Interchange Scheduling and Accounting Subcommittee NAESB WEQ Update Interchange Scheduling and Accounting Subcommittee Sept 18, 2019 Mike Steigerwald BPA

Objective Provide a broad overview of the activities of the NAESB Wholesale Electric Quadrant across the lifecycle of standards development. Disclaimer: Presenter does not represent NAESB. I am BPA’s representative to the NAESB WEQ Executive Committee. I am also a co-chair of the OASIS subcommittee. NAESB WEQ @ ISAS 09/18/19

NAESB WEQ Standard Development Lifecycle WEQ Triage and Prioritize Request Industry Formal Comment to NAESB EC (30 days) Industry Informal Comment to NAESB (30 days) EC considers: Standards approved by the subcommittee in step 2. Formal comments filed by industry in step 3. Subcommittee Standard Development and Vote WEQ Executive Committee Vote 2a 3 4 2 Industry NERC WEQ Membership Segment Vote (30 days) 1 5 SRS Standard development Directive to NAESB 6 8 Standards Published & filed with FERC (1-2 years) Voluntary for jurisdictional entities until ‘adopted by reference’ by FERC Order. FERC Order 7 9 FERC Issues NOPR to Industry Implementation Directive to Industry Industry has 60 days to comment to FERC on proposed standards. NAESB WEQ @ ISAS 09/18/19

Subcommittee Development Backlog 1 2020 Annual Plan being drafted. Subcommittee Development Backlog Topic Sub Description and Status NITS OS Define rollover rights for NITS (API 3e). Initial scoping has been done, but it has taken a backseat to other priorities. Will restart next year. Curtail Info on OASIS BPS Posting of additional curtailment information on OASIS per FERC Order 890 (API 2.a). Will apply only to interconnection-wide congestion management. Draft standards are mostly done, but it has also taken a backseat. Will restart next year. NAESB WEQ @ ISAS 09/18/19

Subcommittee Development In-progress 2 Subcommittee Development In-progress Topic Sub Description and Status NITS OS Modifications to the original NITS standards based on learnings from the NITS industry implementation (API 3c). Should be voted out this year. DLT WEQ Initially focused on investigating whether standards are needed to apply Distributed Ledger Technology (DLT) to Renewable Energy Certificates (REC). Focus has shifted to considering standardizing data elements used for REC Contracts in the voluntary market (not those for RPS). Still in the scoping phase. There has been no decision yet to pursue actual standards development. ACA Cybr Annual review of the Authorized Certification Authorities accreditation (API 4a). NERC CIP Annual review of the NERC CIP standards (API 4b). DOE Surety Assessment Joint OS At the request of DOE, Sandia National Labs conducted a “surety assessment” of NAESB standards regarding cybersecurity protections. The identified risks deemed “low”. Both the OASIS and Cybersecurity subcommittees are working to incorporate the report’s recommendations. Target end of year completion. NAESB WEQ @ ISAS 09/18/19

Pending Informal Comment Subcommittee still actively working. Pending Informal Comment Topic Sub Description and Status NAESB WEQ @ ISAS 09/18/19

Pending Formal Comment 3 Subcommittee passed to the EC. Pending Formal Comment Topic Sub Description and Status EIR OS Require OASIS to use EIR to validate request information (API 3a). Subcommittee voted “No Action” on this as it was deemed to potentially cause more problems than it would solve. Out for Formal Comment until 09/20/19. Tag Timing CISS Request to clarify tag timing requirements in WEQ-004. TPs and BAs are not meeting the strict approval windows defined in NAESB WEQ-004 and NERC INT-006 due to misapplication of these timing requirements. (API 3h) Voted out of the Coordinate Interchange Scheduling Subcommittee 02/12/19. Send back to CISS on 03/26/19 by Executive Committee to work with NERC. NERC rejected request for clarification saying the INT standards are clear. Same recommendation voted out of the CISS again on 08/16/19. Formal Comment period ends today. INT Retirements Review WEQ-004 and other tagging standards in light of NERC proposal to retire the following: INT-004-3.1 and INT-010-2.1, INT-006 (R3.1, R4, R5) and INT-009 (R2). Voted out of the CISS on 08/16/19. MOD Retirements BPS Review WEQ-023 Modeling standard in light of NERC proposal to retire MOD standards (including withdrawal of MOD-001-2). Most content from NERC MOD-001-2 has been moved to NAESB WEQ-023. Out for Formal Comment until 10/07/19. NAESB WEQ @ ISAS 09/18/19

Pending Executive Committee Vote 4 Next EC meeting will be 10/15/19. Pending Executive Committee Vote Topic Sub Description and Status Interchange Modeling OS Improve transmission planning models by making visible a complete path associated with long-term firm interchange when partial path requests are made (API 3d). The eastern regional coordination committee driving this has since found other ways of getting the needed planning information. “No Action” recommendation passed by OS on 04/17/19. Formal Comment period closed on 05/20/19. NAESB WEQ @ ISAS 09/18/19

Pending Membership Segment Vote 5 30 day vote by all NAESB members Pending Membership Segment Vote Topic Sub Description and Status NAESB WEQ @ ISAS 09/18/19

Pending NAESB Publication 6 No publication date announced. Pending NAESB Publication Topic Sub Description and Status 3rd Party Planning Redispatch OS BPS Redispatch Cost Posting to allow for posting on OASIS of 3rd party offers of Planning Redispatch services per FERC Order 890 (API 2.a.i.2). The TP is obligated to provide the posting mechanism on OASIS for 3rd party offers of Planning Redispatch. There is no obligation for any party to use this functionality. Voted out of the OASIS and Business Practice Subcommittees on 01/23/18. Voted out of the Executive Committee on 04/24/18. Voted out of the Segment Membership on 05/25/18. Templates Update OASIS Query/Response templates to allow more flexible and efficient queries for some templates (API 3b). Voted out of the OASIS subcommittee on 06/19/18. Voted out of the WEQ Executive Committee on 08/21/18. Voted out of the Segment Membership vote on 09/24/18. Untagged Pseudo-ties Update OASIS to ensure that capacity reserved for untagged Pseudo-ties is preserved for that purpose (API 3e). The basic requirement does not apply to BPA as Pseudo-ties are tagged in the west. But the proposed standards define a generic way to encumber a TSR for ad-hoc use (i.e., beyond Resale, Redirect, etc). BPA may indeed find a use for such a capability in the future. Voted out of the OASIS subcommittee on 08/22/18. Voted out of the Executive Committee on 10/09/18. Voted out of the Segment Membership on 11/15/18. NAESB WEQ @ ISAS 09/18/19

Pending NAESB Publication (continued) 6 No publication date announced. Pending NAESB Publication (continued) Topic Sub Description and Status PTP Rollover Notification OS Automatically notify customers when PTP renewal deadline approaches (API 3b). Voted out of the OASIS Subcommittee 11/17/18. Formal Comment period closed 12/28/18 with no opposition. Voted out of the Executive Committee on 03/26/19. Voted out of the Segment Membership on 04/30/19. Dynamic Notification Updates to the Dynamic Notification (email) on OASIS to provide a more generic notification capability (API 3.f). Developed in conjunction with updates for PTP Rollover Notification above (API 3f). NHM Modify Next Hour Market (NHM) service to be more applicable to the western EIM (API 3.g). Draft changes make it clear that the tag priority 0-NX can be used for purposes other than Next-hour Market (NHM) service, such as EIM. Voted out of the OASIS Subcommittee 02/19/19. Formal Comment period closes 03/20/19. NAESB WEQ @ ISAS 09/18/19

Pending FERC NOPR 7 Last NOPR just closed in July. Topic Sub Description and Status NAESB WEQ @ ISAS 09/18/19

Pending FERC Final Order 8 v003.1 published 09/30/15. NOPR closed Sept 2016. Pending FERC Final Order Topic Sub Description and Status Entergy / Dynegy OS Standards for treatment of Parent reservation when Redirect is lost to Preemption and Competition per FERC Order 676-H. Lots of NOPR comments to FERC. ATC Standards BPS NAESB standards to complement NERC ATC MOD A. In the NOPR, FERC declined to adopt these NAESB standards pending separate ATC proceedings. DUNS Make the use of DUNS numbers optional. Little NOPR comment. WEQ-004 CISS Modify WEQ-004 to require tagging of intra-BA transactions (replace INT-011-1). Source/Sink Source/Sink will be unmasked once a TSR is in any final state. AFC/TFC Updates templates for posting of AFC and TFC information (like ATC/TTC). Resales Resales will now be submitted as ACCEPTED rather than CONFIRMED. CF TP’s will be able to extend the period for Biennial Reassessment of Conditional Firm. 1d Narrative Clarifies that TP’s will have 1 business day to post a narrative for zero ATC. Secondary Network Clarifies that a TP may invalidate a request to terminate Secondary Network service that exceeds the capacity that is unscheduled. SAMTS Clarifies how reservations included in a Coordinated Request are handled if displaced. NAESB WEQ @ ISAS 09/18/19

Pending FERC Final Order (continued) 8 v003.2 published 12/08/17. NOPR closed July 2019. Pending FERC Final Order (continued) Topic Sub Description and Status Consolidation OS New OASIS request type that will be used to consolidate multiple “like” reservations into a single reservation for easier tagging. Replaces current practice of customers reselling TSR’s to themselves. Aggregation of Resales will still be allowed, but Reseller and Assignee must be different customers. Approved by NAESB Nov’16. Market Operator CISS Changes needed to WEQ-002 (S&CP), WEQ-004 (Coordinate Interchange), and Electric Industry Registration (EIR) to support the Market Operator role for eTag 1.8.3. Approved by NAESB Sep’16. EIR Remove all NERC references from WEQ-022 (which govern the EIR). Approved by NAESB Mar’17. Manual Time Error Correction BPS Retire WEQ-006 (Manual Time Error Correction) due to NERC retirement of BAL-004. Approved by NAESB Mar’17. Separate FERC NOPR closed fall 2018. Dynamic & Pseudo-tie Tagging Modify WEQ-004 following proposed retirement of NERC INT-004-3.1 (API 1.d.i). NAESB standards to require RFI for Dynamic and Pseudo-ties mimic the previous NERC standards. Approved by NAESB Sept’17. NAESB WEQ @ ISAS 09/18/19

Pending FERC Final Order (continued) 8 v003.2 published 12/08/17. NOPR closed July’19. Pending FERC Final Order (continued) Topic Sub Description and Status Short-term Preemption/ Competition OS Five year effort to develop standards for Short-term Preemption and Competition was completed per FERC Order 890. Approved by NAESB Nov’17. This includes a late amendment pushed by the west and led by BPA to resolve a gap in how certain Defenders with ROFR were treated if they were unable to exercise ROFR. Amendment adopted by the EC despite opposition from Duke and Southern. Consistency Changes In July, the OASIS subcommittee also approved various changes to OASIS standards (WEQ-001, 002, 003, and 013). These are considered “consistency” changes to remove NERC references, ensure language alignment between NERC/NAESB, etc. Approved by NAESB Nov’17. DSM-EE In Aug, the DSM-EE subcommittee approved various changes to WEQ-015, 018, and 020. These are also “consistency” changes to ensure alignment between NERC/NAESB. Approved by NAESB Nov’17. NAESB WEQ @ ISAS 09/18/19

Implementation In-progress 9 Implementation In-progress Topic Sub Description and Status NAESB WEQ @ ISAS 09/18/19

Implementation Complete 9 Implementation Complete Topic Sub Description and Status NAESB WEQ @ ISAS 09/18/19

With questions or feedback Contact With questions or feedback Mike Steigerwald (360) 418-2113 mlsteigerwald@bpa.gov NAESB WEQ @ ISAS 09/18/19

Background NAESB WEQ @ ISAS 09/18/19

North American Energy Standards Board (NAESB) Wholesale Retail An industry forum for the development and promotion of standards which will lead to a seamless marketplace for wholesale and retail natural gas an electricity. 4 quadrants BPA participates in the Wholesale Electric Quadrant (WEQ). Wholesale Electric Quadrant (WEQ) Co-chairs: Roy True (ACES) Josh Phillips (SPP) Retail Electric Quadrant (REQ) Electric Wholesale Gas Quadrant (WGQ) Retail Gas Quadrant (RGQ) Gas NAESB WEQ @ ISAS 09/18/19

Summary of WEQ Subcommittees OASIS (OS): Owns processing of TSR’s and posting requirements on OASIS. By far the most active subcommittee in WEQ. Standards and communication protocols for OASIS (WEQ-000, 001, 002, 003, 013). Coordinate Interchange Scheduling (CISS): Owns tagging. Interchange scheduling (tagging) standards (WEQ-004) and the e-Tag Functional Specification. Standards and enhancements to the Electric Industry Registry (EIR). Cybersecurity (CSS): Ensure secure exchange of market data across the internet. Owns the Public Key Infrastructure (PKI) standards (WEQ-012) and the Accreditation Specification that together govern vetting of Authorized Certificate Authorities (ACA). Also performs Annual Reviews of NERC/CIP. Demand-side Management/Energy Efficiency (DSM-EE): Emerging standards. Standards for Demand Response, SmartGrid, and Energy Efficiency (WEQ-015, 018, 020, 021). Business Practice (BPS): Owns standard development for areas not covered above. Takes the lead for standards development not clearly owned by another subcommittee. Standards Review (SRS): Support for other standard development subcommittees. Reviews changes to NERC standards in order to assess impact on NAESB WEQ standards. Reviews proposed WEQ standards for consistency and uniformity. Other subcommittees are ad-hoc or process-related: Annual Plan, Parliamentary, Triage, FERC Forms, etc. NAESB WEQ @ ISAS 09/18/19

Prior Implementation Complete Implementation of major NAESB items. Prior Implementation Complete Topic Sub Description and Status eTag 1.8.2 CISS April 2015: Changes to tagging and Curtailment Manager to manage overlapping Reliability Limits from different TP’s. SAMTS OS May 2015: Enables customers to coordinate transmission requests across multiple TP’s per FERC Order 676-H. Rollover Rights May 2015: Grants Rollover Rights to firm Redirects per FERC Order 676-H. Also allows a customer to explicitly waive such rights. NITS March 2017: Implementation of wide-ranging standards for Network Integration Transmission Service. eTag 1.8.3 Oct 2017: Functional Specification approved to split Market Operator out as a new role, separate from TP and BA. Implemented industry-wide on 10/10/17. eTag 1.8.2 retired on 11/07/17. NAESB WEQ @ ISAS 09/18/19