Late Comments Submitted by the WEQ and WGQ BPS Co-Chairs

FORMAL COMMENTS

Quadrant:Wholesale Electric Quadrant

Recommendation:WEQ 2009 AP Items 5.a.2 (R08004) and 5.i (R09011) “Multiple Annual Plan Items Affecting WEQ-011 Gas/Electric Coordination”

Submitted By:Joint Wholesale Electric Quadrant and Wholesale Gas Quadrant Business Practices Subcommittee Co-Chairs

Date:January 6, 2010

On December 15, 2009 and December 18, 2009, the Wholesale Electric Quadrant and Wholesale Gas Quadrant Business Practices Subcommittees held joint conference calls to review formal comments submitted by the Consumers Energy Company ( in response to the recommendation for WEQ 2009 AP Items 5.a.2 (R08004) and 5.i (R09011) “Multiple Annual Plan Items Affecting WEQ-011 Gas/Electric Coordination.” Based on our review of the comments, the subcommittee co-chairs, on behalf of the subcommittees, offer the following revisions to the proposed definitions for Power Plant Gas Coordinator, Power Plant Gas Coordinator Facility, and Transportation Service Provider. The terms Power Plant Gas Coordinator and Power Plant Gas Coordinator Facility replace existing terms Power Plant Operator and Power Plant Operator Facility, respectively. The term Transportation Service Provider is being defined for the first time within WEQ business practice standards. The subcommittees request the Wholesale Electric Quadrant Executive Committee consider these comments when taking action on this recommendation. The Wholesale Gas Quadrant Business Practices Subcommittee will be proposing similar changes to the proposed revisions to the definitions for Power Plant Gas Coordinator and Power Plant Gas Coordinator Facility when they post their recommendation for the 30-day formal comment period.

Additionally, the Wholesale Electric Quadrant and Wholesale Gas Quadrant Business Practices Subcommittees request that when the Wholesale Electric Quadrant and Wholesale Gas Quadrants take action on the Gas / Electric Coordination standards, they do so in a Joint Executive Committee meeting to ensure these coordination standards remain consistent.

(Note: The Transportation Service Provider term as documented on the following pagewill not be included in the Wholesale Gas Quadrant Standards.)

TERM / DEFINITION
Power Plant Gas Coordinator (PPGC) / The entity(ies) responsible for acquiring natural gas to meet a PPGC Facility’s operating requirements and for scheduling the delivery of said natural gas to the PPGC Facilitythat has responsibility for gas requirements for a natural gas-fired electric generating facility(ies) and is responsible for coordinating natural gas deliveries with the appropriate Transportation Service Provider(s) to meet those requirements. The PPGCmay perform some or allsa number of the following coordinated activities, including, but not limited to, power plant operations, unit dispatch, natural gas procurement and/or gas transportation arrangements. Because each PPGC is structured differently, specific responsibilities within each PPGC should be determined by the PPGC and the point of contact for the PPGC should be communicated to the Transportation Service Provider(s).
(Note: This also applies to NAESB WGQ Standard Nos. 0.2.1, 0.2.2, 0.3.11, 0.3.12, 0.3.13, 0.3.14, and 0.3.15)
Power Plant Gas Coordinator Facility (PPGC Facility) / The A natural gas-fired electric generating unit(s) for which its natural gas supply and transportation requirements are coordinated by a under the direct control of the PPGC.
(Note: This definition also applies to NAESB WGQ Standard Nos. 0.2.3, 0.3.12 and 0.3.13)
Transportation Service Provider / Interstate pipeline(s), intrastate pipeline(s), natural gas gathering pipeline(s) or a local distribution company(ies) The entity that is providinges natural gas delivery services (e.g., transportation).
(Note: This definition also applies to the NAESB Business Practices WGQ Standard Nos. 0.2.1 and 0.3.11 through 0.3.15)