OASIS Method Criteria and Process BP Draft 10 24 08 by w93zRS

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									                OASIS Business Practice –NorthWestern Energy’s Local Attachment K




                 OASIS Attachment K Business Practice


                            FERC Order 890
                      NWE Local Transmission Planning
                              Attachment K

   If there is any difference between this Business Practice and the Tariff, the Tariff is correct.




                                         SUBMISSION OF COMMENTS
     NorthWestern Energy will consider written comments from stakeholders on the this
      Attachment K Business Practice. Written comments may be emailed or faxed to
                           NorthWestern Energy as follows:

                                                  John Leland
                                   Electric Transmission Planning Manager
                                             NorthWestern Energy
                                        john.leland@northwestern.com
                                              Fax: (406) 497-3393



Effective Date
         From: December 7, 2007


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                OASIS Business Practice –NorthWestern Energy’s Local Attachment K
         To:       ____________________




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                   OASIS Business Practice –NorthWestern Energy’s Local Attachment K



Table of Contents

Preamble ....................................................................................................................................... 68
   Introduction ............................................................................................................................... 79
   Principle 1 – Coordination ...................................................................................................... 911
       FERC Order Requirement Summary .................................................................................. 911
       Coordination, Generally...................................................................................................... 911
       NWE Stakeholder Coordination ......................................................................................... 911
       NWE OASIS Website ......................................................................................................... 911
       Stakeholder Involvement Simplified .................................................................................. 911
       NWE Contact Information ................................................................................................ 1012
       Comparable Stakeholder Involvement.............................................................................. 1012
       Types of Planning Meetings ............................................................................................. 1012
       Meeting Information ......................................................................................................... 1113
       Announcements and Communications: ............................................................................ 1214
       Coordination of Study Results From Local Transmission Plan, Generation Interconnection
       Studies, Planning and Economic Studies .......................................................................... 1214
       Sub-Regional/Regional Coordination ............................................................................... 1315
   Principle 2 – Openness.......................................................................................................... 1416
       FERC Order Requirement Summary ................................................................................ 1416
       NWE’s Open Planning Process ........................................................................................ 1416
       Public Meetings ................................................................................................................ 1416
       Standards of Conduct and Critical Energy Information ................................................... 1416
       Confidentiality .................................................................................................................. 1416
       Sub-Regional and Regional Planning ............................................................................... 1517
   Principle 3 – Transparency ................................................................................................... 1618
       FERC Order Requirement Summary ................................................................................ 1618
       Technical Analyses Transparency .................................................................................... 1618
       Consistent Application ...................................................................................................... 1719

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                 OASIS Business Practice –NorthWestern Energy’s Local Attachment K
      Data Access ....................................................................................................................... 1719
      Opportunity For Review and Comment ............................................................................ 1719
      Replication of Planning Studies ........................................................................................ 1819
      Sub-Regional/Regional Transparency .............................................................................. 1820
   Principle 4 - Information Exchange ...................................................................................... 1921
      FERC Order Requirement Summary ................................................................................ 1921
      Information Request.......................................................................................................... 1921
      Schedule ............................................................................................................................ 2022
      Procedure For Data Submission........................................................................................ 2022
      Data Use In Planning Process ........................................................................................... 2022
      Confidentiality .................................................................................................................. 2022
      Customer Responsibility ................................................................................................... 2123
   Principle 5 – Comparability .................................................................................................. 2224
      FERC Order Requirement Summary ................................................................................ 2224
      Ensuring Comparability .................................................................................................... 2224
   Principle 6 - Dispute Resolution ........................................................................................... 2325
      FERC Order Requirement Summary ................................................................................ 2325
      NWE Dispute Resolution.................................................................................................. 2325
      Sub-Regional and Regional Dispute Resolution............................................................... 2426
   Principle 7 - Regional Participation ...................................................................................... 2527
      FERC Order Requirement Summary ................................................................................ 2527
      Sub-Regional Participation ............................................................................................... 2527
      Sub-Regional Plan and Data Coordination ....................................................................... 2628
      Regional Participation....................................................................................................... 2628
      NWE and Sub-Regional Planning Process Differences.................................................... 2628
      Simultaneous Plan Feasibility ........................................................................................... 2729
   Principle 8 - Economic Planning Studies.............................................................................. 2830
      FERC Order Requirement Summary ................................................................................ 2830
      High-Priority Study Requests ........................................................................................... 2931
      Requesting A High-Priority Economic Planning Study ................................................... 2931


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                 OASIS Business Practice –NorthWestern Energy’s Local Attachment K
      Valid NWE Request .......................................................................................................... 2931
      Economic Planning Study Classification .......................................................................... 2931
      Number of NWE High-Priority Studies............................................................................ 2931
      Prioritizing NWE Economic Study Requests ................................................................... 3031
      Clustering Study Requests ................................................................................................ 3032
      NWE Economic Planning Study....................................................................................... 3133
      Customer’s Obligation To Share Data .............................................................................. 3234
      NWE Obligation ............................................................................................................... 3234
      Cost to Conduct NWE’s Two High Priority Economic Studies ....................................... 3334
      NWE Economic Planning Study Timeline and Process ................................................... 3435
      Additional Local Economic Studies ................................................................................. 3536
      Process for Additional Economic Planning Studies ......................................................... 3536
      Sub-Regional Economic Study Coordination ................................................................... 3637
      Economic Planning Study Posting .................................................................................... 3637
   Principle 9 - Cost Allocation for New Projects ........................................................................ 38
      FERC Order Requirement Summary .................................................................................... 38
      Projects Not Covered Under Existing Cost Allocation Rules .............................................. 38
      NWE Cost Allocation Methodology Projects Outside the OATT ........................................ 39
      Sub-Regional and Regional Cost Allocation ........................................................................ 40
   Recovery of Planning Costs ...................................................................................................... 41




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                OASIS Business Practice –NorthWestern Energy’s Local Attachment K

Preamble
The Federal Energy Regulatory Commission (FERC) issued its Order No. 890 on February 16,
2007 (Order). The Order provided amendments to the regulations and the pro forma Open
Access Transmission Tariff (OATT) adopted in Orders 888 and 889. The Order became
effective May 14, 2007, which is 60 days following the date the Order was published in the
Federal Register. One objective of the Order is to limit undue discrimination in planning the
transmission system by requiring coordinated, open, and transparent transmission planning on
both a local and regional level and by involving stakeholders in the early stages of transmission
planning. FERC outlined the need for reform in transmission planning through Order No. 890.
Accordingly, each public utility transmission provider is required to submit, as part of a
compliance filing, a proposal for a planning process that complies with the planning principles
and other requirements in the Order. The Order requires a more inclusive transmission planning
process incorporating the following nine principles: (1) Coordination, (2) Openness, (3)
Transparency, (4) Information exchange, (5) Comparability, (6) Dispute resolution, (7) Regional
participation, (8) Economic planning studies, and (9) Cost allocation for new projects. This
Business Practice provides a discussion on these 9 principles.
The URL address to access NWE’s Attachment K and the various documents and business
practices discussed in this document are identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.




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Introduction

    1. NorthWestern Energy (“NWE”), with input from stakeholders, developed the nine
       principles of NWE’s Attachment K Business Practice (“Business Practice”). This
       Business Practice and its supporting documents and business practices can be obtained on
       NWE’s OASIS website by following at “http:/www.oatioasis.com/NWMT/Transmission
       Planning/”.the URL address identified in
       http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.
       doc.

The NWE local transmission system provides regulated electric transmission services to
approximately 295,000 electric customers. Figure 1Figure 1Figure 1Figure 1Figure 1, below,
provides a graphical overview of NWE’s transmission system. NWE’s electric transmission
system consists of over 7,000 miles of transmission lines and associated terminal facilities. This
system, with voltage levels ranging from 50,000 to 500,000 volts, serves an area of 97,540
square miles, which is equivalent to two-thirds of Montana. The system has interconnections to
five major transmission systems1 located in the Western Electricity Coordinating Council
(WECC) area and Mid-Continent Area Power Pool (MAPP) region through WAPA’s DC
interconnection. NWE is registered as a Balancing Authority, Planning Authority and
Transmission Planner. NWE does not currently own generation used to serve retail customer
load.

The URL address to the various documents and business practices discussed in this document
and in NWE Attachment K are identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.




1
 The five interconnected systems are Idaho Power Company, Avista Corporation, Bonneville Power
Administration, WAPA and PacifiCorp.

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                                         Figure 1: NWE Local Transmission System
                                                                            Peace
                                                                            River
                                                       British
                                                                                                Alberta
                                                    Columbia



                                                                                                         Canada
                                                                 Seattle

                                         Portland           Washington
                                           Area                                                           Montana
                                                                   Celilo
                                      Pacific                                                                      Colstrip
                                                Oregon
                                      Ocean
                                                                                     Idaho
                                                    Malin
                                                                                     Midpoint
                                                                                                               Wyoming
                                                                                                 Borah
                                                      Round
                                                     Mountain
                                                                                                              Jim   Laramie
                                                                    Nevada               Salt Lake          Bridger River

                              San Francisco                                              City Area
                                       Area                                                                        Denver
                                                                     Las                         Utah               Area
                                                                    Vegas
                                                                    Area                           Four
                                                        California                                                Colorado
                                                                            Market              Corners
                                                                            Place                                  New
                                                 Los                                                              Mexico
                                                Angeles
                                                 Area                                                     Albuquerque
                                                                                        Phoenix
                                                                                         Area
                                                                                         Arizona
                                          San Diego
                                                                                      Tucson
                                                                  Mexico               Area                  El Paso




The following Attachment K Business Practice was developed in collaboration with interested
stakeholders in an open, transparent forum.




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Principle 1 – Coordination

FERC Order Requirement Summary
The Commission Determination is found within paragraphs 451 – 454 of the Order. The
Coordination principle requires appropriate lines of communications among transmission
providers, transmission-providing neighbors, State authorities, customers, and other
stakeholders. Transmission providers are allowed to craft coordination requirements that work
for those providers, their customers and stakeholders.
Coordination, Generally
NWE’s local transmission system plantransmission plan (or LTP) will be coordinated in two
ways. First, during the development stage of the local transmission system plantransmission
plan, NWE will have an open public process to allow two-way communication with stakeholders
and interested parties. Second, NWE’s local transmission plan will be coordinated with the
Northern Tier Transmission Group’s (“NTTG”) sub-regional planning and the Western
Electricity Coordinating Council’s (“WECC”) regional planning organizations. See the URL
address for “Transmission Planning Guidance Document” and other documents and business
practices identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
NWE Stakeholder Coordination
NWE’s local transmission system plantransmission plan planning coordination is an open public
process that allows and promotes customers, interconnected neighbors, regulatory and state
bodies and other stakeholder participation in a coordinated nondiscriminatory process for local
transmission system plantransmission plan development. To accomplish this coordination, NWE
will have an open meeting policy and a transparent process that will afford stakeholders an
opportunity to regularly meet with NWE and to provide input on content, methodology, process
and other elements used in the development of NWE’s transmission plan. Furthermore, NWE
has a permanent planning committee called the Transmission Advisory Committee
(“TRANSAC”) that will be involved in developing the local transmission system
plantransmission plan.
NWE OASIS Website
NWE’s OASIS website can be accessed through is
http:/www.oatioasis.com/NWMT/Transmission Planningthe/. URL address identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Stakeholder Involvement Simplified
To simplify stakeholder involvement and understanding of NWE’s planning process, NWE
Transmission Planning has an area on NWE’s OASIS website dedicated to Transmission
Planningtransmission planning . The URL addresses for this website area can be found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
On this website, stakeholders can learn about NWE planning activities including:


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         Past meeting information and minutes,
         Future meeting announcements,
         Review NWE calendar of events and the study cycle,
         Review reports and meeting material, and
         Obtain NWE contact information.


A list of Frequently Asked Questions is also posted on NWE OASIS website to simplify
stakeholder understanding of NWE’s local area planning process. NWE’s OASIS website can
be accessed through the URL address identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
NWE Contact Information
Interested parties can provide comment or contact NWE directly by following the directions
provided in the “How To Contact Transmission Planning” folder on NWE’s OASIS website.
NWE’s OASIS website can be accessed through the URL address identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Comparable Stakeholder Involvement
NWE will make its stakeholder meetings open to the public, except when Standards of Conduct
(SOC) concerns require portions of the meeting to be closed to some participants. NWE’s open
process will allow participation by stakeholders, including, but not limited to, the Montana
Public Service Commission, the Montana Consumer Council, transmission customers (network
and point-to-point), generators, cooperatives, interconnecting utilities, the Governors Office,
transmission-providing neighbors and other stakeholders.
Types of Planning Meetings
NWE will have two types of planning meetings to involve stakeholders in the planning process
and to facilitate and coordinate stakeholder input and involvement in NWE local transmission
system plantransmission plan planning. These planning meetings are the Transmission Advisory
Committee (“TRANSAC”) meetings and Open Public meetings.
TRANSAC Meeting: TRANSAC will be engaged in the various stages of developing NWE’s
local transmission system plantransmission plan. The Access to TRANSAC Charter can be is
posted on NWE’s websiteachieved through the URL address identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
The purpose of this advisory committee will be to provide input to NWE on its local
transmission system plantransmission plan. TRANSAC will not make decisions or implement
the plan. The ultimate responsibility for the transmission plan will remain with NWE.
TRANSAC membership is open to anyone and will be established through self-nomination. If
the membership is either too small or too large, NWE will work with the committee to determine
whether adjusting the size is appropriate and, if so, what mechanism should be used to
accomplish the adjustment. NWE will encourage membership from neighboring transmission
providers, affected state authorities, regulators, customers and other stakeholders.

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All TRANSAC meetings will be open to the public and will allow open and transparent dialogue
on all aspects of the transmission plan to the maximum extent allowed without violating
Standards of Conduct (“SOC”) information and Critical Energy Infrastructure Information
(“CEII”). Members on this committee will be encouraged to be involved in each meeting and to
be actively engaged in the process.
TRANSAC is a stand-alone committee that will provide input into NWE’s transmission plan.
TRANSAC may determine that it needs to form a sub-committee to address a specific issue or
task. Participation on this sub-committee will be open to anyone. The responsibilities of the
sub-committee and its structure will be determined by TRANSAC. If a sub-committee is to be
formed, NWE will consult with TRANSAC before formation and an announcement of the
formation of the sub-committee, its responsibilities and who to contact for more information or
to join will be posted on the Transmission Planning portion of NWE’s OASIS website.
Open Public Meeting: NWE will hold open public meetings to allow a two-way communication
on NWE’s transmission plan. Open public meetings will be scheduled by TRANSAC.
Meeting Information
The number of meetings, scope, notice requirements, and the format for these two types of
meetings is described below.
Number of Meetings:
TRANSAC: TRANSAC will meet regularly in an open forum. NWE will encourage TRANSAC
to meet as often as needed to provide meaningful input into NWE’s transmission plan
development. NWE would anticipate that TRANSAC will meet at least quarterly.
Open Public Meeting: NWE will work with TRANSAC to schedule and hold open public
meetings that will be designed to communicate information about its transmission plan and to
receive input on its transmission plan. TRANSAC may adjust the number of public meetings as
needed, but NWE anticipates one or two meetings per year.
Scope of Meetings:
The meetings will be open to discuss non-confidential aspects of transmission planning activities
including, but not limited to methodology, study inputs, criteria, and study process and results.
The intent is to provide a forum that allows stakeholders to have meaningful input into NWE’s
transmission plan development. Dissemination of market sensitive information or critical
infrastructure information must follow FERC Standards Of Conduct (SOC) requirements and
Critical Energy Infrastructure Information (CEII) requirements.
Notice:
TRANSAC: There will be two forms of meeting notice: (1) A list of participants (name,
organization, phone and email) will be maintained and notice for each meeting will be provided
to prior participants by email; (2) Notice of a TRANSAC meeting will be posted on NWE’s
OASIS website no later than fourteen (14) calendar days prior to the meeting and the available
meeting material will be distributed at least two (2) business days prior to the meeting. Any
additional meeting material presented during the TRANSAC meeting will be posted on NWE’s
OASIS website. The Transmission Planning section of NWE’s OASIS website will include a
“Calendarcalendar of eEvents and sStudy cCycle” (“Calendar”) document. Access to this

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                       OASIS Business Practice –NorthWestern Energy’s Local Attachment K
calendar can be achieved through the URL address identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Open Public Meeting: : There NWE will use, as appropriate, three forms of meeting notice: (1)
A list of participants (name, organization, phone and email) from prior open public meetings will
be maintained and meeting notices will be provided to prior participants by email or by mail if
email is not available; (2) Local media (radio, newspaper, etc) may be used as appropriate to
announce the open public meetings; (3) Notice of an open public meeting will be posted on
NWE’s OASIS website at least thirty (30) calendar days prior to the meeting.
Format:
NWE will retain a neutral moderator to help plan and moderate the meetings. These meetings
will be designed to provide opportunities for information exchange about NWE’s transmission
plans, methodology and processes. Notes taken at the meetings and other information from the
meetings will be posted on NWE’s OASIS website.
TRANSAC: TRANSAC meetings will be held either face-to-face or by conference call. The
face-to-face meetings will also include a phone connection and a web conference service for
those who cannot attend in person.
Open Public Meeting: The Open Public Meeting will be a face-to-face meeting between NWE
and the public.
Announcements and Communications:
Announcements and communications will be posted under the Transmission Planning folders on
NWE’s OASIS website. Information regarding NWE public meetings will be posted and
emailed to interested parties as described under the Notice discussion above.
Coordination of Study Results From Local Transmission Plan, Interconnection
Studies, Transmission Service and Economic Studies
The Local Transmission Plan study (for retail load service), Interconnection study, Transmission
Service study and the Economic Planning study (for customer economic study request studies
described below) are distinct and separate studies. They examine the transmission system for
different purposes and from different perspectives (reliability evaluation vs. economic dispatch
evaluation). Even though these studies are distinct and separate, the applicable study results
from each study will be made available to the other study for consideration.                                                     Field Code Changed



                                                                Sharing Study Result
     Trans Svc &                                       Local Transmission Plan                  Economic Planning Study
     Interconnect
                                                            Prior Cycle Results                    Prior Year Results
      Q1                                               Data Collect, Goal & Scenario                  Receive Requests
                                  Sys Planning Cycle
             Interconnect & TSR




                                                                                       Year 1




      Q2                                                   Base Case Develop                       Prioritize & Begin Study
                Study Results




      Q3                                                  Q3-6 Technical Study                               Study
      Q4                                                                                            Finish Study & Report
      Q5                                                     Q5 Data Collect                          Receive Requests
                                                                                       Year 2




      Q6                                                                                           Prioritize & Begin Study
      Q7                                                        Decision                                     Study
      Q8                                                        Reporting                           Finish Study & Report

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Figure 2: Sharing System and Economic Study Results

Proposed new interconnection (i.e., generation resource, transmission project, or new large load)
or request for transmission service may be coordinated into the Local Transmission Plan during
Q1 and Q5 if 1) there is a signed agreement in place, or 2) it is included in the WECC base case,
or 3) TRANSAC requests including it in the Local Transmission Plan.
A proposed new generation project and an existing generation upgrade are generally reported to
WECC for inclusion in the WECC base case when the proposed project has a signed
interconnection agreement. A proposed new major transmission line will be included in the
WECC base case when the project is in Phase 2 of the WECC Path Rating Process. A request
for transmission service will be coordinated into the Local Transmission Plan study base case
when there is a signed agreement.


Sub-Regional/Regional Coordination
NWE is a member and actively engaged in the Northern Tier Transmission Group (“NTTG”),
which is a permanent planning committee. NWE will coordinate its biannual transmission plan
with NTTG and with other planning entities as required. NTTG has participation of state
commissions, including the Montana PSC. NTTG will coordinate its planning proposals with
WECC and other sub-regional planning groups (e.g., Northwest Power Pool (“NWPP”),
ColumbiaGrid, WestConnect, etc.). NTTG is an open stakeholder process that has formal
stakeholder meetings. Addition information can be found in the “Transmission Planning
Guidance Document”, which can accessed through the URL address identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.




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Principle 2 – Openness

FERC Order Requirement Summary
The Commission Determination is found within paragraph 460 of the Order. The Openness
principle requires that Transmission planning meetings are open to all affected parties, including
all transmission and interconnection customers, state commissions and other stakeholders. If
subgroups are used, the overall transmission plan and planning process must remain open.
NWE’s local transmission system plantransmission plan will be open to all stakeholders and
interested individuals to provide comments and input in the development of NWE’s transmission
system plantransmission plan. These principles are described below.
                                                           Figure 3: Planning Process

NWE’s Open Planning Process                                                     Overview
NWE’s local transmission system                                Local Transmission System Planning Process
plantransmission plan process will be
                                             1. Goal & Scenario
open to all stakeholders. Stakeholders
will have the opportunity through
TRANSAC to review and comment on                                                NWE
                                             2. Technical Study
                                                                            Transmission
NWE’s local transmission plan
                                                                              Advisory
throughout the development of the plan.
                                                                             Committee
See Figure 3: Planning ProcessFigure 3:           3. Decision
                                                                            Input to Plan
Planning ProcessFigure 3: Planning
ProcessFigure 3: Planning ProcessFigure
                                                 4. Reporting
3: Planning Process to the right. This
process is also described in Principle 3 of
this document.- Transparency and the “Local Transmission System Planning Discussion”
document that is posted on NWE’s OASIS under the Transmission Planning tab.
Public Meetings
NWE’s TRANSAC and the Open Public Meetings will be open to public participation and input.
These meetings will be designed to foster an open transparent two-way communication between
NWE and its stakeholders and affected parties
Standards of Conduct and Critical Energy Information
Protection of Critical Energy Infrastructure Information (CEII) and market sensitive information
covered by FERC Standards Of Conduct (SOC) will be observed. NWE’s Anti Trust and SOC
documents are posted on NWE’s OASIS website .
Confidentiality
Access to confidential data by a stakeholder will require a confidentiality agreement. There are
two confidentiality agreements that apply – NWE confidentiality agreement for NWE
confidential data and a WECC confidentiality agreement for confidential WECC base case data.


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                   Access to NWE confidential data will require signing NWE’s confidentiality
                    agreement. A copy of NWE’s confidentiality agreement has been developed and
                    posted on NWE’s OASIS website as identified in .
                    http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice
                    _Links.doc. Stakeholders shall have an opportunity to submit comments on the
                    form of confidentiality agreement. Confidential information shall be provided
                    only to those participants in the planning process that require such information
                    and that execute the confidentiality agreement; provided, however, any such
                    information may be supplied to (i) federal, state or local regulatory authorities that
                    request such information and protect such information subject to non-disclosure
                    regulations, or (ii) upon order of a court of competent jurisdiction.
                   Access to WECC load and resource data and WECC base case data will require
                    signing a WECC confidentiality agreement. A confidentiality agreement is not
                    required for WECC members to obtain access to base case data. A copy of the
                    WECC non-member confidentiality agreement is posted in NWE’s OASIS
                    website. A copy of WECC’s confidentiality agreement is available through the
                    ULR found in
                    http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice
                    _Links.doc.
NWE will apply equal protection to NWE confidential information and to confidential
information received from customers. In the event that a party claims that their planning-related
information is confidential, any party seeking access to such information must agree to adhere to
the terms of a confidentiality agreement.
It is recognized that certain data may not be available to certain participants, even though a
confidentiality agreement is signed, due to their relationship to the market.
Disclosure of confidential data to state commissions, FERC and other regulatory bodies will be
governed by the appropriate protective order. Before confidential data is released to regulating
bodies, NWE will seek protection of that data through a protective order.
Access to confidential information through NWE’s OASIS website will be protected by
controlling access to the information. On NWE’s OASIS website, a button under the
Transmission Planning tab is the gateway to a password-protected site on NWE’s computer.
Access to confidential information must be approved by NWE and anyone who is granted access
will receive a login ID and a password from NWE.
Sub-Regional and Regional Planning
With respect to sub-regional and regional planning entity openness, NWE will coordinate and
provide NTTG, WECC and other planning entities with NWE’s local transmission system
plantransmission plan, associated assumptions and other information as requested. Confidential
data will be protected through NWE confidentially requirements and/or the confidentiality
requirements of the sub-regional and regional entities.




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Principle 3 – Transparency

FERC Order Requirement Summary
The Commission Determination is found within paragraphs 471-479 of the Order. The
Transparency principle requires disclosure of basic methodology, criteria, assumptions, process
and data that underlie transmission system plantransmission plans. Methodologies, criteria and
processes must be published and consistently applied. The Standards of Conduct (SOC)
compliance to the release of certain information is critical.


NWE will disclose its basic methodology, criteria, process and data used to develop its local
transmission system plantransmission plan. NWE’s written document,
OASIS_Method_Criteria_and _Process_Business_Practice NWE Local Transmission System
Planning Discussion, describing its electric transmission system planning basic methodology,
criteria and process is posted on NWE’s website. Access to this document is available through
the ULR found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Also seeSee Principle 7 in this document for additional discussion. A discussion document on
the regional, sub-regional and local plan and data coordination is located under the
“Transmission Planning Guidance Document” section in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc. -
Regional Participation, and Appendices 1 and 2 for regional and sub-regional transparency.
As described in the Local System Planning Discussion document, NWE’s local transmission
system plantransmission plan will cover a fifteen (15) year time period and will be completed
every two years.
To keep NWE process transparent, NWE has developed and will update as needed a list of
frequently asked questions. See the list of Frequently Asked Questions that is posted on NWE
OASIS website (http:/www.oatioasis.com/NWMT/Transmission Planning/).at the URL address
identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Technical Analyses Transparency
NWE’s Local Transmission System Planlocal transmission plan2 technical analyses will use
different engineering studies to evaluate the system performance. Transparency of the technical
analysis is important and will be achieved through communications with TRANSAC. The
technical studies are designed to use different engineering perspectives to ensure system
reliability is maintained. These methods will include, but are not limited to, the following types
of analyses.
   Steady-State Powerflow Analyses


2
  These studies are for expansion planning within NWE’s balancing area. For sub-regional or regional congestion
studies, See Sections 3 and 4 of NWE’s Attachment Kthe “NTTG Sub-Regional Planning Process (K2)” and the
“WECC Regional Planning Process (K3)” presented in sections II and III below.

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   Post Transient Steady-State Powerflow Analyses (or Steady-State Post Fault Analyses)
   Transient Stability Analyses (or Dynamic Analyses)
   Short Circuit Fault Duty Analyses
   Reactive Margin Analyses


Consistent Application
The Transparency Principle requires a discussion as to “how they treat retail native loads, in
order to ensure that standards are consistently applied.” The openness and transparency of
NWE’s planning process will ensure consistent application of the NWE’s methodology, criteria,
and process to all balancing area customers’ data (i.e., retail, network and point-to-point). All
customers will be treated on an equal and comparable basis using the local transmission system
plantransmission planning process, methodology and criteria described herein. All valid
customer data will be included in the planning analysis without regard to their classification.
Data Access
Interested persons can obtain access to NWE’s data used in the transmission planning process by
contacting NWE directly if this data is not available on NWE OASIS site. NWE’s contact
information is provided in the “How To Contact Transmission Planning” folder on NWE’s
OASIS website identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
(http:/www.oatioasis.com/NWMT/Transmission Planning/). Access to confidential information
will follow the process described in Principle 2, Openness.
Opportunity For Review and Comment
Stakeholders, through the TRANSAC meetings, will have opportunity to review, discuss and
comment on NWE’s methodology, criteria, and assumptions and to propose alternative
mitigation for upgrades that are proposed by NWE.
In addition to the written documentation, NWE will use its planning meetings (i.e., TRANSAC
meetings and the Open Public meetings) to communicate basic information and to receive
comments that may improve the methodology, criteria and process.
Changes or updates to database assumptions used in the local transmission plan development
will be presented to TRANSAC and posted on NWE’s OASIS website. Interested parties can
comment on these changes or updates by participating in TRANSAC or Open Public Meeting or
by contacting NWE directly by email or by letter.
Study results will be presented in a manner that is clear to stakeholders. The local tTransmission
planning report will be designed to provide a clear understanding to stakeholders. NWE will
obtain input from TRANSAC in writing the report.
NWE will take necessary precautions to protect CEII and SOC information using appropriate
mechanisms. See Principle 2 – Openness for additional discussion.



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Replication of Planning Studies
Using appropriate base case data and the PTI PSS/E software, will enable customers,
stakeholders or independent third parties to replicate the results of NWE power-flow planning
studies and associated economic studies. Replication of NWE’s transient stability studies is
possible, but will require NWE’s non-proprietary software that must be used with the PTI PSS/E
model. A confidentiality agreement will be required for stakeholders who are not members of
WECC to obtain WECC base cases. WECC members can obtain the base case powerflow data
directly from WECC.
Sub-Regional/Regional Transparency
In the region, NWE will participate in and rely on transparency of the NTTG and WECC for sub-
regional and regional planning process. The URL addresses for NTTG and WECC documents
can be found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.Se
e the “NTTG Sub-Regional Planning Process (K2)” and the “WECC Regional Planning Process
(K3)” presented in sections II and III, respectively.




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Principle 4 - Information Exchange

FERC Order Requirement Summary
The Commission Determination is found within paragraphs 486-488 of the Order. The
Information Exchange principle requires transmission customers to submit information on
projected load and resources. Network, native load and point-to-point customer’s information is
to be supplied on a comparable basis. Transmission providers must develop guidelines and a
schedule for load data submittals from network and point-to-point customers. The information
collected by transmission providers to provide transmission service to their native load customers
must be transparent, and equivalent information must be provided by transmission customers to
ensure effective planning and comparability.
NWE's guideline and schedule for the exchange of information is as follows.
Information Request
NWE will determine the load and generation information needed from customers that will be
used to meet its transmission planning requirements and to meet NWE’s requirements of FERC
Standards, FERC Order 890 and NWE’s Open Access Transmission Tariff. NWE will tailor its
request for information from Load Serving Entities (“LSE”) and/or customers (e.g., network and
point-to-point) after the annual WECC Loads and Resources data request and the WECC Power
Supply Assessment data request. NWE will augment the WECC data requests with requests for
other transmission planning data as necessary to study the local transmission system. NWE will
gather the following types of data.
   Historical Data: NWE's request will ask for one year of monthly historical energy and peak
    data for the last calendar year.
   Load Forecast Data: NWE will request fifteen (15) years of monthly energy and peak load
    forecast data from network and point-to-point transmission customers.
   Generation Forecast Data: NWE will request fifteen (15) years of data from generators.
    Generators will be asked to provide technical engineering data for their generator and
    interconnection facilities. Data reporting requirements (e.g., monthly energy, peak
    capability, fuel type, etc.) will follow the WECC Loads and Resource Data Request and
    WECC Power Supply Assessment data requirements.
   Other Supply Sources: Transmission Customer shall provide fifteen (15) years of monthly
    energy and peak data for electrical supply sources not from generators including, but not
    limited to, point of receipt and point of delivery
   Demand Response Resource: NWE will ask for demand response resource savings,
    conservation savings, and other customer load reduction alternatives that would reduce or
    alter their load forecast.
   Interruptible and Other: Customers who are on an interruptible load tariff will be asked to
    supply a peak load forecast with and without the interruptible portion of the forecast data
    applied.

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   Number of Years of Data: NWE will request fifteen (15) years of data.
   Type of Peak Load Data: The monthly peak load forecast should be based on an average
    (i.e., 1-in-2 or 50% probability of being exceeded) temperature assumption.
   Peak Load Forecast Temperature Adjustment: NWE will request the temperature adjustment
    methodology to adjust the 1-in-2 winter and summer peak load forecasts to an alternative
    probability assumption (e.g., a 1-in-10 and 1-in-20 temperature probability). The alternative
    to providing this methodology, the MW peak forecast for a 1-in-10 and 1-in-20 methodology
    can be provided.
   Narrative Requirements: NWE may request other information such as:
         1.      Discussion of reasons for significant increases or decreases in load or generation
                    forecast;
         2.      Source and vintage of load forecast and generation resource information;
         3.      Weather station assumptions associated with load forecast
   Comparability: The same type of data request for generator forecast data and load forecast
    data will be sent to generators and customers within NWE’s balancing area.
   Use and Confidentiality: The data received will be used to develop NWE’s transmission plan
    and for reporting purposes. Market sensitive and customer specific data will be confidential.
    Confidential data will be administered according to SOC and CEII requirements.
Schedule
NWE will request forecast data annually during the fall time period (Sep-Dec). This annual
schedule will be coordinated with NWE and NTTG’s biannual transmission planning cycle. The
data collection timeline is linked to the annual WECC Load and Resource Data Request
submission and may be adjusted if WECC changes its data request response time frames. NWE
will provide as much advance notice as possible for changes. The URL address for the “LTP
Study Cycle” can be found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Procedure For Data Submission
NWE will provide an Excel workbook and instructions to the responsible party for the data
collection. This workbook will be sent by email to all of the responsible parties. The URL
address to access an example of the “L&R Data Request” can be found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Data Use In Planning Process
All appropriate customer forecast data will be used in NWE’s database.
Confidentiality
NWE will keep all customer specific data confidential. Critical Energy Infrastructure
Information and WECC base case data are confidential, but can be obtained by signing the
appropriate confidentiality agreement. However, some confidential data may not be available to
marketing entities/individuals because of the market sensitive nature of the information (e.g.,
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generator or line maintenance outages). For additional information also see Principle 2,
Confidentiality section.
Customer Responsibility
Customers will be asked to provide NWE with generation, load forecast, and demand response
resources to the maximum extent practical and consistent with protection of proprietary
information. Customers should also provide timely written (email) notice of material changes to
information previously provided relating to its load, its resources, or other aspects of its facility
or operations affecting NWE’s ability to provide service.




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Principle 5 – Comparability

FERC Order Requirement Summary
The Commission determination is found within paragraphs 494-495 of the Order. The
Comparability principle requires the Transmission Provider to develop a transmission plan, after
considering the data and comments supplied by customers and other stakeholders, that: 1) meets
the specific service requests of its transmission customers; and 2) provides comparable treatment
to similarly situated customers (network and retail native load). Customer demand resources
should be considered on a comparable basis to the service provided by comparable generation
resources.
NWE’s local transmission system plantransmission plan will be developed after considering and
including appropriate comments on the data, process and methodology received from
stakeholders. The customer and generator data will augment and replace, if appropriate, NWE
data used to develop the transmission plan.
Ensuring Comparability
Comparability will be achieved in NWE’s local transmission system plantransmission plan in
developing NWE’s local transmission by including valid data that is received from generators
and customers, as is appropriate and to the extent necessary, in the database used in the reliability
assessment.
Combining the forecast load and generation information received from the customers with
NWE’s transmission line and equipment data for the desired year to be studied develops the base
case used in a technical reliability assessment. The load forecast and/or generation dispatch
patterns are varied independently, within appropriate ranges, to depict a specific operating
condition such as the summer peak period. Varying the load and generation patterns in this
manner causes the flows across the transmission lines to vary. Because this assessment is
reliability3 based which is focused on identifying load and generation dispatch patterns that stress
the system, there is no discrimination to customer type or generation dispatch pattern analyzed.
By following this process the resulting plan will have treated similarly situated customers in a
comparable manner.




3
  Reliability includes adequacy and security considerations. Adequacy evaluates whether or not there is sufficient
transmission capacity to serve the load without violating criteria. Security evaluates whether or not the transmission
system response will meet appropriate criteria (voltage, thermal, frequency, reactive margin, etc.) after a
transmission element(s) becomes unavailable for service (e.g., a forced outage of a transmission line).

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Principle 6 - Dispute Resolution

FERC Order Requirement Summary
The Commission Determination is found within paragraphs 501-503 of the Order. The Dispute
Resolution principle requires an Alternate Dispute Resolution (ADR) process be available to
manage disputes that arise from the planning process. ADR must address both substantive and
procedural planning disputes. Three steps should be included in the ADR process: 1)
Negotiation, 2) Mediation, and 3) Arbitration. Existing ADR procedures can be used.
Several dispute resolution processes exist – NWE's process dispute, sub-regional and regional
dispute.
NWE Dispute Resolution
NWE’s dispute resolution process is provided in the OATT, Attachment K, Section 2.8. The
URL addresses to access NWE’s Attachment K and to other documents and business practices
are identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
1If the dispute arises from NWE’s Local System Planning, Dispute Resolution process set forth            Formatted: Bullets and Numbering
       below will be followed.
        1.1Parties agree to use the following dispute resolution process. The use of this
             process will be limited to general and specific issues arising from NWE’s
             local electric transmission system planning. Disputes in all matters will be
             raised in a timely manner.
                Before filing a complaint directly relating to transmission planning to FERC,
                Parties shall complete the process set forth below:
                    1.1.1Step 1 - Direct negotiation between representatives who have                    Formatted: Bullets and Numbering
                                     authority to settle the controversy and who are at a higher
                                     level of management than the persons with direct
                                     responsibility for the matter.
                    1.1.2Step 2 - If Step 1 is unsuccessful at reaching a consensus agreement
                                      to resolve the dispute, the next step shall be mediation, as
                                      defined in Appendix C of the Western Electricity
                                      Coordinating Council (WECC) bylaws.
                    1.1.3Step 3 - If Step 2 is unsuccessful at reaching mutual agreement
                                      among parties to the dispute, the next step shall be
                                      binding arbitration, as defined in Appendix C of the
                                      Western Electricity Coordinating Council (WECC)
                                      bylaws.
                    1.1.4Step 4 - All negotiations and proceedings pursuant to this process are
                                     confidential and shall be treated as compromise and settlement

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                                          negotiations for purposes of applicable rules of evidence and any
                                          additional confidentiality protections provided by applicable
                                          law.
        1.2The basis of the dispute and final non-confidential decisions will be made available to
             stakeholders upon request.
Sub-Regional and Regional Dispute Resolution
NWE will follow the NTTG sub-regional dispute resolution or the WECC regional dispute
resolution process for sub-regional and regional planning disputes, respectively. See the “NTTG
Sub-Regional Planning Process (K2)” and the “WECC Regional Planning Process (K3)” sections
II and III, respectively.NTTG and WECC dispute resolution processes are provided in NWE’s
OATT, Attachment K, Section 3.5 and 4.5, respectively. The URL addresses to access NWE’s
Attachment K and to other documents and business practices are identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.




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Principle 7 - Regional Participation

FERC Order Requirement Summary
The Commission Determination is found within paragraphs 523-528 of the Order. The Regional
Participation principle requires Transmission Providers to coordinate with interconnected
systems to: 1) share system plans to ensure they are simultaneously feasible and otherwise use
consistent assumptions and data, and 2) identify system enhancements that could relieve
congestion or integrate new resources. The existing regional processes may be used if they are
open and inclusive, address both reliability and economic considerations, and coordinate these
issues across the region. Sub-regions must have adequate scope and coordination.
NWE’s participation in regional and sub-regional planning activities will range from providing
data to providing NWE's local transmission system plantransmission plan to participating in sub-
regional and regional studies and committees. NWE’s electric transmission system data,
assumptions and plan will be shared with interconnected transmission systems, sub-regions and
region entities as required or requested. NWE’s base case data and NWE local transmission
system plantransmission plan will be provided when appropriate and with the confidential data
protected.
Sub-Regional Participation
The URL addresses to access various NTTG sub-regional documents can be found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Also access the “Transmission Planning Guidance Document” within this document to gain an
appreciation of the western system transmission planning road map for customer and stakeholder
participation.
In the sub-regional context, NWE is an active member of the Northern Tier Transmission Group
(“NTTG”). NTTG will develop a coordinated Sub-Regional Transmission Plan and will respond
to requests for Economic Planning Studies.
NWE is a member of NTTG, and uses the NTTG process for sub-regional planning, coordination
with adjacent sub-regional groups and other planning entities, and proposals to WECC
Transmission Expansion Policy and Planning Committee (“WECC TEPPC”) for regional
planning.
The NTTG Planning Agreement and the NTTG Planning Charter govern the relationship
between NWE local transmission system plantransmission planning and the NTTG sub-regional
transmission planning. These documents are available on NWE’s OASIS website. The FERC
890 principle obligations are met by NTTG providing an open forum to coordinate transmission
plans of its members with those of other sub-regional transmission groups within the Region.
NTTG will also have a cost allocation committee that will determine cost allocations for
qualifying system additions where agreement on cost allocation has not been reached.
NWE will participate in the NTTG planning process to ensure data and assumptions are
consistent and represented in the NTTG sub-regional plan. The NTTG sub-regional plan will be
coordinated by NTTG with neighboring sub-regional entities (e.g., ColumbiaGrid). Once the
NTTG’s sub-regional plan is developed, it will be shared with WECC, and the WECC process


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will coordinate the NTTG sub-regional plan with all of the other sub-regional plans within the
WECC region.
NWE will continue providing its local transmission system plantransmission plan, data and
assumptions to WECC regional committees4 that are responsible for building databases.
Regional committees use these data for database development, load and resource assessments,
operating studies and planning studies.
Sub-Regional Plan and Data Coordination
                                       Figure 4: Local And Sub-Regional Planning

NWE will coordinate and
                                                               Data and Plan Coordination
submit its data, assumptions and
local transmission system                              WECC Regional Planning & Basecase Development

plantransmission plan to NTTG                                          NTTG Sub-Region
                                                                          Trans Plan
for inclusion in the NTTG sub-
regional transmission plan. An          Data & Database                                              Other Sub-Region
                                         Coordination            NTTG Sub-Regional Planning
example of this process is                                                                           Plan Coordination


shown in Figure 4: Local And                                              Trans Plan
                                                                         Coordination
Sub-Regional PlanningFigure 4:
Local And Sub-Regional                                               NWE Local Planning
                                                                                                     Econmic Planning
                                                                                                       Study Results
PlanningFigure 4: Local And
Sub-Regional PlanningFigure 4:
Local And Sub-Regional PlanningFigure 4: Local And Sub-Regional Planning. As the figures
shows, data and plan information will be coordinated between the local planning process, the
NTTG sub-regional planning process and the WECC regional planning process. NTTG will
coordinate with other sub-regional planning process within the northwest.
Customers can be directly involved in NWE’s local planning through participation in NWE’s
TRANSAC, be involved in NTTG sub-regional planning and be involved in WECC regional
planning.
Regional Participation
NWE will participate in regional transmission reliability and economic planning studies as
appropriate to ensure data and assumptions are coordinated. The footprint of the study and how
NWE is affected by the request will guide NWE’s participation in the study.
Customers can be directly involved in NWE’s planning, which will discuss the regional planning
efforts by participating in NWE’s TRANSAC. Customers can also be directly involved in the
WECC regional planning.
NWE and Sub-Regional Planning Process Differences
The processes used by NWE and NTTG to develop its local and sub-regional plans are different.
NWE’s process will focus on developing a transmission plan to service its balancing area needs
whereas the NTTG sub-regional plan will focus on evaluating and coordinating sub-regional
transmission projects. The NTTG sub-regional planning process will rely on input from the


4
    For example: WECC System Review Work Group (SRWG) and WECC LRS Subcommittee.

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transmission provider’s plan and/or customer requests forwarded by NWE for sub-regional plan
evaluation. Sub-regional planning will be done by the NTTG membership with oversight by the
NTTG Planning Committee.
Once the NTTG sub-regional plan study is complete, NWE and other stakeholders will have
opportunity for input into the sub-regional plan development by participating in the open NTTG
Planning meetings.
The NTTG Steering Committee will approve the NTTG sub-regional transmission plan that is
developed by the NTTG Planning Committee. The NTTG sub-regional plan will be forwarded
to WECC TEPPC.
Simultaneous Plan Feasibility
The simultaneous feasibility of local, sub-regional and regional plans will be achieved in two
ways. First, NWE’s plan will be coordinated with the NTTG sub-regional plan. The NTTG sub-
regional plan will be coordinated with neighboring sub-regional plans. Finally, WECC will
coordinate NTTG’s sub-regional plan with other sub-region plans. Because these plans are
vertically and horizontally coordinated, simultaneous feasibility will be known.
Second, WECC also requires new project(s) or upgrades to existing paths with potential sub-
regional or regional impacts to follow the WECC Regional Planning Process and the WECC
Path Rating Process requirements. The WECC processes may proceed after the NTTG/WECC
planning process or be coincident to the NTTG/WECC processes. Proceeding through the
WECC processes requires that the feasible project(s) have a sponsor.




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Principle 8 - Economic Planning Studies

FERC Order Requirement Summary
The Commission Determination is found within paragraphs 542-551 of the Order. The
Economic Planning Studies are studies provided to all parties with information on future
transmission needs. These studies are separate from those performed for requests for
transmission service and generation interconnection. This Economic Planning Studies principle
requires planning to address both reliability and economic considerations. Stakeholders are
given the right to request a defined number of high priority studies annually to address
congestion or integration of new resources or load. The rule does not obligate Transmission
Providers to fund economic projects and it does not “assign cost responsibility for those
investments or otherwise determine whether they should be implemented”. The rule also
requires customers, stakeholders and merchants to provide economic d
This principle embraces two types of studies – a study of significant and recurring congestion
and a study to consider whether transmission upgrades or other investment can reduce the overall
costs of serving native load. Collectively, these studies are called Economic Planning Studies.
The Order allows customers to choose the studies that are of greatest value to them.
An Economic Planning Study differs from an Interconnection Study, Transmission Service
Request Study and Local Transmission Planning study in several ways.
   Economic Planning Study: An Economic Planning Study (or Economic Congestion Study or
    Congestion Study) is a transmission production cost study, which is not a system impact
    study or facilities study that is requested by regional stakeholders. The study will result in (i)
    an overall non-binding high-level estimate of the estimated cost to increase transmission
    capacity for a request, and (ii) a value associated with this capacity based upon anticipated
    resource production cost savings to the extent that the requestor supplies adequate
    information to do so. The output of each completed study will be posted on NWE’s OASIS,
    and will not assign cost responsibility for those investments or otherwise determine whether
    they should be implemented in any transmission plan.
   Interconnection Study: An Interconnection Study is a reliability study, which shall mean any
    of the following studies: the Interconnection Feasibility Study, the Interconnection System
    Impact Study, and the Interconnection Facilities Study. The purpose of an Interconnection
    Study is to study the transmission system with the proposed facility to identify the
    transmission fixes, if any, that are required to maintain acceptable transmission system
    reliability performance with all lines in service and with one or more lines forced out of
    service. An interconnection Study is initiated when an interconnection request is received for
    proposed generation, transmission or large load interconnection from a project sponsor.
   Transmission Service Request: A Transmission Service Request study is similar to an                  Formatted: Bullets and Numbering
    Interconnection Study, but it focuses on moving the requested amount of MW from a Point-
    of-Receipt to a Point-of-Delivery. It is initiated when a request for Transmission Service is
    received from a customer.


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   Local Transmission Plan Study: A Local Transmission Plan planning study will evaluate the
    local transmission need for native load service. It is the responsibility of the Transmission
    Provider to plan for and maintain a reliable transmission system for its native load customers.




NWE’s Attachment K Section 2.7 also addresses economic planning studies. The URL to access
NWE’s Attachment K can be found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
High-Priority Study Requests
Stakeholders will have the right to submit a request in writing to NWE asking NWE to conduct a
high-priority Economic Planning Study.
Requesting A High-Priority Economic Planning Study
A request for a high-priority economic planning study can be made by completing, signing and
returning to NWE the “Economic Planning Study Request Form”. This economic planning study
request form can be found under the Transmission planning tab on NWE’s OASIS siteis
identified . in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc .
Processing requests will follow the procedure described in the “NWE Economic Planning Study
Timeline and Process” section below.
NWE reserves the right to request additional information, information that is in addition to the
required information provided in the original request form, if that information is needed to
complete the study.
Valid NWE Request
A valid request will be a request that supplies all the data in NWE’s Economic Planning Study
Request Form (i.e., Required Data). Requests that are not valid will follow the procedure
described in the “NWE Economic Planning Study Timeline and Process” section below.
Economic Planning Study Classification
Valid requests will be classified as either a NWE Economic Planning Study request or a Sub-
Regional/Regional Economic Planning Study request. Sub-Regional/Regional Economic
Planning Studies that are received by NWE will be forwarded to NTTG for study.
A study request that is confined to NWE’s transmission will be classified as an NWE Economic
Planning Study. All other economic study requests will be classified as a Sub-Regional/Regional
Economic Planning Study and will be forwarded to NTTG for study.
Number of NWE High-Priority Studies
NWE will study up to two high-priority NWE Economic Planning Studies annually to address
congestion or the integration of new resources or loads. As described below, additional studies
may be studied, but the customer making the request will fund these Additional Studies.


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Prioritizing NWE Economic Study Requests
If more than two valid NWE Economic Planning Study requests are received, and if after
clustering the requests (described below) more than two distinct studies remain, then NWE will
prioritize the studies identifying the two highest priority studies. The studies in excess of the two
highest priority studies will be called Additional Studies. NWE will coordinate the prioritization
with its advisory committee, TRANSAC. Sponsors of the Economic Study Request are invited
to participate in the open TRANSAC meeting. The prioritization methodology will focus on the
spirit of economic study as stated by FERC. That is, “any such studies conducted pursuant to
this principle … would be for the purposes of planning for the alleviation of congestion through
integration of new supply and demand resource into the regional transmission grid or expand the
regional transmission grid in a manner that can benefit large numbers of customers, such as by
evaluating transmission upgrades necessary to connect major new areas of generation resource
(such as areas that support substantial wind generation). Specific requests for service would
continue to be studied pursuant to existing pro forma OATT processes.”5 Request that do not
meet the spirit of this statement may not be studied.
Clustering Study Requests
Clustering of requests for an NWE Economic Study will be triggered by the following
conditions.
     NWE will consult with TRANSAC in making clustering decisions.
     No request is exempt from being included in a cluster study if appropriate.
                                       Figure 5: NWE Internal Paths
     Requests will be clustered                  Internal Paths & External Paths
      in a manner that makes
      the study process
      efficient. Efficiency may
      be determined by the                                   South of
                                                       Hot Springs
                                                            Great Falls
                                            Burke
      location of the requests                    MT- Northwest
                                                                                   West OfGreat Falls
                                                                                  Broadview
      and whether or not there                  Taft                                     West Of
      is a common or a                                                                 Crossover
                                                                                                 West Of
                                                                                          Townsend
                                                                                                 Colstrip
      potentially common                                                    Garrison
                                                                                                        Broadview

      transmission system                                             Mill Creek                        Billings    Crossover
                                                                                                                                   Colstrip
      problem created by the                MT - Idaho
                                                                                                                                Miles City
      requests. For example, as                                                                                                               Miles City DC

                                                                        MT- South East
      shown in Figure 5: NWE
                                                                                                            Yellowtail
      Internal PathsFigure 5:
      NWE Internal                                                            Jefferson


      PathsFigure 5: NWE                                             IDAHO
                                                                     Borah, Brady or

      Internal PathsFigure 5:                                        Midpoint


      NWE Internal
      PathsFigure 5: NWE Internal Paths, requests in the Great Falls area (north central Montana)


5
    Paragraph 549, FERC Order 890, OATT Reform.

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    and requests in the Billings area (south east Montana) would not have a common
    transmission problem. However, a group of requests in the Billings area and the Crossover
    area moving power to the west may have a common transmission problem.
   All information and data resulting from the study will be provided to NTTG and other
    regional entities.
If a request is to move power into NWE’s Balancing Area (i.e., the Point-of-Delivery) or the
request originates within NWE’s Balancing area (i.e., Point-of-Receipt) and moves power out of
NWE’s balancing area or if the regional transmission system is affected by the study request,
then the request will be classified as a Sub-Regional/Regional Economic Study and will be
forwarded to NTTG for study. If appropriate, individual local study study requests will be
clustered into a single request before sending to NTTG by using the following principles.
   NWE will consult with TRANSAC in making decisions.
   No request is exempt from being included in a cluster study.
   Request to move power into or out of NWE balancing area may be clustered.
   Requests within NWE balancing area that have regional impacts when clustered will be
    included in a regional study.
   Requests will be clustered in a manner that makes the study process efficient. Efficiency
    may be determined by the location, if the requests originate (or terminate) in NWE’s
    balancing area and terminate (or originate) outside NWE’s balancing area, and if there is a
    common or a potentially common transmission problem (e.g., congestion point). For
    example, requests in NWE balancing area moving significant amounts of power from NWE
    system to Idaho would have a common transmission problem; that is, there not sufficient
    transmission capacity between NWE and Idaho for the requests.
   A Sub-Regional/Regional Study may require a study of NWE’s local transmission system to
    accommodate the request. For example, a request to move power from Montana to Idaho
    may require NWE’s local transmission system to be enhanced to move the power from the
    source in Montana to the northern terminal of the MT-ID line congestion.
NWE Economic Planning Study
Once a valid request is received and clustered, if appropriate, NWE will proceed with the NWE
Economic Planning Study. NWE’s Economic Planning Study will be conducted, including
appropriate sensitivity analysis, in a manner that is open and coordinated with TRANSAC.
With respect to a NWE Economic Planning Study, NWE will analyze and report on some or all
of the following elements as directed by the requestor.
Location and Magnitude of Congestion: The location(s) of the congestion will be made known
through examination of historical path performance, past studies or through limited powerflow
and transient stability study. To the extent hourly data is available and applicable to the request,
NWE will evaluate historical records to assess the historical duration and magnitude of
congestion across the congested path. Several years of data will be analyzed if it is available to
make this assessment. Once NWE’s studies identify the location of a future congestion, NWE
will obtain that path’s historical hourly flows and extrapolate the flow data to the year when

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congestion occurs. Additional factors such as load growth need, potential future generation, and
transmission service requests needs are examples of adjustments that may be added to historical
flows to make this assessment. This extrapolated data may provide an example of the congestion
hourly profile. Extrapolation of the hourly data will be completed for pre-defined assumptions
about the relevant adjustments. It should be noted that information developed in this manner
may or may not provide a valid example of future congestion across a path, unless the path is
“radial” interface between two areas, because flows across the path may not be linear (i.e., one-
for-one) due to other network transmission paths offloading and generation or load growth
patterns.
Possible Remedies: NWE will define the transmission mitigation options that could relieve the
congestion in whole or in part. NWE transmission planning will likely need input from NWE’s
Default Supply and/or the customers making the request to define the non-transmission
mitigation measures that could relieve the congestion in whole or in part. The robustness of the
possible remedies may be affected by failure of customers to provide information. A plan will
be considered acceptable only if it meets all reliability criteria.
Associated Cost of Congestion: The cost of congestion will be the most difficult for NWE to
evaluate since NWE is a transmission company only and does not have knowledge of generation
dispatch costs unless the customer making the request provides the information. If NWE does
not obtain this data from the customers making the request, NWE will not be able to complete
this portion of the economic study. NWE’s Default Supply will be required to submit relevant
data as appropriate. Confidential information and CEII data will be protected as appropriate.
NWE will not be able to complete this portion of the economic study internally because the study
requires an economic dispatch model such as PROMOD. NWE will likely consult this portion of
the study request to NTTG, WECC or to a consultant.
Cost to Relieving Congestion: Once the mitigation measures are identified, NWE will be able to
estimate the cost to relieve the congestion. NWE will be able to define the costs for transmission
mitigation measures, but may need help from the customers making the request or NWE’s
Default Supply to define the costs of the non-transmission solutions.
Customer’s Obligation To Share Data
The customers’ obligation to share information is critical to completing an economic planning
study. NWE cannot be obligated to study the cost of congestion if it does not have the
information to do so. Any customer requesting an economic study must supply all relevant
information that it has in its possession for the study. If critical study information is missing,
NWE will work with the customer to determine how the data can be obtained or estimated. If
critical data cannot be obtained or estimated, the study cannot be completed. All confidential
data will be protected by SOC and CEII concerns.
NWE Obligation
This Principle does not require an economic planning study to be completed by NWE unless
requested by customers. The Principle does not obligate NWE to fund economic projects or to
assign cost responsibility for investments or to determine whether the investment should be
implemented.



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Cost to Conduct NWE’s Two High Priority Economic Studies
The cost to conduct the two high priority NWE’s Economic Planning Studies will be tracked and
included in NWE’s next FERC filing for recovery as part of the overall pro forma OATT cost of
service.




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NWE Economic Planning Study Timeline and Process
                                                                               Figure 6: Economic Planning Study

NWE will follow the process shown in Figure 6:
Economic Planning StudyFigure 6: Economic                                   NWE Economic Planning Study
Planning StudyFigure 6: Economic Planning
StudyFigure 6: Economic Planning StudyFigure                               Mth *                    Activity
6: Economic Planning Study. The following                                   1
                                                                                            Receive Requests
process steps will be used.                                                 2
                                                                            3               Cluster & Prioritize
1       Requests Received: Economic study                                   4
        requests will be received from customers                            5
        during a predetermined 60-calendar day                              6
        Request Window.                                                     7                        Study
        1.1     Customers must complete and return                          8
                the Economic Study Request form                             9
                and all relevant data within the                            10
                Request Window.                                             11                    Report
                                                                            12                Results Meeting
        1.2     The start and close of the Request
                                                                         * NWE will use reasonable efforts to meet these time
                Window will be January 1st through                       frames.
                the end of February of each
                year.posted on NWE’s OASIS website.
        1.3     Requests that are not valid will be returned to customer for revision. Revised
                requests that are not returned to NWE within 15 calendar days will be deemed
                withdrawn.
2       Cluster and Prioritize: The studies will be clustered, if appropriate, and prioritized during
        the next 30 calendar days.
        2.1     Studies will be classified as either NWE Economic Planning Study or Sub-Regional
                (Regional) Economic Planning Study.
        2.2     Sub-Regional and (Regional) Economic Planning Studies will be forwarded to
                NTTG.
        2.3     Customers will be notified of their study request classification.
3       Study: NWE will use reasonable efforts to complete the study within 210 calendar
        daysbetween March 1st and September 30th each year.
        3.1     NWE will establish a pre-study conference call with the customer(s) to discuss the
                details of the study.
        3.2     The progress of all NWE Economic Planning Studies will be discussed at
                TRANSAC. The customer(s) will be informed of these TRANSAC meetings and
                are encouraged to participate in these meetings.



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        3.3     If the study will not be completed within the specified 210-calendar day study time,
                NWE will inform the customer in writing of the delay, the reason for the delay and
                an estimated time for completion.
4       Report: NWE will furnish the customer with a study report within 30 days of completion
        of the study.
5       Study Results Meeting: NWE will schedule a study results meeting, which may be
        coordinated with the next scheduled TRANSAC meeting.
6       Posting: The report will be posted on NWE’s OASIS website under the Transmission
        Planning Tab.
7       The Economic Planning Study result will be available for reference and appropriate
        consideration into NWE’s local transmission plan Local Transmission System
        Planplanning Study study and will be forwarded to NTTG.
Additional Local Economic Studies
Local economic study requests that are not prioritized as one of the two highest priority studies
will be called Additional Studies. Sponsors of Additional Study requests will be given the option
to pay for consulting services to complete the study or to withdraw the study. The sponsor may
re-submit the economic study request for study consideration in the next economic planning
cycle. The process that will be followed for Additional Studies is discussed below.
If NWE’s Economic Planning Study will not be completed by the end of the study period, NWE
will inform the requestor(s) before the end of the study period of the study delay, the reasons for
the delay and an estimated completion date. NWE will make reasonable efforts to complete the
two high priority studies within the allotted study time.
Process for Additional Economic Planning Studies
The following process will be used for conducting an Additional Economic Planning Study.
1. Once the customer’s economic study request has been determined to not be one of the two
   high-priority studies describe above, NWE will notify the customer within 15 calendar days
   of that determination. An Additional Economic Planning Study Agreement will accompany
   the notification.
2. Upon receipt of the Additional Economic Planning Study Agreement, the customer must sign
   and return the Agreement with a study deposit within 30 calendar days of receipt of the
   Additional Economic Planning Study Agreement.
             The study deposit is $75,000.
             If NWE does not receive the signed study agreement and deposit within 30 calendar
              days, the Economic Planning Study request will be deemed withdrawn.
             Withdrawn study requests may be re-submitted by the customer for consideration
              during the next NWE Economic Planning Study cycle.
3. Customer will be responsible for all actual costs to complete the economic planning study.
             Actual costs less than the $75,000 deposit will be refunded to the customer.

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             The customer will be invoiced monthly for actual study costs greater than the $75,000
              study deposit.
             The customer must pay the invoiced amount within 30-calendar days of receipt.
4. Once NWE receives the signed study agreement and deposit, NWE will follow the NWE
   Economic Planning Study Process starting with step 3.
Sharing of Study Results Between ,System Planning and Economic Studies
The Local Transmission System Planning Study (for retail load service)GgIi and the Economic
Planning sStudy (for customer economic study requests studies) are distinct and separate studies.
They examine the transmission system from different perspectives (reliability evaluation vs.
economic dispatch evaluation). Even though these studies are distinct and separate studies, the
applicable study results from eachone study will be made available to the other study for
consideration. See Figure 6: Sharing System and Economic Study Results.
Figure 6: Sharing System and Economic Study Results

1) 2) 3) 4) .
Sub-Regional Economic Study Coordination
Regional/Sub-Regional Economic Planning Studies that are received by NWE will be forwarded
to NTTG for study. A study request that is confined to NWE’s transmission will be classified as
an NWE Economic Planning Study. All other economic study requests will be forwarded to
NTTG for study. NTTG Transmission Use Committee will prioritize the economic planning
studies it receives and will either retain the request for NTTG study, send the study request to
WECC for study or return the study to NWE. Additional information on NTTG economic study
process can be found through the “NTTG Info & Documents” URL address in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
Economic Planning Study Posting
NWE will post a listing of all Economic Planning Study requests received by NWE. This list
will include the following information.
   Date received
   Study Request Name
   Brief discussion of study request
   Whether or not the request is valid
   Type of study (NWE high-priority study, additional study, sub-regional study)
   Cluster status (none or cluster group number)
   Request status (received, in study, study complete, withdrawn)
   Date the study request forwarded to the sub-region, if appropriate
   Expected completion date

This listing will be posted on NWE’s OASIS website under the Transmission Planning tab.
Interested persons can contact NWE for copies of the completed economic planning study
reports shown on this listed posting. The URL address for the “Economic Study Request Listing


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& Meeting Info” is identified in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.




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Principle 9 - Cost Allocation for New Projects

FERC Order Requirement Summary
The Commission Determination is found within paragraphs 557-561 of the Order. The Cost
Allocation for New Projects principle requires the planning process to address cost allocation for
joint projects, economic projects, and projects that do not fit into existing OATT cost allocation
principles. Examples of new projects requiring a cost allocation principle are projects involving
several transmission owners or economic projects that are identified through the study process
described in Principle 8 – Economic Planning Studies. The rule does not specify a particular
allocation method, but the method should provide for fair allocation to beneficiaries, adequate
incentives to construct transmission, and should have the support of state authorities and region-
wide participants.
Principle 9 states that “t[T]he proposal should identify the types of new projects that are not
covered under existing cost allocation rules and, therefore, would be affected by this cost
allocation principle. … We will not impose a particular allocation method for such projects, but
rather will permit transmission providers and stakeholders to determine their own specific
criteria which best fit their own experiences and regional needs.”
Projects Not Covered Under Existing Cost Allocation Rules
The following are examples of projects not covered under existing cost allocation rules and
would be affected by the cost allocation principle.
   A new project confined to NWE balancing area not for load service. For example, this
    project could move power across a future internal transmission constraint and be the result of
    a NWE Economic Planning Study. This project may have little or no regional impact, but
    would be a proactive look to relieve future transmission congestion. WECC Regional
    Planning Process and Path Rating Process may be required, but sub-regional coordination
    would be required.
   A new project extending beyond NWE’s balancing area. A project from a regional economic
    planning study could be a major transmission line that has sub-regional or regional
    consequences. An example would be a new transmission line starting in Montana and
    terminating in Phoenix. This study would traverse a large geographic area and would impact
    the transmission systems of at least one other utility. This project would have sub-regional
    impacts and would require sub-regional coordination through NTTG. The WECC Regional
    Planning Process and the Path Rating Process would also be required.
   A new project involving several transmission owners. An example of this would be a new
    transmission line, sponsored by several entities, built to move power out of NWE’s balancing
    area to the Northwest. This project could have sub-regional and regional impacts and would
    require sub-regional coordination through NTTG. The WECC Regional Planning Process
    and the Path Rating Process would also be required.



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   A new project resulting from an Open Season Solicitation. This type of project could be a
    major transmission line that has sub-regional or regional consequences. An example would
    be a new transmission line starting in Montana and terminating in Idaho. This study would
    traverse a large geographic area and would impact the transmission systems of at least one
    other utility. A joint study would be required and would be facilitated by NTTG. This
    project could have sub-regional and regional impacts and would require sub-regional
    coordination through NTTG. The WECC Regional Planning Process and the Path Rating
    Process would also be required.
NWE Local Cost Allocation Methodology Projects Outside the OATT
The URL address to access NWE’s “Local Cost Allocation Methodology Outside of OATT”
business practice is found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
NWE’s cost allocation methodology is described in Section 2.6 of NWE Attachment K. The
URL address for this document can be found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.
For new local projects that do not fit into NWE OATT cost allocation principles, NWE will
follow the “NWE Local Cost Allocation Methodology Projects Outside OATT” that is posted on
NWE’s website unless a mutually agreeable cost allocation method can be reached between
NWE and the project participants or sponsors. In developing alternative cost allocation methods,
NWE will seek input from its stakeholders, through TRANSAC, if appropriate. Cost allocation
will be discussed and agreed to on a case-by-case basis with project participants or sponsors. It
is possible that the cost allocation principles for economic projects will be different from the cost
allocation methods for projects involving multiple owners.
The cost allocation developed from this methodology for a Project falling outside NWE’s OATT
are not binding and are intended to represent an example of the cost allocation that could be
agreed to by the sponsors of the study request. The actual cost allocation for a project will be
determined once the project is committed to and the cost allocation is negotiated and agreed to
by the committed project sponsors, which may be different than the sponsors making the study
request. The actual cost allocation will be specified in the contract between the committed
project sponsors.
There are various methods to assign costs for new projects within NWE's balancing area that do
not have a regional impact and do not fall under NWE’s tariff. One methodology is the principle
based on cost-causation as shown in “NWE Local Cost Allocation Methodology Projects Outside
OATT”. The costs that are allocated to customers are all appropriate costs for the system
mitigation (i.e., upgrades, enhancements, etc.) that eliminate the unacceptable system
performance. Through this principle, the customer whose request caused the problems is the
customer that benefits most through the elimination of the problem and the quantification is
based on the relative contribution to the problem being eliminated. Other methods that could be
used for cost allocation include, but are not limited to, the following.
   An open season to determine ownership share;
   Open season for allocation of capacity without ownership; and
   Share prorated on MW use.

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   Any of these methods may be the appropriate method for a particular situation.
Sub-Regional and Regional Cost Allocation
The NTTG cost allocation principles are posted on the NTTG web page and on NWE’s OASIS
website. The URL address to access additional information for NTTG cost allocation can be
found under the “NTTG Info & Documents” section found in
http://www.oatioasis.com/NWMT/NWMTdocs/Attachment_K_Business_Practice_Links.doc.




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Recovery of Planning Costs

NWE does not have a specific mechanism under the OATT or other funding sources for the
recovery of the planning-related costs. NWE will capture the planning costs for NWE OATT
using traditional test period requirements in the next FERC tariff filing. No specific allocation to
specific customers is contemplated.
TRANSAC will be NWE’s vehicle to discuss if any other entities are in need of cost recovery for
planning related activities.




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