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Cc: pdmichie@bpa.gov, mwood@stoel.com, bmspeckman@aol.com,
jboucher@kemaconsulting.com, nwrto@pplmt.com, ambarnes@bpa.gov, sberman@hewn.com, kcarlson@do.usbr.gov, gdahlke@painehamblen.com, michaelearly@earthlink.net, pfeldberg@lawsonlundell.com, ericf@prestongates.com, mhain@enron.com, sjarsky@pn.usbr.gov, snkripalani@stoel.com, srlarson@bpa.gov, jpm@aelaw.com, terrym@millcreeklaw.com, pmurphy@mbllp.com, douglas_nichols@pgn.com, lnichols@bpa.gov, rkrodewald@bpa.gov, tshuba@sheagardner.com, dswatkins@bpa.gov, cwestadt@sppc.com, cindy.wright@ci.seattle.wa.us Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit Bcc: pdmichie@bpa.gov, mwood@stoel.com, bmspeckman@aol.com, jboucher@kemaconsulting.com, nwrto@pplmt.com, ambarnes@bpa.gov, sberman@hewn.com, kcarlson@do.usbr.gov, gdahlke@painehamblen.com, michaelearly@earthlink.net, pfeldberg@lawsonlundell.com, ericf@prestongates.com, mhain@enron.com, sjarsky@pn.usbr.gov, snkripalani@stoel.com, srlarson@bpa.gov, jpm@aelaw.com, terrym@millcreeklaw.com, pmurphy@mbllp.com, douglas_nichols@pgn.com, lnichols@bpa.gov, rkrodewald@bpa.gov, tshuba@sheagardner.com, dswatkins@bpa.gov, cwestadt@sppc.com, cindy.wright@ci.seattle.wa.us X-From: "Shuba, Timothy" <TShuba@SheaGardner.com< X-To: "'Christensen, Eric '" <ELChristensen@SNOPUD.com<, "''Sarah Dennison-Leonard' '" <sdleonard@earthlink.net< X-cc: "'Preston Michie '" <pdmichie@bpa.gov<, "'Marcus Wood '" <mwood@stoel.com<, "'Barney Speckman '" <bmspeckman@aol.com<, "'John Boucher '" <JBoucher@kemaconsulting.com<, "'nwrto@pplmt.com '" <nwrto@pplmt.com<, "'Arlena '" <ambarnes@bpa.gov<, "'sberman@hewn.com '" <sberman@hewn.com<, "'kcarlson@do.usbr.gov '" <kcarlson@do.usbr.gov<, "'Gary Dahlke '" <gdahlke@painehamblen.com<, "'Michael Early '" <michaelearly@earthlink.net<, "'pfeldberg@lawsonlundell.com '" <pfeldberg@lawsonlundell.com<, "'Eric Freedman '" <ericf@prestongates.com<, "'mhain@enron.com '" <mhain@enron.com<, "'sjarsky@pn.usbr.gov '" <sjarsky@pn.usbr.gov<, "'snkripalani@stoel.com '" <snkripalani@stoel.com<, "'Steve Larson '" <srlarson@bpa.gov<, "'jpm@aelaw.com '" <jpm@aelaw.com<, "'terrym@millcreeklaw.com '" <terrym@millcreeklaw.com<, "'pmurphy@mbllp.com '" <pmurphy@mbllp.com<, "'Doug Nichols '" <douglas_nichols@pgn.com<, "'lnichols@bpa.gov '" <lnichols@bpa.gov<, "'rkrodewald@bpa.gov '" <rkrodewald@bpa.gov<, "Shuba, Timothy" <TShuba@SheaGardner.com<, "'Don Watkins '" <dswatkins@bpa.gov<, "'Connie Westadt '" <cwestadt@sppc.com<, "'cindy.wright@ci.seattle.wa.us '" <cindy.wright@ci.seattle.wa.us< X-bcc: X-Folder: \Mary_Hain_Aug2000_Jul2001\Notes Folders\All documents X-Origin: Hain-M X-FileName: mary-hain.nsf I'm not sure, but I think that Nevada may have a net metering law as well, although the cut-off is probably less than 25 MW. I think that a net metering provision would be appropriate for a number of reasons, not all of which are compelled by state renewable laws/policies. Many small wholesale entities (at least in Utah and other east-side locations have modest generators behind their meters and would be disadvantaged if there were no net metering accommodations avilable. Given the size of the generators (generally much less than 25MW), they are not significant to the grid, but are to their owners. -----Original Message----- From: Christensen, Eric To: 'Sarah Dennison-Leonard' Cc: Preston Michie; Marcus Wood; Barney Speckman; John Boucher; nwrto@pplmt.com; Arlena; sberman@hewn.com; kcarlson@do.usbr.gov; Christensen, Eric; Gary Dahlke; Michael Early; pfeldberg@lawsonlundell.com; Eric Freedman; mhain@enron.com; sjarsky@pn.usbr.gov; snkripalani@stoel.com; Steve Larson; jpm@aelaw.com; terrym@millcreeklaw.com; pmurphy@mbllp.com; Doug Nichols; lnichols@bpa.gov; rkrodewald@bpa.gov; tshuba@sheagardner.com; Don Watkins; Connie Westadt; cindy.wright@ci.seattle.wa.us Sent: 6/23/00 2:39 PM Subject: RE: Initial E-mail Communication - Subgroup Working on GIA, LIA, Etc. Sarah, The Generation Interconnection Agreement will have to be modified to accommodate the Net Metering law (R.C.W. Chapter 80.60) that was passed here in Washington in 1998. The law covers generators of 25 kW or less that are powered by solar, wind, hydro or fuel cells. Washington distribution utilities are required to install two-way meters for all customers with such facilities and to credit those customers for any power produced in excess of the customer's needs. We are required to accept all qualified net metering customers until the total generating capacity of the net metered systems reaches 0.1 percent of our 1996 peak load. Because these generators are tiny and, even in the aggregate, are unlikely to have any appreciable effect on the operation of the grid, I think the easiest approach would be simply to write an exemption into the GIA for such net metered generators. I don't know whether any of the other RTO-West states have net metering laws. However, net metering has been kicked around quite a bit in connection with federal restructuring legislation. Hence, we need to keep an eye developments in DC in this regard. Eric Christensen Associate General Counsel Snohomish County PUD No. 1 (425) 783-8649 Toll free from WA: (877) 783-1000 x8649 Office fax: (425) 783-8305 Direct fax: (425) 267-6071 elchristensen@snopud.com <mailto:elchristensen@snopud.com< -----Original Message----- From: Sarah Dennison-Leonard [SMTP:sdleonard@earthlink.net] Sent: Wednesday, June 21, 2000 5:45 AM To: nwrto@pplmt.com; Arlena; sberman@hewn.com; kcarlson@do.usbr.gov; elchristensen@snopud.com; Gary Dahlke; Sarah Dennison-Leonard; Michael Early; pfeldberg@lawsonlundell.com; Eric Freedman; mhain@enron.com; sjarsky@pn.usbr.gov; snkripalani@stoel.com; Steve Larson; jpm@aelaw.com; terrym@millcreeklaw.com; pmurphy@mbllp.com; Doug Nichols; lnichols@bpa.gov; rkrodewald@bpa.gov; tshuba@sheagardner.com; Don Watkins; Connie Westadt; cindy.wright@ci.seattle.wa.us Cc: Gary Dahlke; Preston Michie; Marcus Wood; Barney Speckman; John Boucher Subject: Initial E-mail Communication - Subgroup Working on GIA, LIA, Etc. Good morning, everyone! I am sorry it has taken me so long to contact you. This e-mail is intended to get things rolling for the RTO West Legal Subgroup working on the Generation Integration and Load Integration Agreements, as well as Security Coordination and Scheduling Coordinator Agreements if necessary. First, for your reference I have attached the following documents: (1) a list of participants in our subgroup; (2) the original IndeGO Generation Integration Agreement ("GIA"); and (3) the original IndeGO Load Integration Agreement ("LIA"). If you know of anyone who would like to be included in this subgroup that does not appear on the attached participants list, please let me know. I will also post each of the attached documents on the RTO West website, at the link on the Legal Work Group page set up for our subgroup. Second, I would like to share some initial feedback I have received with respect to our assigned tasks: (A) Concerning the Generation GIA, I have the following initial feedback: - Carl Imparato has expressed strong concern about existing provisions in the GIA designed to address instances when hydro generation facility operators are forced to move water through turbines, rather than spill it, to avoid dissolved gas super-saturation problems; - James Mosher has expressed concern that the GIA as currently drafted does not adequately address issues unique to Qualifying Facilities, and would like us to work on that; and - Steve Larson of BPA has contacted me to let me know that BPA has developed some initial comments on the GIA (and LIA), but I have not yet had a chance to have a conversation with BPA representatives about what those comments are. I hope to do that sometime tomorrow (Thursday, June 22) if possible. (B) I have talked with John Boucher, who leads the Implementation Work Group, and he says that the initial consensus within the Implementation Work Group is that we should begin with the approach that security coordination for RTO West will be accomplished through the existing organization set up in the Northwest to perform security coordination (Pacific Northwest Security Coordinator or "PNSC," which is a Washington non-profit corporation); and (C) John Boucher says that the initial thinking in the Implementation Work Group about scheduling coordinators as that we should assume that we will have scheduling coordinators for RTO West and therefore will need to develop a scheduling coordinator agreement. With that in mind, I have also attached to this e-mail an e-mail message from Barney Speckman on this topic. Barney's e-mail describes input he has received from Carl Imparato concerning areas in the West that have already developed scheduling coordinator agreements, and includes an e-mail from Carl with sample documents. I will also post these on the RTO West website as soon as possible, along with the basic form of Security Coordination Agreement developed for PNSC. I think it might be useful to plan to meet or have a telephone conference call during the week of July 10 (early in the week, if possible) to discuss our various tasks and strategies for accomplishing them. If most of you are going to be at the Legal Work Group meeting on June 27, that might be a good opportunity to try to identify a time and date that works for most subgroup members and to decide whether to meet in person or by telephone conference. I also hope to make initial "cosmetic" changes to the GIA and LIA very soon, and will put the initial revised versions of those documents on the website as soon as they are ready. In the meantime, if anyone else has some input they would like to offer with respect to the issues and documents assigned to our subgroup, you are welcome to contact me by e-mail or telephone. Thank you very much. Sarah Dennison-Leonard Krogh & Leonard 506 SW Sixth Avenue, Suite 750 Portland, OR 97204-1533 Office: (503) 219-9649 Fax: (503) 224-1895 E-mail: sdleonard@earthlink.net << File: Legal WG - GIA&LIA Subgroup List June 21 2000.doc.rtf << << File: IndeGO Generation Integration Agreement.doc << << File: IndeGO Load Integration Agreement.doc << << Message: Fwd: NWRTO-Scheduling Coordinator Concept <<
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