January 26, 2021 VIA ELECTRONIC FILING the Honorable Kimberly D

January 26, 2021

VIA ELECTRONIC FILING

The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426

Re: Revisions to Schedule 24 of the ISO New England Open Access Transmission Tariff to Comply with Order No. 676-I; ISO New England Inc. and New England Power Pool, Docket No. ER21-___-000

Dear Secretary Bose:

Pursuant to Section 205 of the Federal Power Act (“FPA”)1 and Order No. 676-I,2 ISO New England Inc. (the “ISO” or “ISO-NE”)3 joined by the New England Power Pool (“NEPOOL”) Participants Committee4 (together, the “Filing Parties”), hereby electronically submit to the Federal Energy Regulatory Commission (“FERC” or “Commission”) revisions to Schedule 24 – Incorporation by Reference of NAESB Standards (“Schedule 24”) of the ISO OATT to include certain updated business practice standards adopted by the Wholesale Electric Quadrant (“WEQ”) of the North American Energy Standards Board (“NAESB”) and incorporated by reference in the Commission’s regulations through Order No. 676-I (the “Schedule 24 Revisions”).

1 16 U.S.C. § 824d (2006 and Supp. II 2009). 2 Standards for Business Practices and Communication Protocols for Public Utilities, Order No. 676-I, 170 FERC ¶ 61,062 (2020) (“Order No. 676-I”). 3 Capitalized terms used but not otherwise defined in this filing have the meanings ascribed thereto in the ISO’s Transmission, Markets and Services Tariff (the “ISO Tariff”). Section II of the ISO Tariff contains the Open Access Transmission Tariff (the “ISO OATT”). 4 Under New England’s RTO arrangements, the rights to make this filing of changes to Schedule 24 of the ISO OATT under Section 205 of the FPA are the ISO’s. NEPOOL, which, pursuant to the Participants Agreement provides the sole Participant Processes for advisory voting on ISO matters, supported the changes reflected in this filing and, accordingly, joins in this Section 205 of filing. The Honorable Kimberly D. Bose January 26, 2021 Page 2 of 8

Consistent with Order No. 676-I, the Filing Parties respectfully request that the Commission accept the Schedule 24 Revisions as proposed in this filing, without modifications or conditions, effective as of date that the Commission accepts the revisions.

I. DESCRIPTION OF THE FILING PARTIES AND COMMUNICATIONS

The ISO is the private, non-profit entity that serves as the regional transmission organization (“RTO”) for New England. The ISO operates the New England bulk power system and administers New England’s organized wholesale electricity market pursuant to the ISO Tariff and operating agreements with transmission owners. In its capacity as an RTO, the ISO has the responsibility to protect the short-term reliability of the New England Control Area and to operate the system according to reliability standards established by the Northeast Power Coordinating Council (“NPCC”) and the North American Electric Reliability Corporation (“NERC”).

NEPOOL is a voluntary association organized in 1971 pursuant to the New England Power Pool Agreement, and it has grown to include more than 500 members. The Participants include all of the electric utilities rendering or receiving service under the Tariff, as well as independent power generators, marketers, load aggregators, brokers, consumer-owned utility systems, end users, demand resource providers, developers, and a merchant transmission provider. Pursuant to revised governance provisions accepted by the Commission,5 the Participants act through the NEPOOL Participants Committee. The Participants Committee is authorized by Section 6.1 of the Second Restated NEPOOL Agreement and Section 8.1.3(c) of the Participants Agreement to represent NEPOOL in proceedings before the Commission. Pursuant to Section 2.2 of the Participants Agreement, “NEPOOL provide[s] the sole Participant Processes for advisory voting on ISO matters and the selection of ISO Board members, except for input from state regulatory authorities and as otherwise may be provided in the Tariff, TOA and the Market Participant Services Agreement included in the Tariff.”

All correspondence and communications in this proceeding should be addressed to the undersigned for the ISO and NEPOOL as follows:

To the ISO:

Graham Jesmer, Esq.* ISO New England Inc. One Sullivan Road Holyoke, MA 01040-2841 Tel: (413) 540-4557 Fax: (413) 535-4379 E-mail: [email protected]

5 ISO New England Inc., et al., 109 FERC ¶ 61,147 (2005). The Honorable Kimberly D. Bose January 26, 2021 Page 3 of 8

To NEPOOL:

Eric K. Runge* José A. Rotger Day Pitney LLP Transmission Committee, Vice Chair One Federal Street Director, Market Intelligence – New England Boston, MA 02110 c/o Customized Energy Solutions Ltd. Tel.: (617) 345-4735 25 Dyer Avenue Fax: (617) 345-4745 Melrose, MA 02176 E-mail: [email protected] Tel.: (781) 258-8662 E-mail: [email protected] *Persons designated for service.

II. STANDARD OF REVIEW

The Schedule 24 Revisions are being submitted pursuant to Section 205 of the FPA, which “gives a utility the right to file rates and terms for services rendered with its assets.”6 Under Section 205, the Commission “plays ‘an essentially passive and reactive’ role”7 whereby it “can reject [a filing] only if it finds that the changes proposed by the public utility are not “just and reasonable.”8 The Commission limits this inquiry “into whether the rates proposed by a utility are reasonable – and [this inquiry does not] extend to determining whether a proposed rate schedule is more or less reasonable than alternative rate designs.”9 The changes proposed herein “need not be the only reasonable methodology, or even the most accurate.”10 As a result, even if an intervenor or the Commission develops an alternative proposal, the Commission must accept the ISO’s Section 205 filing if it finds that the filing is just and reasonable.11

III. BACKGROUND

On February 4, 2020, the Commission issued Order No. 676-I, which amended its regulations to incorporate by reference the latest version (Version 003.2) of the Standards for Business Practices and Communication Protocols for Public Utilities adopted by the WEQ of

6Atlantic City Elec. Co. v. FERC, 295 F.3d 1, 9 (D.C. Cir. 2002). 7Id. at 10 (quoting City of Winnfield v. FERC, 744 F.2d 871, 876 (D.C. Cir 1984). 8Id. 9See ISO New England Inc., 114 FERC ¶ 61,315 at P 33 and n.35 (2005), citing Pub. Serv. Co. of New Mexico v. FERC, 832 F.2d 1201, 1211 (10th Cir. 1987) and City of Bethany v. FERC, 727 F.2d 1131, 1136 (D.C. Cir. 1984) (“City of Bethany”), cert. denied, 469 U.S. 917 (1984). 10Oxy USA, Inc. v. FERC, 64 F.3d 679, 692 (D.C. Cir. 1995). 11Cf. Southern California Edison Co., et al., 73 FERC ¶ 61,219 at 61,608 n. 73 (1995) (“Having found the Plan to be just and reasonable, there is no need to consider in any detail the alternative plans proposed by the Joint Protesters.” (citing City of Bethany, 727 F.2d at 1136)). The Honorable Kimberly D. Bose January 26, 2021 Page 4 of 8

NAESB, with certain enumerated exceptions. The new standards adopted by the Commission were initially filed as a package on December 8, 2017 (December 8 Filing), and include minor clarifications and updates submitted by NAESB on June 5, 2019, and July 23, 2019 respectively.

Order No. 676-I requires RTOs and ISOs to revise their open access transmission tariffs to include revised standards WEQ-000, -001, -002, -003, -004, -006, -008, -012, -013, and -015, as well new standards WEQ-022 and -023. Public utilities were required to modify their respective OATTs to include these references and to make a compliance filing through eTariff no later than ninety (90) days from the date the final rule is published in the Federal Register (May 26, 2020), using an indeterminate effective date (12/31/9998) for the tariff records.

On March 18, 2020, Southwest Power Pool, Inc. (“SPP”) and Midcontinent Independent System Operator (“MISO”) submitted a motion to request an extension of time for utilities to comply with Order No 676-I.12 The motion requested an extension until October 27, 2021, because, MISO and SPP argued, Open Access Technology International, Inc. (“OATI”) which provides Open Access Same-Time Information System (“OASIS”) software would not have completed software developments necessary for the implementation of certain of the new NAESB Standards prior to May 26, 2020. The OATI software development referenced by MISO and SPP relates specifically to WEQ-001-9 and WEQ-001-10, which set standards for the implementation of features in OASIS that are not utilized by ISO-NE.

On April 3, 2020, the Commission granted the motion and stated that the “deadline for public utilities required to make a compliance filing through e-Tariff is extended from May 25, 2020, up to and including July 27, 2021.”13 The Commission further stated that it “will determine an implementation date for all utilities, including utilities whose tariffs incorporate each version of the NAESB standards, without modification, when the version is accepted by the Commission, no sooner than three months following the submission of compliance filings (i.e., October 27, 2021).”14

On March 5, 2020, Southern Company Services, Inc., filed a Request for Clarification or, in the alternative, Request for Rehearing of Order No. 676-I.15 Edison Electric Institute (“EEI”)

12 Joint Motion for Extension of Time, Alternative Request for Clarification, and Request for Expedited Ruling of Southwest Power Pool, Inc. and Midcontinent Independent System Operator, Docket Nos. RM05-5-025, et al. (Mar. 18, 2020). 13 Notice of Extension of Time, Docket No. RM05-5-028 (April 3, 2020) 14 Id. 15 Request for Clarification or, in the Alternative, Request for Rehearing of Southern Company Services, Inc., acting as agent for Alabama Power Company, et al. of the February 4, 2020 under RM05-5, Docket No. RM05-5-028 (March 5, 2020). The Honorable Kimberly D. Bose January 26, 2021 Page 5 of 8

and OATI filed separate requests for clarification and comments.16 The requests were focused on the application of Commission’s Dynegy policy,17 which generally relates to a customer’s right to keep its contractual rights to point-to-point firm transmission service on the original path it has reserved while the customer’s request for a redirect is pending, relative to new WEQ 001-9.5; as well as certain procedural matters regarding the form of the filing required by under Order No. 676-I. The Commissions issued an Order on Clarification on November 25, 2020,18 which provided clarification on the application of the Dynegy policy and stated that existing Tariff schedules may be modified in order to comply with Order No. 676-I.

IV. DESCRIPTION OF TARIFF REVISIONS

In accordance with Order No. 676-I, the ISO has modified Schedule 24 of the ISO OATT to include the revised and new WEQ standards enumerated by the Commission. The revised Schedule 24 explicitly identifies the incorporated provisions.

Consistent with ISO-NE’s July 20, 2015 Compliance Filing in Docket No. ER15-519,19 Schedule 24 and Attachment A thereto provide clarity to the ISO’s transmission customers regarding which NAESB products the ISO provides and the specific regional transmission services offered under the ISO OATT, as well as the NAESB standards that the ISO does not implement given the services that it does not offer. Including this level of specificity in the Tariff not only informs the ISO’s transmission customers, but also avoids the potential for inconsistencies or ambiguity in the Tariff.

As stated above, because ISO-NE does not utilize the features of OASIS that were the subject of the Extension Order or the Clarification Order, ISO-NE is unaffected by the OATI software implementation efforts, allowing for the instant filing to be made in advance of the July 27, 2021 date set by the Commission.

V. STAKEHOLDER PROCESS

The NEPOOL Transmission Committee reviewed the Schedule 24 Revisions at its April 28, 2020 meeting at which time it unanimously voted to recommend Participants Committee

16 Comment of Open Access Technology International, Inc. under RM05-5-025, et. al. (March 5, 2020); Request for Clarification of the Edison Electric Institute of the February 4, 2020 Order under RM05-5 (March 5, 2020) 17 Dynegy Power Marketing, Inc. v. Southwest Power Pool, Inc., 99 FERC ¶ 61,054, at P 9 (2002) (Dynegy) 18 Order on Clarification, 173 FERC ¶ 61,173. 19 ISO New England Inc. Revisions to ISO New England Inc. Open Access Transmission Tariff Related to Order No. 676-H in Compliance with Order Issued on May 19, 2015; Docket No. ER15-519 (July 20, 2015. The Honorable Kimberly D. Bose January 26, 2021 Page 6 of 8

support for those revisions. The NEPOOL Participants Committee voted unanimously to support the Schedule 24 Revisions at its May 7, 2020 meeting.

VI. REQUESTED EFFECTIVE DATE

Consistent with Paragraph 65 of Order No. 676-I, the Filing Parties respectfully request that the Commission accept the Schedule 24 Revisions as proposed in this filing, without modifications or conditions, effective as of the date that the Commission accepts the Revisions.

VII. ADDITIONAL SUPPORTING INFORMATION

Section 35.13 of the Commission’s regulations generally requires public utilities to file certain cost and other information related to an examination of traditional cost-of service rates. However, the ISO Tariff changes submitted herewith do not modify a traditional “rate.” Therefore, to the extent necessary, the Filing Parties request waiver of Section 35.13 of the Commission’s regulations.20 Notwithstanding this request for waiver, the Filing Parties submit the following additional information in substantial compliance with relevant provisions of Section 35.13 of the Commission’s regulations:

35.13(b)(1) – Materials included herewith are as follows:

 This transmittal letter;

 Marked tariff sheets reflecting the Schedule 24 Revisions discussed in this filing;

 Clean revised tariff sheets reflecting the Schedule 24 Revisions discussed in this filing; and

 List of governors and utility regulatory agencies in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island and Vermont to which a copy of this filing is being sent electronically.

35.13(b)(2) – As noted above, the Filing Parties request that this filing become effective as of the date the Commission accepts the Revisions.

35.13(b)(3) – Pursuant to Section 17.11(e) of the Participants Agreement, Governance Participants are being served electronically rather than by paper copy. The names and addresses of the Governance Participants are posted on the ISO’s website at http://www.iso- ne.com/regulatory/ferc/nepool/gov_prtcpnts_eserved.pdf. An electronic copy of this transmittal letter and the accompanying materials has also been sent to the governors and electric utility regulatory agencies for the six New England states that comprise the New England Control Area, and to NECPUC. The names and addresses of these governors and regulatory agencies are shown in the above-referenced list, which is included in this filing. In accordance with Commission rules

20 18 C.F.R. § 35.13 (2009). The Honorable Kimberly D. Bose January 26, 2021 Page 7 of 8

and practice, there is no need for the Governance Participants or the entities identified in the above- referenced list to be included on the Commission’s official service list in the captioned proceeding unless such entities become intervenors in this proceeding.

35.13(b)(4) – A description of the materials submitted pursuant to this filing is contained in this transmittal letter.

35.13(b)(5) – The reasons for this filing are discussed in this transmittal letter.

35.13(b)(6) – As explained above, the Tariff revisions for which the ISO holds Section 205 rights reflect the results of the Participant Processes required by the Participants Agreement and reflect the support of the Participants Committee.

35.13(b)(7) – The Filing Parties have no knowledge of any relevant expenses or costs of service that have been alleged or judged in any administrative or judicial proceeding to be illegal, duplicative, or unnecessary costs that are demonstrably the product of discriminatory employment practices.

35.13(b)(8) – A form of notice and electronic media are no longer required for filings in light of the Commission’s Combined Notice of Filings notice methodology.

35.13(c)(1) – The Tariff changes herein do not modify a traditional "rate." The statement required under this Commission regulation is not applicable to this filing.

35.13(c)(2) – The ISO does not provide services under other rate schedules that are similar to the wholesale, resale and transmission services it provides under the ISO Tariff.

35.13(c)(3) – No specifically assignable facilities have been or will be installed or modified in connection with the revision submitted herein.

The Honorable Kimberly D. Bose January 26, 2021 Page 8 of 8

VIII. CONCLUSION

The Filing Parties respectfully request that the Commission accept the Schedule 24 Revisions contained in this filing to become effective as of the Commission accepts the Revisions without modification or condition.

Respectfully submitted,

By: /s/ Graham Jesmer By: Eric Runge

Graham Jesmer, Esq. Eric Runge, Esq. ISO New England Inc. Day Pitney LLP One Sullivan Road One Federal Street Holyoke, MA 01040-2841 Boston, MA 02110 Tel: (413) 540-4557 Tel: (617) 345-4735 Fax: (413) 535-4379 Fax: (617) 345-4745 E-mail: [email protected] E-mail: [email protected]

Counsel for ISO New England Inc. Counsel for the New England Power Pool

SCHEDULE 24

Incorporation By Reference of NAESB Standards

In accordance with paragraph 89 of Commission Order No. 676-IH, the following North American Electric Standard Board’s (“NAESB”) Whole Electric Quadrant’s (“WEQ”) Version 003.2 Business Practice Standards incorporated by reference below are implemented by the ISO in association with the transmission services – Regional Network Service and Through or Out Service – that the ISO offers over the Pool Transmission Facilities that are part of the New England Transmission System, except as described in Attachment A to this Schedule 24. The reference below to Version 003.2 of the WEQ Business Practice Standards and any future revisions shall not affect the transmission service products offered by the ISO.

 WEQ-000, Abbreviations, Acronyms, and Definition of Terms (WEQ Version 003.1, September 30, 2015) (including only the definitions of Interconnection Time Monitor, Time Error, and Time Error Correction);, WEQ Version 003, July 31, 2012, as modified by NAESB final actions ratified on Oct. 4, 2012, Nov. 28, 2012 and Dec. 28, 2012 (with minor corrections applied Nov. 26, 2013);

 WEQ-001, Open Access Same-Time Information Systems (OASIS), [OASIS] Version 2.2 (WEQ Version 003.2, Dec. 8, 2017), excluding standards WEQ-001-9 preamble text, WEQ-001-10 preamble text;OASIS Version 2.0, WEQ Version 003, July 31, 2012, as modified by NAESB final actions ratified on Dec. 28, 2012 (with minor corrections applied Nov. 26, 2013) excluding Standards 001-9.5, 001-10.5, 001-14.1.3, 001-15.1.2 and 001-106.2.5;

 WEQ-002, Open Access Same-Time Information Systems (OASIS) Business Practice Standards and Communication Protocols (S&CP), [OASIS] Version 2.2 (WEQ Version 003.2, Dec. 8, 2017); OASIS Version 2.0, WEQ Version 003, July 31, 2012, as modified by NAESB final actions ratified on Nov. 28, 2012 and Dec. 28, 2012 (with minor corrections applied Nov. 26, 2013);

 WEQ-003, Open Access Same-Time Information Systems (OASIS) Data Dictionary Business Practice Standards, [OASIS] Version 2.2 (WEQ Version 003.2, Dec. 8, 2017) (with minor corrections applied July 23, 2019);OASIS Version 2.0, WEQ Version 003, July 31, 2012, as modified by NAESB final actions ratified on Dec. 28, 2012 (with minor corrections applied Nov. 26, 2013);

 WEQ-004, Coordinate Interchange (WEQ Version 003.2, Dec. 8, 2017);, WEQ Version 003, July 31, 2012 (with Final Action ratified on December 28, 2012);

 WEQ-005, Area Control Error (ACE) Equation Special Cases (WEQ Version 003.2, Dec. 8, 2017);, WEQ Version 003, July 31, 2012;

 WEQ-006, Manual Time Error Correction (WEQ Version 003.1, Sept. 30, 2015);, WEQ Version 003, July 31, 2012;

 WEQ-007, Inadvertent Interchange Payback (WEQ Version 003.2, Dec. 8, 2017);, WEQ Version 003, July 31, 2012;

 WEQ-008, Transmission Loading Relief (TLR) – Eastern Interconnection (WEQ Version 003.2, Dec. 8, 2017);, WEQ Version 003, July 31, 2012 (with minor corrections applied November 28, 2012);

 WEQ-011, Gas / Electric Coordination (WEQ Version 003.2, Dec. 8, 2017);, WEQ Version 003, July 31, 2012;

 WEQ-012, Public Key Infrastructure (PKI) (WEQ Version 003.2, Dec. 8, 2017);, WEQ Version 003, July 31, 2012, as modified by NAESB final actions ratified on Oct. 4, 2012);

 WEQ-013, Open Access Same-Time Information Systems (OASIS) Implementation Guide, [OASIS] Version 2.2 (WEQ Version 003.2, Dec. 8, 2017);OASIS Version 2.0, WEQ Version 003, July 31, 2012, as modified by NAESB final actions ratified on Dec. 28, 2012 (with minor corrections applied Nov. 26, 2013);

 WEQ-015, Measurement and Verification of Wholesale Electricity Demand Response (WEQ Version 003.2, Dec. 8, 2017);, WEQ Version 003, July 31, 2012; and

 WEQ-021, Measurement and Verification of Energy Efficiency Products (WEQ Version 003.2, Dec. 8, 2017);, WEQ Version 003, July 31, 2012.

 WEQ–022, Electric Industry Registry Business Practice Standards (WEQ Version 003.2, Dec. 8, 2017); and

 WEQ-023, Modeling. The following standards are incorporated by reference: WEQ-023-5; WEQ-023-5.1; WEQ-023-5.1.1; WEQ-023-5.1.2; WEQ-023-5.1.2.1; WEQ-023-5.1.2.2; WEQ- 023-5.1.2.3; WEQ-023-5.1.3; WEQ-023-5.2; WEQ-023-6; WEQ-023-6.1; WEQ-023-6.1.1; WEQ-023-6.1.2; and WEQ-023-A Appendix A. (WEQ Version 003.2, Dec. 8, 2017).

ATTACHMENT A to SCHEDULE 24

NAESB Business Practice Standards Not Implemented by the ISO Given the Nature of Transmission Services Offered

The ISO does not offer the Point-To-Point Transmission Service or the Network Integration Transmission Service that are available under the Commission’s pro forma open access transmission tariff. Under Sections II.B and II.C of the ISO OATT, the ISO offers Regional Network Service and Through or Out Service over the Pool Transmission Facilities that are part of the New England Transmission System. RNS and TOUT Service differ from the pro forma OATT Point-To-Point Transmission Service and Network Integration Transmission Service.

Because the ISO does not offer the pro forma Point-To-Point Transmission Service or the Network Integration Transmission Service, the ISO does not implement the WEQ Business Practice Standards that relate specifically to those services. Specifically, the ISO does not implement the WEQ-001, Open Access Same-Time Information Systems Business Practice Standards that are applicable to pro forma Point-To-Point Service and Network Integration Transmission Service and the WEQ-001 Coordination Of Requests For Service Across Multiple Transmission Systems-related Business Practice Standards for the coordination of the pro forma transmission services: 001-2.1 through 001-2.14; 001-2.2 through 001- 2.2.2; 001-2.3 through 001-2.3.2; 001-4 through 001-4.27; 001-5 through 001-5.6; 001-8 through 001- 8.3.2; 001-9 through 001-9.8.1; 001-10 through 001-10.8.7; 001-11 through 001-11.7.2.31; 001-12 through 001-12.5.2; 001-18 through 001-18.2; 001-19 through 001-19.1.2; 001-20 through 001-20.3; 001- 21 through 001-21.5.5; 001-22 through 001-22.2; 001-23 through 23.3.9; 001-24 through 001-24.8.2; 001-25 through 001-25.4.7.3.1; 001-101 through 101.13.4; 001-102 through 102.5.3; 001-103 through 103.9.2; 001-104 through 104.5; 001-105 through 105.6.7.2; 001-106 through 106.2.7; 001-107 through 107.3.1; 001-INT2; and 001-D through 001-E.

Because of the geographical and electrical relationship of the ISO Control Area with other systems in the Eastern Interconnection, parallel flows associated with inter-Control Area transactions do not flow through the ISO Control Area in sufficient magnitude to require the use of Transmission Loading Relief or Transmission Loading Relief -like procedures. The ISO does not use Transmission Loading Relief procedures or initiate Transmission Loading Relief requests for inter-Control Area “interchange” transactions to manage parallel flows or to initiate curtailments. As such, the ISO does not implement the following NAESB Business Practice Standards within WEQ-008, Transmission Loading Relief (TLR) – Eastern Interconnection: 008-1 through 008-1.8.17.1.2; 008-2 through 008-2.4.4; 008-3 through 008- 3.11.2.8, and 008-A through 008-D.

SCHEDULE 24

Incorporation By Reference of NAESB Standards

In accordance with paragraph 89 of Commission Order No. 676-I, the following North American Electric Standard Board’s (“NAESB”) Whole Electric Quadrant’s (“WEQ”) Version 003.2 Business Practice Standards incorporated by reference below are implemented by the ISO in association with the transmission services – Regional Network Service and Through or Out Service – that the ISO offers over the Pool Transmission Facilities that are part of the New England Transmission System, except as described in Attachment A to this Schedule 24. The reference below to Version 003.2 of the WEQ Business Practice Standards and any future revisions shall not affect the transmission service products offered by the ISO.

• WEQ-000, Abbreviations, Acronyms, and Definition of Terms (WEQ Version 003.1, September 30, 2015) (including only the definitions of Interconnection Time Monitor, Time Error, and Time Error Correction);

• WEQ-001, Open Access Same-Time Information Systems (OASIS), [OASIS] Version 2.2 (WEQ Version 003.2, Dec. 8, 2017), excluding standards WEQ-001-9 preamble text, WEQ-001-10 preamble text;

• WEQ-002, Open Access Same-Time Information Systems (OASIS) Business Practice Standards and Communication Protocols (S&CP), [OASIS] Version 2.2 (WEQ Version 003.2, Dec. 8, 2017);

• WEQ-003, Open Access Same-Time Information Systems (OASIS) Data Dictionary Business Practice Standards, [OASIS] Version 2.2 (WEQ Version 003.2, Dec. 8, 2017) (with minor corrections applied July 23, 2019);

• WEQ-004, Coordinate Interchange (WEQ Version 003.2, Dec. 8, 2017);

• WEQ-005, Area Control Error (ACE) Equation Special Cases (WEQ Version 003.2, Dec. 8, 2017);

• WEQ-006, Manual Time Error Correction (WEQ Version 003.1, Sept. 30, 2015);

• WEQ-007, Inadvertent Interchange Payback (WEQ Version 003.2, Dec. 8, 2017);

• WEQ-008, Transmission Loading Relief (TLR) – Eastern Interconnection (WEQ Version 003.2, Dec. 8, 2017);

• WEQ-011, Gas / Electric Coordination (WEQ Version 003.2, Dec. 8, 2017);

• WEQ-012, Public Key Infrastructure (PKI) (WEQ Version 003.2, Dec. 8, 2017);

• WEQ-013, Open Access Same-Time Information Systems (OASIS) Implementation Guide, [OASIS] Version 2.2 (WEQ Version 003.2, Dec. 8, 2017);

• WEQ-015, Measurement and Verification of Wholesale Electricity Demand Response (WEQ Version 003.2, Dec. 8, 2017);

• WEQ-021, Measurement and Verification of Energy Efficiency Products (WEQ Version 003.2, Dec. 8, 2017);

• WEQ–022, Electric Industry Registry Business Practice Standards (WEQ Version 003.2, Dec. 8, 2017); and

• WEQ-023, Modeling. The following standards are incorporated by reference: WEQ-023-5; WEQ-023-5.1; WEQ-023-5.1.1; WEQ-023-5.1.2; WEQ-023-5.1.2.1; WEQ-023-5.1.2.2; WEQ- 023-5.1.2.3; WEQ-023-5.1.3; WEQ-023-5.2; WEQ-023-6; WEQ-023-6.1; WEQ-023-6.1.1; WEQ-023-6.1.2; and WEQ-023-A Appendix A. (WEQ Version 003.2, Dec. 8, 2017).

ATTACHMENT A to SCHEDULE 24

NAESB Business Practice Standards Not Implemented by the ISO Given the Nature of Transmission Services Offered

Because the ISO does not offer the pro forma Point-To-Point Transmission Service or the Network Integration Transmission Service, the ISO does not implement the WEQ Business Practice Standards that relate specifically to those services. Specifically, the ISO does not implement the WEQ-001, Open Access Same-Time Information Systems Business Practice Standards that are applicable to pro forma Point-To-Point Service and Network Integration Transmission Service and the WEQ-001 Coordination Of Requests For Service Across Multiple Transmission Systems-related Business Practice Standards for the coordination of the pro forma transmission services: 001-2.1 through 001-2.14; 001-2.2 through 001- 2.2.2; 001-2.3 through 001-2.3.2; 001-4 through 001-4.27; 001-5 through 001-5.6; 001-8 through 001- 8.3.2; 001-9 through 001-9.8.1; 001-10 through 001-10.8.7; 001-11 through 001-11.7.2.3; 001-12 through 001-12.5.2; 001-20 through 001-20.3; 001-21 through 001-21.5.5; 001-22 through 001-22.2; 001-23 through 23.3.9; 001-24 through 001-24.8.2; 001-25 through 001-25.4.7.3.1; 001-101 through 101.13.4; 001-102 through 102.5.3; 001-103 through 103.9.2; 001-104 through 104.5; 001-105 through 105.6.7.2; 001-106 through 106.2.7; 001-107 through 107.3.1; 001-INT2; and 001-D through 001-E.

Because of the geographical and electrical relationship of the ISO Control Area with other systems in the Eastern Interconnection, parallel flows associated with inter-Control Area transactions do not flow through the ISO Control Area in sufficient magnitude to require the use of Transmission Loading Relief or Transmission Loading Relief -like procedures. The ISO does not use Transmission Loading Relief procedures or initiate Transmission Loading Relief requests for inter-Control Area “interchange” transactions to manage parallel flows or to initiate curtailments. As such, the ISO does not implement the following NAESB Business Practice Standards within WEQ-008, Transmission Loading Relief (TLR) – Eastern Interconnection: 008-1 through 008-1.8.1; 008-2 through 008-2.4.4; 008-3 through 008-3.11.2.8, and 008-A through 008-D. New England Governors, State Utility Regulators and Related Agencies*

Connecticut Boston, MA 02133

The Honorable Ned Lamont Massachusetts Attorney General Office Office of the Governor One Ashburton Place State Capitol Boston, MA 02108 210 Capitol Ave. [email protected] Hartford, CT 06106 [email protected] Massachusetts Department of Public Utilities One South Station Connecticut Attorney General Office Boston, MA 02110 55 Elm Street [email protected] Hartford, CT 06106 [email protected] [email protected] [email protected] [email protected]

Connecticut Department of Energy and New Hampshire Environmental Protection 79 Elm Street The Honorable Chris Sununu Hartford, CT 06106 Office of the Governor [email protected] 26 Capital Street [email protected] Concord NH 03301 [email protected] Connecticut Public Utilities Regulatory Authority 10 Franklin Square New Hampshire Public Utilities Commission New Britain, CT 06051-2605 21 South Fruit Street, Ste. 10 [email protected] Concord, NH 03301-2429 [email protected] [email protected] Maine [email protected] [email protected] The Honorable Janet Mills [email protected] One State House Station [email protected] Office of the Governor [email protected] Augusta, ME 04333-0001 [email protected] [email protected] [email protected]

Maine Public Utilities Commission 18 State House Station Augusta, ME 04333-0018 Rhode Island [email protected] The Honorable Gina Raimondo Office of the Governor 82 Smith Street Massachusetts Providence, RI 02903 [email protected] The Honorable Charles Baker [email protected] Office of the Governor [email protected] State House

4/15/20 New England Governors, State Utility Regulators and Related Agencies*

Rhode Island Public Utilities Commission Meredith Hatfield, Executive Director 89 Jefferson Blvd. New England Conference of Public Utilities Warwick, RI 02888 Commissioners [email protected] 72 N. Main Street [email protected] Concord, NH 03301 [email protected]

Vermont Anthony Roisman, President New England Conference of Public Utilities The Honorable Phil Scott Commissioners Office of the Governor 112 State Street – Drawer 20 109 State Street, Pavilion Montpelier, VT05620 Montpelier, VT 05609 [email protected] [email protected]

Vermont Public Utility Commission 112 State Street Montpelier, VT 05620-2701 [email protected] [email protected] [email protected]

Vermont Department of Public Service 112 State Street, Drawer 20 Montpelier, VT 05620-2601 [email protected] [email protected] [email protected]

New England Governors, Utility Regulatory and Related Agencies

Jay Lucey Coalition of Northeastern Governors 400 North Capitol Street, NW, Suite 370 Washington, DC 20001 [email protected]

Heather Hunt, Executive Director New England States Committee on Electricity 655 Longmeadow Street Longmeadow, MA 01106 [email protected] [email protected]

4/15/20