UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION. Southwest Power Pool, Inc. ) Docket No. ER

Transcription

1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Southwest Power Pool, Inc. ) Docket No. ER ANSWER OF SOUTHWEST POWER POOL, INC. Pursuant to Rule 213 of the Federal Energy Regulatory Commission s ( Commission ) Rules of Practice and Procedure, 18 C.F.R , Southwest Power Pool, Inc. ( SPP ) files this Answer 1 to the comments submitted in this proceeding. 2 I. BACKGROUND On February 1, 2016, SPP submitted an unexecuted Network Integration Transmission Service Agreement between SPP as Transmission Provider and Western Farmers Electric Cooperative ( WFEC ) as Network Customer ( WFEC Service Agreement ); and (2) an executed Network Operating Agreement among SPP as Transmission Provider, WFEC as Network Customer, and WFEC, American Electric Power Service Corporation, and Oklahoma Gas and Electric Company as Host Transmission Owners ( WFEC NOA ). 3 WFEC requested changes to the delivery points 1 SPP seeks leave to submit this answer to assist the Commission s decisionmaking process and clarify the issues. The Commission regularly allows answers for such purposes. See, e.g., Sw. Power Pool, Inc., 135 FERC 61,223, at P 27 (2011) (accepting answers that aided the Commission s decision-making); Sw. Power Pool, Inc., 132 FERC 61,042, at P 28 (2010) (same), reh g denied, 136 FERC 61,050 (2011); Sw. Power Pool, Inc., 131 FERC 61,252, at P 19 (2010) (same), reh g denied, 137 FERC 61,075 (2011); Sw. Power Pool, Inc., 128 FERC 61,018, at P 15 (2009) (same); Sw. Power Pool, Inc., 126 FERC 61,153, at P 18 (2009) (same). 2 SPP s silence in this Answer on any issue or argument addressed in any comment should not be construed as SPP s agreement with any such issue or argument. 3 Submission of Network Integration Transmission Service Agreement and Network Operating Agreement of Southwest Power Pool, Inc., Docket No. ER16-1

2 listed in Appendix 3 of the WFEC Service Agreement. SPP was unable to make all the changes requested by WFEC because requests to add, modify, or abandon delivery points are governed by the Delivery Point Addition ( DPA ) study process in Attachment AQ of the SPP Tariff. 4 As a result, WFEC requested SPP file the WFEC Service Agreement unexecuted. On February22, 2016, WFEC filed comments. 5 To ensure a full and accurate record, SPP submits this Answer to respond to the WFEC Comments and to aid the Commission s decision-making. II. ANSWER During the review of the WFEC Agreements, WFEC provided a list of changes to be made to Appendix 3 of the WFEC Service Agreement which included the addition and removal of certain delivery points. SPP reviewed the list of changes and notified WFEC which changes SPP could make and which changes SPP could not make. For example, SPP added the delivery point for Diane Alfalfa to Appendix 3 because the delivery point had been studied in a DPA study in However, many of the changes requested by WFEC had not yet been studied in the Attachment AQ process. In the WFEC Comments, WFEC claims that delivery points that were added, modified or abandoned prior to the adoption of Attachment AQ should not have to go through the DPA process. For those changes that SPP has been able to verify were included in the SPP models prior to the adoption of the Attachment AQ process in 2010, SPP agrees to make those changes (February 1, 2016) ( February 1 Filing ). The WFEC Service Agreement and WFEC NOA are collectively referred to as the WFEC Agreements. 4 Southwest Power Pool, Inc., Open Access Transmission Tariff, Sixth Revised Volume No. 1 ( SPP Tariff ) at Sections 31.2, 31.2a-c and Attachment AQ. 5 Motion to Intervene and Comments of Western Farmers Electric Cooperative (February 22, 2016) ( WFEC Comments ) 2

3 However, SPP has been unable to verify that the majority of the requested changes were reflected in SPP s models prior to As a result, the requested changes are required to be studied through the DPA process outlined in Attachment AQ of the SPP Tariff. Once those studies are complete, SPP will work with WFEC to update Appendix 3 of the WFEC Service Agreement. Attachment A hereto identifies which delivery points SPP was able to identify as predating Attachment AQ. III. CONCLUSION For the reasons set forth above and as provided in the February 1 Filing, SPP requests that the Commission accept the WFEC Agreements with an effective date of January 1, Respectfully submitted, /s/ Tessie Kentner Tessie Kentner Attorney Southwest Power Pool, Inc. 201 Worthen Drive Little Rock, AR Telephone: (501) tkentner@spp.org Attorney for Southwest Power Pool, Inc. 3

4 CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated at Little Rock, Arkansas, this 8th day of March _/s/ Tessie Kentner Tessie Kentner 4

5 Delivery Point WFEC Requested Action Bus # Bus Name Attachment A SPP recommended action Justification Woodward, ISD 1/1994, prior 2010 (human error) *** add WOODWRD Add to NITSA Load modeled at provided bus since 2008 Paradigm, ISD 8/2009, prior 2010 *** add PARADSE DPA study required Load has been modeled at provided bus since 2008, but bus PARADIGM4 has not been modeled since before Windfarm Sw.Station 69/26.4KV, 22.4MVA (cannot identify) remove Not listed DPA study required No bus provided Braums (distribution meter downstream from Tuttle sub)(human error) remove Not listed DPA study required No bus provided for this load Blue Canyon 5, ISD 9/2009, prior 2010 *** add Not listed DPA study required No data for provided bus number Blue Canyon 2, ISD 11/2005, prior 2010 *** add Not listed DPA study required No data for provided bus numbers Comanche sub, ISD 6/2010, prior 2010 (human error) add Not listed DPA study required No data for this bus Gould, ISD 10/2009, prior 2010 (human error) *** add Not listed DPA study required No data for this bus New Braman, ISD 1/2009, prior 2010 *** add BRAMAN DPA study required No load modeled at this bus since 2009 Cana, ISD 8/2010, prior 2010 *** add CANA DPA study required This bus is not in the models prior to 2016 ITP

6 Caddo Sequoyah (distribution meter downstream from Sequoyah sub)(human error) remove Hollytex CI (distribution meter downstream from Watonga sub)(human error) remove Lacey #2 (distribution meter downstream from Lacey sub)(human error) remove Attachment A SEQUOYAHJ DPA study required This bus is not in the models prior to 2016 ITP SEQUOYAHJ DPA study required This bus is not in the models prior to 2016 ITP LACEY DPA study required 2 loads modeled at this bus through Braman, OSD 5/2009 remove BRAMAN Remove from NITSA Load ID 2 removed after 2008 Step Peckham, bus # (human error) remove PECKHMT Remove from NITSA Bus is modeled, but with no load