1. Improving Access to the Federal Columbia River Transmission System: The IPP Perspective NIPPC September 8, 2005 Stephen Hall Partner Stoel Rives, LLP

2. Improving Access to the FCRTS Redispatch Curtailment Scheduling Ancillary Services

3. Redispatch BPA currently uses redispatch to maintain Network (NT) transmission schedules only. BPA is currently exploring the use of commercial redispatch to create additional ATC across constrained paths for firm Point to Point (PTP) transmission schedules. Benefits of commercial redispatch for PTP : –Maximizes value of existing federal transmission system –Increases ATC to satisfy pending requests for long-term PTP firm transmission –Facilitates new generation –Increases TBL revenues –May create new business opportunities for non-federal redispatch providers

4. Curtailment Concerns of generators –Real time curtailments of paths such as John Day-COB are frequent. –BPA does not distinguish between firm and non-firm transmission when cutting schedules. –BPA does not make schedule cuts pro rata. –BPA places too much reliance on Remedial Action Schemes (RAS) to reduce constraints. –Under BPA’s ‘take or pay’ policy, BPA does not give any credit for the derated portion of the interties to customers holding firm transmission rights.

5. Non-Redirectable Power Problem: –If TBL cuts a transmission schedule in which BPA or a BPA Slice customer is the generator, BPA will not allow the buyer to redirect the power. Solution: –Revise practice to conform with other regional transmission providers.

6. Transmission Scheduling TBL is currently using a hybrid system to schedule transmission transactions –Real Time Operations Dispatch and Scheduling system (RODS) –Open Access Same-Time Information System (OASIS)

7. Transmission Scheduling (cont.) –OASIS (aka, OATI) Not fully operational Many communications still made by telephone –Inefficient and introduces potential for mistakes –Customer Web Interface (CWI) Transmission requests are processed manually Lacks functionality of other OASIS sites –Limited information about ATC –RODS Transmission schedules require an accounting number for each transmission path –TBL cannot build these accounts in real time. –TBL will not pre-build accounts unless such accounts will be activated immediately.

8. Ancillary Services Issue: –Generators would like to TBL consider other sources besides PBL for ancillary services. Proposal: –TBL should implement a pilot program to procure its ancillary services (other than Scheduling, System Control and Dispatch) through a competitive bidding process, e.g., issue an RFP where third party providers could compete with PBL to provide ancillary services to TBL.