NV Energy s Open Access Transmission Tariff (OATT) Proposed Changes. November 2011

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1 NV Energy s Open Access Transmission Tariff (OATT) Proposed Changes November 2011

2 Proposed Tariff Changes More detailed Intra-hour scheduling language to be added Revisions to Attachment N (Large Generator Interconnection Procedures) Revisions to Attachment O (Small Generator Interconnection Procedures) Clean up Items CBNS removed, WECC reliability criteria updated November

3 Intra-hour Scheduling Language Added NV Energy s current tariff allows intra-hour scheduling but refining tariff language to provide more direction to customers regarding intra-hour scheduling Consistent with Western Interconnection initiatives following language will be added to section 13.8 of the Tariff: Intra-hour scheduling changes will also be permitted if authorized by the Transmission Provider in a business practice and such intra-hour scheduling changes are made in accordance with the timeline contained in such business practice, provided that all parties to the interchange transaction agree to the modification. November

4 Generator Interconnection Process Problems: Too many projects in the queue to be handled in an efficient manner Process is not designed to move developers through the process effectively given permitting issues in Nevada Proposed Tariff changes to solve problems: Streamline process to move through studies to an interconnection agreement Recognize role of public lands (primarily BLM) in permitting process in Nevada Address identified problem areas early in the SIS process to prevent future delays and/or restudies November

5 Background NVE Interconnection Queue Projects as of October 2011 Over 6,400 MW in Queue Down from 7,800 MW in queue in August due to withdrawals and completion of LGIA/SGIAs Combined Systems Peak Load about 7,200 MW 5

6 Concerns with Generator Interconnection Process Too many early-stage projects potentially clogging up the queue and resulting in re-studies NV Energy has a large number of interconnection requests, primarily on public lands Over 80% of land in Nevada is owned by governmental entities Bureau of Land Management (BLM) Issues Customer or Company facilities may be required to go through an environmental process with BLM If an EIS is required, it may take more than 5 years to reach a decision Lack of initial coordination on BLM application(s) between NV Energy and customer results in incomplete/inaccurate permit applications, necessary restudies and delays in interconnection Not enough time allowed in SIS process to complete full buildability analysis Generally, need more time for permitting, environmental issues to be worked out November

7 Summary of Interconnection Process Changes Implement Pre-Application Process to coordinate generation data/facilities/permitting requirements Eliminate Feasibility study Pre-Application process replaces Feasibility study process Adjust timing of System Impact and Facilities studies to reflect complexity of interconnection studies and address unique land/permitting issues in the state of Nevada Timeline for project study completion approximately the same as under the current process November

8 Pre-Application Process Pre-Application process would be used to ensure that no unresolvable environmental or land issues are present and to improve the later studies this would apply to all customers regardless of whether located on public and/or private land Customer to provide accurate generator specific data so interconnection facilities may be properly assessed Process would include coordination of generator location as well as interconnection facilities location/potential design or restrictions Pre-Application process gives Parties the opportunity to include Customer and anticipated NV Energy facilities in BLM POD and designate a more accurate Point of Interconnection (POI) A Completed Application for studies would include an agreed upon preliminary Plan of Development (generation location, transmission routing, switching station site, if applicable) Initial non-refundable deposit of $10,000 (balance, if any, credited towards later study costs) balance non-refundable if project does not proceed Customers successfully completing Pre-Application Process are placed in the Interconnection Queue November

9 Other LGIP Changes System Impact Study 30 days added to study period to ensure all issues, including BLM issues, are fully dealt with Deposit increased from $50,000 to $75,000 to pay for more detailed Study Facilities Study Deposit reduced from $100,000 to $75,000 to reflect more work done in the SIS and less in Facilities study process Eliminate plus or minus 10% cost option (and 180 day study timeframe) generally not used by customers in study process and infeasible in most cases due to commodity and equipment price fluctuations Additional LGIA only changes: Removal of Appendix H to LGIA (Reliability Management System) NERC process has superseded need for this agreement Addition of Milestones Page with Signature line in LGIA to ease milestone changes once LGIA is executed (similar to Attachment 4 of SGIA) November

10 SGIP Changes Eliminate Feasibility study replace with Pre-Application process, as described SIS study time frame increased from 45 business days to 120 calendar days; deposit increased from $25,000 ( good faith estimate ) to $50,000 Facilities study study time frame increased from 45 business days to 90 calendar days; no change to deposit Reflects the fact that small generators take as much time to study as large generators Time frame would increase slightly for small generation projects November

11 Clean-up Items WECC Reliability criteria removed (Minimum Operating Reliability Criteria) superseded by NERC criteria now in effect Remove Capacity-based Network Service (CBNS) expired in 2010 Other minor clerical changes November

12 Next Steps Comments on Proposed Changes Through December 15, 2011 Customer may submit questions and comments FAQ s to be posted on OASIS, as appropriate Proposed FERC Filing of New Tariff December 2011 NV Energy will request that tariff changes be made effective 60 days after filing November

13 Contacts Patricia Englin Kiley McElroy Renee Hull November