2007/oct/er08-54-000_10-11-07_amendments_transmission_markets_services.pdf (“Order No. 890 Compliance Filing”).

26 See id.

27 See ISO-NE WEQ Version 000 Waiver Request.

Page 6: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

the WEQ standards are generally based,” and because the ISO’s request for waiver was reasonable.28

On July 21, 2008, the Commission issued Order No. 676-C to amend its regulations to incorporate the NAESB WEQ Version 001 standards. As with Order No. 676, Order No. 676-C provided that “each public utility that wants a waiver of any standard we are incorporating by reference in this Final Rule may file a request for waiver, supported by the reasons it believes a waiver is warranted.”29 The ISO filed such a request, seeking a limited waiver of Version 001 standards that addressed matters relating to pro forma Point-To-Point Service and the TLR Procedures.30 The Commission granted the ISO’s request as it pertained to the standards relating to pro forma Point-To-Point Service because the ISO does not offer that service and the standards did not apply to the ISO’s business model.31 The Commission also granted the ISO’s request for waiver of the standard relating to the procedure for involving TLR because “ISO-NE does not initiate the type of procedures addressed by this standard.”32

On November 24, 2009, the Commission issued Order No. 676-E to amend its regulations to incorporate the NAESB WEQ Version 002.1 standards.33 As with Order Nos. 676 and 676-C, Order No. 676-E provided that a public utility that wants a waiver of any standard incorporated by reference in the Final Rule may file a request for a waiver with the Commission.34 The ISO filed such a request, seeking a limited waiver of Version 002.1 standards that addressed matters relating to pro forma Point-To-Point Service and NITS, as well as the TLR Procedures.35 The Commission granted the ISO’s request as it pertained to the standards relating to pro forma Point-To-Point Service and NITS because the ISO does not offer those services and the standards did not apply to the ISO’s business model.36 The Commission also granted the ISO’s request for waiver of the standard relating to the procedure for involving TLR because “ISO-NE does not initiate the type of procedures addressed by this standard”.

28 November 16, 2006 Order at P 14. 29 Order No. 676-C at P 19.

30 ISO-NE WEQ Version 001 Waiver Request.

31 November 20, 2008 Order at PP 12-13.

32 See id. at P 14.

33 See Order No. 676-E at PP 14, 129.

34 See id. at P 130.

35 ISO-NE WEQ Version 002 Waiver Requests.

36 See December 16, 2010 Order; September 7, 2010 Order.

Page 7: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

C. Order No. 676-H

On September 18, 2014, the Commission issued Order No. 676-H to amend its regulations to incorporate the NAESB WEQ Version 003 Standards.37 As with Order Nos. 676 and 676-C, Order No. 676-H provides that a public utility that wants a waiver of any standard being incorporated by reference in the Final Rule may file a request for a waiver with the Commission.38 The WEQ Version 003 Standards, among other things, include modifications that are necessary to support Order Nos. 890, et al., including:

the standards to support Network Integration Transmission Service on an Open Access Same-Time Information System (OASIS), Service Across Multiple Systems (SAMTS), standards to support the Commission’s policy regarding rollover rights for redirects on a firm basis, standards to incorporate functionality for Transmission Providers to credit redirect requests with the capacity of the parent reservation and standards modifications to support consistency across the OASIS-related standards.39

Order No. 676-H requires all public utilities to modify their open access transmission tariffs to include the WEQ standards being incorporated by reference into the Commission’s regulations by making a compliance filing by December 1, 2014, and permits any waiver requests to be filed at that time.40 As the new standards adopted to support Order Nos. 890, et al. relate to the pro forma OATT services that are not offered by the ISO under the ISO OATT, the ISO submits the following waiver request.

IV. REQUEST FOR WAIVER OF CERTAIN NAESB WEQ STANDARDS

A. Renewal for Waivers Previously Granted by the Commission

As noted earlier, the ISO has requested, and the Commission has granted, waiver of certain NAESB WEQ standards otherwise required to be incorporated by reference into their respective tariff provisions pursuant to Order Nos. 676, 676-C and 676-E. After review of Order No. 676-H, the ISO has concluded that the previous waivers granted by the Commission should similarly be applicable pursuant to the same WEQ Standards (Version 003) being adopted by reference in Order No. 676-H. Such waivers were requested and granted as they relate to the pro forma Point-to-Point Service and Network Integration Transmission Service, which are not offered by the ISO, and TLR procedures, which are not used by the ISO. The ISO submits that

37 See Order No. 676-H at P 1.

38 See id. at PP 20 and 86.

39 See id. at P 2.

40 Id. at P 20. The Commission has delayed the requirement for submission of waiver requests or a compliance filing for the adoption by incorporation of NAESB WEQ Standard WEQ-002-5.10.3 until 16 months after the effective date of Order 676-H.

Page 8: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

the relevant provisions of the ISO Tariff and the circumstances supporting the Commission’s determinations in the orders granting the previously-requested waivers have not changed.41 Therefore, it is appropriate for the Commission to grant this waiver request.

More specifically, in accordance with Order No. 676-H, the ISO requests a waiver of the

compliance requirements associated with the following Version 003 WEQ Standards incorporated by reference into the Commission’s regulations in Order No. 676-H, but for which the ISO has previously received Commission waiver:

• Standards 001-2.1 through 001-2.14;

• Standards 001-2.2 through 001-2.2.2;

• Standards 001-2.3 through 001-2.3.2;

• Standards 001-4 through 001-4.27;

• Standards 001-5 through 001-5.6;

• Standards 001-8 through 001-8.3.2;

• Standards 001-9 through 001-9.8.1;

• Standards 001-10 through 001-10.8.7;

• Standards 001-11 through 001-11.7.1;

• Standards 001-12 through 001-12.5.2;

• Standards 001-18 through 001-18.2;

• Standards 001-19 through 001-19.1.2;

• Standards 001-20 through 001-20.3;

• Standards 001-21 through 001-21.5.5;

• Standards 001-22 through 001-22.2;

• Standard 001-D;

41 See December 16, 2010 Order; September 7, 2010 Order; November 20, 2008 Order; November 16, 2006 Order.

Page 9: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

• Standards 008-1 through 008-1.7.1.2;

• Standards 008-2 through 008-2.4.4;

• Standards 008-3 through 008-3.11.2.8; and

• Standards 008-A through 008-D.

B. Request for Waivers of New Standards Supporting NITS and SAMTS

As noted above, NAESB’s WEQ Version 003 incorporates new standards related to the pro forma OATT NITS. More specifically, WEQ Version 003 adopts the following new standards to provide consistency in the processing of NITS requests, including the submission and evaluation of requests, modifications to applications for NITS, and other NITS-specific features such as secondary network transmission service:

• Standards 001-101 through 101.13.4;

• Standards 001-102 through 102.5.3;

• Standards 001-103 through 103.9.2;

• Standards 001-104 through 104.5;

• Standards 001-105 through 105.6.7.2;

• Standards 001-106 through 106.2.7;

• Standards 001-107 through 107.3.1; and

• Standard 001-INT2

As explained above, the pro forma OATT NITS is not offered by the ISO under the ISO OATT. Therefore, the ISO requests waiver of these new standards because they are not applicable to the ISO.

The ISO also requests waiver of the new standards adopted to support SAMTS –Standards 001-23 through 001-23.3.9, and Standard 001-E. Like the standards discussed above, the SAMTS-related standards relate specifically to the coordination of pro forma OATT Point-to-Point Service and NITS requests across multiple transmission systems, which the ISO does not provide.42 Accordingly, it is appropriate for the Commission to grant the waiver requested herein.

42 See Order No. 676-H at P 60 (explaining, “the SAMTS standards address the coordination of point-to-point transmission service and/or network transmission service request across multiple systems.”).

Page 10: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

V. DESCRIPTION OF THE SCHEDULE 24 REVISIONS

In accordance with Order No. 676-H, the ISO has modified Schedule 24 of the ISO OATT to incorporate by reference the NAESB WEQ Version 003 Standards. The revised Schedule 24 explicitly identifies the NAESB WEQ Version 003 Standards as incorporated by reference in Paragraph 89 of Order No. 676-H, excluding the standards for which the ISO requests waiver in this filing. The Schedule 24 Revisions also modify the manner in which the numbering of certain excluded WEQ-001 and WEQ-008 standards is referenced for consistency throughout the document.

VI. STAKEHOLDER PROCESS

The compliance timeframe did not allow for the entire stakeholder process, pursuant to Section 11.5 of the Participants Agreement, to be completed. However, on December 1, 2014, the ISO presented, and the Transmission Committee voted unanimously to recommend that the Participants Committee support the Schedule 24 Revisions at the December 5, 2014 Participants Committee meeting. The Schedule 24 Revisions have been included on the agenda for vote at the Participants Committee meeting on December 5. No issues have been raised to date.

VII. REQUESTED EFFECTIVE DATE

The ISO respectfully requests that the Commission waive compliance requirements for the WEQ Standards specified in this filing and accept the Schedule 24 Revisions as proposed in this filing, without modifications or conditions, with an effective date of February 2, 2015.

VIII. ADDITIONAL SUPPORTING INFORMATION

Section 35.13 of the Commission’s regulations generally requires public utilities to file certain cost and other information related to an examination of traditional cost-of service rates. However, the ISO Tariff changes submitted herewith do not modify a traditional “rate.” Therefore, to the extent necessary, the ISO requests waiver of Section 35.13 of the Commission’s regulations.43 Notwithstanding this request for waiver, the ISO submits the following additional information in substantial compliance with relevant provisions of Section 35.13 of the Commission’s regulations:

35.13(b)(1) – Materials included herewith are as follows: • This transmittal letter;

• Marked tariff sheets reflecting the Schedule 24 Revisions discussed in this filing;

• Clean revised tariff sheets reflecting the Schedule 24 Revisions discussed in this filing; and

43 18 C.F.R. § 35.13 (2009).

Page 11: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

• List of governors and utility regulatory agencies in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island and Vermont to which a copy of this filing is being sent electronically.

35.13(b)(2) – As noted above, the Filing Parties requests that this filing become effective on February 2, 2015. 35.13(b)(3) – Pursuant to Section 17.11(e) of the Participants Agreement, Governance Participants are being served electronically rather than by paper copy. The names and addresses of the Governance Participants are posted on the ISO’s website at http://www.iso-ne.com/participate/participant-asset-listings. An electronic copy of this transmittal letter and the accompanying materials has also been sent to the governors and electric utility regulatory agencies for the six New England states that comprise the New England Control Area, and to NECPUC. The names and addresses of these governors and regulatory agencies are shown in the above-referenced list, which is included in this filing. In accordance with Commission rules and practice, there is no need for the Governance Participants or the entities identified in the above-referenced list to be included on the Commission’s official service list in the captioned proceeding unless such entities become intervenors in this proceeding. 35.13(b)(4) – A description of the materials submitted pursuant to this filing is contained in this transmittal letter. 35.13(b)(5) – The reasons for this filing are discussed in this transmittal letter. 35.13(b)(6) – As explained above, the Schedule 24 Revisions rights reflect the results of the Participant Processes required by the Participants Agreement and reflect the support of the Participants Committee. 35.13(b)(7) – The ISO has no knowledge of any relevant expenses or costs of service that have been alleged or judged in any administrative or judicial proceeding to be illegal, duplicative, or unnecessary costs that are demonstrably the product of discriminatory employment practices. 35.13(b)(8) – A form of notice and electronic media are no longer required for filings in light of the Commission’s Combined Notice of Filings notice methodology. 35.13(c)(1) – The Tariff changes herein do not modify a traditional "rate." The statement required under this Commission regulation is not applicable to this filing. 35.13(c)(2) – The ISO does not provide services under other rate schedules that are similar to the wholesale, resale and transmission services it provides under the ISO Tariff. 35.13(c)(3) – No specifically assignable facilities have been or will be installed or modified in connection with the revision submitted herein.

Page 12: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

IX. CONCLUSION

The ISO respectfully requests that the Commission waive compliance requirements for the WEQ Standards specified in this filing and accept the Schedule 24 Revisions as proposed in this filing, without modifications or conditions, with an effective date of February 2, 2015.

Respectfully submitted,

/s/ Monica Gonzalez Monica Gonzalez Senior Regulatory Counsel

ISO New England Inc. One Sullivan Road Holyoke, MA 01040-2841 Tel: (413) 535-4178 Fax: (413) 535-4379 E-mail: [email protected]

Counsel for ISO New England Inc.

Page 13: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

SCHEDULE 24

Incorporation By Reference of NAESB Sstandards

Page 14: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

In accordance with paragraph 129 89 of Commission Order No. 676-HE and paragraph 45 of Order No.

676-F, the NAESB Version 0032.1 Standards listed below apply to the provision of transmission service

over the New England Transmission System, except as noted below:

• WEQ-000, Abbreviations, Acronyms, and Definition of Terms, WEQ Version 003, July 31, 2012

(with minor corrections applied Nov. 26, 2013);

• WEQ-001, Open Access Same-Time Information Systems (OASIS), OASIS Version 2.0, WEQ

Version 003, July 31, 2012 (Version 1.5 (WEQ-001, Version 002.1, March 11, 2009, with minor

corrections applied November 26, 2013May 29, 2009 and September 8, 2009), excluding with the

exception of Standards WEQ 001-0.1, 001-0.9 through 001-0.13, 001-1.0, 001-9.75, WEQ-001-

10.5, WEQ 001-14.1.3, WEQ and 001-15.1.2 and WEQ-001-106.2.5; and excluding

o 001-2.1 through 001-2.1.9, and 001-2.10 through 001-2.14;

o 001-2.2 through 001-2.2.2;

o 001-2.3 through 001-2.3.2

o 001-4 through 001-4.27;

o 001-5 through 001-5.6;

o 001-8 through 001-8.3.2;

o 001-9 through 001-9.8.1;

o 001-10 through 001-10.8.7;

o 001-11 through 001-11.7.1;

o 001-12 through 001-12.5.2;

o 001-18, 001-18.1 through 001-18.2;

o 001-19 through 001-19.1.2;

o 001-20 through 001-20.3;

o 001-21 through 001-21.5.5;

o 001-22 through 001-22.2;

o 001-23 through 23.3.9;

o 001-101 through 101.13.4;

o 001-102 through 102.5.3;

o 001-103 through 103.9.2;

o 001-104 through 104.5;

Page 15: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

o 001-105 through 105.6.7.2;

o 001-106 through 106.2.7;

o 001-107 through 107.3.1;

o 001-INT2; and

o 001-D through 001-E;

• WEQ-002, Open Access Same-Time Information Systems (OASIS) Business Practice Standards

& Communication Protocols, (S&CP), OASIS Version 2.0, WEQ Version 003, July 31, 2012

Version 1.5 (WEQ-002, Version 002.1, March 11, 2009, (with minor corrections applied May 29,

2009 and September 8, 2009November 26, 2013);

• WEQ-003, Open Access Same-Time Information Systems (OASIS) Data Dictionary Business

Practice Standards, OASIS Version 2.0, WEQ Version 003, July 31, 2012 (, Version 1.5 (WEQ-

003, Version 002.1, March 11, 2009, with minor corrections applied November 26, 2013May 29,

2009 and September 8, 2009);

• WEQ-004, Coordinate Interchange, WEQ Version 003, July 31, 2012 (with Final Action ratified

on December 28, 2012)(WEQ-004, Version 002.1, March 11, 2009, with minor corrections

applied May 29, 2009 and September 8, 2009);

• WEQ-005, Area Control Error (ACE) Equation Special Cases Standards, WEQ Version 003, July

31, 2012(WEQ-005, Version 002.1, March 11, 2009, with minor corrections applied May 29,

2009 and September 8, 2009);

• WEQ-006, Manual Time Error Correction, WEQ Version 003, July 31, 2012(WEQ-006, Version

001, October 31, 2007, with minor corrections applied on November 16, 2007);

• WEQ-007, Inadvertent Interchange Payback, WEQ Version 003, July 31, 2012(WEQ-007,

Version 002.1, March 11, 2009, with minor corrections applied May 29, 2009 and September 8,

2009);

• WEQ-008, Transmission Loading Relief (TLR) – Eastern Interconnection, WEQ Version 003,

July 31, 2012 (WEQ-008, Version 002.1, March 11, 2009, with minor corrections applied

November 28, 2012May 29, 2009 and September 8, 2009); and excluding

Page 16: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

o 008-0.1 through 008-1.7.1.2;

o 008-2 through 008-2.4.4;

o 008-3 through 008-3.11.2.8, and

o 008-A through 008-D;

• WEQ-011, Gas / Electric Coordination, WEQ Version 003, July 31, 2012(WEQ-011, Version

002.1, March 11, 2009, with minor corrections applied May 29, 2009 and September 8, 2009);

• WEQ-012, Public Key Infrastructure (PKI), WEQ Version 003, July 31, 2012, as modified by

NAESB final actions ratified on Oct. 4, 2012) (WEQ-012, Version 002.1, March 11, 2009, with

minor corrections applied May 29, 2009 and September 8, 2009);

• WEQ-013, Open Access Same-Time Information Systems (OASIS) Implementation Guide,

OASIS Version 2.0, WEQ Version 003, July 31, 2012 Version 1.5 (WEQ-013, Version 002.1,

March 11, 2009, (with minor corrections applied November 26, 2013May 29, 2009 and

September 8, 2009);

• WEQ-015, Measurement and Verification of Wholesale Electricity Demand Response, WEQ

Version 003, July 31, 2012(WEQ-015, 2010 Annual Plan Items 4(a) and 4(b), March 21, 2011);

and

• WEQ-021, Measurement and Verification of Energy Wholesale Electricity Efficiency Products,

WEQ Version 003, July 31, 2012.(WEQ-021 2010 Annual Plan Item 4(d), July 16, 2012); and

excluding

o 021-1 through 021-1.1, and

o 021-2 through 021-2.1.3.

Page 17: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

SCHEDULE 24

Incorporation By Reference of NAESB Standards

Page 18: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

In accordance with paragraph 89 of Commission Order No. 676-H, the NAESB Version 003 Standards

listed below apply to the provision of transmission service over the New England Transmission System,

except as noted below:

• WEQ-000, Abbreviations, Acronyms, and Definition of Terms, WEQ Version 003, July 31, 2012

(with minor corrections applied Nov. 26, 2013);

• WEQ-001, Open Access Same-Time Information Systems (OASIS), OASIS Version 2.0, WEQ

Version 003, July 31, 2012 (with minor corrections applied November 26, 2013) excluding

Standards WEQ 001-9.5, WEQ-001-10.5, WEQ 001-14.1.3, WEQ 001-15.1.2 and WEQ-001-

106.2.5; and excluding

o 001-2.1 through 001-2.14;

o 001-2.2 through 001-2.2.2;

o 001-2.3 through 001-2.3.2

o 001-4 through 001-4.27;

o 001-5 through 001-5.6;

o 001-8 through 001-8.3.2;

o 001-9 through 001-9.8.1;

o 001-10 through 001-10.8.7;

o 001-11 through 001-11.7.1;

o 001-12 through 001-12.5.2;

o 001-18 through 001-18.2;

o 001-19 through 001-19.1.2;

o 001-20 through 001-20.3;

o 001-21 through 001-21.5.5;

o 001-22 through 001-22.2;

o 001-23 through 23.3.9;

o 001-101 through 101.13.4;

o 001-102 through 102.5.3;

o 001-103 through 103.9.2;

o 001-104 through 104.5;

o 001-105 through 105.6.7.2;

Page 19: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

o 001-106 through 106.2.7;

o 001-107 through 107.3.1;

o 001-INT2; and

o 001-D through 001-E;

• WEQ-002, Open Access Same-Time Information Systems (OASIS) Business Practice Standards

& Communication Protocols, (S&CP), OASIS Version 2.0, WEQ Version 003, July 31, 2012

(with minor corrections applied November 26, 2013);

• WEQ-003, Open Access Same-Time Information Systems (OASIS) Data Dictionary Business

Practice Standards, OASIS Version 2.0, WEQ Version 003, July 31, 2012 (with minor corrections

applied November 26, 2013);

• WEQ-004, Coordinate Interchange, WEQ Version 003, July 31, 2012 (with Final Action ratified

on December 28, 2012);

• WEQ-005, Area Control Error (ACE) Equation Special Cases, WEQ Version 003, July 31, 2012;

• WEQ-006, Manual Time Error Correction, WEQ Version 003, July 31, 2012;

• WEQ-007, Inadvertent Interchange Payback, WEQ Version 003, July 31, 2012;

• WEQ-008, Transmission Loading Relief (TLR) – Eastern Interconnection, WEQ Version 003,

July 31, 2012 (with minor corrections applied November 28, 2012); and excluding

o 008-1 through 008-1.7.1.2;

o 008-2 through 008-2.4.4;

o 008-3 through 008-3.11.2.8, and

o 008-A through 008-D;

• WEQ-011, Gas / Electric Coordination, WEQ Version 003, July 31, 2012;

• WEQ-012, Public Key Infrastructure (PKI), WEQ Version 003, July 31, 2012, as modified by

NAESB final actions ratified on Oct. 4, 2012);

Page 20: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

• WEQ-013, Open Access Same-Time Information Systems (OASIS) Implementation Guide,

OASIS Version 2.0, WEQ Version 003, July 31, 2012 (with minor corrections applied November

26, 2013);

• WEQ-015, Measurement and Verification of Wholesale Electricity Demand Response, WEQ

Version 003, July 31, 2012; and

• WEQ-021, Measurement and Verification of Energy Efficiency Products, WEQ Version 003,

July 31, 2012.

Page 21: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

New England Governors, State Utility Regulators and Related Agencies*

*People on this list are included on the distribution lists used by Legal (filings), Finance (default on payment notices) and

Enterprise Risk Management (financial assurance changes) for email correspondence and notices. Updates should be sent to the

“Membership Coordinator” list in the global address list of Outlook so changes can be made in the CAMS system for Enterprise

Risk Management. In your email to the membership coordinator: 1) Identify in the subject that it is an update to the external

affairs company/contact information in CAMS and 2) Include in the body of the email the company that is being updated and

what the updates are. Updates should be made in EtQ for Finance and Legal receives a copy of this document if changes are

made.

Maine

The Honorable Paul LePage

One State House Station

Office of the Governor

Augusta, ME 04333-0001

[email protected]

Maine Public Utilities Commission

18 State House Station

Augusta, ME 04333-0018

[email protected]

New Hampshire

The Honorable Maggie Hassan

Office of the Governor

26 Capital Street

Concord NH 03301

[email protected]

[email protected]

New Hampshire Public Utilities Commission

21 South Fruit Street, Ste. 10

Concord, NH 03301-2429

[email protected] [email protected] [email protected] [email protected] [email protected] [email protected]

Vermont

The Honorable Peter Shumlin

Office of the Governor

109 State Street, Pavilion

Montpelier, VT 05609

[email protected] [email protected]

Vermont Public Service Board

112 State Street

Montpelier, VT 05620-2701

[email protected]

Vermont Department of Public Service

112 State Street, Drawer 20

Montpelier, VT 05620-2601

[email protected]

[email protected]

[email protected]

Massachusetts

The Honorable Deval Patrick

Office of the Governor

Rm. 360 State House

Boston, MA 02133

Massachusetts Attorney General Office

One Ashburton Place

Boston, MA 02108

[email protected]

Massachusetts Department of Public Utilities

One South Station

Boston, MA 02110

[email protected]

[email protected]

[email protected]

Rhode Island

The Honorable Lincoln Chafee

Office of the Governor

State House Room 115

Providence, RI 02903

[email protected]

[email protected]

[email protected]

[email protected]

Page 22: VIA ELECTRONIC FILINGDec 01, 2014  · December 1, 2014 . VIA ELECTRONIC FILING . The Honorable Kimberly D. Bose, Secretary . Federal Energy Regulatory Commission 888 First Street,

New England Governors, State Utility Regulators and Related Agencies*

*People on this list are included on the distribution lists used by Legal (filings), Finance (default on payment notices) and

Enterprise Risk Management (financial assurance changes) for email correspondence and notices. Updates should be sent to the

“Membership Coordinator” list in the global address list of Outlook so changes can be made in the CAMS system for Enterprise

Risk Management. In your email to the membership coordinator: 1) Identify in the subject that it is an update to the external

affairs company/contact information in CAMS and 2) Include in the body of the email the company that is being updated and

what the updates are. Updates should be made in EtQ for Finance and Legal receives a copy of this document if changes are

made.

Rhode Island Public Utilities Commission

89 Jefferson Blvd.

Warwick, RI 02888

[email protected]

Connecticut

The Honorable Dannel P. Malloy

Office of the Governor

State Capitol

210 Capitol Ave.

Hartford, CT 06106

[email protected]

[email protected]

[email protected]

Connecticut Public Utilities Regulatory

Authority

10 Franklin Square

New Britain, CT 06051-2605

[email protected]

[email protected] [email protected]

New England Governors, Utility Regulatory

and Related Agencies

Anne Stubbs

Coalition of Northeastern Governors

400 North Capitol Street, NW

Washington, DC 20001

[email protected]

Heather Hunt, Executive Director

New England States Committee on Electricity

655 Longmeadow Street

Longmeadow, MA 01106

[email protected]

[email protected]

Sarah Hofman, Executive Director

New England Conference of Public Utilities

Commissioners

50 State Street – Suite 1

Montpelier, VT 05602

[email protected] [email protected]

James Volz, President

New England Conference of Public Utilities

Commissioners

112 State Street, Drawer 20

Montpelier, VT 05620-2601

[email protected]

Harvey L. Reiter, Esq.

Counsel for New England Conference of Public

Utilities Commissioners, Inc.

c/o Stinson Morrison Hecker LLP

1150 18th Street, N.W., Ste. 800

Washington, DC 20036-3816

[email protected]