January 11, 2015 via efiling Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street N.E. Washington, DC 20426 Re: NorthWestern Corporation, Docket No. ER16- -000 Revisions to Montana Open Access Transmission Tariff Dear Secretary Bose: Pursuant to Section 205 of the Federal Power Act 1 and Section 35.13 of the Federal Energy Regulatory Commission s regulations, 2 NorthWestern Corporation d/b/a NorthWestern Energy submits proposed revisions to certain sections of its Montana Open Access Transmission Tariff (OATT). These changes are ministerial and are summarized in the attached table. NorthWestern Energy requests an effective date of March 12, 2016, for the proposed revisions. I. Background NorthWestern Energy is a public utility engaged in the generation, transmission, and distribution of electricity and the supply and transportation of natural gas. Its facilities are located primarily in Montana and South Dakota. In South Dakota, NorthWestern Energy is a transmission owner within the Southwest Power Pool, Inc. and has transferred functional control of a large portion of its electric transmission facilities there to SPP. In Montana, NorthWestern Energy is a transmission owner/operator and Balancing Authority Area operator within the Western Electricity Coordinating Council. NorthWestern Energy s Montana and South Dakota transmission facilities are not physically connected and are not in the same electric reliability region. Accordingly, NorthWestern Energy 1 16 U.S.C. 824d. 2 18 C.F.R. 35.13. 208 N. Montana Avenue, # 205 Helena, MT 59601 O 406-443-8987
maintains separate open access transmission tariffs for operations in each state. This filing concerns only NorthWestern Energy s Montana OATT. II. Description of and Justification for Tariff Revisions NorthWestern Energy respectfully requests the Commission approve the changes discussed below. These revisions do not affect or present changes to any Commission-approved rates or services; rather, they are ministerial changes intended to correct or clarify the tariff (e.g., typos, name and address changes, etc.). To aid the Commission in its review, NorthWestern has provided an index summarizing the proposed revisions. A. Section 7.1, Billing Procedure The billing procedure was revised to specifically allow for payment in immediately available funds rather than specifying that all payments must be made by electronic wire transfer. This provides more flexibility to the customer. In addition, NorthWestern Energy is removing its specific bank account information and will instead provide the requisite information directly to the customer. Removing account information allows NorthWestern Energy to change bank accounts without updating the OATT and protects NorthWestern Energy by not having its account information publicly available. B. Attachment C, Methodology to Assess Available Transfer Capacity NorthWestern Energy s proposed changes to Attachment C revise the language to more closely match the language in NERC s Modeling, Data and Analysis (MOD) reliability standards. For example, the mathematical algorithms in Section (1) were revised to include the definition of each acronym, consistent with MOD-029. The proposed changes also include revisions designed to update the language and provide more clarity. For example, the definition of Total Transfer Capability in Section (3) was revised to match 18 C.F.R. 37.6(b)(1)(vi), and broken hyperlinks were removed or edited. The changes do not substantively change the ATC methodology. The proposed changes are marked in the attached tariff record and outlined in more detail in the attached index. When NorthWestern Energy made its baseline etariff filing, the Process Flow Diagram did not pass through the etariff system. NorthWestern has made this diagram an appendix to Attachment C so that it can be filed as a separate tariff record. Kimberly D. Bose, Secretary January 11, 2016 Page 2
C. Attachment K, Transmission Planning Process NorthWestern Energy inadvertently omitted Paragraph 3.9.2 Reevaluation of Cost Allocation when it submitted its Second Order No. 1000 Regional Compliance Filing in Docket No. ER13-67-001. This language is being inserted now to conform NorthWestern Energy s Attachment K to those of the other Northern Tier Transmission Group entities. 3 D. Ministerial Changes NorthWestern Energy proposes several ministerial changes throughout the OATT. These changes are detailed in the attached index. These ministerial changes including updating contact information, updating citations to the Standards of Conduct, and correcting typographical errors and broken hyperlinks. III. General Information Pursuant to 18 C.F.R. 35.13(b), NorthWestern Energy provides the following information: 1) This filing includes the following documents: a. This transmittal letter; b. Index of Proposed Tariff Revisions; c. Clean and marked versions of the title page to FERC Electric Tariff Volume No. 5, Open Access Transmission Tariff; d. Clean and marked versions of the table of contents; e. Clean and marked versions of Section 1, Definitions; f. Clean and marked versions of tariff Section 7, Billing and Payment; g. Clean and marked versions of tariff Section 17, Procedures for Arranging Firm Point-to-Point Transmission Service; h. Clean and marked versions of tariff Section 18, Procedures for Arranging Non-Firm Point-to-Point Transmission Service; i. Clean and marked versions of tariff Section 29, Initiating Service; j. Clean and marked versions of Attachment C, Methodology to Assess Available Transfer Capacity; 3 See regional Order No. 1000 compliance filings of PacifiCorp, Docket No. ER13-64; Deseret Generation & Transmission Cooperative, Inc., ER13-65; Portland General Electric Company, ER13-68; and Idaho Power Company, ER13-127. Kimberly D. Bose, Secretary January 11, 2016 Page 3
k. Clean and marked versions of Attachment F, Form of Service Agreement for Network Integration Transmission Service; l. Clean and marked versions of Attachment J, Procedures for Addressing Parallel Flows; m. Clean and marked versions of Attachment K, Transmission Planning Process; and n. Clean and marked versions of Appendices 2, 3, 4 and 5 of Attachment M, Large Generator Interconnection Procedures. 2) NorthWestern Energy respectfully requests an effective date of March 12, 2016, for the proposed revisions. 3) NorthWestern Energy is providing a copy of this filing to each active transmission customer under the Montana OATT and to the Montana Public Service Commission. NorthWestern Energy will also post a copy of this filing on its OASIS. 4 4) This filing does not involve a rate change. In addition, NorthWestern Energy respectfully submits that the requirements of 18 C.F.R. 35.13(b) that have not been specifically addressed are inapplicable to this filing. To the extent that the Commission determines the requirements of Section 35.13(b) or (c) or any other rules to be applicable, NorthWestern Energy respectfully requests waiver of the requirements of such provisions. IV. Communications Communications in this proceeding should be directed to the following representatives, who should be included on the official service list compiled by the Secretary in this proceeding: Michael R. Cashell Vice President Transmission NorthWestern Energy 11 East Park Butte, MT 59701 Phone: (406) 497-4575 michael.cashell@northwestern.com M. Andrew McLain Corporate Counsel & FERC Compliance Officer NorthWestern Energy 208 N. Montana Avenue, Suite 205 Helena, MT 59601 Phone: (406) 443-8987 andrew.mclain@northwestern.com 4 http://www.oatioasis.com/nwmt/index.html Kimberly D. Bose, Secretary January 11, 2016 Page 4
V. Conclusion NorthWestern Energy respectfully requests the Commission to accept the proposed tariff revisions, effective March 12, 2016, and grant waiver of any other Commission regulations deemed applicable this filing. Respectfully submitted, s/ M. Andrew McLain M. Andrew McLain Corporate Counsel & FERC Compliance Officer andrew.mclain@northwestern.com O (406) 443-8987 MAM/dq Attachments cc: Transmission Customers (Montana OATT) Montana Public Service Commission Kimberly D. Bose, Secretary January 11, 2016 Page 5
Certificate of Service I hereby certify that I have this day served the foregoing document upon each person designated in the foregoing transmittal letter, in accordance with Rule 2010 of the Commission s Rules of Practice and Procedure, 18 C.F.R. 385.2010. Dated this 11 th day of January, 2016. s/ M. Andrew McLain M. Andrew McLain Corporate Counsel & FERC Compliance Officer NorthWestern Energy 208 N. Montana Avenue, Suite 205 Helena, MT 59601 (406) 443-8987 andrew.mclain@northwestern.com Kimberly D. Bose, Secretary January 11, 2016 Page 6
Index of Proposed Tariff Revisions NorthWestern Corporation, Docket No. ER16- -000 Ministerial Revisions to Montana Open Access Transmission Tariff No. Title Changes 0 Tariff Title Page 0 Table of Contents 1 Definitions 7 Billing and Payment The contact person and corresponding information is being updated to reflect executive and organizational changes and a new street address. References were added to the LGIA (Attachment M) and Attachment N, SGIP & SGIA. The reference to the Standards of Conduct was removed from Section 1.30 (OASIS). This is consistent with the Version 003 of the NAESB WEQ standards. The billing procedure is being revised to specifically allow for payment in immediately available funds. In addition, NorthWestern Energy is removing its specific bank account information. 17 18 Procedures for Arranging Firm Point-to-Point Transmission Service Procedures for Arranging Non-Firm Point-to-Point Transmission Service Contact information for submission of a written application is being updated. The citation to the Standards of Conduct was updated in Section 17.2. In addition, long-term was added to Section 17.3 to clarify that the deposit requirement only applies to long-term point-to-point transmission service. The citation to the Standards of Conduct was updated in Section 18.2. 29 Initiating Service The citation to the Standards of Conduct was updated in Section 29.2 Index of Proposed Revisions Page 1 of 3
No. Title Changes C Methodology to Assess Available Transfer Capacity In Section (1), the terms in the mathematical algorithms were revised to match Reliability Standard MOD-029-1a Rated System Path Methodology. The Process Flow Diagram was made an appendix so that it can be filed as a separate tariff record. In Section (3)(a)(i), the definition of Total Transfer Capability was revised to match the Code of Federal Regulations. Section (3)(a)(ii) was streamlined to be more in line with Reliability Standard MOD-029-1a and updated for accuracy. In Sections (3)(a)(iii) and (iv), seasonal SOL information was added. Language was clarified and revised to more closely match Reliability Standard MOD-029-1a. Outdated links to the WECC procedures were removed. Section (3)(d)(iv) was revised to align with Reliability Standard MOD-008 and to reference the Transmission Reliability Margin Implementation Document (TRMID), which is available on OASIS. Section (3)(e) was revised to align with Reliability Standard MOD-004. Section (3)(g) was revised to describe how a Load Serving Entity may request that CBM be set aside. Throughout, broken hyperlinks were removed or edited, acronyms were defined, and grammatical and typographical errors were fixed. In Appendix 1, Operating Transfer Capability was updated to System Operating Limit. It was clarified that TRM is used to reduce firm transfer capability to a lower point on the nomogram. Index of Proposed Revisions Page 2 of 3
No. Title Changes F J K M Form of Service Agreement for Network Integration Transmission Service Procedures for Addressing Parallel Flows Transmission Planning Process Large Generator Interconnection Procedures Section 7.6 Billing Information was added. Oftentimes a customer s billing address is different from the address for providing notice. It is helpful and more efficient if the customer provides the billing information when entering into a service agreement. In addition, several ministerial changes were made, including the following: corrected page numbers in table of contents; changed blanks for years from 19 to 20 ; inserted blanks in Sections 5.1 & 5.2; filled in NorthWestern Energy s address for notice; and added blanks for the name of the signing representatives. A space was inserted to correct a typographical error. Inserted Section 3.9.2 (Reevaluation of Cost Allocation), which was inadvertently omitted from NorthWestern s filing in Docket No. ER13-67-001. The street address was updated in Section 8.0 (notice) of the study agreements (Appendices 2, 3, 4 & 5). Index of Proposed Revisions Page 3 of 3