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Via posting
TO: Wholesale Gas Quadrant and Wholesale Electric Quadrant e-Tariff Subcommittee members, and Interested Industry Participants

FROM: Jonathan Booe, Meeting Administration Counsel

RE: Draft Minutes of e-Tariff Subcommittee Meeting – January 23-25, 2008

DATE: March 18, 2008

NORTH AMERICAN ENERGY STANDARDS BOARD

WEQ and WGQ E-Tariff Subcommittee Meeting

January 23, 2008 – 9:00 AM to 5:00 PM Mountain

January 24, 2008 – 9:00 AM to 5:00 PM Mountain

January 25, 2008 – 9:00 AM to 5:00 PM Mountain

Hosted by El Paso Western Pipeline – Colorado Springs, CO

Draft Minutes

1. Welcome and Administrative Items

Mr. Sappenfield and Ms. Daly welcomed the meeting participants in the room and on the phone. Mr. Sappenfield thanked El Paso Western Pipeline for hosting the meeting. Mr. Booe read the antitrust guidelines. The participants reviewed the agenda. Ms. Davis suggested that the group add the adoption of the January 8, 2008 meeting minutes to the agenda. Ms. Mespelli asked that the National Grid presentation on shared and joint filing rights be moved to agenda item three. Ms. Davis moved, seconded by Ms. Key, to adopt the agenda with the suggested revisions. The motion passed without objection. Mr. Sappenfield reviewed the NAESB standards approval process, and noted that the goal of the three day meeting is to vote the recommendation out of the subcommittee.

The subcommittee reviewed the minutes from the October 11-12, 2008 meeting. Ms. Davis submitted redlined minutes posted as a work paper for this meeting: Proposed Changes to the October 11-12, 2007 eTariff Draft Minutes - Submitted by D.Davis, Williams - Redlined. Ms. Davis moved, seconded by Ms. Van Pelt, to adopt the minutes as redlined by Ms. Davis. The final minutes are posted on the e-Tariff page: http://naesb.org/pdf3/etariff101107fm.doc.

The subcommittee also reviewed the minutes from the January 8, 2008 e-Tariff Technical Task Force conference call. A minor modification was made to the draft version of the minutes. Ms. Davis moved, seconded by Ms. Van Pelt, to adopt the minutes as revised. The final minutes are posted on the e-Tariff page: http://naesb.org/pdf3/etariff_ttf010808fm.doc.

2. Update from e-Tariff Technical Task Force

Mr. Burden provided an update of the progress of the e-Tariff Technical Task Force (eTTF). Since the last business group meeting, the eTTF developed a list of use cases for the implementation guide, and reviewed the nullable characters in the xml schema and tibp manual with the FERC staff. Mr. Burden reviewed the modifications made to the implementation guide based upon the eTTF meetings and stated that the guide was posted for an informal comment period beginning on December 14, 2007 and ending January 16, 2008.

3. Review Comments Submitted in Response to Corrected e-Tariff Technical Task Force Memo to e-Tariff Subcommittee, List of Open Business Issues, and Draft Implementation Guide.

The subcommittee reviewed the comments submitted in response to the Corrected e-Tariff Technical Task Force Memo to e-Tariff Subcommittee, List of Open Business Issues, and Draft Implementation Guide posted by the eTTF on December 14, 2007.

Electric Comments

Executive Summary

Ms. Daly suggested that the subcommittee review the Revised Electric Comments on the Guide first, as they are the most voluminous. The participants reviewed the proposed modifications to the Executive Summary. Ms. Davis initiated discussion by stating that she opposes replacing the term “tariff” with “Jurisdictional Documents” and noted that other gas standards reference “tariff” in the same context as the implementation guide. In response, Mr. Bartholomot stated that the term “Jurisdictional Documents” was suggested to make clear that “tariff” is an all inclusive term describing a single tariff, rate schedule, or service agreement. Ms. Daly confirmed that “Jurisdictional Documents” references all documents filed with the FERC. The participants agreed to return to the issue and the Executive Summary after addressing the proposed modifications to the definition section of the guide.

Definitions

Tariff Submitter

Ms. Daly reviewed the proposed modification to the definition of “Tariff Submitter”:

Tariff Submitter is the term used to describe any entity that is required to submit Tariff Filings pursuant to Title 18 Code of Federal Regulations Parts 35, 154, 284, 300, 341 or other Parts as required by the Federal Energy Regulatory Commission.

The participants agreed to remove the C.F.R. reference.

Tariff Filing

Ms. Daly reviewed the proposed modifications to the term “Tariff Filing”.

Tariff Filing is the term used to describe a compilation of Data Elements of all (documentTariff Record(s), associated data, and supporting documents, etc.) that areis required to be filed by a Tariff Submitter pursuant to Title 18 Code of Federal Regulations Parts 35, 154, 284, 300, 341 or other Parts as required by the Federal Energy Regulatory Commission

Ms. Davis opposed the inclusion of the defined term “Data Elements” in the definition. Ms. Key stated that the term “Data Elements” needs to be defined because it is pervasive through the guide and is meaningless for those that have not read a NAESB standard. Ms. Van Pelt stated that the “data elements” are already defined in the data tables of the guide and that another definition is unnecessary. The participants discussed the hierarchy of Tariff Filings, Tariff Filing Attachments, and Tariff Records and how data elements are used at all three levels of the structure. After further discussion, the participants decided not to accept the proposed modifications.

Tariff Record

Ms. Key reviewed the proposed modifications to the definition and proposed some alternate language:

Tariff Record is a term used to describe a compilation of Data Elements associated with a sheet, a section)s), or a complete Jurisdictional Document filed with the Federal Energy Regulatory Commission

Ms. Daly suggested that the term “Jurisdictional Document” be removed. The participants agreed and made a few other modifications to the language of the proposed definition. The group came to consensus on the following definition:

Tariff Record is the term used to describe a compilation of data elements associated with a sheet, section, or whole document that is filed with the Federal Energy Regulatory Commission

Jurisdictional Document

The participants decided to skip ahead to the proposed term “Jurisdictional Document”, as it is used in several of the proposed definitions. Mr. Spangler reviewed the definition and asked someone to explain the rationale behind its addition. Ms. Key stated that the term needs to be included to distinguish the large set of documents that are submitted with a tariff filing from those documents which are statutory. The participants discussed various ways to make the distinction. Ms. Bradford suggested defining what exactly goes into a tariff record and including that in the definition. She stated that a tariff record represents a single tariff, rate schedule, or service agreement. The participants supported the suggestion and the definition was modified to reflect the suggestion:

Tariff Record is the term used to describe the part of a Tariff Filing that consists of the data elements that relate to a sheet, section, or entire tariff, rate schedule, or service agreement that is required to be filed with the Federal Energy Regulatory Commission.

Sheet Based Format

After reviewing the proposed definition of “Sheet Based Format”, Ms. Daly offered an alternate definition. Mr. Spangler proposed the following as a slightly modified version of Ms. Daly’s definition:

Sheet-Based Format and Section-Based Format are the terms used to describe the subdivision into sheets or sections, respectively, of a tariff, rate schedule, or service agreement for purposes of a Tariff Filing.

The participants approved of Mr. Spangler’s proposal.

Whole Document Format

Mr. Sappenfield proposed the following definition for “Whole Document Format”:

Whole Document Format is the term used to describe tariff, rate schedule, or service agreement submitted as a single document with a Tariff Record

Ms. Myers suggested that the language “for purposes of a Tariff Filing” be added to the end of the sentence. The participants approved of the addition and the definition.

Tariff

Ms. Daly reviewed the proposed definition of “Tariff”. Ms. Davis stated that the definition was included initially so that it was clear that the standard was being referenced. Mr. Bartholomot noted that all six of the definitions discussed relate to the standards, and suggested that the definition be removed. Ms. Davis stated that the definition could be removed and that it was only included for clarification. Ms. Myers noted that the term “Tariff” rather than “tariff” is used in the current standard and robustly throughout the guide. The group undertook to change all instances of “Tariff” to “tariff” while reviewing the standard and guide.

The participants reviewed the remaining proposed terms D7 through D13 and determined that they were unnecessary as they are sufficiently defined in the Implementation Guide.

Standards

The participants reviewed the proposed modifications to the Standard:

NAESB WGQ Standard [x.4.z] / NAESB WEQ Standard [X]. S1 A Tariff Submitter should must upload a Tariff Filing (or components of a Tariff Filing and corresponding revisions), using one of the following methods for structuring the Tariff Records: (i) a Sheet-basedSheet-Based Format, (ii) Section-basedSection-Based Format or (iii) Whole Document Format for the Tariff Record(s), pursuant to the requirements as set forth in NAESB WGQ Standard [x.4.z] / NAESB WEQ Standard [X].this implementation guide.

Ms. Davis suggested that the standard be structured differently, making it easier to read. She suggested that (i), (ii), (iii) be ordered under the standard. She also noted that the word “must” is not used in NAESB Standards. Ms. Van Pelt suggested that “for the Tariff Record(s)” be removed after (iii).

Ms. Nagle suggested that the standard specify that it applies only to an electric tariff filing rather to all tariff filings. Mr. Spangler responded that the use of the defined term Tariff Filing in the Standard narrows the standard to electronically filed tariff. Ms. Daly stated that she supports the idea of specifically noting the Standard applies to an electronic filing and suggested adding such language. Ms. Van Pelt suggested moving the cite at the end of the standard to the top of the standard.

Mr. Peirce stated that the addition of “one of the following methods for structuring the Tariff Records” language is misleading because any of the methods can be used. Ms. Daly suggested modifying the language to read “one or more of the following methods”. After further discussion Ms. Davis proposed the following to the group:

S1 A Tariff Submitter should electronically submit a Tariff Filing pursuant to the requirements as set forth in NAESB WGQ Standard [x.4.z] / NAESB WEQ Standard [X].

S2 For the electronic submission of a Tariff Filing, a tariff, rate schedule, or service agreement, and changes thereto, should be structured using one or more of the following methods:

(i)  Sheet-Based Format,

(ii)  Section-Based Format, or

(iii)  Whole Document Format

The participants approved of Ms. Davis’s proposed standards language.

General Purpose

Next, the participants reviewed the suggested modifications to the General Purpose Section of the Implementation Guide. Ms. Key stated that the suggested modifications may not coincide with the decisions made thus far. Ms. Davis stated that a majority of what was struck in the comments was the explanation of the e-Tariff data set requested by the electric participants. Ms. Davis suggested striking the modifications made in the comments and starting over. The participants decided to work through the comments rather than starting over as Ms. Davis had suggested. Ms. Van Pelt and Ms. Davis explained how data sets are differentiated from standards and how they are numbered. The participants went through the language and made modifications based upon the changes made to the definitions and the suggestions of the group. The term “Jurisdictional Documents” was changed to “tariff(s), rate schedule(s), and service agreement(s)” or “databases” when the context so required.

Ms. Key stated that the additional paragraphs included in the General Purpose section introduce new concepts that the group needs to discuss. The new concepts concern the granularity of the Tariff Record and baseline information compliance. She stated that the FERC staff has appeared amenable to the concepts explained in the paragraphs and that including the issues in the guide is important for gaining WEQ support. Ms. Daly stated that a comment would be a more appropriate method of passing the concepts on to the Executive Committees. Mr. Sappenfield noted that the comment process to the Executive Committee is an open process and that all comments are included in the FERC filing. The participants discussed whether to remove the language from the General Purpose section and include it in comments to the Executive Committees or to put it elsewhere in the Implementation Guide. The FERC staff reassured the participants that the concepts had been discussed by the staff members and that they were not opposed to them. Mr. Hairston asked if he could vote to approve the standard and note that it was based upon the representations made by FERC. Mr. Sappenfield stated that the vote on the standard can not be made contingent on anything and that issues outside of the standard should be included in comments. After much discussion, the participants agreed to remove the additional language from the guide and include it in comments to the Executive Committees if so desired.

e-Tariff Filings Process Flow Diagram and Description

Ms. Davis reviewed the Diagram and the comment submitted by MISO concerning the reliability of email. Mr. Goldenburg noted that comment addresses an Order 703 e-Filing issue rather than the draft standard. Mr. Luzeando stated that the comment may be removed. Ms. Myers noted that SOC needs to be defined as the Secretary of the Commission on the diagram. Ms. Davis undertook to make the change offline as the diagram is in a picture format rather than editable text.

The group reviewed the comments on the Process Flow Diagram Description and noted that the comments were FERC issues rather than items that can be addressed by the subcommittee. The comments were removed and the references to “Tariff(s)” were changed to “database(s)” and references to “Jurisdictional Document” were changed to “tariff, rate schedule, or service agreement” to reflect the previous discussion and modifications. Mr. Bartholomot stated that he does not understand the intent of the bracketed language in Note 1. Mr. Burden stated that it was included to signal FERC staff to the security issues. The participants decided to remove the bracketed language.