1. Want to be a Path Operator?

2. No true definition of Path Operator in Reliability requirements, responsible entities listed are RC, TOP, TO, BA, GO, GOP, LSE………….. No mention of Path Operator

3. Rely on neighboring TOP and BAAs to submit correct outage information –For the Northwest utilities the NWPP Outage Coordination process is utilized – manual process open for mistakes 01MAR, 2012. Also NWPP process has an exclusion list that contains line elements at 115kV and 230kV that are non-radial. –WECC and FERC states NWPP process not mandatory requiring the BPA to emit TOP-004-2 R6 requests for required outage information for study purposes –FERC and WECC would have every individual TOP file their own requirements – coordination nightmare? –The BPA proposes use of WECC COS with longer reporting duration (two weeks prior) –Utilities do not want their elements listed as critical due to outage coordination requirements –Path Operator Outage office must be diligent to assure its received all information – requirement falls on Path Operator Outage office to assure correct topology to the WECC RC –WECC RC does not use information from individual TOP but relies on path operator to submit correct information

4. If neighboring utility gives incorrect outage information WECC enforcement finds the TOP that has assigned Path Operator responsibilities as being responsible. Capital D Directives issued to Path/Flowgate operator(s) for Path SOL exceedences regardless of element not being owned or operated by the Path Operator.

5. Path Operators have no assigned authority, in reality for the Western Interconnection they are the same as a TOP –Have to perform all the studies that involves everyone's BES/BPS elements. –WECC RC COS requires short notification timeframes – Are they performing SOL/IROL studies for both transient voltage and thermal capabillities?

6. Eastern Interconnection the Path Operator is assigned to ISOs. The RCs for the Eastern Interconnection are co-located with the ISO - Western Interconnection should follow this model. –In the East TLR and IDC implemented by ISO/RC

7. Rating information from neighboring utilities –Some utilities only want to share Summer ratings at 40degree C (104F) and do not allow the path Operator to extrapolate ratings for lower temperatures – creates concerns during outage conditions with these ratings utilized in studies. Mitigation of ultraconservative SOLs can lead to increased Firm curtailments and possible load shedding

8. Compensation for path Operator?