Association of Major Power Customers of BC (AMPC) BCUC Inquiry into the BC MRS Program, Project No:

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1 C14-8 Association of Major Power Customers of BC (AMPC) BCUC Inquiry into the BC MRS Program, Project No: Response to Information Request No.1 of FortisBC April 26, Reference: B. General Views Concerning MRS in BC, Page 4 Preamble: AMPC states that in the U.S., Alberta, and other Canadian provinces, only transmission facility operators and generators are typically subject to MRS standards, and not customers. 1.1 Please provide examples supporting this statement, as it relates to the WECC region. Response: AMPC s knowledge comes largely from the experience of its members. AMPC members report they do not experience the onerous obligations placed on them in B.C. in other jurisdictions, and that the involvement of many B.C. industrial customers in the B.C. MRS program arises from the ownership of small sections of transmission infrastructure such as on-site transformation, or under-frequency load-shedding equipment. 1 This ownership is required by BC Hydro inter-connection agreements. Only Alberta and B.C. are within the WECC region in Canada. The compliance registry links for B.C., Alberta and NERC (which can be sorted to show WECC-only) are found below: %20-%20BCUC%20Registered%20Entities%20- %20Functions%20Report.xlsx xls AMPC s conclusions from comparing the registries follow. Alberta Only a few Alberta entities appear to be in any relevant way similar to B.C. large industrial loads. AMPC understands that the Alberta Functional Model Table 2 applies to activities in 2013 and beyond and reflects revised functional model definitions. 1 Mandatory Reliability Standards Regulation, ss. 1, 2(b), (c)(ii)(a).

2 AMPC Response to FortisBC IR No. 1 April 26, 2013 BCUC Inquiry into the BC MRS Program Page 2 of 3 The link to the consolidated Alberta Reliability Standards (ARS) is here: pdates_mar_14_2013_ap.pdf There are only two standards applicable to transmission level customers in this document ( a market participant receiving service under Rate DTS of the ISO tariff ) who do not have other operating characteristics attracting ARS compliance, such as selfgeneration or operating an electric distribution system. They are: EOP 003 AB1 1 Load Shedding Plans (universal) PRC 021 AB1 1 Under Voltage Load Shedding Program Data (restricted to DTS customers that own an under voltage load shed system) In B.C., operating under-frequency load-shedding equipment triggers eligibility for MRS standards generally. Conversely, in Alberta being a transmission level customer triggers much less onerous obligations to adhere to up to two specific load shedding standards. EOP 003 AB1 1 requires transmission level customers to shed load when directed, be capable of manually shedding load, and maintain electronic records of shedding load. PRC 021 AB1 1 requires transmission level customers to provide under voltage load shedding data to the AESO on request. WECC As a general rule, industrial customers are absent from the WECC portion of the NERC registry. To illustrate, AMPC filtered the NERC registry to only show entities in WECC that registered on the basis of one or more of the following functions: LSE (load-serving entity), DP (distribution provider), TP (transmission provider), or TOP (transmission operator). The choice of these functions reflects the registrations of B.C. industrial customers (excepting self-generation). The resulting three page list is attached as FortisBC-AMPC-1.1-Attachment A and does not appear to include industrial customers.

3 AMPC Response to FortisBC IR No. 1 April 26, 2013 BCUC Inquiry into the BC MRS Program Page 3 of Reference: Section 2, Streamlining the De-Registration Process, Page 6 Preamble: If entities can decide when MRS applies to them, they should be permitted to deregister unless someone in authority objects for cause. 2.1 Please elaborate on who would be someone in authority. Would it include the Balancing Authority and/or the Regional Entity? Response: In drafting the referenced section, AMPC contemplated WECC (and identifies WECC in this role elsewhere in its submission). AMPC agrees with FortisBC s implicit observation that the Balancing Authority has relevant technical expertise and familiarity with the BC system. This expertise should also exist within WECC, and AMPC would prefer to use WECC on enforcement matters because AMPC does not support expanding the Balancing Authority s current role to include enforcement of MRS standards.

4 FortisBC-AMPC-1.1-Attachment A NCR Matrix (with Dates) NCR ID# Entity Name NCR10042 Alameda Municipal Power NCR05024 Benton Rural Electric Association NCR05025 Big Bend Electric Cooperative, Inc. NCR05028 Blachly Lane Electric Coop/PNGC NCR05033 Bountiful City Light & Power NCR05061 Central Electric Coop/PNGC NCR05062 Central Lincoln People's Utility District NCR05063 Central New Mexico Electric Cooperative, Inc. NCR05076 City of Ellensburg NCR10040 City of Forest Grove Light and Power NCR05079 City of Fort Collins NCR05489 City of Gallup NCR05492 City of Lodi NCR05493 City of Lompoc, A Municipal Corporation NCR05086 City of Longmont NCR05087 City of Loveland, Colorado NCR05089 City of Palo Alto NCR05092 City of Richland Energy Services Department NCR05095 City of Shasta Lake NCR05494 City of Ukiah NCR05099 Clallam County PUD No.1 NCR05101 Clearwater Power Company NCR05109 Columbia River People's Utility District NCR05110 Columbia Rural Electric Assoc. NCR05114 Consumer's Power, Inc. Page 1

5 FortisBC-AMPC-1.1-Attachment A NCR Matrix (with Dates) NCR05115 Continental Divide Electric Cooperative NCR05116 Coos Curry Electric Cooperative, Inc. NCR05498 Delta Montrose Electric Association NCR05130 Dixie Escalante Rural Electric Association, Inc. NCR05142 Electrical District No. 2 NCR05144 Elmhurst Mutual Power & Light Company NCR05147 Empire Electric Association, Inc. NCR05154 Fall River Rural Electric/PNGC NCR05156 Flathead Electric Cooperative, Inc. NCR05167 Garkane Energy Cooperative, Inc. NCR05171 Glacier Electric Cooperative, Inc. NCR05178 Harney Electric Cooperative, Inc. NCR05185 High Plains Power, Inc. NCR05186 High West Energy, Inc. NCR06003 Highline Electric Association NCR05190 Holy Cross Energy NCR05198 Inland Power and Light Company NCR11226 Intermountain Rural Electric Association NCR05202 K.C. Electric Association, Inc. NCR05203 Kaysville City Corporation NCR05506 Kit Carson Electric Cooperative, Inc. NCR05209 Kootenai Electric Cooperative Inc. NCR05507 La Plata Electric Association, Inc. NCR05211 Lakeview Light & Power NCR05212 Lane Electric Cooperative, Inc./PNGC NCR05216 Lassen Municipal Utility District NCR05218 Lehi City Corporation NCR02920 Logan City Light and Power NCR05225 Lower Valley Energy NCR05233 Mason County PUD No. 3 NCR05237 Midstate Electric Cooperative, Inc. NCR05241 Mission Valley Power NCR05242 Missoula Electric Cooperative, Inc. NCR05243 Modern Electric Water Company NCR05248 Moon Lake Electric Assn., Inc. NCR05249 Morgan County Rural Electric Association NCR05513 Mountain Parks Electric, Inc. NCR05251 Mountain View Electric Association, Inc. NCR05255 Mt. Wheeler Power, Inc. NCR05257 Murray City Corporation NCR10260 National Nuclear Security Administration and Sandia National Laboratories NCR05259 Navajo Tribal Utility Authority NCR05260 Navopache Electric Cooperative, Inc. NCR05279 Northern Lights/PNGC NCR05280 Northern Wasco County People's Utility District NCR05287 Oregon Trail Electric Consumers Cooperative Page 2

6 FortisBC-AMPC-1.1-Attachment A NCR Matrix (with Dates) NCR05314 Parkland Light and Water Company NCR05316 Peninsula Light Company, Inc. NCR05322 Plumas Sierra Rural Electric Cooperative NCR05519 Poudre Valley Rural Electric Assoc., Inc. NCR05332 Provo City Corporation NCR05341 Public Utility District No. 1 of Skamania County NCR05522 Public Utility District No. 1 of Whatcom County NCR05336 Public Utility District No. 2 of Pacific County NCR05346 Raft River Rural Electric Coop/PNGC NCR05370 Salem Electric NCR05371 Salmon River Electric Cooperative NCR05376 San Carlos Irrigation Project NCR05379 San Isabel Electric Association, Inc. NCR05524 San Luis Valley Rural Electric Cooperative, Inc. NCR05525 San Miguel Power Association, Inc. NCR05403 Southwestern Electric Cooperative, Inc. NCR05404 Springer Electric Cooperative, Inc. NCR05405 Springfield Utility Board NCR05532 The Socorro Electric Cooperative, Inc. NCR05427 Tillamook People's Utility District NCR05428 Town of Estes Park Light and Power Department NCR03036 Trans Bay Cable LLC NCR05436 Umatilla Electric Cooperative Assoc. NCR05437 United Electric Co op, Inc. NCR05536 United Power, Inc NCR05442 US Department Of Energy Richland Operations Office NCR05444 US Navy, Naval Base Kitsap NCR05448 Vera Water and Power NCR05541 Vigilante Electric Cooperative, Inc. NCR05458 Wells Rural Electric Company NCR05471 Wheat Belt Public Power District NCR05472 White River Electric Association, Inc. NCR05549 Y W Electric Association, Inc. Page 3