© 2011 The Williams Companies, Inc. All rights reserved. Consolidated Nominations Jeramie Kilpack Mary White

© 2011 The Williams Companies, Inc. All rights reserved.2 Customer Survey Response “… I would like to have the ability to aggregate contracts for nominating purposes. So instead of 20 numbers, they get rolled up into five for example.” Northwest’s current Tariff provision (Section 14.2 Consolidated Nominations)  Transporter may approve a Shipper’s request to consolidated the nominations under its Service Agreements from the same Rate Schedule having the same receipt and delivery point, provided that the consolidated nominations would not negatively impact other Shippers and Transporter can reasonably administer the requested under this Tariff, utilizing Transporter’s current nomination system. Passage User Group Meeting - April 2014

© 2011 The Williams Companies, Inc. All rights reserved.3 In Response: Northwest is proposing to expand its flexibility for customers to consolidate nominations associated with various contracts, by:  Expanding to allow shippers to consolidate agreements with multiple receipts to one delivery or multiple deliveries to one receipt; and  Northwest will allow contracts in other rate schedules if they can for invoicing.  Allow Agents to consolidate various agreements for which they are Agent for; and  Allow single Shippers to consolidate various agreements. Passage User Group Meeting - April 2014

© 2011 The Williams Companies, Inc. All rights reserved.4 Consolidated Nomination Process Passage User Group Meeting - April 2014  Shipper would identify the Master Consolidated Agreement (“MCA”).  Shipper would specify which agreements will be rolled-up to the MCA.

© 2011 The Williams Companies, Inc. All rights reserved.5 Consolidated Rules Passage User Group Meeting - April 2014 Consolidated Agreements:  Cannot increase Shipper’s primary rights above the primary rights of the sum of the consolidated agreements.  Must be able to invoice accurately on each individual contract.  Contracts with OFO requirements will be calculated for directional flow adjustments.  Entitlement percentages will be calculated as necessary.  MCAs contract demand will be adjusted daily to account for capacity release, recalls, and re-put capacity.  Commodity charges will be assessed on scheduled volumes on the MCA.

© 2011 The Williams Companies, Inc. All rights reserved.6 Consolidated Nomination Rules Passage User Group Meeting - April 2014  The MCA cannot increase shipper’s primary rights above the primary rights of the sum of the consolidated agreements. Example 1: Assume a shipper has two contracts of similar paths with same receipt but different delivery points. Consolidating these two agreements would be allowed since consolidated rights equal the sum of the individual agreements. T-1000 R1 - D1 T-1001 R1 - D2

© 2011 The Williams Companies, Inc. All rights reserved.7 Consolidated Nomination Rules Passage User Group Meeting - April 2014 Example 2: Assume a shipper wishes to consolidate two contracts. In this situation Northwest would not allow the consolidation of these two agreements because the resulting MCA would create new primary rights from R2 to D1. T-1000 R1 - D1, D2 T-1001 R2 - D3

© 2011 The Williams Companies, Inc. All rights reserved.8 Consolidated Nomination Rules Passage User Group Meeting - April 2014 Example 3: Assume a shipper wishes to consolidate two contracts with unique receipt and delivery points. Northwest would not allow the consolidation of these agreements because the resulting MCA would have firm primary rights from R1 to D2 where the individual agreements do not. The MCA cannot have both multiple receipts and multiple deliveries. T-1000 R1 - D1 T-1001 R2 - D2

© 2011 The Williams Companies, Inc. All rights reserved.9 Consolidated Nomination Rules Passage User Group Meeting - April 2014  Northwest must be able to invoice  Multiple Reservation Rates Example: Assume three Sumas to Stanfield contracts are consolidated with different reservation rates. K1 10, ,500 K225, ,250 K315, ,500 14,250 Northwest would be able to invoice the new MCA by calculating the invoice based off the original agreements.

© 2011 The Williams Companies, Inc. All rights reserved.10 Consolidated Nomination Rules Passage User Group Meeting - April 2014  Northwest must be able to invoice Volumetric Rates Example: Assume two contracts with different volumetric rates are consolidated with a contract having a reservation rate. K1 10,000.41Reservation K225,000.30Volumetric K315,000.10Volumetric Consolidating agreements with different volumetric rates is not possible because Northwest is unable to allocate the scheduled quantities from the MCA between the volumetric rates. Volumetric contracts may be consolidated with other same rate Volumetric contracts only.

© 2011 The Williams Companies, Inc. All rights reserved.11 Consolidated Nomination Rules Passage User Group Meeting - April 2014  Northwest must be able to calculate Entitlement. Example: Assume a shipper consolidates two contracts with similar paths and Northwest issues an Entitlement north of constraint C1. Northwest can still calculate the entitlement because this is accomplished through milepost of the delivery points. T-1000R1-D1 T-1001R1-D2

© 2011 The Williams Companies, Inc. All rights reserved.12 Consolidated Nomination Rules  Northwest must be able to adjust the CD on the MCA agreement daily, accounting for the individual contracts (base level) rolled up to the MCA, if capacity release, recalls, and re-put capacity are changed. Example: Assume a shipper has rolled up multiple contracts under (1) MCA agreement. Total CD volume is a combination of each of the contracts CD rolled up for one CD total. K12,000 K21,500 K39,200 12,700 CD = MCA Agreement Customer decides to release K2 (1,500) cd. The MCA Agreement will be adjusted to reflect a reduction of the “Base” cd for the contract being released. Upon execution of the new agreement a MCA Total of 11,200 cd will be on the MCA Agreement. Passage User Group Meeting - April 2014

© 2011 The Williams Companies, Inc. All rights reserved.13 Proposed Opportunities Passage User Group Meeting - April 2014 Shipper with title, allows consolidation of multiple contracts to roll up under (1) contract with the same rate, under the same rate schedule.  Requirement of “Shipper must have title” is fulfilled where the Shipper has the Transportation Agreement is in their name. (124 FERC P 61,145) 8/5/2008.  Multiple Shippers with an Agent, demonstrate the agency relationship in writing, that each Shipper is jointly and individually liable to the obligations under the contract. 124 FERC P 61,726) 8/5/2008.  Shippers are willing to be treated collectively as one Shipper for nomination, billing and allocation purposes under the contract. Consolidation of contracts by multiple shippers do not have to be included on Service Agreement where the Shipper is a single entity.