Tariff Revision Request (TRR)
TRR Number / TRR 120 / TRR Title / Attachment AICross Reference # / MPRR BRR Other (Specify) ______
Presenter
Name / Matthew Harward
E-mail Address /
Company / SPP
Phone Number / 501-614-3560
Date / For review September ,2014 RTWG
Tariff Section(s) Requiring Revision / Attachment AI, Sections I, II and IV
Requested Resolution / Normal Urgent (provided justification below for urgent request)
Revision Description / The main substantive changes proposed in this TRR are to Section IV of Attachment AI. Section IV of Attachment AI currently sets forth transitional procedures for determining which facilities are Transmission Facilities based on Attachment AI. This section is outdated. The proposed TRR revisions replaces the current Section IV with language that provides a review process by SPP of initial rate filings to be made by Transmission Owners (or by SPP on behalf of Transmission Owners) to incorporate Transmission Owner revenue requirements and protocols into Attachment H. Section IV provides that at least six months prior to the submission of a filing to FERC to incorporate a Transmission Owner’s initial annual transmission revenue requirement and protocols into Attachment H, the Transmission Owner shall provide the information and data relating to the inputs into the rates and the facilities included in the rate as Transmission Facilities to SPP for review. No later than 30 days prior to the planned submission date of the Tariff revisions to incorporate the initial annual revenue requirement and protocols into Attachment H of this Tariff, SPP shall notify the Transmission Owner of the results of its review and whether it has identified any issues relating to the data, analysis or information provided by Transmission Owner. Section IV further provides that the results of SPP’s review will not constitute a finding or recommendation by the Transmission Provider that the proposed initial rate is or is not just and reasonable or unduly preferential within the meaning of the Federal Power Act, that the initial rate filing itself is complete or incomplete, or that any facility included in the proposed initial annual revenue requirement and protocols satisfies or does not satisfy the criteria in Attachment AI or otherwise qualifies or does not qualify as a Transmission Facility. In addition, SPP’s action or inaction with respect to this review or the results of the review cannot be cited as evidence in any FERC proceeding concerning a Transmission Owner’s initial rate. Finally, nothing in the new Section IV of Attachment AI prohibits: (i) SPP from submitting a filing with the FERC, at the request of the Transmission Owner, to incorporate the Transmission Owner’s initial annual revenue requirement and protocols into Attachment H of this Tariff, at the completion of the Transmission Provider’s review; or (ii) SPP or the Transmission Owner from submitting other pleadings in addition to the initial rate filing in such a proceeding.
There are additional minor changes to accommodate the new Section IV as well a new definition of “Transmission Facilities.” A few minor clean up revisions to the other sections of Attachment AI also are proposed.
Reason for Revision / These TRR revisions like those proposed in TRR 119 (Attachment H - Voluntary Refunds for New or Amended Revenue Requirements), were developed in settlement negotiations by the parties in Docket Nos. EL13-15 and EL13-35, which involved the application of the SPP Tariff to a filing made by SPP on behalf of a non-jurisdictional entity to incorporate that entity’s revenue requirement into Attachment H. The complainant and intervenors desire to have a process whereby SPP reviews initial rate filings prior to the Transmission Owner’s, or SPP’s (on behalf of Transmission Owner) submission of such a filing with FERC. The purpose of this review is for SPP to identify, in its opinion, any issues with the proposed initial rate filing, thereby providing the Transmission Owner an opportunity to address potential problems prior to filing its initial rate filing with the FERC. However, this review in no way constitutes SPP’s approval or disapproval of a filing or an opinion as to the just and reasonableness of a proposed annual revenue requirement or protocols. In addition, in no way will this review preclude a Transmission Owner or SPP on behalf of a Transmission Owner from filing an initial revenue requirement or protocols for incorporation into Attachment H of the SPP Tariff. This review process applies only to initial rate filings and not to annual updates.
Stakeholder Approval Required (specify date and record outcome of vote; n/a for those stakeholders not required) / MWG (n/a)
BPWG (n/a)
TWG (n/a)
ORWG (n/a)
Other (specify) (n/a)
RTWG - 9/24/2014 – Approved with one abstention (Empire)
MOPC
Board of Directors
Legal Review Completed / Yes (Include any comments resulting from the review)
No
Market Protocol Implications or Changes / Yes (Include a summary of impact and/or specific changes & PRR #)
No
Business Practice Implications or Changes / Yes (Include a summary of impact and/or specific changes & BPR #)
No
Criteria Implications or Changes / Yes (Include a summary of impact and/or specific changes)
No
Other Corporate Documents Implications (i.e., SPP By-Laws, Membership Agreement, etc.) / Yes (Include which corporate documents)
No
Credit Implications / Yes (Include a summary of impact and/or specific changes)
No
Impact Analysis Required / Yes
No
Proposed Tariff Language Revisions (Redlined)
Notes:
This draft has been revised to add language providing that SPP may waive or adjust the 6 month requirement at its discretion.
ATTACHMENT AI
Transmission Facility DefinitionCriterIa AND pRE-FILING REVIEW PROCESS
I. Introduction
A Transmission Facility is a facility that is included as part of the Transmission System. This Attachment sets forth the definition of Transmission Facilities to be implemented in accordance with the schedule in Section IV of this Attachment. Transmission Facilities shall be the facilities which meet (i) the criteria specified in this Attachmenta facility must meet to be included as part of the Transmission System and which are used(ii) a pre-filing review process by the Transmission Provider. to provide transmission service under Part II, Part III and Part V of the Tariff.set forth in Section IV of this Attachment AI.
III. Criteria for Inclusion of Transmission Facilities
A Transmission Facility is a facility that is included as part of the Transmission System. The Transmission FacilitiesSystem shall include all facilitiesany facility(ies) that meets any of the following criteria:
1. All existing non-radial power lines, substations, and associated facilities, operated at 60 kV or above, plus all radial lines and associated facilities operated at or above 60 kV that serve two or more eligible customersEligible Customers not Affiliates of each other. Rate treatment for transmission upgrades completed after October 1, 2005 will be determined pursuant to Section 1.3 (h) Attachment J of this Tariff. For the purpose of the application of this criterion, “open loops” are radial lines. Additionally, at such time an existing radial is incorporated into a looped transmission circuit, that existing radial would be eligible for inclusion in rates on the same basis as the remainder of the facilities in the loop.
2. All facilitiesFacility(ies) that are utilized for interconnecting the various internal zonesZones to each other as well as those facilities that interconnect SPPthe Transmission System with other surrounding entities.
3. Control equipment and facilities necessary to control and protect facilitiesa facility qualifying as a Transmission FacilitiesFacility.
4. For substationsa substation connected to power lines qualifying asthe Transmission facilitiesSystem, where power is transformed from a voltage higher than 60 kV to a voltage lower than 60 kV, the facilities on the high voltage side of the transformer will be included as Transmission Facilities with the exception of transformer isolation equipment.
5. The portion of the direct-current interconnections with areas outside of the SPP Region (DC ties) that are owned by a Transmission Owner in the SPP Region, including those portions of the DC tie that operate at a voltage lower than 60 kV.
6. All facilitiesA facility operated below 60 kV that havehas been determined to be transmission by the Commission pursuant to the seven (7) factor test set forth in FERCCommission Order No. 888, 61 Fed Reg. 21,540, 21,620 (1996), or any applicable successor test.
IIIII. Excluded Facilities
The following facilities shall not constitute Transmission Facilities:
1. Generator step-up transformers and generator leads;
2. Radial lines from a generating station to a single substation or switching station on the Transmission System; and
3. Direct Assignment Facilities.
IVIII. Implementation Schedule Transmission Owner Pre-Filing Requirements and Transmission Provider Review Process
Within three (3) years from the date of acceptance by FERC of this Attachment AI to the Tariff, each Transmission Owner shall file a request(s) based on this Attachment with its appropriate regulatory authority or authorities for a determination as to which of its facilities are Transmission Facilities. Each Transmission Owner that is not subject to regulation by a regulatory authority shall apply to SPP for such a determination.
Each Transmission Owner shall use reasonable efforts to cause the aforementioned determinations to be made and the applicable transmission service rates to be adjusted accordingly as soon as possible after such determinations are finalized.
The review process set forth in this Section IV shall apply to initial rate filings with the Commission to reference or state a new annual revenue requirement in Attachment H of this Tariff as specified in Section 6.0 of Attachment H.
1. Transmission Owner Pre-Filing Requirements
An entity that shall provide the following information and data to the Transmission Provider for review at least six months prior to the submission of a filing to the Commission to incorporate into Attachment H of this Tariff the entity’s initial annual transmission revenue requirement (stated rate), or formula rate and protocols. The Transmission Provider in its sole discretion may waive or adjustreduce the six month requirement if the Transmission Provider determines that such waiver or adjustment will not adversely affect the Transmission Provider’s ability to adequately review the information and data or to prepare and submit the filing on the entity’s behalf. :
a. Supporting documentation for all inputs into the proposed formula or stated rate, including, to the extent required, testimony or affidavits. Such inputs shall be based on FERC Form 1 or other comparable source. In the event the inputs are based on a source other than FERC Form 1, the entity shall provide an explanation as to why the use of such other source is appropriate;
b. Formula or stated rate implementation procedures or protocols, as applicable;
c. Supporting documentation and calculation methodology for the return on common equity, margin or other comparable component;
d. Supporting documentation for the depreciation rates that will be applied to plant, and an indication as to whether the depreciation rates are Commission accepted or approved stated values that are subject to change only pursuant to an FPA section 205 or 206 filing;
e. Data supporting the cost of each facility to be included in rate base that the entity has determined qualifies as a Transmission Facility; and
f. Identification of all facilities included in rate base according to the criteria established in Attachment AI as follows:
i. Non-radial facilities that comply with Section II.1;
ii. Radial facilities that comply with Section II.1;
iii. Facilities that comply with Section II.2;
iv. Facilities that comply with Section II.3;
v. Facilities that comply with Section II.4;
vi. Facilities that comply with Section II.5; and
vii. Facilities that comply with Section II.6.
2. Transmission Provider Review Process
Transmission Provider willshall review the data, analysis and information provided by the entity in accordance with Section IV.1 above to determine whether all data and information specified in that section has been provided. No later than 30 days prior to the planned submission date of the Tariff revisions to incorporate the initial rate and protocols, as applicable, into Attachment H of this Tariff, the Transmission Provider shall notify the entity of the results of its review and whether the Transmission Provider identified any issues relating to the data, analysis or information provided by the entity. The results of the Transmission Provider review in no way constitutes a finding or recommendation by the Transmission Provider that the proposed initial rate is or is not just and reasonable or unduly preferential within the meaning of the Federal Power Act, that the initial rate filing itself is complete or incomplete, or that any facility included in the proposed initial rate satisfies or does not satisfy the criteria in Attachment AI or otherwise qualifies or does not qualify as a Transmission Facility. Transmission Provider’s action or inaction with respect to this review or the results of the review cannot be cited as evidence in any Commission proceeding concerning the entity’s initial rate. Nothing in this section prohibits: (i) the Transmission Provider from submitting a filing with the Commission, at the request of the entity, to incorporate the entity’s initial annual transmission revenue requirement and protocols, as applicable, into Attachment H of this Tariff, at the completion of the Transmission Provider’s review; or (ii) the Transmission Provider or the entity from submitting other pleadings in addition to the initial rate filing in such a proceeding.
Proposed Market Protocol Language Revision (Redlined)N/A
Proposed Business Practices Language Revision (Redlined)
N/A
Proposed Criteria Language Revision (Redlined)
N/A
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