William M. Dudley Assistant General Counsel 1800 Larimer Street, Suite 1100 Denver, CO 80202 Phone: 303.294.2842 Fax: 303.294-2852 Email: [email protected] October 30, 2014 Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Re: Public Service Company of Colorado Xcel Energy Operating Companies Joint Open Access Transmission Tariff – Second Revised Volume No. 1 Proposed Tariff Revisions Docket No. ER15-____-000 Dear Ms. Bose: Pursuant to Section 205 of the Federal Power Act (“FPA”), 16 U.S.C. § 824d (2012), and Section 35.13 of the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) regulations, 18 C.F.R. § 35.13 (2014), Xcel Energy Services Inc. (“XES”), 1 on behalf of Public Service Company of Colorado (“PSCo”) hereby submits proposed tariff sheets to the Xcel Energy Operating Companies Joint Open Access Transmission Tariff (“Xcel Energy OATT”). The proposed tariff sheets reflect changes to the Xcel Energy OATT designed to facilitate the joint dispatch of the generating resources of PSCo, Platte River Power Authority (“PRPA”), and Black Hills Colorado Electric Utility Company, LP (“BHCE”) (collectively, the “Parties”). 2 The Parties have entered into a Joint Dispatch Agreement (“JDA”), to be filed in conjunction with the instant tariff revisions, that is intended to provide the Parties with a centralized, coordinated, intra-hour dispatch system for their generation resources with the overall goal of achieving more efficient and lower cost generation to serve the combined participating native load requirements within the PSCo Balancing Authority Area (“PSCo BAA”). In this filing, 1 XES is the service company subsidiary of Xcel Energy Inc., the holding company parent of PSCo and the other Xcel Energy Operating Companies, namely, Northern States Power Company, a Minnesota corporation, Northern States Power Company, a Wisconsin corporation, and Southwestern Public Service Company. As such, XES makes filings with, and appears in proceedings before, the Commission on behalf of the Xcel Energy Operating Companies. 2 Consistent with the requirements of Order No. 714, FERC Stats. & Regs. ¶ 31,276 at P 63 (2008), PSCo is the designated e-Tariff filing entity for the Xcel Energy OATT and will include in its tariff database the rate schedule representing the JDA being submitted with this filing. BHCE will be seeking Commission approval of changes corresponding to those PSCo is submitting in the instant filing. PRPA, while a non-jurisdictional entity, will also make conforming revisions to its transmission arrangements to provide for Joint Dispatch Transmission Service. Honorable Kimberly D. Bose October 30, 2014 Page 2 of 8 PSCo proposes revisions to the Xcel Energy OATT to provide the Parties with non-firm transmission service to be used to deliver the energy dispatched under the JDA at no additional cost. As further discussed herein, the new service proposed in the attached revisions will not have an adverse impact on other transmission users, will not be unduly discriminatory, and will facilitate the Parties’ efforts to achieve dispatch cost savings from their committed resources. Thus, PSCo respectfully requests that the Commission approve the attached provisions with an effective date of January 1, 2015. I. Introduction PSCo is a direct subsidiary of Xcel Energy, a holding company that primarily engages in the production, transmission and distribution of electricity and the distribution of natural gas through its four utility subsidiaries: PSCo, SPS and Northern States Power Company, a Minnesota corporation and Northern States Power Company, a Wisconsin corporation. PSCo generates, transmits and distributes electric power and energy throughout portions of the State of Colorado. PSCo provides electric service to approximately 1.3 million wholesale and retail customers in Colorado. The Company's greatest concentration of retail customers is in the Denver metropolitan area. PSCo is located at the eastern edge of the Western Interconnection and is a member of the Western Electricity Coordinating Council ("WECC"). Since there is no regional transmission organization ("RTO") serving Colorado, PSCo is the Transmission Provider for the PSCo transmission system. PSCo provides Network Integration Transmission Service (“NITS”) and Point-to-Point Transmission Services and derives rates for such services pursuant to Attachment O-PSCo of the Xcel Energy OATT, on file with the Commission pursuant to Order Nos. 888 and 890. PSCo has collaborated with the other Parties to establish the JDA in order to realize cost savings through a centralized system of energy dispatch within the PSCo BAA. The overarching goal of joint dispatch is to achieve efficiencies through the collaborative use of the Parties’ generation resources. The purpose of the instant filing is to establish tariff provisions that provide corresponding non-firm transmission service to the Parties for the delivery of energy under the JDA. Honorable Kimberly D. Bose October 30, 2014 Page 3 of 8 II. Communications PSCo requests that all correspondence, communications, and service related to this filing be directed to the following individuals: Terri K. Eaton Director, Federal Regulatory/Compliance Xcel Energy Services Inc. 1800 Larimer Street Denver, CO 80202 Tel: (303) 571-7112 Email: [email protected] Floyd L. Norton IV Arjun P. Ramadevanahalli Morgan, Lewis & Bockius LLP 1111 Pennsylvania Ave., N.W. Washington, DC 20004 Tel: (202) 739-5620/5913 Email: [email protected] [email protected] Robert Staton Control Center Manager Xcel Energy Services Inc. 18201 West 10th Ave. Golden, CO 80401 Tel: (303) 273-4797 Email: [email protected] William M. Dudley Assistant General Counsel Xcel Energy Services Inc. 1800 Larimer Street, 11th Floor Denver, CO 80202 Tel: (303) 294-2842 Email: [email protected] Daniel Ahrens Standards of Conduct / Fed. Reg. Manager Xcel Energy Services Inc. 1800 Larimer Street, 14th Floor Denver, CO 80202 Tel: (303) 571-6428 Email: [email protected] Peter Colussy Manager, Market Operations Xcel Energy Services Inc. 1800 Larimer, Suite 10 Denver, CO 80202 Tel: (303) 808-2607 Email: [email protected] III. Description of Proposed Revisions A. Background The Parties developed the JDA in order to achieve efficiencies through the collaborative use of generation resources within the PSCo BAA. The JDA will facilitate the real-time optimization of generation dispatch decisions between the Parties and allocate the lowest cost generation available in real-time to serve native load requirements. The joint economic dispatch of the pooled generation resources will occur intra-hour and will utilize Available Transfer Capability (“ATC”) that is otherwise unused after the scheduling hour is closed. As discussed below in section B.3, the ATC will be monitored at designated interconnection points between the Parties so that intra-hour schedules by other transmission users will have priority over Joint Dispatch Transmission Service. Overall, the JDA will result in an organized and cost-effective Honorable Kimberly D. Bose October 30, 2014 Page 4 of 8 means for the Parties to meet their own native load requirements within the PSCo BAA. The proposed revisions submitted with this filing will add a new section to the Xcel Energy OATT titled “Joint Dispatch Transmission Service” that will provide for delivery by PSCo of energy provided under the JDA. B. Schedule 15, Joint Dispatch Transmission Service 1. Terms and Service Description Joint Dispatch Transmission Service is a non-firm transmission product provided only on an “as-available” basis for the sole purpose of facilitating energy transfers under the JDA. The conditions that an entity must meet in order to take Joint Dispatch Transmission Service are as follows: Be a load serving entity within the PSCo BAA; Execute the JDA with each participating transmission provider; Offer generating resources that meet the dispatch criteria into the JDA pool; Secure an agreement with the JDA Customer’s host transmission provider to provide corresponding non-firm, zero rate transmission service for use by other Parties to the JDA. 3 The Joint Dispatch Transmission Service is not limited solely to PSCo, PRPA, and BHCE. Other similarly situated entities may become Parties to the JDA and take Joint Dispatch Transmission Service if those entities meet the conditions for service, outlined above. If those conditions are met, a prospective JDA Customer need only submit an application to obtain the Joint Dispatch Transmission Service. Due to the non-firm nature of Joint Dispatch Transmission Service, prospective JDA Customers will not need to arrange for transmission studies prior to taking Joint Dispatch Transmission Service. 2. Rates and Charges PSCo proposes to offer Joint Dispatch Transmission Service at a zero rate to eligible customers, and no additional transmission charges will be assessed for the receipt or delivery of energy dispatched pursuant to the JDA. The zero rate term is consistent with the nature of this transmission service as the Joint Dispatch Transmission Service will only utilize non-firm ATC within the operating hour that is otherwise unused—capability that is not being compensated currently. As discussed by Ms. Eaton, every Joint Dispatch Transmission Service Customer will still be required to maintain adequate firm network and point-to-point service for its wholesale and retail native load, and each Party will continue to pay third parties for point-to-point service. 4 In this manner, Joint Dispatch Transmission Service is structured as a zonal or license3 See Exh. No. PSC-3 at Section 42. 4 See Eaton Testimony, Exh. No. PSC-1 at 11. Honorable Kimberly D. Bose October 30, 2014 Page 5 of 8 plate service, in which a customer will not be responsible for additional charges beyond those it is already bearing for transmission facilities located within its zone. Charges for power losses will continue to be the responsibility of the Joint Dispatch Transmission Service Customer, and these charges will be paid at pancaked rates. In other words, energy transactions delivered across two different systems will be assessed losses by both of those systems. 5 Additionally, Joint Dispatch Transmission Service Customers will continue to be responsible for charges for ancillary services provided by PSCo as a Balancing Authority. 6 Imbalance charges for Joint Dispatch Transmission Service Customers will not apply. Because PSCo will serve as the scheduling and dispatch authority under the JDA, and will thus be responsible for balancing the combined load and participating resources of all the Parties. 3. Restrictions on Joint Dispatch Transmission Service As discussed above, Joint Dispatch Transmission Service will be limited solely to the receipt and delivery of energy dispatched under the JDA within the PSCo BAA to serve the wholesale and/or retail load of any Party. Joint Dispatch Transmission Service will not be available for off-system sales of capacity or energy or for providing direct or indirect transmission service to a third party. Joint Dispatch Transmission Service Customers must continue to ensure that point-to-point transmission service has been obtained, as needed, to import purchases from outside the PSCo BAA or export off-system sales, in accordance with FERC regulations. 7 In addition, the transfer of energy will be limited to ATC at designated interconnection points under the JDA. PSCo will limit transfers under Joint Dispatch Transmission Service by determining every five minutes the unused ATC that remains on the system after all other procurement and scheduling deadlines have passed. Although scheduledriven ATC updates may occur every quarter-hour, the five-minute update ensures that any intrahour schedule changes, such as those prompted by outages, are captured and that only the leftover ATC be made available for Joint Dispatch Transmission Service. 8 This also ensures that scheduled transmission receives priority over Joint Dispatch Transmission Service for JDA transactions, causing adjustments to the joint economic dispatch to ensure ATC will not be exceeded. C. The New Joint Dispatch Transmission Service Is in the Public Interest Joint Dispatch Transmission Service facilitates the efficient and cost-effective use of pooled generating resources under the JDA, with multiple benefits to the Parties and their wholesale and retail customers, and is therefore in the public interest. Under the design of the 5 Eaton Testimony, Exh. No. PSC-1 at 13. 6 Customers will be responsible for services under the following schedules in the Xcel Energy OATT: Scheduling, System Control and Dispatch, Reactive Supply and Voltage Control, Reserve Sharing, Operating Reserve – Spinning, and Operating Reserve – Supplemental. See Eaton Testimony, Exh. No. PSC-1 at Page 13. 7 Exh. No. PSC-3 at Section 42.3. Off-system deliveries of Joint Dispatch Energy will be accomplished by redirecting point-to-point reservations. See Eaton Testimony, Exh. No. PSC-1 at 11. 8 Eaton Testimony, Exh. No. PSC-1 at 9. Honorable Kimberly D. Bose October 30, 2014 Page 6 of 8 JDA, the Parties will be able to access a broader pool of resources to serve their own native load requirements. As a result, the Parties will have the ability to purchase energy at a rate that is less than what it would cost the Party to produce a corresponding amount of energy. These cost savings will ultimately be passed on to wholesale and/or retail customers within the PSCo BAA. 9 D. The New Joint Dispatch Service Will Not Adversely Impact Other Transmission Users and Is Not Unduly Discriminatory Energy transfers made under the Joint Dispatch Transmission Service will facilitate a more efficient use of transmission capacity, but will not adversely impact other transmission users. As described above, the Parties will provide transmission access based on residual ATC after the close of the last scheduling deadline during each intra-hour period. 10 Thus, pooled energy under the JDA will be capped based on the maximum residual ATC on the system. Moreover, Joint Dispatch Transmission Service will have the lowest curtailment priority, and will not displace other transmission service. The Joint Dispatch Transmission Service is not unduly discriminatory to nonparticipating transmission customers because it provides an alternative mechanism to manage the difference between scheduled and actual load, which is currently managed through Energy Imbalance services under Schedule 4 of the Xcel Energy OATT. PSCo as the BAA provides energy imbalance services without purchasing transmission service to do so. PSCo balances the system after taking into account the resources provided by each customer. Under joint economic dispatch facilitated by the JDA and Joint Dispatch Transmission Service, PSCo will have dispatch authority over participating resources of the parties, drawing from the committed resources of each party as determined prior to the start of the hour. Participating generation resources of the Parties will be dispatched by PSCo in economic order to achieve balance. In this manner, the JDA framework is analogous to an energy imbalance market or other energy market, albeit on a small scale. The Commission has approved the use of zonal transmission rates based on the host transmission owner’s cost and has eliminated intra-market pancaked transmission rates in a number of instances. 11 In a recent example, the Commission approved the California Independent System Operator Corporation’s (“CAISO”) proposed tariff revisions to implement an Energy Imbalance Market (“EIM”), in which neighboring BAAs may participate in CAISO’s real-time market for imbalance energy. 12 To facilitate the transfer of EIM energy between participating BAAs, CAISO proposed that it would not assess charges on transmission capacity made available to the real-time market through the EIM. 13 The 9 Eaton Testimony, Exh. No. PSC-1 at 7. 10 Eaton Testimony, Exh. No. PSC-1 at 9. 11 See, e.g., PJM Interconnection, L.L.C., Opinion No. 494, 119 FERC ¶ 61,063 (2007), order on reh’g and compliance filing, Opinion No. 494-A, 122 FERC ¶ 61,082, order denying reh’g, 124 FERC ¶ 61,033 (2008); ITC Holdings Corp., 143 FERC ¶ 61,257 at P 124 (2013) (“[T]he Commission has . . . accepted reconfigurations of license plate pricing zones that deviate from historical configurations.”). 12 Cal. Indep. Sys. Operator Corp., 147 FERC ¶ 61,231 (2014). 13 Id. at P 125 n. 172. Honorable Kimberly D. Bose October 30, 2014 Page 7 of 8 Commission approved CAISO’s proposal to eliminate intra-market pancaked transmission rates, noting that doing so could promote more efficiency, provide customers in the EIM and in CAISO with access to additional energy supplies, and result in downward pressure on market prices. 14 Although the Commission’s approval of CAISO’s elimination of pancaked transmission rates occurred in the RTO context, the example is relevant here, as both the EIM and the JDA aim to promote efficiency by employing a zonal transmission scheme to provide access to additional energy supplies. Joint Dispatch Transmission Service facilitates these economic energy deliveries at zero cost in recognition that the Service will only utilize ATC that is currently being unused. Additionally, this zero cost transmission service will maximize cost savings for customers of the participating Parties in a not unduly discriminatory manner. Participation in the JDA is voluntary and non-exclusive, and those transmission customers that do not participate in the JDA will continue to be provided balancing service under Schedule 4 of the Xcel Energy OATT. Moreover, the implementation of zero cost transmission for Joint Dispatch Transmission Service is limited to providing economic energy transfers pursuant to the JDA. E. The Proposed Tariff Revisions Do Not Significantly Alter PSCo’s OATT Lastly, the proposed tariff provisions do not depart from the Commission’s previous determination that PSCo’s OATT conforms with, or is superior to, the pro forma OATT. 15 First, the proposed tariff provisions serve only to provide a new type of service for Parties to the JDA. Moreover, as discussed above, Joint Dispatch Transmission Service is not exclusive, and any load-serving entity in the PSCo BAA that is willing to sign the JDA, has the ability to contribute generating resources to the JDA pool, and whose transmission provider agrees to the terms comparable to those proposed in this filing would also be able to participate in the JDA. IV. Proposed Effective Date and Request for Waivers PSCo requests that the Commission approve the requested effective date of January 1, 2015. PSCo also respectfully requests waiver of any other requirements of the Commission’s rules and regulations, as well as any authorizations as may be necessary or required, to permit the proposed tariff sheets to be accepted by the Commission and made effective in the manner proposed herein. Because no charge will be assessed for Joint Dispatch Transmission Service, cost support under Section 35.13 of the Commission’s regulations is not necessary. 14 Id. at P 156. 15 See Letter Order Accepting Xcel Energy’s Baseline OATT, Docket No. ER10-2070 (Sept. 24, 2010). Honorable Kimberly D. Bose October 30, 2014 Page 8 of 8 V. Contents of Filing Pursuant to 18 C.F.R. § 35, this filing consists of the following documents: This transmittal letter; Attachment 1: Testimony of Terri K. Eaton, Director, Federal Regulatory Administration, Xcel Energy Services Inc. (Exhibit No. PSC-1); Attachment 2: Redlined version of the proposed tariff changes (Exhibit No. PSC-2); and Attachment 3: Clean version of the tariff changes (Exhibit No. PSC-3). To the extent necessary, PSCo respectfully requests waiver of any of the other applicable requirements of 18 C.F.R. § 35.13. The proposed tariff revisions do not involve a rate increase within the meaning of section 35.13(a)(2)(iii) of the Commission’s regulations and do not otherwise modify any existing terms or conditions of the Xcel Energy OATT. VI. Service and Posting An electronic copy or notice of this filing will be served on all customers of PSCo taking transmission or ancillary services under the Xcel Energy OATT and on the Public Utilities Commission of Colorado. In advance of this filing, on October 1, 2014, PSCo provided a complete copy of this filing in draft form, including the transmittal letter, testimony, and tariff sheets, to its transmission Customers for their review. A copy of this filing is also available at the Open Access Transmission Tariff filings pages of the Xcel Energy Inc. website (www.xcelenergy.com). VII. Conclusion For the reasons stated herein, PSCo respectfully requests that the Commission accept the proposed tariff sheets to be effective on January 1, 2015. PSCo sincerely appreciates the Commission’s prompt attention to this matter. Please direct any questions regarding this filing to the undersigned. Sincerely, /s/ William M. Dudley William M. Dudley Assistant General Counsel EXHIBIT 1 Exhibit PSC-1 Page 1 of 13 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Public Service Company of Colorado ) Docket No. ER15-___-000 PREPARED TESTIMONY OF TERRI K. EATON XCEL ENERGY SERVICES INC. ON BEHALF OF PUBLIC SERVICE COMPANY OF COLORADO October 30, 2014 Exhibit PSC-1 Page 2 of 13 1 I INTRODUCTION AND EXPERIENCE 2 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 3 A. My name is Terri K Eaton. My office address is 1800 Larimer Street, 14th Floor, Denver, 4 Colorado, 80202. 5 Q. BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY? 6 A. I am employed by Xcel Energy Services Inc. (“XES”). I am the Director, Federal 7 Regulatory Administration. 8 Q. ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS PROCEEDING? 9 A. I am testifying on behalf of Public Service Company of Colorado (“PSCo” or the 10 “Company”), a wholly owned subsidiary of Xcel Energy Inc. (“Xcel Energy”). PSCo is 11 an integrated electric and natural gas utility operating in Colorado, including in the 12 Denver metropolitan area, and is one of four utility operating company subsidiaries of 13 Xcel Energy. 14 Q. PLEASE EXPLAIN YOUR DUTIES AND RESPONSIBILITIES. 15 A. My department is responsible for regulatory filings, regulatory activity, and compliance 16 monitoring activities involving the Federal Energy Regulatory Commission (“FERC” or 17 “Commission”) for the four Xcel Energy utility operating companies, including PSCo. 18 The FERC compliance monitoring responsibilities include PSCo compliance with North 19 American Electric Reliability Corporation (“NERC”) and the Western Electricity 20 Coordinating Council (“WECC”) mandatory electric reliability standards. Exhibit PSC-1 Page 3 of 13 1 Q. 2 3 WHAT IS YOUR EDUCATION AND YOUR EXPERIENCE IN THE ELECTRIC UTILITY BUSINESS? A. In 1981, I received my B.S. degree from the University of Texas. In 1985, I received my 4 J.D. from the University of Texas School of Law. From 2000 to 2002, I worked as a staff 5 attorney for the Public Utility Commission of Texas (“PUCT”). In that role, I was 6 responsible for representing PUCT staff in rate case, transmission line, stranded cost, and 7 various other proceedings. 8 Manager of Governmental Affairs, representing the company’s interests as a competitive 9 retail electric provider before the PUCT, the Texas legislature, and the Electric Reliability 10 Council of Texas (“ERCOT”). I joined XES in 2005 as a Manager of Market Operations, 11 representing the interests of PSCo’s affiliate Southwestern Public Service Company 12 (“SPS”) in the efforts by Southwest Power Pool, Inc. (“SPP”) to create its Energy 13 Imbalance Service market. In 2006, I transferred into XES’s FERC regulatory group 14 where I managed electric market policy issues. In 2007, I assumed a newly created 15 position focused on monitoring and oversight of mandatory reliability standards 16 compliance efforts of the Xcel Energy Operating Companies. In 2009, I assumed my 17 current position. 18 Q. 19 20 In 2002, I joined Green Mountain Energy Company as HAVE YOU PREVIOUSLY SUBMITTED TESTIMONY BEFORE ANY REGULATORY COMMISSION? A. Yes, I have previously submitted pre-filed testimony before this Commission in Docket 21 No. ER12-1589 and ER14-1969. Additionally, I have submitted affidavits to the 22 Commission on various matters, including affidavits in support of tariff change filings in 23 Docket Nos. ER12-435-000, ER12-436-000, and ER12-455-000. Exhibit PSC-1 Page 4 of 13 1 II PURPOSE AND SUMMARY 2 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY? 3 A. The purpose of my testimony is to provide a brief description of Xcel Energy, XES and 4 PSCo, and to provide an overview of PSCo’s request for approval of revisions to its Open 5 Access Transmission Tariff (“Xcel Energy OATT”) to facilitate transactions under the 6 Joint Dispatch Agreement (“JDA”). 7 approval of the JDA, an agreement that will provide for the economic dispatch of 8 participating generation within the PSCo Balancing Authority Area (“BAA”), and the 9 other FERC jurisdictional party to the JDA is filing revisions to its Open Access 10 Concurrent with this filing, PSCo is filing for Transmission Tariff corresponding to PSCo’s changes in this filing. 11 Q. PLEASE SUMMARIZE THE PROPOSED TARIFF CHANGES. 12 A. The proposed revisions to the Xcel Energy OATT include: 13 A new section titled Joint Dispatch Transmission Service that provides non-firm 14 transmission service at a rate discounted to zero applicable only to load serving 15 entities that have participating generation that they can contribute to the joint 16 dispatch pool in the PSCo Balancing area and are signatories to a Joint Dispatch 17 Agreement; 18 A new Schedule 15, Joint Dispatch Transmission Service; and, 19 A Service Agreement for Joint Dispatch Transmission Service. 20 21 Q. ARE THERE EXCEPTIONS TO THE REQUIREMENT THAT GENERATION BE LOCATED INSIDE THE BAA? Exhibit PSC-1 Page 5 of 13 1 A. Yes. Generation could be located outside the PSCo Balancing area but pseudo-tied into 2 the PSCo balancing area. A pseudo-tie essentially involves electrically sinking the 3 output of a generator in one balancing area into another sink balancing area. 4 Q. 5 6 HAVE YOU INCLUDED ATTACHMENTS TO YOUR TESTIMONY SHOWING THE CHANGES TO THE OATT? A. 7 Yes. The attached Exhibit No. PSC-2 is a redlined version of the proposed tariff changes, while Exhibit No. PSC-3 is a clean version of the tariff changes. 8 III CORPORATE OVERVIEW 9 Q. PLEASE PROVIDE A BRIEF DESCRIPTION OF XCEL ENERGY. 10 A. Xcel Energy is a holding company that primarily engages in the production, transmission 11 and distribution of electricity and the distribution of natural gas through its four utility 12 subsidiaries: PSCo, SPS and Northern States Power Company, a Minnesota corporation 13 (“NSPM”) and Northern States Power Company, a Wisconsin corporation (“NSPW”) 14 (NSPM and NSPW jointly the “NSP Companies”). PSCo, NSPM and NSPW are each 15 combination electric and natural gas utilities. SPS is an electric-only utility. Collectively 16 Xcel Energy’s utility operating company subsidiaries serve 3.4 million electric and 1.9 17 million natural gas customers in Colorado, Michigan, Minnesota, New Mexico, North 18 Dakota, South Dakota, Texas and Wisconsin. 19 transmission facilities in Kansas and Oklahoma. I note that the changes to the Xcel 20 Energy OATT proposed in this filing do not affect the rates or terms of service on the 21 NSP Companies or SPS transmission systems. 22 Q. PLEASE DESCRIBE XES. In addition, SPS owns and operates Exhibit PSC-1 Page 6 of 13 1 A. XES is a service company that provides a variety of management and administrative 2 services to Xcel Energy’s four utility operating companies, including PSCo. Some of the 3 services provided by XES include executive management, human resources, accounting, 4 audit, legal, claims, regulatory and compliance, fuel and energy management, 5 engineering and customer services. As a service company, XES files an annual Form 60 6 service company report with the Commission each year detailing the revenues from its 7 charges to the individual utility operating companies. 8 Q. PLEASE PROVIDE A BRIEF DESCRIPTION OF PSCO. 9 A. PSCo generates, transmits and distributes electric power and energy throughout portions 10 of the State of Colorado. PSCo provides electric service to approximately 1.3 million 11 wholesale and retail customers in Colorado. The Company’s greatest concentration of 12 retail customers is in the Denver metropolitan area. 13 PSCo is located at the eastern edge of the Western Interconnection and is a 14 member of the Western Electricity Coordinating Council (“WECC”). Since there is no 15 regional transmission organization (“RTO”) serving Colorado, PSCo is the Transmission 16 Provider for the PSCo transmission system. 17 Transmission Service (“NITS”) and Point-to-Point Transmission Services and derives 18 rates for such services pursuant to Attachment O-PSCo of the Xcel Energy OATT, on file 19 with the Commission pursuant to Order Nos. 888 and 890. PSCo provides Network Integration 20 IV JDA BACKGROUND 21 Q. WHAT IS THE PURPOSE OF THE INSTANT FILING? 22 A. The instant filing reflects changes to the Xcel Energy OATT designed to facilitate joint 23 dispatch of the resources of PSCo, Platte River Power Authority (“PRPA”) and Black Exhibit PSC-1 Page 7 of 13 1 Hills Colorado Electric Utility Company, LP (“BHCE”) (collectively referred to as “the 2 Parties”) under the JDA. More specifically, the proposed tariff changes provide that non- 3 firm transmission service used to deliver energy dispatched under the JDA will be 4 provided at no cost, other than payment of losses, to parties to the JDA. 5 Q. WHAT IS THE PURPOSE OF THE JDA? 6 A. The Parties to the JDA intend to capture efficiencies and cost savings through joint 7 dispatch of their committed resources to serve the native load obligation of the parties to 8 the JDA within the PSCo BAA. 9 Q. HOW WILL THE JDA CAPTURE EFFICIENCIES? 10 A. As discussed in more detail in the companion filing, the parties to the JDA have agreed 11 to allow PSCo to dispatch the committed and participating resources of all the parties in 12 real-time in a manner that maintains reliability while minimizing overall production costs 13 and respecting transmission constraints and unit operating characteristics. 14 Q. WHERE IS THE LOAD THAT WILL BE SERVED BY THE JDA LOCATED? 15 A. Under the JDA, the load that can be served under the agreement is limited to that which is 16 located within the PSCo BAA. 17 V POLICY 18 Q. WHY 19 20 SHOULD THE TARIFF REVISION BE APPROVED BY THE COMMISSION, AND IS THE JDA IN THE PUBLIC INTEREST? A. The JDA will enable optimal dispatch of the combined participating resources of all the 21 participating parties, resulting in increased dispatch efficiency. The tariff revisions are in 22 the public interest because, among other things, the dispatch efficiency facilitated by the Exhibit PSC-1 Page 8 of 13 1 JDA and tariff revisions will be reflected through reduced fuel costs for the customers of 2 all participating parties, including PSCo’s retail and wholesale customers. 3 The JDA and tariff revisions provide an alternative mechanism to effectively 4 manage the difference between scheduled and actual load, which is currently managed 5 through Energy Imbalance services under Schedule 4 of the PSCo OATT. PSCo, as the 6 BAA, provides energy imbalance services without purchasing transmission service to do 7 so. PSCo balances the system after taking into account the committed resources from 8 each customer that were determined prior to the start of the hour. Under joint economic 9 dispatch facilitated by the JDA and Joint Dispatch Transmission Service, participating 10 generation resources will be dispatched in the most economic order to achieve this 11 balance. 12 VI OATT REVISIONS 13 Q. WHAT REVISIONS ARE BEING MADE TO PSCO’S OATT? 14 A. PSCo is revising its OATT in order to offer Joint Dispatch Transmission Service. Joint 15 Dispatch Service is service that can only be used to receive and deliver energy dispatched 16 under the JDA to the Parties’ wholesale and retail native load customers. 17 Q. 18 19 ARE THE TARIFF PROVISIONS PROVIDING FOR THE NEW SERVICE OPTION EXCLUSIVE OR UNDULY DISCRIMINATORY? A. No. The tariff provisions are not limited to the initial Parties of the JDA. Any load- 20 serving entity in the PSCo BAA that is willing to sign the JDA, has the ability to 21 contribute generating resources to the JDA pool, and whose host transmission provider 22 agrees to provide joint dispatch service at rates and terms comparable to those proposed 23 in this filing would also be able to participate in the JDA. Exhibit PSC-1 Page 9 of 13 1 Q. 2 3 ARE THE PROPOSED CHANGES CONSISTENT WITH, OR SUPERIOR TO, THE COMMISSION’S PRO FORMA OATT? A. Yes. The new tariff provisions provide for a new type of service for Parties to the JDA 4 that is essentially a license plate rate available to those entities that have committed to 5 joint dispatch of their participating resources to serve load located in the PSCo BAA. 6 These new provisions do not depart from the Commission’s prior determination that 7 PSCo’s OATT conforms with, or is superior to, the pro forma OATT. In addition to 8 being non-discriminatory, the new service will not have an adverse impact on other 9 transmission users. 10 Q. 11 12 PLEASE EXPLAIN HOW THE JOINT DISPATCH TRANSMISSION SERVICE WILL NOT ADVERSELY IMPACT OTHER TRANSMISSION USERS. A. Joint Dispatch Transmission Service is only available if there is posted non-firm 13 Available Transmission Capacity (“ATC”) after all other procurement and scheduling 14 deadlines have passed. PSCo will limit transfers under Joint Dispatch Transmission 15 Service to the amount of unused ATC that remains on the system after such procurement 16 and scheduling deadlines have passed. Although schedule-driven ATC updates may 17 occur every quarter-hour, PSCo will update ATC limits for Joint Dispatch Transmission 18 Service every five minutes. By conducting these updates every five minutes, PSCo will 19 ensure that any immediate intra-hour schedule changes, such as those prompted by 20 outages, are captured and only the leftover ATC be made available for Joint Dispatch 21 Transmission Service. In this way, energy transfers are limited by ATC availability on 22 the system, and participating generation units will be adjusted to limit volumetric 23 transfers between Parties based on unused ATC that remains after the close of Exhibit PSC-1 Page 10 of 13 1 transmission schedules. Thus, Joint Dispatch Transmission Service will only use ATC 2 that would otherwise go unused. Additionally, Joint Dispatch Transmission Service will 3 have the lowest priority, and any party seeking transmission service will be in a queue 4 position higher than Joint Dispatch Transmission Service. 5 Each Party’s transmission service provider will be required to post ATC that 6 PSCo will collect and use to determine appropriate transfer capabilities. Based on 7 historic data, PSCo estimates the transfer capabilities needed to execute the JDA should 8 not exceed 300 MW between parties. Typically, transfers are expected to be less than 9 150 MW. 10 Q. IS PSCO THE ONLY PARTY PROPOSING TO REVISE ITS OATT? 11 A. No. BHCE will be seeking FERC approval of revisions to its OATT that mirror the 12 changes PSCo is proposing here. Further, while PRPA is a non-jurisdictional entity, it 13 has committed to revising its tariff to conform to the revisions proposed by PSCo here. 14 VII DESCRIPTION OF THE SERVICE 15 Q. WHAT TYPE OF TRANSMISSION SERVICES WILL BE PROVIDED UNDER 16 17 THE NEW TARIFF PROVISIONS? A. Joint Dispatch Transmission Service is a non-firm, “as-available” transmission service 18 provided at zero cost that is made available for the sole purpose of facilitating energy 19 transfers pursuant to the JDA. 20 Q. WOULD A JDA BE FEASIBLE WITH TRANSMISSION CHARGES? 21 A. No. Xcel Energy and BHCE explored a joint dispatch arrangement a few years ago, but 22 shelved the idea primarily because the economic benefits would be severely diminished if 23 both PSCo and BHCE secured point-to-point transmission service to facilitate dynamic Exhibit PSC-1 Page 11 of 13 1 transfers or if BHCE became a network customer under the PSCo OATT. 2 proposal too, transmission charges would likely eliminate the benefits that the Parties 3 expect to achieve through the JDA. 4 Q. In this CAN JOINT DISPATCH TRANSMISSION SERVICE BE USED BY A PARTY 5 FOR TRANSACTIONS OTHER THAN TO SERVE NATIVE LOAD WITH JDA 6 ENERGY? 7 A. No. Joint Dispatch Transmission Service will not be available for off-system sales of 8 capacity or energy or for providing direct or indirect transmission service to a third party 9 and is limited to the use described above. The Service cannot be used as a substitute for 10 point-to-point or network service. For off-system purchases and sales, Joint Dispatch 11 Transmission Service Customers must ensure point-to-point transmission service has 12 been obtained, as needed, to import purchases from outside the PSCo BAA, or to export 13 off-system sales, in accordance with FERC regulations. 14 Transmission Service customer will continue to be required to maintain adequate firm 15 network and point-to-point service for its wholesale and retail native load and its 16 contractual commitments. Thus, each Joint Dispatch 17 Q. DOES THE JDA ITSELF PROVIDE FOR TRANSMISSION SERVICE? 18 A. No transmission services are provided under the JDA. 19 Q. WHO CAN TAKE JOINT DISPATCH TRANSMISSION SERVICE? 20 A. Joint Dispatch Transmission Service will be limited to entities that have signed the JDA, 21 offer resources into the JDA pool and serve load within the PSCo BAA. 22 VIII. TRANSMISSION CHARGES 23 Q. WHAT IS THE CHARGE FOR JOINT DISPATCH TRANSMISSION SERVICE? Exhibit PSC-1 Page 12 of 13 1 A. PSCo is proposing that Joint Dispatch Transmission Service be priced at $0 per MWh, 2 meaning that the Joint Dispatch Transmission Service Customers will not pay any 3 charges for receipt and delivery of energy dispatched under the JDA. 4 Dispatch Transmission Service Customer will have to maintain adequate firm network 5 and firm point-to-point service to serve its wholesale and retail native load; no additional 6 transmission service charge will be imposed for energy deliveries under the JDA. The 7 proposed $0 rate is consistent with the nature of this transmission service because the 8 Joint Dispatch Transmission Service will only utilize non-firm ATC within the operating 9 hour that is otherwise unused—capability that is not being compensated currently. In 10 essence Joint Dispatch Transmission Service is a zonal or license plate service since each 11 party to the JDA will be required to maintain network and point-to-point service to serve 12 its load. Each Party will continue to pay point-to-point charges for sales to third parties. Each Joint 13 Q. IS THERE PRECEDENT FOR THIS TYPE OF LICENSE PLATE SERVICE? 14 A. Yes. In Docket No. ER14-1386 the Commission conditionally approved a proposal by 15 California Independent System Operator (“CAISO”) to facilitate and Energy Imbalance 16 Market outside of the CAISO footprint. PacifiCorp is one of the first participants and 17 filed revisions to its OATT in Docket No. ER14-1578 to allow it to participate in the 18 EIM. In that case, FERC conditionally accepted PacifiCorp’s OATT revisions, but 19 specifically rejected the proposal to require participating resources in the EIM in 20 PacifiCorp’s Balancing Authority Area to pay for additional transmission service to 21 participate above what they would regularly pay as transmission customers on PaciCorp’s 22 OATT. Exhibit PSC-1 Page 13 of 13 1 Q. 2 3 HOW WILL ANCILLARY SERVICES BE CHARGED UNDER THESE PROPOSED TARIFF PROVISIONS? A. As provided in the proposed tariff language, all Joint Dispatch Transmission Service 4 Customers will be responsible for losses, paid at pancaked rates. So, for example, if 5 energy is delivered from PRPA to BHCE, which necessarily involves a delivery across 6 PSCo’s system, BHCE will be assessed losses by both PRPA and PSCo. 7 Q. WILL JOINT DISPATCH CUSTOMERS BE RESPONSIBLE FOR ANY OTHER 8 ANCILLARY SERVICE CHARGES? 9 Joint Dispatch Transmission Service Customers will be responsible for services provided 10 by PSCo as a Balancing Authority under the following schedules in the Xcel Energy 11 OATT including Scheduling, System Control and Dispatch, Reactive Supply and Voltage 12 Control, Reserve Sharing, Operating Reserve – Spinning, and Operating Reserve -- 13 Supplemental. 14 Notably, however, while Joint Dispatch Transmission Service Customers would 15 otherwise be responsible for imbalance charges under Schedule 4 of the Xcel Energy 16 OATT. This is because, by definition, PSCo will be responsible for balancing the load 17 and resources of all parties to the JDA. More detail about the services offered under the 18 JDA and the charges associated with those services is found in the companion JDA filing. 19 IX CONCLUSION 20 Q. DOES THIS CONCLUDE YOUR PREPARED PRE-FILED TESTIMONY? 21 A. Yes. EXHIBIT 2 TABLE OF CONTENTS I. COMMON SERVICE PROVISIONS 1 Definitions 1.1 Affiliate 1.2 Ancillary Services 1.3 Annual Transmission Costs 1.4 Application 1.5 Commission 1.6 Completed Application 1.7 Control Area 1.8 Curtailment 1.9 Delivering Party 1.10 Designated Agent 1.11 Direct Assignment Facilities 1.12 Eligible Customer 1.13 Facilities Study 1.14 Firm Point-To-Point Transmission Service 1.15 Good Utility Practice 1.16 Interruption 1.17 Load Ratio Share 1.18 Load Shedding 1.19 Long-Term Firm Point-To-Point Transmission Service 1.20 Native Load Customers 1.21 NERC TLR Procedures 1.22 Network Customer 1.23 Network Integration Transmission Service 1.24 Network Load 1.25 Network Operating Agreement 1.26 Network Operating Committee 1.27 Network Resource 1.28 Network Upgrades 1.29 Non-Firm Point-To-Point Transmission Service 1.30 Non-Firm Sale 1.31 Non-Variable Energy Resource 1.32 Open Access Same-Time Information System (OASIS) 1.33 Part I 1.34 Part II 1.35 Part III 1.35A Part IV 1.36 Parties 1.37 Point(s) of Delivery 1.38 Point(s) of Receipt 1.39 Point-To-Point Transmission Service 1.40 Power Purchaser 1.41 Pre-Confirmed Application 1.42 Receiving Party 1.43 Regional Transmission Group (RTG) 1.44 Reserved Capacity 2 3 4 5 6 7 8 9 10 11 12 1.45 Service Agreement 1.46 Service Commencement Date 1.47 Short-Term Firm Point-To-Point Transmission Service 1.48 System Condition 1.49 System Impact Study 1.50 Third-Party Sale 1.51 Transmission Customer 1.52 Transmission Provider 1.53 Transmission Provider's Monthly Transmission System Peak 1.54 Transmission Service 1.55 Transmission System 1.56 Variable Energy Resource Initial Allocation and Renewal Procedures 2.1 Initial Allocation of Available Transfer Capability 2.2 Reservation Priority For Existing Firm Service Customers Ancillary Services 3.1 Scheduling, System Control and Dispatch Service 3.2 Reactive Supply and Voltage Control from Generation or Other Sources Service 3.3 Regulation and Frequency Response Service 3.4 Energy Imbalance Service 3.5 Operating Reserve - Spinning Reserve Service 3.6 Operating Reserve - Supplemental Reserve Service 3.7 Flex Reserve Service 3.8 Generator Imbalance Service Open Access Same-Time Information System (OASIS) 4.1 Terms and Conditions 4.2 NAESB WEQ Business Practice Standards Local Furnishing Bonds 5.1 Transmission Providers That Own Facilities Financed by Local Furnishing Bonds 5.2 Alternative Procedures for Requesting Transmission Service Reciprocity Billing and Payment 7.1 Billing Procedure 7.2 Interest on Unpaid Balances 7.3 Customer Default Accounting for the Transmission Provider's Use of the Tariff 8.1 Transmission Revenues 8.2 Study Costs and Revenues Regulatory Filings Force Majeure and Indemnification 10.1 Force Majeure 10.2 Indemnification Creditworthiness Dispute Resolution Procedures 12.1 Internal Dispute Resolution Procedures 12.2 Mediation Procedures 12.3 External Arbitration Procedures 12.4 Arbitration Decisions 12.5 Costs 12.6 II. Rights Under The Federal Power Act POINT-TO-POINT TRANSMISSION SERVICE Preamble 13 Nature of Firm Point-To-Point Transmission Service 13.1 Term 13.2 Reservation Priority 13.3 Use of Firm Transmission Service by the Transmission Provider 13.4 Service Agreements 13.5 Transmission Customer Obligations for Facility Additions or Redispatch Costs 13.6 Curtailment of Firm Transmission Service 13.7 Classification of Firm Transmission Service 13.8.1 Scheduling of Firm Point-To-Point Transmission Service on the PSCo System 13.8.2 Scheduling of Firm Point-To-Point Transmission Service on the NSP and SPS Systems 14 Nature of Non-Firm Point-To-Point Transmission Service 14.1 Term 14.2 Reservation Priority 14.3 Use of Non-Firm Point-To-Point Transmission Service by the Transmission Provider 14.4 Service Agreements 14.5 Classification of Non-Firm Point-To-Point Transmission Service 14.6.1 Scheduling of Non-Firm Point-To-Point Transmission Service on the PSCo System 14.6.2 Scheduling of Non-Firm Point-To-Point Transmission Service on the NSP and SPS Systems 14.7 Curtailment or Interruption of Service 15 Service Availability 15.1 General Conditions 15.2 Determination of Available Transfer Capability 15.3 Initiating Service in the Absence of an Executed Service Agreement 15.4 Obligation to Provide Transmission Service that Requires Expansion or Modification of the Transmission System, Redispatch or Conditional Curtailment 15.5 Deferral of Service 15.6 Other Transmission Service Schedules 15.7 Real Power Losses 16 Transmission Customer Responsibilities 16.1 Conditions Required of Transmission Customers 16.2 Transmission Customer Responsibility for Third-Party Arrangements 17 Procedures for Arranging Firm Point-To-Point Transmission Service 17.1 Application 17.2 Completed Application 17.3 Deposit 17.4 Notice of Deficient Application 17.5 Response to a Completed Application 17.6 Execution of Service Agreement 17.7 Extensions for Commencement of Service 18 Procedures for Arranging Non-Firm Point-To-Point Transmission Service 19 20 21 22 23 24 25 26 27 III. 18.1 Application 18.2 Completed Application 18.3.1 Reservation of Non-Firm Point-To-Point Transmission Service on the PSCo System 18.3.2 Reservation of Non-Firm Point-To-Point Transmission Service on the NSP and SPS Systems 18.4 Determination of Available Transfer Capability Additional Study Procedures For Firm Point-To-Point Transmission Service Requests 19.1 Notice of Need for System Impact Study 19.2 System Impact Study Agreement and Cost Reimbursement 19.3 System Impact Study Procedures 19.4.1 Facilities Study Procedures 19.4.2 Clustered Transmission Service Requests 19.5 Facilities Study Modifications 19.6 Due Diligence in Completing New Facilities 19.7 Partial Interim Service 19.8 Expedited Procedures for New Facilities 19.9 Penalties For Failure to Meet Study Deadlines Procedures if The Transmission Provider is Unable to Complete New Transmission Facilities for Firm Point-To-Point Transmission Service 20.1 Delays in Construction of New Facilities 20.2 Alternatives to the Original Facility Additions 20.3 Refund Obligation for Unfinished Facility Additions Provisions Relating to Transmission Construction and Services on the Systems of Other Utilities 21.1 Responsibility for Third-Party System Additions 21.2 Coordination of Third-Party System Additions Changes in Service Specifications 22.1 Modifications On a Non-Firm Basis 22.2 Modification On a Firm Basis Sale or Assignment of Transmission Service 23.1 Procedures for Assignment or Transfer of Service 23.2 Limitations on Assignment or Transfer of Service 23.3 Information on Assignment or Transfer of Service Metering and Power Factor Correction at Receipt and Delivery Points(s) 24.1 Transmission Customer Obligations 24.2 Transmission Provider Access to Metering Data 24.3 Power Factor Compensation for Transmission Service Stranded Cost Recovery Compensation for New Facilities and Redispatch Costs NETWORK INTEGRATION TRANSMISSION SERVICE Preamble 28 Nature of Network Integration Transmission Service 28.1 Scope of Service 28.2 Transmission Provider Responsibilities 28.3 Network Integration Transmission Service 28.4 Secondary Service 28.5 Real Power Losses 29 30 31 32 33 34 28.6 Restrictions on Use of Service Initiating Service 29.1 Condition Precedent for Receiving Service 29.2 Application Procedures: 29.3 Technical Arrangements to be Completed Prior to Commencement of Service 29.4 Network Customer Facilities 29.5 Filing of Service Agreement Network Resources 30.1 Designation of Network Resources 30.2 Designation of New Network Resources 30.3 Termination of Network Resources 30.4 Operation of Network Resources 30.5 Network Customer Redispatch Obligation 30.6 Transmission Arrangements for Network Resources Not Physically Interconnected With The Transmission Provider 30.7 Limitation on Designation of Network Resources 30.8 Use of Interface Capacity by the Network Customer 30.9 Network Customer Owned Transmission Facilities Designation of Network Load 31.1 Network Load 31.2 New Network Loads Connected With the Transmission Provider 31.3 Network Load Not Physically Interconnected with the Transmission Provider 31.4 New Interconnection Points 31.5 Changes in Service Requests 31.6 Annual Load and Resource Information Updates Additional Study Procedures For Network Integration Transmission Service Requests 32.1 Notice of Need for System Impact Study 32.2 System Impact Study Agreement and Cost Reimbursement 32.3 System Impact Study Procedures 32.4.1 Facilities Study Procedures 32.4.2 Clustered Transmission Service Requests 32.5 Penalties For Failure to Meet Study Deadlines Load Shedding and Curtailments 33.1.1 Procedures on the PSCo System 33.1.2 Procedures on the NSP and SPS Systems 33.2 Transmission Constraints 33.3 Cost Responsibility for Relieving Transmission Constraints 33.4 Curtailments of Scheduled Deliveries 33.5 Allocation of Curtailments 33.6 Load Shedding 33.7 System Reliability Rates and Charges 34.1.1 Monthly Demand Charge on the SPS Transmission System 34.1.2 Monthly Demand Charge on the PSCo Transmission System 34.2 Determination of Network Customer's Monthly Network Load 34.3 Determination of Network Customer’s Average Network Load on the SPS System 34.4 35 Determination of Transmission Provider's Monthly Transmission System Load on the SPS Transmission System 34.5 Reserved For Future Use 34.6 Determination of Transmission Provider’s Average Transmission System Load on the SPS Transmission System 34.7 Redispatch Charge 34.8 Stranded Cost Recovery 34.9 SPS Meter Charge Operating Arrangements 35.1 Operation under The Network Operating Agreement 35.2 Network Operating Agreement 35.3 Network Operating Committee IV. BALANCING AUTHORITY ANCILLARY SERVICES Preamble 36 Definitions 36.1 Ancillary Service Customer (ASC) 36.2 Ancillary Service Load 36.3 Balancing Authority Area (BAA) 36.4 Balancing Authority (BA) Operator 36.5 Balancing Authority (BA) Services 36.6 Internal Transmission Owner (ITO 36.7 Load Serving Entity (LSE) 36.8 Reserved Capacity 36.9 RMRG 36.10 WECC 37 Nature of Balancing Authority Services 37.1 Requirement to Provide and Obtain BA Services 37.2 Source and Acquisition of BA Services 37.3 Sufficiency of Balancing Authority Services 37.4 Real Power Losses 37.5 Service Agreements 37.6 No Transmission Service Provided 38 Authority and Obligations 38.1 BA Operator Authority 38.2 ASC Obligations 39 Metering 39.1 ASC Obligations 39.2 Metering Data 39.3 Testing 39.4 Meter Failure 39.5 Billing Adjustments 39.6 Examination of Records 39.7 BA Operator Access to Metering Data 40 Billing V. JOINT DISPATCH TRANSMISSION SERVICE (Applicable to Public Service Company of Colorado only) Preamble 41 Definitions 41.1 Joint Dispatch Arrangement 41.2 41.3 41.4 42 43 Joint Dispatch Agreement Joint Dispatch Transmission Service Service Agreement for Joint Dispatch Transmission Service (“Service Agreement”) 41.5 Joint Dispatch Transmission Service Customer Nature of Joint Dispatch Transmission Service 42.1 Limited Transmission Provider Responsibilities 42.2 Real Power Losses 42.3 Restrictions on Use of Service 42.4 Imbalance Service Initiating Service 43.1 Condition Precedent for Receiving Service 43.2 Application Procedures 43.3 Joint Dispatch Transmission Customer Facilities 43.4 Filing of Service Agreement SCHEDULE 1 SCHEDULE 2 SCHEDULE 3 SCHEDULE 3A - Scheduling, System Control and Dispatch Service Reactive Supply and Voltage Control from Generation Sources Service Regulation and Frequency Response Service Regulation and Frequency Response Service for Point-To-Point Transmission Service for the PSCo Balancing Authority Area SCHEDULE 4 Energy Imbalance Service SCHEDULE 4A Reserve Sharing Energy Charges SCHEDULE 4B Reserve Sharing Energy Charges SCHEDULE 5 Operating Reserve - Spinning Reserve Service SCHEDULE 6 Operating Reserve - Supplemental Reserve Service SCHEDULE 6A Flex Reserve Service SCHEDULE 7 Long-Term Firm and Short-Term Firm Point-To-Point Transmission Service SCHEDULE 8 Non-Firm Point-To-Point Transmission Service SCHEDULE 9 Generator Imbalance Service SCHEDULE 10 Tax Adjustment Rider for Service by Southwestern Public Service Company SCHEDULE 11 Reserved For Future Use SCHEDULE 12 Midwest Independent Transmission System Operator, Inc. Charges SCHEDULE 13 Network Integration Transmission Service on the PSCo Transmission System SCHEDULE 13A Network Integration Transmission Service across the Lamar Tie Line SCHEDULE 14 Point-to-Point Transmission Losses on the PSCo Transmission System SCHEDULE 15 Joint Dispatch Transmission Service ATTACHMENT A-1 - Form of Service Agreement For Short-Term Firm Point-To-Point Transmission Service ATTACHMENT A-2 - Form of Service Agreement For Long-Term Firm Point-To-Point Transmission Service ATTACHMENT A-3 - Form of Service Agreement For The Resale, Reassignment Or Transfer Of Point-To-Point Transmission Service ATTACHMENT B - Form of Service Agreement For Non-Firm Point-To-Point Transmission Service ATTACHMENT C - Methodology To Assess Available Transfer Capability ATTACHMENT D ATTACHMENT E ATTACHMENT F - Methodology for Completing a System Impact Study Index of Point-To-Point Transmission Service Customers Form of Service Agreement For Network Integration Transmission Service ATTACHMENT G - Form of Network Operating Agreement ATTACHMENT H - Annual Transmission Revenue Requirement For Network Integration Transmission Service ATTACHMENT I Index of Network Integration Transmission Service Customers ATTACHMENT J - Procedures for Addressing Parallel Flows ATTACHMENT K - Form of System Impact Study Agreement ATTACHMENT L - Form of Facilities Study Agreement ATTACHMENT M - Methodology for Allocating Transmission Revenues Among Utility Operating Companies ATTACHMENT N - Standard Large Generator Interconnection Procedures (LGIP) Applicable to Generating Facilities that exceed 20 MWs ATTACHMENT O - Public Service Company of Colorado Formulaic Rates ATTACHMENT O – SPS - Southwestern Public Service Company Formulaic Rates ATTACHMENT P - Standard Small Generator Interconnection Procedures (SGIP) Applicable to Generating Facilities less than 20 MWs ATTACHMENT Q - Creditworthiness Procedures ATTACHMENT R – PSCo - Transmission Planning Process ATTACHMENT S - Reserved For Future Use ATTACHMENT T - Form of Service Agreement For Balancing Authority Ancillary Services Applicable to the Public Service Company of Colorado (PSCo) System ATTACHMENT U - Form of Service Agreement For Transmission to Load Interconnection Service ATTACHMENT V - Form of Service Agreement For Joint Dispatch Transmission Service ATTACHMENT AA – Service Agreements For Point-To-Point Transmission Service ATTACHMENT BB – Service Agreements For Network Transmission Service ATTACHMENT CC – Service Agreements For Generation Interconnection Service ATTACHMENT DD – Service Agreements For Balancing Authority Ancillary Services ATTACHMENT EE - Reserved For Future Use ATTACHMENT FF – Service Agreements For Transmission to Load Interconnection Service Additional Volumes of Xcel Energy Operating Companies Transmission Service Tariffs Volume No. Contents Joint Open Access Transmission Tariff Original Volume 2 Reserved for Future Use FERC Electric Transmission Tariff Original Volume 3 Northern States Power Company transmission rate schedules Original Volume 4 Northern States Power Company (Wisconsin) transmission rate schedules Original Volume 5 Public Service Company of Colorado transmission rate schedules Original Volume 6 Southwestern Public Service Company) transmission rate schedules Original Volume 7 WestConnect Point-to-Point Regional Transmission Service Experiment Tariff Note: The noted tariff volumes contain transmission-related rate schedules filed by the Transmission Services function of the Xcel Energy Operating Companies. Rate schedules related to electric supply services may be found in the Electric Services Tariffs separately maintained by the Xcel Energy Markets function. V. JOINT DISPATCH TRANSMISSION SERVICE (Applicable to Public Service Company of Colorado only) Preamble Service under Part V shall be applicable only to load serving entities in the PSCo Balancing Authority Area that are signatories to a Joint Dispatch Agreement (JDA) under which: (1) participating generating resources of the parties are dispatched as a pool on a least-cost basis respecting transmission limitations; (2) the Joint Dispatch Transmission Service Customers’ respective transmission service providers have provided within their OATT a transmission service schedule for energy dispatched pursuant to the JDA at a rate equal to zero dollars on a non-firm, as-available basis with the lowest curtailment priority, pursuant to the provisions of this Part V of the Tariff. 41 Definitions In addition to the Definitions and Terms set forth in the Common Service Provisions found in Part 1 of this Tariff, the following definitions shall apply to this Part V, the Joint Dispatch Services set forth in Schedule 15 and Attachment V of this Tariff. 42 41.1 Joint Dispatch Arrangement: An operating arrangement whereby participating generation resources owned, operated or controlled by load serving entities within the PSCo Balancing Authority Area are dispatched as a pool on a leastcost basis respecting transmission limitations in order to economically optimize dispatch on an aggregate real-time basis among all participants in the Joint Dispatch Arrangement. 41.2 Joint Dispatch Agreement: An agreement detailing the rights and obligations of participants in a Joint Dispatch Arrangement. 41.3 Joint Dispatch Transmission Service: Non-firm transmission service across transmission facilities of the Transmission Provider that is used to transmit energy dispatched pursuant to a Joint Dispatch Agreement and that is subject to the provisions of this Part V of the Tariff. Joint Dispatch Transmission Service will be made available from posted ATC after procurement and scheduling deadlines have passed for the current operating hour, as specified in the Transmission Provider’s Business Practices posted on OASIS. 41.4 Service Agreement for Joint Dispatch Transmission Service (“Service Agreement”): An agreement between the Transmission Provider and a Joint Dispatch Transmission Service Customer for Joint Dispatch Transmission Service. 41.5 Joint Dispatch Transmission Service Customer: Any entity (or its Designated Agent) that: (i) executes a Service Agreement; or (ii) requests in writing that the Transmission Provider file with the Commission a proposed unexecuted Service Agreement. Nature of Joint Dispatch Transmission Service Joint Dispatch Transmission Service is an optional service available to any load serving entity in the PSCo Balancing Authority Area that: (1) has entered into a Joint Dispatch Agreement; and (2) makes Joint Dispatch Transmission Service on its transmission system, if any, available to PSCo and all other parties to the Joint Dispatch Agreement at the same rate, terms, and conditions as set out in this Part V of the Tariff and related schedules and attachments. As further detailed herein, Joint Dispatch Transmission Service may only be used to deliver energy dispatched under a Joint Dispatch Agreement to the entity’s wholesale and retail native load customers. Joint Dispatch Transmission Service is provided only on a non-firm, as available basis and has the lowest curtailment priority. 42.1 Limited Transmission Provider Responsibilities. The Transmission Provider shall have the obligation to operate its Transmission System in accordance with Good Utility Practice. For purposes of Joint Dispatch Transmission Service, the Transmission Provider shall have no obligation to plan, construct, or maintain its Transmission System for the benefit of any Joint Dispatch Transmission Service Customer. 42.2 Real Power Losses. Real Power Losses are associated with all transmission service. The Joint Dispatch Transmission Service Customer shall be responsible for all losses associated with Joint Dispatch Transmission Service, which responsibility shall be manifested as the difference between the amount of energy dispatched on behalf of the Joint Dispatch Transmission Service Customer and the amount of energy actually delivered to such customer based on the following loss factors. PRPA Seller Buyer PRPA PSCo BHCE PRPA PRPA+PSCo PSCo BHCE PSCo PSCo+BHCE BHCE PSCo Where: PRPA= Loss Factor set forth in PRPA’s OATT Section 15.7 (where PRPA’s Loss Factor 1.7% as of January 1, 2015) PSCo=Loss Factor set forth in PSCo OATT Section 15.7 (where PSCo’s Loss Factor is 2.56% as of January 1, 2015) BHCE= Loss Factor set forth in BHCE OATT Section 15.7 (BHCE’s Loss Factor is 1.94% as of January 1, 2015) 42.3 Restrictions on Use of Service. The Joint Dispatch Transmission Service Customer shall not use Joint Dispatch Transmission Service for (i) off-system sales of capacity or energy or (ii) direct or indirect provision of transmission service by the Joint Dispatch Transmission Service Customer to any third party. Joint Dispatch Transmission Service may be used only for receipt or delivery of energy dispatched within the PSCo Balancing Authority Area on a non-firm basis to serve wholesale or retail native load of any participant in a Joint Dispatch Agreement. 42.4 43 Imbalance Service. The purpose of the Joint Dispatch Arrangement is to balance loads and resources of the parties by optimizing dispatch of the parties’ resources. As a result, the Transmission Provider shall not assess energy imbalance charges under Ancillary Service Schedule 4 or 9 to any Joint Dispatch Transmission Service Customer. Initiating Service 43.1 Condition Precedent for Receiving Service. Subject to the terms and conditions of this Part V of the Tariff, and related schedules and attachments, the Transmission Provider will provide Joint Dispatch Transmission Service to any eligible customer, provided that (i) the eligible customer has wholesale or retail native load in the Transmission Provider’s Balancing Authority Area; (ii) the eligible customer has entered into a Joint Dispatch Agreement; (iii) the eligible customer’s transmission provider has a transmission service tariff offering Joint Dispatch Transmission Service on the same terms and conditions as offered under this Part V of the Tariff, and related schedules and attachments; and (iv) the eligible customer executes a Service Agreement pursuant to Attachment V for service under this Part V of the Tariff or requests in writing that the Transmission Provider file a proposed unexecuted Service Agreement with the Commission. 43.2 Application Procedures. An Eligible Customer requesting service under Part V of this Tariff must submit an application containing the information specified below. No deposit or credit evaluation is necessary to obtain Joint Dispatch Transmission Service. Further, no transmission studies shall be required to obtain Joint Dispatch Transmission Service because such service is provided only on a non-firm, as available basis. Applications should be submitted to the Transmission Provider via e-mail to the person(s) listed on OASIS. Application contents: (i) (ii) (iii) (iv) (v) (vi) (vii) The identity, address, telephone number and facsimile number of the party requesting service; A statement that the party requesting service is, or will be upon commencement of service, an Eligible Customer under the tariff; A statement that the party requesting service has, or will have upon commencement of service, wholesale or retail native load in the PSCo Balancing Authority Area; A statement that the party requesting service has, or will have upon commencement of service, entered into a Joint Dispatch Agreement with PSCo; A statement that the party requesting service has, or will have upon commencement of service, a tariff offering Joint Dispatch Transmission Service at the same rates, terms, and conditions as this Part V of the Tariff and associated schedules and attachments; Service Commencement Date and the term of the requested Joint Dispatch Transmission Service. A statement signed by an authorized officer from or agent of the Joint Dispatch Transmission Service Customer attesting that Joint Dispatch (viii) Transmission Service will be used only for receipt or delivery of energy dispatched under a Joint Dispatch Agreement for the benefit of that customer’s wholesale and retail native load customers. Service is conditioned on the Transmission Provider being in receipt of an executed Joint Dispatch Agreement. Unless the Parties agree to a different timeframe, the Transmission Provider must acknowledge the request within ten (15) days of receipt. The acknowledgement must include a date by which a response, including a Service Agreement, will be sent to the Eligible Customer. If an application fails to meet the requirements of this section, the Transmission Provider shall notify the Eligible Customer requesting service within fifteen (15) days of receipt and specify the reasons for such failure. Wherever reasonably possible, the Transmission Provider will attempt to remedy deficiencies in the Application through informal communications with the Eligible Customer. If efforts are unsuccessful, the Transmission Provider shall return the Application, without prejudice to the Eligible Customer filing a new or revised Application that fully complies with the requirements of this section. 43.3 Joint Dispatch Transmission Customer Facilities: The Joint Dispatch Transmission Service Customer’s transmission provider will retain its existing obligations to plan, construct, operate and maintain its transmission system using standard utility practices. 43.4 Filing of Service Agreement. The Transmission Provider will file Service Agreements with the Commission in compliance with applicable Commission regulations, if any. Schedule 15 Joint Dispatch Transmission Service This is an optional service provided by PSCo, subject to the terms and conditions of Part V of this Tariff. For Joint Dispatch Transmission Service Customers meeting the conditions set forth in Part V of this Tariff, no charge shall be assessed for receipt or delivery of energy dispatched pursuant to a Joint Dispatch Agreement with PSCo provided the customer makes Joint Dispatch Transmission Service available to PSCo at the same rates, terms, and conditions as set forth in Part V of this Tariff, this Schedule 15, and any other related schedules or attachments to this Tariff. Joint Dispatch Transmission Service is provided in real-time on a non-firm, as available basis having the lowest curtailment priority. 1) Monthly delivery: the rate or $0.00/kW-month of Reserved Capacity. 2) Weekly delivery: the rate $0.00/kW-week of Reserved Capacity. 3) Daily delivery: the rate $0.00/kW-day of Reserved Capacity. 4) Hourly delivery: On-Peak Hours: the on-peak rate $0.00/MWh of Reserved Capacity. Off-Peak Hours: the off-peak rate $0.00/MWh of Reserved Capacity. ATTACHMENT V Form of Service Agreement For Joint Dispatch Transmission Service Applicable to the Public Service Company of Colorado (PSCo) System 1.0 This Joint Dispatch Transmission Service Agreement, dated as of __________________________, is entered into, by and between __________________________ (“Transmission Provider”), and __________________________ ("Joint Dispatch Transmission Customer"), all of whom may be referred to individually as “Party” or jointly as “Parties”. 2.0 The Joint Dispatch Transmission Customer has been determined by the Transmission Provider to have a signed a Joint Dispatch Agreement. 3.0 Service under this agreement shall commence on the later of (1) the requested service commencement date, or (2) such other date as it is permitted to become effective by the Commission. Service under this agreement shall terminate on such date as mutually agreed upon by the parties. 4.0 Any notice or request made to or by either Party regarding this Service Agreement shall be made to the representative of the other Party as indicated below. Transmission Provider: _____________________________________ _____________________________________ _____________________________________ Transmission Customer: _____________________________________ _____________________________________ _____________________________________ 5.0 The Tariff is incorporated herein and made a part hereof. IN WITNESS WHEREOF, the Parties have caused this Service Agreement to be executed by their respective authorized officials. Transmission Provider: By: ___________________ ___________________ ___________________ Name Title Date Transmission Customer: By: ___________________ ___________________ ___________________ Name Title Date EXHIBIT 3 Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 TABLE OF CONTENTS Version: 0.4.0 Effective: 1/1/2015 TABLE OF CONTENTS I. COMMON SERVICE PROVISIONS 1 Definitions 1.1 Affiliate 1.2 Ancillary Services 1.3 Annual Transmission Costs 1.4 Application 1.5 Commission 1.6 Completed Application 1.7 Control Area 1.8 Curtailment 1.9 Delivering Party 1.10 Designated Agent 1.11 Direct Assignment Facilities 1.12 Eligible Customer 1.13 Facilities Study 1.14 Firm Point-To-Point Transmission Service 1.15 Good Utility Practice 1.16 Interruption 1.17 Load Ratio Share 1.18 Load Shedding 1.19 Long-Term Firm Point-To-Point Transmission Service 1.20 Native Load Customers 1.21 NERC TLR Procedures 1.22 Network Customer 1.23 Network Integration Transmission Service 1.24 Network Load 1.25 Network Operating Agreement 1.26 Network Operating Committee 1.27 Network Resource 1.28 Network Upgrades 1.29 Non-Firm Point-To-Point Transmission Service 1.30 Non-Firm Sale 1.31 Non-Variable Energy Resource 1.32 Open Access Same-Time Information System (OASIS) 1.33 Part I 1.34 Part II 1.35 Part III 1.35A Part IV 1.36 Parties 1.37 Point(s) of Delivery 1.38 Point(s) of Receipt 1.39 Point-To-Point Transmission Service 1.40 Power Purchaser 1.41 Pre-Confirmed Application 1.42 Receiving Party 1.43 Regional Transmission Group (RTG) 1.44 Reserved Capacity Page No. 1 Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 2 3 4 5 6 7 8 9 10 11 12 Page No. 2 1.45 Service Agreement 1.46 Service Commencement Date 1.47 Short-Term Firm Point-To-Point Transmission Service 1.48 System Condition 1.49 System Impact Study 1.50 Third-Party Sale 1.51 Transmission Customer 1.52 Transmission Provider 1.53 Transmission Provider's Monthly Transmission System Peak 1.54 Transmission Service 1.55 Transmission System 1.56 Variable Energy Resource Initial Allocation and Renewal Procedures 2.1 Initial Allocation of Available Transfer Capability 2.2 Reservation Priority For Existing Firm Service Customers Ancillary Services 3.1 Scheduling, System Control and Dispatch Service 3.2 Reactive Supply and Voltage Control from Generation or Other Sources Service 3.3 Regulation and Frequency Response Service 3.4 Energy Imbalance Service 3.5 Operating Reserve - Spinning Reserve Service 3.6 Operating Reserve - Supplemental Reserve Service 3.7 Flex Reserve Service 3.8 Generator Imbalance Service Open Access Same-Time Information System (OASIS) 4.1 Terms and Conditions 4.2 NAESB WEQ Business Practice Standards Local Furnishing Bonds 5.1 Transmission Providers That Own Facilities Financed by Local Furnishing Bonds 5.2 Alternative Procedures for Requesting Transmission Service Reciprocity Billing and Payment 7.1 Billing Procedure 7.2 Interest on Unpaid Balances 7.3 Customer Default Accounting for the Transmission Provider's Use of the Tariff 8.1 Transmission Revenues 8.2 Study Costs and Revenues Regulatory Filings Force Majeure and Indemnification 10.1 Force Majeure 10.2 Indemnification Creditworthiness Dispute Resolution Procedures 12.1 Internal Dispute Resolution Procedures 12.2 Mediation Procedures 12.3 External Arbitration Procedures 12.4 Arbitration Decisions 12.5 Costs Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 12.6 II. Page No. 3 Rights Under The Federal Power Act POINT-TO-POINT TRANSMISSION SERVICE Preamble 13 Nature of Firm Point-To-Point Transmission Service 13.1 Term 13.2 Reservation Priority 13.3 Use of Firm Transmission Service by the Transmission Provider 13.4 Service Agreements 13.5 Transmission Customer Obligations for Facility Additions or Redispatch Costs 13.6 Curtailment of Firm Transmission Service 13.7 Classification of Firm Transmission Service 13.8.1 Scheduling of Firm Point-To-Point Transmission Service on the PSCo System 13.8.2 Scheduling of Firm Point-To-Point Transmission Service on the NSP and SPS Systems 14 Nature of Non-Firm Point-To-Point Transmission Service 14.1 Term 14.2 Reservation Priority 14.3 Use of Non-Firm Point-To-Point Transmission Service by the Transmission Provider 14.4 Service Agreements 14.5 Classification of Non-Firm Point-To-Point Transmission Service 14.6.1 Scheduling of Non-Firm Point-To-Point Transmission Service on the PSCo System 14.6.2 Scheduling of Non-Firm Point-To-Point Transmission Service on the NSP and SPS Systems 14.7 Curtailment or Interruption of Service 15 Service Availability 15.1 General Conditions 15.2 Determination of Available Transfer Capability 15.3 Initiating Service in the Absence of an Executed Service Agreement 15.4 Obligation to Provide Transmission Service that Requires Expansion or Modification of the Transmission System, Redispatch or Conditional Curtailment 15.5 Deferral of Service 15.6 Other Transmission Service Schedules 15.7 Real Power Losses 16 Transmission Customer Responsibilities 16.1 Conditions Required of Transmission Customers 16.2 Transmission Customer Responsibility for Third-Party Arrangements 17 Procedures for Arranging Firm Point-To-Point Transmission Service 17.1 Application 17.2 Completed Application 17.3 Deposit 17.4 Notice of Deficient Application 17.5 Response to a Completed Application 17.6 Execution of Service Agreement 17.7 Extensions for Commencement of Service 18 Procedures for Arranging Non-Firm Point-To-Point Transmission Service Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 19 20 21 22 23 24 25 26 27 III. Page No. 4 18.1 Application 18.2 Completed Application 18.3.1 Reservation of Non-Firm Point-To-Point Transmission Service on the PSCo System 18.3.2 Reservation of Non-Firm Point-To-Point Transmission Service on the NSP and SPS Systems 18.4 Determination of Available Transfer Capability Additional Study Procedures For Firm Point-To-Point Transmission Service Requests 19.1 Notice of Need for System Impact Study 19.2 System Impact Study Agreement and Cost Reimbursement 19.3 System Impact Study Procedures 19.4.1 Facilities Study Procedures 19.4.2 Clustered Transmission Service Requests 19.5 Facilities Study Modifications 19.6 Due Diligence in Completing New Facilities 19.7 Partial Interim Service 19.8 Expedited Procedures for New Facilities 19.9 Penalties For Failure to Meet Study Deadlines Procedures if The Transmission Provider is Unable to Complete New Transmission Facilities for Firm Point-To-Point Transmission Service 20.1 Delays in Construction of New Facilities 20.2 Alternatives to the Original Facility Additions 20.3 Refund Obligation for Unfinished Facility Additions Provisions Relating to Transmission Construction and Services on the Systems of Other Utilities 21.1 Responsibility for Third-Party System Additions 21.2 Coordination of Third-Party System Additions Changes in Service Specifications 22.1 Modifications On a Non-Firm Basis 22.2 Modification On a Firm Basis Sale or Assignment of Transmission Service 23.1 Procedures for Assignment or Transfer of Service 23.2 Limitations on Assignment or Transfer of Service 23.3 Information on Assignment or Transfer of Service Metering and Power Factor Correction at Receipt and Delivery Points(s) 24.1 Transmission Customer Obligations 24.2 Transmission Provider Access to Metering Data 24.3 Power Factor Compensation for Transmission Service Stranded Cost Recovery Compensation for New Facilities and Redispatch Costs NETWORK INTEGRATION TRANSMISSION SERVICE Preamble 28 Nature of Network Integration Transmission Service 28.1 Scope of Service 28.2 Transmission Provider Responsibilities 28.3 Network Integration Transmission Service 28.4 Secondary Service 28.5 Real Power Losses Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 29 30 31 32 33 34 Page No. 5 28.6 Restrictions on Use of Service Initiating Service 29.1 Condition Precedent for Receiving Service 29.2 Application Procedures: 29.3 Technical Arrangements to be Completed Prior to Commencement of Service 29.4 Network Customer Facilities 29.5 Filing of Service Agreement Network Resources 30.1 Designation of Network Resources 30.2 Designation of New Network Resources 30.3 Termination of Network Resources 30.4 Operation of Network Resources 30.5 Network Customer Redispatch Obligation 30.6 Transmission Arrangements for Network Resources Not Physically Interconnected With The Transmission Provider 30.7 Limitation on Designation of Network Resources 30.8 Use of Interface Capacity by the Network Customer 30.9 Network Customer Owned Transmission Facilities Designation of Network Load 31.1 Network Load 31.2 New Network Loads Connected With the Transmission Provider 31.3 Network Load Not Physically Interconnected with the Transmission Provider 31.4 New Interconnection Points 31.5 Changes in Service Requests 31.6 Annual Load and Resource Information Updates Additional Study Procedures For Network Integration Transmission Service Requests 32.1 Notice of Need for System Impact Study 32.2 System Impact Study Agreement and Cost Reimbursement 32.3 System Impact Study Procedures 32.4.1 Facilities Study Procedures 32.4.2 Clustered Transmission Service Requests 32.5 Penalties For Failure to Meet Study Deadlines Load Shedding and Curtailments 33.1.1 Procedures on the PSCo System 33.1.2 Procedures on the NSP and SPS Systems 33.2 Transmission Constraints 33.3 Cost Responsibility for Relieving Transmission Constraints 33.4 Curtailments of Scheduled Deliveries 33.5 Allocation of Curtailments 33.6 Load Shedding 33.7 System Reliability Rates and Charges 34.1.1 Monthly Demand Charge on the SPS Transmission System 34.1.2 Monthly Demand Charge on the PSCo Transmission System 34.2 Determination of Network Customer's Monthly Network Load 34.3 Determination of Network Customer’s Average Network Load on the SPS System Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 6 34.4 35 Determination of Transmission Provider's Monthly Transmission System Load on the SPS Transmission System 34.5 Reserved For Future Use 34.6 Determination of Transmission Provider’s Average Transmission System Load on the SPS Transmission System 34.7 Redispatch Charge 34.8 Stranded Cost Recovery 34.9 SPS Meter Charge Operating Arrangements 35.1 Operation under The Network Operating Agreement 35.2 Network Operating Agreement 35.3 Network Operating Committee IV. BALANCING AUTHORITY ANCILLARY SERVICES Preamble 36 Definitions 36.1 Ancillary Service Customer (ASC) 36.2 Ancillary Service Load 36.3 Balancing Authority Area (BAA) 36.4 Balancing Authority (BA) Operator 36.5 Balancing Authority (BA) Services 36.6 Internal Transmission Owner (ITO 36.7 Load Serving Entity (LSE) 36.8 Reserved Capacity 36.9 RMRG 36.10 WECC 37 Nature of Balancing Authority Services 37.1 Requirement to Provide and Obtain BA Services 37.2 Source and Acquisition of BA Services 37.3 Sufficiency of Balancing Authority Services 37.4 Real Power Losses 37.5 Service Agreements 37.6 No Transmission Service Provided 38 Authority and Obligations 38.1 BA Operator Authority 38.2 ASC Obligations 39 Metering 39.1 ASC Obligations 39.2 Metering Data 39.3 Testing 39.4 Meter Failure 39.5 Billing Adjustments 39.6 Examination of Records 39.7 BA Operator Access to Metering Data 40 Billing V. JOINT DISPATCH TRANSMISSION SERVICE (Applicable to Public Service Company of Colorado only) Preamble 41 Definitions 41.1 Joint Dispatch Arrangement Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 7 41.2 41.3 41.4 42 43 Joint Dispatch Agreement Joint Dispatch Transmission Service Service Agreement for Joint Dispatch Transmission Service (“Service Agreement”) 41.5 Joint Dispatch Transmission Service Customer Nature of Joint Dispatch Transmission Service 42.1 Limited Transmission Provider Responsibilities 42.2 Real Power Losses 42.3 Restrictions on Use of Service 42.4 Imbalance Service Initiating Service 43.1 Condition Precedent for Receiving Service 43.2 Application Procedures 43.3 Joint Dispatch Transmission Customer Facilities 43.4 Filing of Service Agreement SCHEDULE 1 SCHEDULE 2 SCHEDULE 3 SCHEDULE 3A - Scheduling, System Control and Dispatch Service Reactive Supply and Voltage Control from Generation Sources Service Regulation and Frequency Response Service Regulation and Frequency Response Service for Point-To-Point Transmission Service for the PSCo Balancing Authority Area SCHEDULE 4 Energy Imbalance Service SCHEDULE 4A Reserve Sharing Energy Charges SCHEDULE 4B Reserve Sharing Energy Charges SCHEDULE 5 Operating Reserve - Spinning Reserve Service SCHEDULE 6 Operating Reserve - Supplemental Reserve Service SCHEDULE 6A Flex Reserve Service SCHEDULE 7 Long-Term Firm and Short-Term Firm Point-To-Point Transmission Service SCHEDULE 8 Non-Firm Point-To-Point Transmission Service SCHEDULE 9 Generator Imbalance Service SCHEDULE 10 Tax Adjustment Rider for Service by Southwestern Public Service Company SCHEDULE 11 Reserved For Future Use SCHEDULE 12 Midwest Independent Transmission System Operator, Inc. Charges SCHEDULE 13 Network Integration Transmission Service on the PSCo Transmission System SCHEDULE 13A Network Integration Transmission Service across the Lamar Tie Line SCHEDULE 14 Point-to-Point Transmission Losses on the PSCo Transmission System SCHEDULE 15 Joint Dispatch Transmission Service ATTACHMENT A-1 - Form of Service Agreement For Short-Term Firm Point-To-Point Transmission Service ATTACHMENT A-2 - Form of Service Agreement For Long-Term Firm Point-To-Point Transmission Service ATTACHMENT A-3 - Form of Service Agreement For The Resale, Reassignment Or Transfer Of Point-To-Point Transmission Service ATTACHMENT B - Form of Service Agreement For Non-Firm Point-To-Point Transmission Service ATTACHMENT C - Methodology To Assess Available Transfer Capability Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 ATTACHMENT D ATTACHMENT E ATTACHMENT F - Page No. 8 Methodology for Completing a System Impact Study Index of Point-To-Point Transmission Service Customers Form of Service Agreement For Network Integration Transmission Service ATTACHMENT G - Form of Network Operating Agreement ATTACHMENT H - Annual Transmission Revenue Requirement For Network Integration Transmission Service ATTACHMENT I Index of Network Integration Transmission Service Customers ATTACHMENT J - Procedures for Addressing Parallel Flows ATTACHMENT K - Form of System Impact Study Agreement ATTACHMENT L - Form of Facilities Study Agreement ATTACHMENT M - Methodology for Allocating Transmission Revenues Among Utility Operating Companies ATTACHMENT N - Standard Large Generator Interconnection Procedures (LGIP) Applicable to Generating Facilities that exceed 20 MWs ATTACHMENT O - Public Service Company of Colorado Formulaic Rates ATTACHMENT O – SPS - Southwestern Public Service Company Formulaic Rates ATTACHMENT P - Standard Small Generator Interconnection Procedures (SGIP) Applicable to Generating Facilities less than 20 MWs ATTACHMENT Q - Creditworthiness Procedures ATTACHMENT R – PSCo - Transmission Planning Process ATTACHMENT S - Reserved For Future Use ATTACHMENT T - Form of Service Agreement For Balancing Authority Ancillary Services Applicable to the Public Service Company of Colorado (PSCo) System ATTACHMENT U - Form of Service Agreement For Transmission to Load Interconnection Service ATTACHMENT V - Form of Service Agreement For Joint Dispatch Transmission Service ATTACHMENT AA – Service Agreements For Point-To-Point Transmission Service ATTACHMENT BB – Service Agreements For Network Transmission Service ATTACHMENT CC – Service Agreements For Generation Interconnection Service ATTACHMENT DD – Service Agreements For Balancing Authority Ancillary Services ATTACHMENT EE - Reserved For Future Use ATTACHMENT FF – Service Agreements For Transmission to Load Interconnection Service Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 9 Additional Volumes of Xcel Energy Operating Companies Transmission Service Tariffs Volume No. Contents Joint Open Access Transmission Tariff Original Volume 2 Reserved for Future Use FERC Electric Transmission Tariff Original Volume 3 Northern States Power Company transmission rate schedules Original Volume 4 Northern States Power Company (Wisconsin) transmission rate schedules Original Volume 5 Public Service Company of Colorado transmission rate schedules Original Volume 6 Southwestern Public Service Company) transmission rate schedules Original Volume 7 WestConnect Point-to-Point Regional Transmission Service Experiment Tariff Note: The noted tariff volumes contain transmission-related rate schedules filed by the Transmission Services function of the Xcel Energy Operating Companies. Rate schedules related to electric supply services may be found in the Electric Services Tariffs separately maintained by the Xcel Energy Markets function. Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 10 Part V Joint Dispatch Trans Svc Version: 0.0.0 Effective: 1/1/2015 V. JOINT DISPATCH TRANSMISSION SERVICE (Applicable to Public Service Company of Colorado only) Preamble Service under Part V shall be applicable only to load serving entities in the PSCo Balancing Authority Area that are signatories to a Joint Dispatch Agreement (JDA) under which: (1) participating generating resources of the parties are dispatched as a pool on a least-cost basis respecting transmission limitations; (2) the Joint Dispatch Transmission Service Customers’ respective transmission service providers have provided within their OATT a transmission service schedule for energy dispatched pursuant to the JDA at a rate equal to zero dollars on a non-firm, as-available basis with the lowest curtailment priority, pursuant to the provisions of this Part V of the Tariff. Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 11 41 Definitions Version: 0.0.0 Effective: 1/1/2015 41 Definitions In addition to the Definitions and Terms set forth in the Common Service Provisions found in Part 1 of this Tariff, the following definitions shall apply to this Part V, the Joint Dispatch Services set forth in Schedule 15 and Attachment V of this Tariff. 41.1 Joint Dispatch Arrangement: An operating arrangement whereby participating generation resources owned, operated or controlled by load serving entities within the PSCo Balancing Authority Area are dispatched as a pool on a leastcost basis respecting transmission limitations in order to economically optimize dispatch on an aggregate real-time basis among all participants in the Joint Dispatch Arrangement. 41.2 Joint Dispatch Agreement: An agreement detailing the rights and obligations of participants in a Joint Dispatch Arrangement. 41.3 Joint Dispatch Transmission Service: Non-firm transmission service across transmission facilities of the Transmission Provider that is used to transmit energy dispatched pursuant to a Joint Dispatch Agreement and that is subject to the provisions of this Part V of the Tariff. Joint Dispatch Transmission Service will be made available from posted ATC after procurement and scheduling deadlines have passed for the current operating hour, as specified in the Transmission Provider’s Business Practices posted on OASIS. 41.4 Service Agreement for Joint Dispatch Transmission Service (“Service Agreement”): An agreement between the Transmission Provider and a Joint Dispatch Transmission Service Customer for Joint Dispatch Transmission Service. 41.5 Joint Dispatch Transmission Service Customer: Any entity (or its Designated Agent) that: (i) executes a Service Agreement; or (ii) requests in writing that the Transmission Provider file with the Commission a proposed unexecuted Service Agreement. Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 12 42 Nat of Joint Dispatch Trans Svc Version: 0.0.0 Effective: 1/1/2015 42 Nature of Joint Dispatch Transmission Service Joint Dispatch Transmission Service is an optional service available to any load serving entity in the PSCo Balancing Authority Area that: (1) has entered into a Joint Dispatch Agreement; and (2) makes Joint Dispatch Transmission Service on its transmission system, if any, available to PSCo and all other parties to the Joint Dispatch Agreement at the same rate, terms, and conditions as set out in this Part V of the Tariff and related schedules and attachments. As further detailed herein, Joint Dispatch Transmission Service may only be used to deliver energy dispatched under a Joint Dispatch Agreement to the entity’s wholesale and retail native load customers. Joint Dispatch Transmission Service is provided only on a non-firm, as available basis and has the lowest curtailment priority. 42.1 Limited Transmission Provider Responsibilities. The Transmission Provider shall have the obligation to operate its Transmission System in accordance with Good Utility Practice. For purposes of Joint Dispatch Transmission Service, the Transmission Provider shall have no obligation to plan, construct, or maintain its Transmission System for the benefit of any Joint Dispatch Transmission Service Customer. 42.2 Real Power Losses. Real Power Losses are associated with all transmission service. The Joint Dispatch Transmission Service Customer shall be responsible for all losses associated with Joint Dispatch Transmission Service, which responsibility shall be manifested as the difference between the amount of energy dispatched on behalf of the Joint Dispatch Transmission Service Customer and the amount of energy actually delivered to such customer based on the following loss factors. PRPA Seller Buyer PRPA PSCo BHCE PRPA PRPA+PSCo PSCo BHCE PSCo PSCo+BHCE BHCE PSCo Where: PRPA= Loss Factor set forth in PRPA’s OATT Section 15.7 (where PRPA’s Loss Factor 1.7% as of January 1, 2015) PSCo=Loss Factor set forth in PSCo OATT Section 15.7 (where PSCo’s Loss Factor is 2.56% as of January 1, 2015) BHCE= Loss Factor set forth in BHCE OATT Section 15.7 (BHCE’s Loss Factor is 1.94% as of January 1, 2015) 42.3 Restrictions on Use of Service. The Joint Dispatch Transmission Service Customer shall not use Joint Dispatch Transmission Service for (i) off-system sales of capacity or energy or (ii) direct or indirect provision of transmission service by the Joint Dispatch Transmission Service Customer to any third party. Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 13 Joint Dispatch Transmission Service may be used only for receipt or delivery of energy dispatched within the PSCo Balancing Authority Area on a non-firm basis to serve wholesale or retail native load of any participant in a Joint Dispatch Agreement. 42.4 Imbalance Service. The purpose of the Joint Dispatch Arrangement is to balance loads and resources of the parties by optimizing dispatch of the parties’ resources. As a result, the Transmission Provider shall not assess energy imbalance charges under Ancillary Service Schedule 4 or 9 to any Joint Dispatch Transmission Service Customer. Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 14 43 Initiating Svc Version: 0.0.0 Effective: 1/1/2015 43 Initiating Service 43.1 Condition Precedent for Receiving Service. Subject to the terms and conditions of this Part V of the Tariff, and related schedules and attachments, the Transmission Provider will provide Joint Dispatch Transmission Service to any eligible customer, provided that (i) the eligible customer has wholesale or retail native load in the Transmission Provider’s Balancing Authority Area; (ii) the eligible customer has entered into a Joint Dispatch Agreement; (iii) the eligible customer’s transmission provider has a transmission service tariff offering Joint Dispatch Transmission Service on the same terms and conditions as offered under this Part V of the Tariff, and related schedules and attachments; and (iv) the eligible customer executes a Service Agreement pursuant to Attachment V for service under this Part V of the Tariff or requests in writing that the Transmission Provider file a proposed unexecuted Service Agreement with the Commission. 43.2 Application Procedures. An Eligible Customer requesting service under Part V of this Tariff must submit an application containing the information specified below. No deposit or credit evaluation is necessary to obtain Joint Dispatch Transmission Service. Further, no transmission studies shall be required to obtain Joint Dispatch Transmission Service because such service is provided only on a non-firm, as available basis. Applications should be submitted to the Transmission Provider via e-mail to the person(s) listed on OASIS. Application contents: (i) (ii) (iii) (iv) (v) (vi) (vii) (viii) The identity, address, telephone number and facsimile number of the party requesting service; A statement that the party requesting service is, or will be upon commencement of service, an Eligible Customer under the tariff; A statement that the party requesting service has, or will have upon commencement of service, wholesale or retail native load in the PSCo Balancing Authority Area; A statement that the party requesting service has, or will have upon commencement of service, entered into a Joint Dispatch Agreement with PSCo; A statement that the party requesting service has, or will have upon commencement of service, a tariff offering Joint Dispatch Transmission Service at the same rates, terms, and conditions as this Part V of the Tariff and associated schedules and attachments; Service Commencement Date and the term of the requested Joint Dispatch Transmission Service. A statement signed by an authorized officer from or agent of the Joint Dispatch Transmission Service Customer attesting that Joint Dispatch Transmission Service will be used only for receipt or delivery of energy dispatched under a Joint Dispatch Agreement for the benefit of that customer’s wholesale and retail native load customers. Service is conditioned on the Transmission Provider being in receipt of an executed Joint Dispatch Agreement. Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 15 Unless the Parties agree to a different timeframe, the Transmission Provider must acknowledge the request within ten (15) days of receipt. The acknowledgement must include a date by which a response, including a Service Agreement, will be sent to the Eligible Customer. If an application fails to meet the requirements of this section, the Transmission Provider shall notify the Eligible Customer requesting service within fifteen (15) days of receipt and specify the reasons for such failure. Wherever reasonably possible, the Transmission Provider will attempt to remedy deficiencies in the Application through informal communications with the Eligible Customer. If efforts are unsuccessful, the Transmission Provider shall return the Application, without prejudice to the Eligible Customer filing a new or revised Application that fully complies with the requirements of this section. 43.3 Joint Dispatch Transmission Customer Facilities: The Joint Dispatch Transmission Service Customer’s transmission provider will retain its existing obligations to plan, construct, operate and maintain its transmission system using standard utility practices. 43.4 Filing of Service Agreement. The Transmission Provider will file Service Agreements with the Commission in compliance with applicable Commission regulations, if any. Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 16 15 Joint Dispatch Trans Svc Version: 0.0.0 Effective: 1/1/2015 Schedule 15 Joint Dispatch Transmission Service This is an optional service provided by PSCo, subject to the terms and conditions of Part V of this Tariff. For Joint Dispatch Transmission Service Customers meeting the conditions set forth in Part V of this Tariff, no charge shall be assessed for receipt or delivery of energy dispatched pursuant to a Joint Dispatch Agreement with PSCo provided the customer makes Joint Dispatch Transmission Service available to PSCo at the same rates, terms, and conditions as set forth in Part V of this Tariff, this Schedule 15, and any other related schedules or attachments to this Tariff. Joint Dispatch Transmission Service is provided in real-time on a non-firm, as available basis having the lowest curtailment priority. 1) Monthly delivery: the rate or $0.00/kW-month of Reserved Capacity. 2) Weekly delivery: the rate $0.00/kW-week of Reserved Capacity. 3) Daily delivery: the rate $0.00/kW-day of Reserved Capacity. 4) Hourly delivery: On-Peak Hours: the on-peak rate $0.00/MWh of Reserved Capacity. Off-Peak Hours: the off-peak rate $0.00/MWh of Reserved Capacity. Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 17 V Form of Svc Agrmt for Joint Dispatch Trans Svc Version: 0.0.0 Effective: 1/1/2015 ATTACHMENT V Form of Service Agreement For Joint Dispatch Transmission Service Applicable to the Public Service Company of Colorado (PSCo) System 1.0 This Joint Dispatch Transmission Service Agreement, dated as of __________________________, is entered into, by and between __________________________ (“Transmission Provider”), and __________________________ ("Joint Dispatch Transmission Customer"), all of whom may be referred to individually as “Party” or jointly as “Parties”. 2.0 The Joint Dispatch Transmission Customer has been determined by the Transmission Provider to have a signed a Joint Dispatch Agreement. 3.0 Service under this agreement shall commence on the later of (1) the requested service commencement date, or (2) such other date as it is permitted to become effective by the Commission. Service under this agreement shall terminate on such date as mutually agreed upon by the parties. 4.0 Any notice or request made to or by either Party regarding this Service Agreement shall be made to the representative of the other Party as indicated below. Transmission Provider: _____________________________________ _____________________________________ _____________________________________ Transmission Customer: _____________________________________ _____________________________________ _____________________________________ 5.0 The Tariff is incorporated herein and made a part hereof. Xcel Energy Operating Companies FERC Electric Tariff, Second Revised Volume No. 1 Page No. 18 IN WITNESS WHEREOF, the Parties have caused this Service Agreement to be executed by their respective authorized officials. Transmission Provider: By: ___________________ ___________________ ___________________ Name Title Date Transmission Customer: By: ___________________ ___________________ ___________________ Name Title Date
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