# Executive Summary

As envisioned in the Regional Representative Group's (RRG) regional
proposal, Grid West will act as the central scheduling authority for the
Grid West Managed Transmission System (GWMT). As the central scheduling
authority, Grid West will implement a flow based physical scheduling
process. This process requires all Grid West Transmission Customers to
possess the proper physical transmission rights prior to scheduling in
the Day-Ahead period. Physical rights may be in the form of existing
transmission rights (ETRs) or Grid West issued Injection Withdrawal
Rights (IWRs). Grid West will manage these physical rights through three
distinct processes:

-   Rights inventorying: Compilation of Transmission Owner rights
    obligations (TO obligations)

-   Rights Certification: Certification of Transmission Customer's
    existing transmission rights, when requested by these customers;

-   IWR translation: Translation of Transmission Customers\' ETRs into
    Injection Withdrawal Rights (IWR) based on specific and voluntary
    request by these customers; and

-   Bilateral trade registration: Registration of IWR trades in the
    secondary market.

Collectively, these processes are referred to as Rights Data Management
(RDM).

# Purpose

The purpose of this white paper is to review the proposed right data
management design, including both the Rights Inventorying, Rights
Certification, and Rights Translation processes.

# Background

Currently, no single entity has a regional view of the Northwest
transmission system prior to real-time.[^1] The region's transmission
capacity is managed principally on a "contract path" basis by 17
individual control areas. Additionally, the current contract path
methodology does not match the physical operation of the transmission
grid. In addition, each Transmission Operator determines its available
transmission capacity based upon its own criteria.

As a part of its Basic Functions, Grid West will manage all energy
scheduling in the GWMT. In this role, Grid West will not only have a
regional view of the transmission system prior to real-time operation
but will centrally mange transmission capacity in an independent manner.
This new scheduling paradigm should have the capability to account for
and honor all existing transmission rights, along with their full
flexibilities, as well as acquired IWRs. The same capability needs to be
extended to all Grid West services that use rights data, e.g., to the
reconfiguration service.

# Rights Data Management

As the central scheduling authority, Grid West will manage available
flowgate capacity (AFC). To do so, it must have a regional view of the
obligations that exist on the transmission system. This includes both
pre-existing obligations derived from existing transmission contracts as
well as changes due to bilateral trading and new obligations (IWRs)
created through capacity expansion, and the reconfiguration auction.

## Existing Rights Inventorying

> Physical transmission rights will be in the form of either existing
> transmission rights (ETRs) or Grid West issued Injection Withdrawal
> Rights (IWRs). Transmission Customers currently have extensive
> existing transmission rights. These rights will be honored in the new
> scheduling paradigm. In order to accommodate these existing
> transmission rights, Grid West will maintain an appropriate amount of
> transmission "headroom".
>
> As opposed to performing a contract by contract review, Grid West will
> work directly with the Transmission Owners to determine and inventory
> their net obligations (TO obligations) on the transmission system
> related to existing transmission rights. This process is referred to
> as Rights Inventorying. This rights inventory will be used to support
> three separate processes: the calculation of AFC, the validation of
> schedules, and the operation of the Reconfiguration Service.[^2]

## Existing Rights Certification

Grid West will maintain an inventory of Transmission Owner's net
obligations related to existing transmission rights. However,
Transmission Customers with existing transmission rights may want to
schedule directly with Grid West and participate in the Day-Ahead
Reconfiguration Service. To do so, Transmission Customers with existing
transmission rights can request to have their rights certified by Grid
West. In each case Grid West will work with the Transmission Owner to
identify and certify the Transmission Customer\'s existing transmission
rights. Existing Rights Certification will generally produce a set of
injections/withdrawal flexibility for sources and sinks identified in
the existing transmission right. This flexibility may be offered into
the Day-Ahead Reconfiguration Service (see the Reconfiguration Service
white paper for additional details). To account for this flexibility,
the Transmission Owner's net obligations must be modified to reflect
these changes.

## IWR Translation

After existing transmission rights are certified, rights holders will
have the opportunity to translate their certified rights into Injection
Withdrawal Rights (IWRs). IWR translation is a prerequisite to
participation in the Grid West Annual, Monthly and Intra-Monthly
Reconfiguration Service.

Certified existing rights can be translated for a specific time period
(e.g. one month, one year, etc.) or for the entire duration of the
ETR.[^3] Additionally, translation may result in a single IWR or set of
IWRs. Finally, Transmission Customers may translate their entire
existing transmission right or just a portion of it. Transmission
Customers that translate their certified exiting rights into IWRs will
be eligible to participate in the all RCS auctions. Additionally, they
can submit their schedules directly to Grid West. However, at the end of
the translation period (defined in the translation request), the IWR
will revert back to a certified transmission right.

## Bilaterally Traded Rights Data Registration

Registration of bilaterally traded transmission rights, whether ETRs or
IWRs, is another process of RDM. A Grid West participant who has
bilaterally purchased rights will initiate the registration process with
Grid West. Grid West will confirm the transaction through interaction
with the selling counterparty and, for ETRs, with the impacted TO. If
confirmed, Grid West will register the transaction and update the rights
data accordingly.

# Rights Data Format

The development of a common rights data format is one of the key steps
in implementing Rights Data Management. The format should be flexible
enough to account for all existing rights/obligations flexibilities and
uniform enough to be efficiently stored and accessed. To help explain
the concepts described in this paper, an example of types of the data
needed has been included in Appendix A.

# Roles and Responsibilities

Table 6 below presents the roles and responsibilities of the Grid West
and its participants related to RDTM:

Table 6 - Grid West and its participants\' roles and responsibilities in
the RCS

+------------+--------------------+-------------------+---------------+
| RDM        | Grid West          | Transmission      | Transmission  |
| Function   |                    | Owners            | Customer      |
+============+====================+===================+===============+
| Rights     | -   Receive,       | -   Provide       | -             |
| In         |     review and     |     existing      |               |
| ventorying |     compile TO     |     obligation    |               |
|            |     rights data    |     information   |               |
|            |                    |     to Grid West  |               |
|            | -   Standardize    |                   |               |
|            |     format         |                   |               |
+------------+--------------------+-------------------+---------------+
| Rights     | -   Receive,       | -   Help with the | -   Request   |
| Cer        |     approve and    |     review of ETR |     ETR       |
| tification |     compile        |     inventory     |     i         |
|            |     Transmission   |     request by    | dentification |
|            |     Customers ETR  |     Transmission  |     and       |
|            |                    |     Customers     |               |
|            | -   Standardize    |                   |  inventorying |
|            |     format         |                   |               |
+------------+--------------------+-------------------+---------------+
| IWR        | -   Receive and    | -   Assist Grid   | -   Request   |
| T          |     review IWR     |     West with IWR |     IWR       |
| ranslation |     translation    |     review        |               |
|            |     request        |                   |   translation |
|            |                    |                   |               |
|            | -   Issue IWR      |                   |               |
|            |     certificate    |                   |               |
+------------+--------------------+-------------------+---------------+
| Bilateral  | -   Receive and    | -   Assist with   | -   Submit    |
| Rights     |     review/confirm |     registration  |               |
| Data       |     registration   |     review        |  registration |
| Re         |     request        |                   |     request   |
| gistration |                    |                   |               |
|            | -   Register       |                   |               |
|            |     bilaterally    |                   |               |
|            |     traded rights  |                   |               |
|            |     data           |                   |               |
+------------+--------------------+-------------------+---------------+

# Market Benchmarks

Existing RTOs and ISOs have normally converted their participants\' ETRs
into FTRs (and/or ARRs) on a single occasion. After conversion to
FTR/ARR, the ETRs cease to exist in their original form. One of the most
contrasting features of Grid West is that Grid West, through RDM will
ensure that holders of existing rights can hold onto and exercise those
rights for their entire term. Table 7 provides a more detailed
comparison of Grid West with PJM, ERCOT and MISO.

Table 7 - Comparing Grid West RDTM with FTR management in existing
RTOs/ISOs

+------------+------------------+------------------+------------------+
| RDTM       | PJM              | ERCOT            | MISO             |
| Function   |                  |                  |                  |
+============+==================+==================+==================+
| Rights     | -   No direct    | -   No direct    | -   No direct    |
| Inventory  |     dealing with |     dealing with |     dealing with |
|            |     TOs on       |     TOs on       |     TOs on       |
|            |     existing     |     existing     |     existing     |
|            |     rights       |     rights       |     rights       |
+------------+------------------+------------------+------------------+
| IWR        | -   One time     | -   One time     | -   One time     |
| T          |     translation  |     translation  |     translation  |
| ranslation |     of ETRs to   |     of ETRs to   |     of ETRs to   |
|            |     FTRs         |     TCRs         |     FTRs         |
+------------+------------------+------------------+------------------+
| Bilateral  | -   Voluntary    | -   Voluntary    | -   Voluntary    |
| Trade      |     registration |     registration |     registration |
| Re         |     and based    |     and based    |     and based    |
| gistration |     only on      |     only on      |     only on      |
|            |     request by   |     request by   |     request by   |
|            |     participants |     participants |     participants |
|            |     and approval |     and approval |     and approval |
|            |     by RTO       |     by RTO       |     by RTO       |
+------------+------------------+------------------+------------------+

# Technology Solutions

Most of the technology solutions needed for RDTM are industry standard
products. Table 8 provides a summary of such required technologies.

Table 8 - Technology solutions for RDTM

  ---------------- ------------------------------------------------------
  RTO/ISO          Life of Issued Right

  RDF Development  Straightforward relational database (RDB) solutions.

  Rights Inventory Straightforward database forms for entering Rights
                   data in RDF structure.

  ETR Translation  Straightforward database forms for entering ETR data
                   in RDF structure.

  IWR Translation  Straightforward database forms for entering IWR data.

  Bilateral Rights Straightforward database forms for registering
  Data             (entering) rights data in RDF structure.
  Registration     
  ---------------- ------------------------------------------------------

# Organization Requirements

Most RDTM processes are heavily manual and resource intensive as
presented in table 9 below.

Table 9 - RDTM Staff Requirements

+---------------+--------------+---------+----------------------------+
| Division      | Department   | Role    | Responsibility             |
+---------------+--------------+---------+----------------------------+
| Market        | Forward      | Manager | -   Same as the RCS        |
| Operations    | Markets      |         |     manager                |
+---------------+--------------+---------+----------------------------+
| Market        | Forward      | Analyst | -   Rights inventorying    |
| Operations    | Markets      | (5)     |     (one time effort for 6 |
|               |              |         |     months to one year)    |
+---------------+--------------+---------+----------------------------+
| Market        | Forward      | Analyst | -   ETR translation        |
| Operations    | Markets      | (2)     |                            |
|               |              |         | -   IWR translation        |
+---------------+--------------+---------+----------------------------+
| Information   | Market       | Analyst | -   Application Support    |
| Technology    | Systems      | (2)     |                            |
+---------------+--------------+---------+----------------------------+
| Information   | Forward      | Analyst | -   Application Support    |
| Technology    | Markets      | (1)     |                            |
+---------------+--------------+---------+----------------------------+
| Information   | Market       | Analyst | -   Database Support       |
| Technology    | Systems      | (2)     |                            |
+---------------+--------------+---------+----------------------------+

#  Cost Drivers

RDTM primary cost drivers are due to manual processes involved. Such
costs could be reduced if:

-   TOs performed all the footwork related Rights inventorying using the
    RDF and Grid West RDTM systems and under Grid West coordination

-   Grid West could increase the turn around time for ETR and IWR
    translation services

#  Appendix A - Rights Data Format:

Rights Data Format (RDF) development is the single most critical step in
implementing the RDTM. RDF should be flexible enough to account for all
existing rights/obligations flexibilities and uniform enough to be
efficiently stored and accessed in industry standard data storage
technologies, e.g. relational databases. For this purpose we will use a
format that contains the following information:

1.  Right Identifiers: Uniquely identifies each right;

2.  Right Owner(s): Identifies entity(ies) who own such right, if
    applicable;

3.  \"Right "Authorized Representative (RAR)" Identifies the entity that
    can interface with Grid West regarding rights use and finances (this
    is expected to normally be the right owner);

4.  Right Status/Origination: Identifies the status/history of the right
    including its origin within a right, if applicable;

5.  Right Duration: Identifies calendar duration of the right (e.g.,
    from now till 2050);

6.  Right Timeline: Identifies duration of the right applicability
    (e.g., summer 2006 peak);

7.  Right Injection Point(s): Identifies all scheduling point(s) that
    can be used as the right injection point(s);

8.  Injection Right Value(s), or value ranges, at individual Right
    injection point(s): Identifies injections right MW value, range of
    values, at individual injection point(s);

9.  Right Withdrawal Point(s): Identifies all scheduling point(s) that
    can be used as the right withdrawal point(s);

10. Withdrawal Right Value(s) \[or value range(s)\] at individual
    withdrawal points: Identifies injections right MW value, range of
    values, at individual injection point(s); and

11. Overall Right Constraint: Identifies a overall constraining factor
    on an existing right/obligation (ETR) such as the fact that total
    injection right where rights are presented in a range is limited

.The following table is intended to show this general format for an 800
MW flexible multipoint to multipoint right, held by the Grid West
participant \"GWP2\" through year 2020, from scheduling points A, B and
C to scheduling points U and V where injection and withdrawal rights at
every one of these scheduling points is also a variable as follows:

-   Up to 400 MW injection right at scheduling point A

-   Up to 300 MW injection right at scheduling point B

-   Up to 300 MW injection right at scheduling point C

-   Up to 400 MW withdrawal right at scheduling point U

-   Up to 600 MW injection right at scheduling point V

The flexibility is shown in the Table in the form of the variable
injection and withdrawal rights at the scheduling points associated with
the right.

> Table 4.1: Uniform Right Data Format

+------------------------+---------------------------------------------+
| > **Right Attribute**  | > **RDF Value**                             |
+------------------------+---------------------------------------------+
| > Right Identifier     | > ETR2-MPtMP-2020                           |
+------------------------+---------------------------------------------+
| > Right Ownership      | > GWP2                                      |
+------------------------+---------------------------------------------+
| > Right Authorized Rep | > GWP2                                      |
+------------------------+---------------------------------------------+
| > Right                | > ETR2-GWP2                                 |
| > Status/Origination   |                                             |
+------------------------+---------------------------------------------+
| > Right Duration       | > Now to 12/31/2020-HE24                    |
+------------------------+---------------------------------------------+
| > Right Timeline       | > Regular                                   |
+------------------------+---------------------------------------------+
| > Right Injection      | > Buses A & B & C                           |
| > point(s)             |                                             |
+------------------------+---------------------------------------------+
| > Injection Right      | > IR~A~ [\<]{.underline} 400MW & IR~B~      |
| > value(s)             | > [\<]{.underline} 300MW & IR~C~            |
|                        | > [\<]{.underline} 300MW                    |
+------------------------+---------------------------------------------+
| > Right Withdrawal     | > Buses U & V                               |
| > point(s)             |                                             |
+------------------------+---------------------------------------------+
| > Withdrawal Right     | > WR~U~ [\<]{.underline} 400MW & WR~V~      |
| > value(s)             | > [\<]{.underline} 600MW                    |
+------------------------+---------------------------------------------+
| > Overall Right        | > \[IR~A~ + IR~B~ + IR~C~ = WR~U~ + WR~V~\] |
| > Constraint           | > [\<]{.underline} 800                      |
+------------------------+---------------------------------------------+

The format presented in the above table is flexible enough to hold all
information about the rights and can be readily implemented within a
relational database framework.

[^1]: The Pacific Northwest Security Coordinator (PNSC) has real-time
    monitoring of the Northwest's transmission system, but lacking
    schedule information, it does not have look ahead capability.

[^2]: See the Reconfiguration, Scheduling, and Bilateral Trading White
    Papers for additional details

[^3]: The motive for such an extra translation can be simply that there
    are additional forums to trade IWRs than there are for trading ETRs.