Definition of Retail Sales

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           GIS Requirements Definition                                 APX                                NEPOOL

a. Develop, implement and maintain the GIS                   Develop, implement and               Provide requirements and
     database with a flexible architecture capable of         maintain the GIS database.            GIS definition
     handling additional data fields that might be           Provide flexible                     Provide additional fields as
     added later due to evolving statutory or                 infrastructure                        required
     regulatory standards and/or market                      Develop process for                  Provide information on type
     requirements;                                            NEPOOL to input                       and structure of likely
                                                              additional field                      changes and additions.
b.   Catalog the initial assignment of each                  Design the capability to             Develop this requirement
     electronic “certificate” based on information            transfer electronic                   further
     provided by the ISO and participating                    certificates                         Define information provided
     generators                                                                                     by the ISO and participating
c.   Document generation and associated attributes           Develop a registration               Define associated attributes
     of each participating generator or importing             system that documents                Define information that the
     system, produce electronic certificates based on         generation and associated             electronic certificates are
     that information and provide for database                attributes of each                    based on
     access to necessary information.                         participating generator or           Define necessary
                                                              importing system                      information that that
                                                             Develop a system that                 requires data base access
                                                              produces electronic
                                                              certificates based on
                                                             Provide database access to
                                                              necessary information.
d.   Monitor and document all electronic certificate         Design an electronic                 Define information provided
     exchanges from and between all participating             certificate exchange                  by those entities to base
     entities based on information provided by those          capability for participants.          electronic certificate
     entities to the Administrator.                          Monitor and document all              exchanges on.
                                                              electronic certificate               Explore the way participants
                                                              exchanges.                            want to report trades
e.   Prepare monthly reports, with quarterly digests         Design monthly reports,              Define the content of these
     of those reports, for each entity participating in       with quarterly digests of             reports
     the GIS for each account in the database, which          those reports, for each
     reports will form the basis for retail LSEs to           participant
     demonstrate their compliance with state statutes
     and regulations and support any additional
     marketing claims in filings with the state
     agency or agencies that administer the relevant
     state statutes and regulations.
f.   Provide participating entities with the real-time       Provide real-time GIS                Define participants account
     status of their GIS accounts upon request.               account access to                     status requirements
                                                              participants accounts
g.   Monitor for potential undue or improper                 Develop software that                Define rules for potential
     exercises of market power, identify any related          monitors for potential undue          undue or improper exercises
     problems to NEPOOL, the ISO and state                    or improper exercises of              of market power
     regulators and propose mitigating actions.               market power                         Define reports and reporting
                                                             Provide NEPOOL, ISO and               procedures that identify
                                                              state regulators with reports         undue or improper exercises
                                                              that identify undue or                of market power and any
                                                              improper exercises of                 related problems
                                                              market power and any

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                                                             related problems                  Develop enforcement plan
                                                            Support NEPOOL, ISO and            when ISO-NE suspects
                                                             state regulators strategy          market abuses.
                                                             sessions in proposing
                                                             mitigating actions.
h.   Cooperate with state agencies in the                   Cooperate with state              Develop this requirement
     verification of retail LSE filings with those           agencies.                          further.
     state regulators subject to the NEPOOL
     Information Policy.
i.   Work with NEPOOL and the ISO to formulate              Support Working Groups            Assign Working Group to
     operating rules and procedures for the GIS.             with NEPOOL and the ISO            perform this task
                                                             to formulate operating rules      Develop the plan for
                                                             and procedures for the GIS.        performing this
j.   Implement the appropriate policy with respect          Design participant account        Develop this requirement
     to confidential information.                            information confidentiality.       further.
2.3.1 Overview                                              Develop, implement and
The GIS, using information provided by the ISO               maintain the GIS.
and participating generators, will create a one-for-
one match between energy produced and energy
consumed in New England, as well as
accommodates imports and exports. The ISO
currently administers a wholesale electricity market
that is settled each hour as to supply and load
obligations. The GIS will contain hourly generation
information for each individual New England
generation unit that is subject to NEPOOL central
dispatch or otherwise participates in the GIS, and it
will create generator-specific and importing system-
specific electronic “certificates” that identify the
relevant generation attributes necessary for retail
LSEs to demonstrate satisfaction of state generation
information requirements. (4) Retail LSEs will be
required to obtain certificates equal to the load they
serve. The certificates will contain the information
needed to allow retail LSEs to demonstrate their
compliance with state requirements and to allow
state agencies to verify that compliance.
4 Certificates associated with imports will either be
“generator specific” or “system
average” depending on the controlling regulatory
standards in effect from time to time.
2.3.2 Sources of Generation Information for GIS
The ISO currently provides monthly settlement               Integrate the GIS with the        Provide integration data for
statements to all NEPOOL Participants that take              MSS revenue quality meter          the revenue quality meter
part in the wholesale electricity markets                    readings.                          readings in the MSS.
administered by the ISO, through the ISO’s market           Design the GIS to support         Provide rule design for the
settlement system (“MSS”). Those monthly                     the import/export rules            GIS to administer the MSS
statements are based on hourly load and supply               developed by NEPOOL.               produced hourly scheduled
assignments for all market participants as produced         Ensure that the small              energy flows of imports and
by the ISO’s markets software. The initial                   wholesale generators that          exports.
generation credits produced by the real-time                 request inclusion in the          Provide the procedures and

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dispatch of generation based on telemetered data are         MSS database are supported          design that allows the small
modified by revenue quality meter readings that are          in the GIS.                         wholesale generators that
submitted within 48 hours of the close of each day’s                                             are not telemetered to be
market. The MSS also produces hourly scheduled                                                   included in the overall MSS
energy flows of imports and exports over the                                                     database.
external ties to and from the NEPOOL control area.
Those tie-lines connect to New Brunswick (1),
Quebec (2), and New York (8). Small wholesale
generators that are not telemetered as part of the
real-time wholesale market but that request
inclusion in the MSS database are included in the
overall MSS database based on revenue-quality
meter readings. Those readings are submitted within
48 hours of the close of each day’s market.
The basic MSS database maintained for financial             Integrate the GIS with the         Provide the data interface
settlement purposes will provide the initial set of          MSS.                                information for the MSS.
inputs for hourly generation credits by resource for        Design the MSS                     Provide details of the basic
the GIS database. The MSS will need to be                    modifications or the plan for       MSS database.
modified to include some additional information on           the GIS to support the             Define the MSS
individual generation units, and the cost of that            information.                        modifications.
upgrade should be included in the capital costs of          Design the GIS to accept the       Provide characteristics that
the GIS that are described below. In addition, labor         characteristics that are not        are not kept in the MSS that
characteristics and possibly some other                      kept in the MSS and that are        may be provided directly to
characteristics that are not kept in the MSS may be          provided directly to the            the Administrator.
provided directly to the Administrator by the                Administrator.                     Provide POC for the MSS
generators participating in the GIS.                                                             related inquiries.
2.3.3 Sources of Retail Load, Export and
Wholesale Station Service Withdrawal
Information for GIS
Information for GIS ISO monthly settlement                  Develop the GIS to                 Define what ISO
statements also include information on energy                ascertain hourly retail load        information type and at
withdrawals in the form of exports of energy to              responsibility by retail LSE,       what frequency it will be
neighboring control areas and supply of wholesale            based on the combination of         available for LSE’s
station service power to some generating facilities          ISO information available          Define the information type
when they are not generating. ISO monthly                    and information provided by         and at what frequency it will
settlement information for energy responsibility,            that LSE.                           be provided by that LSE
however, is not necessarily reflective of the
associated participant’s retail LSE responsibility.
For example, a monthly settlement statement may
reflect the wholesale bilateral supply of wholesale
energy by a wholesale supplier with no Adjusted
Net Interchange reflected in the statement of the
retail LSE. The ISO does have information as to the
owner of each load asset, which is not necessarily
the retail LSE for that load asset. It will be
necessary for the Administrator to ascertain hourly
retail load responsibility by retail LSE, based on the
combination of ISO information available and
information provided by that LSE. 5
5 Where either a retail load has switched to a
different retail LSE or a retail LSE has
contracted with a third party for the management of
its generation disclosure obligations, such
transfer or contract must be confirmed by the
transferee or third party.

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2.3.4 GIS Database
While it may be technically feasible to expand the          Build a GIS Database               Provide additional fields as
ISO-administered MSS and other databases to                 Design the GIS database to          available
include the additional fields necessary for a GIS            be expandable to include           Define the NEPOOL
database, at this time this RFP seeks responses to           new fields                          products.
develop and administer a separate, stand-alone GIS                                              Provide feedback on
database. On a practical level, both databases could                                             registration and data screens
utilize the same platform if the legal and operational                                           developed to meet
issues related to a shared platform can be resolved.                                             NEPOOL requirements.
However, having separate databases will provide
advantages in terms of access, data manipulation,
maintenance, and, most importantly, modifications.
It is highly likely that the GIS database will need
frequent modifications in the first few years to
accommodate the introduction of new or revised
state requirements and changes in the underlying
GIS rules.
In addition to the hourly data, which will be listed
on the certificates, provided from the MSS database,
the GIS database will need to include fields for
other data, on a product-by-product basis. At this
time, some of those fields are known, but the GIS
database should include the ability to be expanded
to include many additional fields. The current list
includes, but is not limited to, the following:
 Fuel Source
 Hydro size
        Less than 100MW
        Greater than 100MW
 Hydro type
 Solid waste
 Biomass
         low emission, advanced
 Qualifying cogeneration (ME)
 Vintage (year commercially operational or as
      otherwise required by state regulations)
 Union labor (MA)
 Emissions factors for SOx, NOx, and CO2
      which may vary over time or by fuel
 Eligibility for state RPS (MA, ME, CT) 6
6 Eligibility will be determined by the applicable
regulatory agency.
 Identification of specific unit
 Location
 Time and date of generation
The Administrator will develop and maintain the             Develop and maintain the           Define the content of the
database, as well as catalog the initial assignment of       database                            reports on net retail LSEs’
certificates and any trading of certificates, and           Catalog the initial                 attribute accounting to
provide reports on net retail LSEs’ attribute                assignment of certificates          facilitate verification by the
accounting to facilitate verification by the                Catalog any trading of              appropriate state agency.
appropriate state agency. Entry and updating of              certificates
generator-specific attributes may be performed by           Provide LSE Reports
the generator owner or its designated agent, subject        Facilitate entry and updating

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to confirmation by the Administrator.                         of generator-specific
2.3.5 Production of Certificates
The Administrator will produce electronic                    Develop electronic                 Define the data
certificates based on the hourly generation                   certificates that meet the          requirements for the
information from the settlements database and/or              NEPOOL rules and data               electronic certificates.
from information provided by generators. The                  requirements.
certificates will be numbered and may or may not
include additional information from the other fields
in the GIS database. Each certificate will provide
sufficient information (or access to information in
the GIS database) so that a retail LSE will be able to
determine, in combination with other certificates, its
ability to comply with individual state statutes and
regulations. 7
7 It is not intended that the GIS will impact the
allocation of generation attributes under
bilateral agreements.
The owner for each generator whose output is                 Design the GIS to provide          Provide the NEPOOL rules
settled through the NEPOOL wholesale energy                   generators with the                 for certificate creation,
market will receive from the Administrator a                  capability to review and            dispute, and resolution.
monthly statement of the certificates created by its          request modifications to
monthly generation. As with financial settlements,            their MSS generation data
certificate settlements for each month will be                before certificates are
provided by the Administrator prior to the 15 the of          created.
the following month, with an opportunity for the             Provide generators with a
generation owner to review and request                        method to dispute the
modifications, if appropriate, for a time thereafter          number of certificates
consistent with after-the-fact adjustments in the             awarded after award.
In addition, the GIS will need to reflect end-of-the-        Incorporate GIS rules to           Provide GIS rules that allow
month adjustments to meter reads and load asset               incorporate end-of-the-             the time to incorporate end-
values effected by the ISO.                                   month adjustments to meter          of-the- month adjustments
                                                              reads and load asset values.        to meter reads and load
                                                                                                  asset values.
2.3.6 Transfer of Certificates
Certificates may be transferred through a variety of         Develop certificate transfer       Define the NEPOOL rules
mechanisms, and the Administrator should                      mechanisms defined by the           for certificate transfer.
encourage flexible approaches for the exchange of             NEPOOL rules.                      Define trading period.
certificates. Entities should be able to self-supply,        Design the GIS database to         Define the central bulletin
arrange bilateral exchanges in advance of actual              be flexible enough to permit        board or auction
generation, purchase certificates through                     new types of transfers.             requirements.
a central bulletin board or auction, and exchange
certificates through private arrangements over a
later period of time. In addition, the GIS database
must be flexible enough to permit new types of
transfers as they arise. Regardless of the exchange
process used, any entity transferring certificates will
be required to notify the Administrator of the
transfer prior to the close of the trading period.
2.3.7 Retirement of Certificates
Issuance and trading of certificates between and             Design the GIS to provide a        Define the LSE’s four
among entities participating in the GIS will occur            three-month + lag period for        quarterly reports.
over a three-month period. After each calendar                issuance and tracking of           Define the “Lag Period”.
quarter and at the end of a short additional period           trading of certificates

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(the “Lag Period”) to be defined, the retail LSE               between and among entities
accounts maintained by the Administrator will be               participating.
closed and a report sent to each account holder.              Provide the capability to
Compliance with state requirements will be                     close accounts.
determined by regulatory authorities on an annual             Provide the LSE’s four
basis based on the four quarterly reports produced in          quarterly reports.
each year.
In order to ensure a one-to-one match of generation           Provide a preliminary              Develop the NEPOOL rules
and load for accounting purposes, at the end of each           determination of those              for “Unsettled Certificates.”
quarterly period but prior to the end of the Lag               certificates explicitly            Define the content of the
Period, the Administrator will make a preliminary              associated with a retail LSE        final report of the aggregate
determination of those certificates explicitly                 load, Direct Tags                   characteristics of remaining
associated with a retail LSE load, Direct Tags                 Transaction or export               Unsettled Certificates for
Transaction (as defined below) or export                       transaction.                        that quarter the “Residual
transaction. All remaining certificates will be               Provide a preliminary report        Mix”.
deemed “Unsettled Certificates.” The Administrator             of the aggregate
will issue a preliminary report of the aggregate               characteristics of those
characteristics of those Unsettled Certificates, as            Unsettled Certificates, as
well as a detailed listing of those Unsettled                  well as a detailed listing of
Certificates authorized for release by their current           those Unsettled Certificates
title-holders, to all entities participating in the GIS        authorized for release by
at the end of each calendar quarter to facilitate              their current title-holders.
further trading of those Unsettled Certificates during        Provide a final report of the
the Lag Period if needed or desired. At the end of             aggregate characteristics of
the Lag Period, all trading of certificates for that           remaining Unsettled
quarter will cease and the Administrator will issue a          Certificates for that quarter
final report to regulators and entities participating in       the “Residual Mix”.
the GIS of the aggregate characteristics of
remaining Unsettled Certificates for that quarter (the
“Residual Mix”).8
8 For purposes of compliance with certain
regulations, it is anticipated that some
regulators may reference the aggregate
characteristics of the Residual Mix with respect to
Retail LSEs whose total certificates as designated in
the final report fall short of their total retail load.
It is anticipated that certain renewable (or other)           Design the GIS to avoid the        Develop the NEPOOL rules
generators may continue a current practice of selling          possibility of double               for “Unsettled Certificates”,
the rights to attributes represented by certificates, or       counting certificates.              “Direct Tags Transactions”,
the certificates themselves, directly to retail end-                                               and the “Residual Mix”.
users independent of transactions between those
retail end-users and their retail LSEs (“Direct Tags
Transactions”). To avoid the possibility of double
counting certificates, the Administrator will provide
a mechanism for generators to inform the
Administrator of certificates transacted under
verifiable Direct Tags Transactions. At the end of
each quarter, the Administrator will exclude any
such certificates from determination of any retail
LSE’s account balance, and from the determination
of Unsettled Certificates and the Residual Mix.
The Administrator must monitor for potential                  Design the GIS to monitor          Develop the NEPOOL rules
exercises of undue market power by generators,                 for potential exercises of          for defining exercises of
LSEs and other entities participating in the GIS,              undue market power.                 undue market power.
notify NEPOOL, the ISO and state regulators of                Provide reports that               Develop the NEPOOL rules
potential problems and propose mechanisms for                  NEPOOL, the ISO and state           for market power penalties.

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preventing and mitigating such exercises, to the                regulators could use to            Develop reports that
extent such problems arise.                                     identify and document               monitor participant activity
                                                                market power violators.             for potential exercises of
                                                                                                    undue market power.
2.3.8 Retail LSE Obligations
Each retail LSE will have a certificates account with          Provide LSE’s with                 Provide access to LSE retail
the Administrator. Each account will have a                     certificate accounts.               energy sales.
certificates obligation equal to all of its retail energy      Integrate the LSE retail           Define retail line loss
sales in each calendar quarter, including retail line           energy sales data into the          NEPOOL rules.
losses consistent with local distribution company               GIS.
allocation of line losses (“Certificates Obligation”).         Accommodate retail line
The Certificates Obligation may be disaggregated               Provide disaggregation of          Define retail LSE products.
into accounts for each product offered by the retail            LSE’s Certificates                 Define retail LSE’s
LSE, at the retail LSE’s discretion.                            Obligation into LSE product         discretion for disaggregation
                                                                offerings.                          of their products. (Real
                                                                                                    time vs. working group)
To the extent required to demonstrate compliance               Provide LSE’s with the             Develop NEPOOL rules for
with state or other statutes or regulations, retail             capacity to view their              compliance.
LSEs must obtain, through bilateral transactions or             Certificates Obligation and
otherwise, certificates equal to all or part of its             with the ability to acquire
Certificates Obligation in each quarter.                        certificates using the GIS.
The final balance of certificates in each of a retail          Provide the reporting              Define the report for the
LSE’s accounts, as well as any shortfall in                     capability to deliver to the        LSE’s Certificate
certificates relative to its Certificates Obligation,           LSE and regulators the LSE          Obligation.
will be reported to each retail LSE and to regulators           final balance of certificates
if applicable.                                                  and shortfall.
2.3.9 Verification of Retail LSE Claims
The GIS will maintain one or more accounts based               Design the capability to           Define LSE products and
on the request of each participating entity that                follow and document all             their requirement for
serves retail load. For retail LSEs selling multiple            certificate exchanges.              separate accounts.
products, there will be an account for each product.           Design accounts to specify         Define capability to follow
The Administrator will need the capability to follow            the corresponding megawatt          and document all certificate
and document all certificate exchanges from and                 hours assigned to each              exchanges.
between all relevant accounts. Each account will                wholesale, retail and              Define where the
also specify the corresponding megawatt hours                   product account.                    information will be acquired
assigned to each wholesale, retail and product                                                      to specify the corresponding
account.                                                                                            MWh’s assigned to each
                                                                                                    wholesale, retail and
                                                                                                    product account.
On a quarterly basis, the Administrator will provide           Provide the Quarterly Retail       Define the Quarterly Retail
a report to each participating entity for each account          LSE Regulatory Filing               LSE Regulatory Filing
in the database. Those quarterly reports will form              Report.                             Report.
the basis for the retail LSEs to make filings with the         Allow state regulators read-
state agency or agencies that administer the relevant           only access to view
state statutes and regulations. Auditing of claims              Quarterly Retail LSE
will be the responsibility of the state regulators.             Regulatory Filing Reports.
2.3.10 Exports and Imports
Exports of power from the NEPOOL control area                  Design the GIS to support          Provide further definition of
will be treated like other energy withdrawals within            the export/import                   applicable regulatory
the NEPOOL control area. The exporting entity may               requirements.                       policies concerning exports.
export certificates equivalent to the MWhs of power                                                Define all energy
exported or may export power without associated                                                     withdrawals within the
certificates. Moreover, certificates may be exported                                                NEPOOL control area.
without associated power to the extent consistent

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with applicable regulatory policies.                                                          Assign Working Group
                                                                                               Export/Import definition.
                                                                                              Cooperate with adjoining
                                                                                               control areas to reduce
Imports of power from outside the NEPOOL control           Account for the total             Develop a method for
area may produce certificates. Ultimately, the total        imported MWhs in the               recognizing all imports.
imported MWhs will need to be accounted for.                NEPOOL control area.              Coordinate with Northeast
Ideally, a method would be developed for                   Design the GIS to be               regulators to address
recognizing the specific attributes of some, if not         flexible in relation to            regulatory treatments are
all, imports to the extent allowed or required by the       imports/exports.                   adopted with respect to
applicable statutes and regulations. There will need       Ensure that import/export          imports.
to be coordination among regional control areas in          MWhs are not counted
order to ensure that attributes are not counted twice       twice.
(once in each control area). Some preliminary
discussions among Northeast regulators suggest that
coordination efforts are reasonable and worth
pursuing, and those regulators are continuing those
discussions. The GIS will need to be flexible
enough to permit the Administrator to address
whatever regulatory treatments are adopted with
respect to imports.

2.3.11 Potential Database Adjustments Related
to State Policies
An initial design assumption has been that the GIS         Integrate the GIS to the
database would include only the NEPOOL                      ISO’s MSS database.
generation volumes reflected in the ISO’s MSS
database. Thus, it has been assumed that
(i)       generating units that do not provide             If required, provide a            Define requirements for
separately metered data to the NEPOOL wholesale             manual capability for              generating units that do not
market system, including generation located behind          generating units that do not       provide separately metered
retail customer meters, would not be included in the        provide separately metered         data to the NEPOOL
GIS database                                                data to the NEPOOL                 wholesale market system.
                                                            wholesale market system.
(ii)      certain generating units that are not            Support line loss reduction       Define line loss
connected to NEPOOL pool transmission facilities            requirements.                      requirements.
would have their outputs reduced in the GIS to the
same extent that they are reduced in the MSS for
line losses
(iii)     the output of each generating unit would be      The APX GIS will have the         Define individual states
measured at its interconnection meter and would             capability for automated           regulatory generation
thus be reduced for station service to the same             meter data entry and manual        requirements.
extent that they are reduced in the MSS. Individual         meter data entry.
states could, however, implement their own                 Design the GIS to be
procedures to allow and recognize for regulatory            flexible enough to reflect
purposes the incremental generation amounts and             additional data sources.
attributes associated with such limitations, and such
qualifying generation amounts could, when reliably
metered, then be included in the GIS database and
certificate program. The GIS would need to be
flexible enough to reflect such additional data
2.3.12 Development of Emission Factors
Emissions data necessary to issue certificates will        Design participant                Assign Working Group

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be supplied to the Administrator by individual               Registration system to             Emission factors definition.
generators. Details with respect to sources of               include emission factors.         Define emission sources.
emissions data, mechanisms for transferring data to                                            Define the timing of
the Administrator, and the timing of data submittals                                            emissions data submittals.
are to be discussed by the Committee and will be
resolved in consultation with the Administrator.
The GIS must accommodate co-firing multi-fuel               Design the GIS to                 Define rules of to include
units. The Administrator will need to develop a              accommodate duel fuel              duel fuel units.
mechanism to allow new generation units (with no             units.                            Define prospective
history) and retrofitted generation units (with             Design the GIS to be               emissions factors.
anticipated reduced emissions) to adopt prospective          flexible enough to adopt
emissions factors.                                           prospective emissions

2.3.13 Pumped Storage
Pumped storage and generation presents a complex            Design the GIS to meet the        Assign Working Group the
issue for the GIS. The pumps that put the water into         requirements for pumped            pumped storage definition.
storage consume energy generated in some hours of            storage.                          Define a method of
the real-time wholesale energy market for use in                                                accounting for pumped
generating energy in subsequent hours. The real-                                                storage.
time generation that runs the pumps will have
certificates issued at the end of the month equal to
the megawatt hours of energy that the pumps use.
When the stored water is released, additional
generation (about 30 percent less than the energy
that initially pumped the water) occurs that is sold
into the wholesale market and ultimately to retail
The retail LSE that purchases the electricity               Design the GIS to meet the
produced by the pumped storage facility has the              requirements for pumped
obligation to acquire certificates for the megawatt          storage.
hours of electricity sold to its retail customers. In
order to balance the total amount of monthly
certificates assigned to retail loads with the total
monthly megawatt hours of generation, the losses
associated with pumped storage (approximately 30
percent) need to be allocated.
The proposed solution is to require all retail LSEs to      Support the Working Group         Assign Working Group to
assume a pro-rata share of pumped storage losses.            in proposing alternatives to       propose alternatives to
That means that each LSE will need to purchase               reflect the benefits pumped        reflect the benefits pumped
additional certificates to account for its retail load       storage provides to the            storage provides to the
pro-rata share of certificates needed to cover these         region after initial               region after initial
losses, estimated at less than one-half of one percent       implementation.                    implementation.
of its retail sales. While initially the emission
reduction benefits of peak clipping from pumped
storage facilities and other load management
programs will not be explicitly recognized in the
certificate program, the Administrator will propose
alternatives to reflect the benefits they provide to
the region after initial implementation.

DRAFT For Discussion                                                                     GIS Proprietary

Description: Definition of Retail Sales document sample