**UNITED STATES OF AMERICA**

**BEFORE THE**

**FEDERAL ENERGY REGULATORY COMMISSION**

  ------------------------------------- -- --------------------------------
  The California Independent System        Docket No. ER02-1656-\_\_\_
  Operator                                 

  ------------------------------------- -- --------------------------------

+-------------------------------------+---+-------------------------------+
| Avista Corporation,                 |   | Docket No. RT01-35-\_\_\_     |
|                                     |   |                               |
| Bonneville Power Administration,    |   |                               |
|                                     |   |                               |
| Idaho Power Company,                |   |                               |
|                                     |   |                               |
| The Montana Power Company,          |   |                               |
|                                     |   |                               |
| Nevada Power Company,               |   |                               |
|                                     |   |                               |
| PacifiCorp,                         |   |                               |
|                                     |   |                               |
| Portland General Electric Company,  |   |                               |
|                                     |   |                               |
| Puget Sound Energy, Inc.,           |   |                               |
|                                     |   |                               |
| Sierra Pacific Power Company        |   |                               |
+-------------------------------------+---+-------------------------------+

+-------------------------------------+---+-------------------------------+
| Arizona Public Service Company,     |   | Docket Nos. RT02-1-\_\_\_     |
|                                     |   |                               |
| El Paso Electric Company,           |   | EL02-9-\_\_\_                 |
|                                     |   |                               |
| Public Service Company of New       |   |                               |
| Mexico,                             |   |                               |
|                                     |   |                               |
| Tucson Electric Power Company       |   |                               |
+-------------------------------------+---+-------------------------------+

**INFORMATIONAL FILING OF THE CALIFORNIA ISO,**

**THE RTO WEST FILING UTILITIES, AND**

**THE WESTCONNECT APPLICANTS REPORTING ON**

**ACTIVITIES OF THE SEAMS STEERING GROUP - WESTERN INTERCONNECTION**

# A. Introduction and Procedural Background.

This informational filing is submitted to the Federal Energy Regulatory
Commission (the "Commission") as follow-up to a report (the "Initial
SSG-WI Report")[^1] filed with the Commission on January 7, 2003 by the
California Independent System Operator Corporation (the "California
ISO"); the RTO West filing utilities, which consist of Avista
Corporation, Bonneville Power Administration, the British Columbia
Transmission Company, Idaho Power Company, Nevada Power Company,
NorthWestern Energy (formerly the Montana Power Company), PacifiCorp,
Portland General Electric Company, Puget Sound Energy, Inc., and Sierra
Pacific Power Company \[*note: Does the B.C. Transmission Company wish
to participate in this filing?*\]; and the WestConnect Applicants, which
consist of Arizona Public Service Company, El Paso Electric Company,
Public Service Company of New Mexico, and Tucson Electric Power
Company.[^2] The foregoing parties are referred to in this filing as the
"SSG-WI Participants."

The SSG-WI Participants filed the Initial SSG-WI Report in response to
instructions from the Commission in various orders and notices[^3]
related to proposals to form Regional Transmission Organizations
("RTOs") in the West in accordance with Order 2000[^4] and to
restructure certain existing markets.[^5] The Initial SSG-WI Report set
out a proposed work schedule for the highest priority tasks of SSG-WI
and its work groups during 2003. This informational filing is to update
the Commission on the progress of SSG-WI activities since the Initial
SSG-WI Report.

# B. Brief Overview of Informational Filing.

The Initial SSG-WI Report described the structure and objectives of
SSG-WI, including the Steering Committee and the current SSG-WI work
groups: the Planning Work Group, the Congestion Management Alignment
Work Group, the Market Monitoring Work Group, the Common Systems
Interface Coordination Work Group, and the Pricing Reciprocity Work
Group.[^6] Since they submitted the Initial SSG-WI Report, the SSG-WI
Participants have worked diligently, together with other interested
parties participating in SSG-WI's open public process, to move forward
with the high-priority activities outlined in the Initial SSG-WI
Report.[^7]

The Steering Group also recognizes that the context of SSG-WI's
activities continues to evolve, both regionally and nationally. There
are many uncertainties surrounding the direction of future market
reforms, and there are many different views about whether, how, and at
what pace the electric industry should evolve from its existing
structures and business models. These uncertainties have not diluted
SSG-WI's commitment to facilitate a seamless western electricity market,
but they have highlighted the need for SSG-WI to remain both cautiously
optimistic and flexible in its approach. Since the Initial SSG-WI
Report, the Steering Committee has re-focused or re-prioritized some
SSG-WI work group activities so that they better reflect the current
status of RTO development in the West and make more effective use of
SSG-WI resources.[^8]

As explained in the Initial SSG-WI Report, the overarching goal of
SSG-WI is to facilitate continued progress toward a seamless western
market, particularly through supporting the development of the electric
infrastructure necessary to foster competitive wholesale electricity
markets and efforts to promote an efficient market design process.[^9]
The Steering Committee has coordinated and guided the SSG-WI work groups
in pursuit of this goal, constantly striving to promote approaches that
will serve the best interests of the Western Interconnection as whole,
not just individual companies or industry sectors.

Central to these efforts are the activities of the SSG-WI Planning Work
Group and Congestion Management Alignment Work Group, both of which have
made substantial progress on the initial tasks set out for them in the
Initial SSG-WI Report. The Planning Work Group met its key goal of
developing a regional transmission planning process that furthers the
economic expansion of and investment in the West's interstate
transmission system, as well as promoting seamless western electricity
markets. In addition, the Planning Work Group has produced the SSG-WI
Transmission Report -- Framework for Expansion of the Western
Interconnection Transmission System -- October 2003 (the "Transmission
Report"). An executive summary of the Transmission Report is included
with this filing as Attachment A; the entire report is available through
the SSG-WI Website at
\<<http://www.ssg-wi.com/GeneralWorkGroupDetails.asp?wg_id=3&wg_name=Planning>\>.
The Transmission Report and the regional planning process are described
in further detail below in part C.1 of this filing.

The Congestion Management Alignment Work Group has continued to work on
the high-priority tasks identified for it in the Initial SSG-WI Report,
focusing primarily on assessing the compatibility of the congestion
management approaches under development for the three RTOs proposed in
the West (the California ISO, RTO West, and WestConnect, which are
referred to in this filing as the "Western RTOs"). In particular, the
Congestion Management Alignment Work Group has considered the commercial
and operational workability of a combination of financial and physical
rights schemes, congestion pricing at the seams, modeling of the West's
physical transmission system for transmission scheduling and management,
and core elements of a seamless western electricity market.

The Market Monitoring Work Group has focused on its primary task of
developing options related to the structure of a single West-wide market
monitoring function, and brought a consensus proposal to the Steering
Group on October 17, 2003.. The Market Monitoring Work Group has also
developed a consensus proposal concerning confidentiality of and access
to data for market monitoring. At its October 17, 2003 meeting, the
Steering Committee reaffirmed its support for the Market Monitoring Work
Group's efforts and directed it continue work to refine its proposals
for implementing a West-wide market monitoring function.

The Common Systems Interface Coordination Work Group has adjusted its
work schedule to reflect the pace of development among the Western RTOs.
It has focused its efforts since the Initial SSG-WI Report on working
collaboratively with the Congestion Management Alignment Work Group to
develop recommendations for creating a single point of access for
transmission customers to obtain service across the Western
Interconnection. It is also working to identify and participate in North
American "best practice" efforts to develop technical methodologies and
standards that will provide seamless reliability and business
interaction for the wholesale electricity participants in the west.

The Pricing Reciprocity Work Group has made significant progress on the
high-priority tasks it identified for the first three quarters of 2003,
which included gathering and evaluating data on how the Western RTOs (or
their constituent transmission owners) currently collect revenue from
interregional transactions.

In addition to the specific work group activities highlighted above,
SSG-WI representatives have attended joint meetings organized among the
existing and proposed RTOs in North America. During 2003 there have been
two well-attended meetings, on June 8 and October 7, and another meeting
is planned for January 8 and 9, 2004. SSG-WI representatives continue to
meet regularly with members of the Committee on Regional Electric Power
Cooperation (CREPC) and the Western Electric Coordinating Council (WECC)
to enhance collaboration and cooperation with these organizations, so
that all three entities' activities are complementary, rather than
overlapping or duplicative.

-   

# C. More Detailed Description of Informational Filing Elements.

Attachment A to the Initial SSG-WI Report included a summary of the
high-priority tasks planned for each of the SSG-WI work groups during
2003. Attachment B to this filing sets forth the same information, with
additional text in bold and underlined font inserted to describe the
progress that has been made on these initial tasks as of the end of the
third quarter of 2003. The sections that follow provide highlights of
the work groups' accomplishments to date.

1.  [SSG-WI Planning Work]{.underline}.

> a\. *Highlights of Planning Work Group Activities*

The Initial SSG-WI Report identified the following items as
high-priority tasks for the Planning Work Group:[^10]

-   Develop a process to identify transmission projects that are needed
    for economic reasons to facilitate a competitive and seamless
    west-wide wholesale electricity market.

-   For projects that: (1) would have a direct effect on more than one
    RTO, (2) are developed by sponsors outside of the Planning Work
    Group planning process, and (3) seek cost recovery from Western RTO
    ratepayers, SSG-WI will develop a process to evaluate whether the
    projects are justified (necessary and cost effective).

-   Determine if and how SSG-WI will support implementation of projects
    recommended by the Planning Work Group.

-   Develop a process to resolve differences in transmission
    interconnections at the local level so that parties can avoid going
    to the Commission under the process set forth in sections 210 and
    211 of the Federal Power Act.

-   Submit SSG-WI Western Interconnection Transmission Plan to the
    Western RTOs.

The Planning Work Group has completed all of these tasks, and the
Steering Group approved the Planning Work Group's proposals with respect
to the first four items on August 5, 2003. On October 17, 2003, the
Steering Committee approved the Transmission Report for submission to
the Western RTOs.

> b\. *Highlights of Transmission Planning Study Report*

The Transmission Report builds on a report prepared for the Western
Governors' Association in August 2001 entitled "Conceptual Plans for
Electricity Transmission in the West" (the "WGA Report"). The WGA Report
noted that changes in the nature of the electric industry had "uncoupled
the historical linkages between new generation development and
transmission construction,"[^11] and that there had not as yet developed
alternative industry approaches to compensate for this fundamental
change. The Transmission Report makes a valuable contribution to
reestablishing the linkage between generation development and
transmission construction.

The Transmission Report presents assessments for two future years (2008
and 2013) using average load forecasts projected against a set of
"bookend" generation development scenarios, as well as varied
assumptions concerning the region's hydro conditions and prices for
natural gas.[^12] Perhaps the most significant conclusion the
Transmission Report offers is that there are some additions to the
western transmission system that preliminary analyses indicate would
make sense under a wide range of differing generation scenarios. The
Transmission Report's analyses also provide valuable insights into
transmission additions that can support resource diversity and improved
reliability.

The Steering Group recognizes that the greatest value any transmission
planning effort can produce is positive results---to create a foundation
for action that benefits the region and its electricity consumers. While
SSG-WI itself does not have the authority or the resources to sponsor
transmission construction, it can help illuminate the pathway to
meaningful action and can act to catalyze follow-up on West-wide and
subregional planning activities. The SSG-WI Participants believe many
significant barriers to investment in transmission expansion remain,
which must be addressed and resolved if the West is to realize
appropriate electric infrastructure development. Many of these barriers
relate to cost allocation, cost recovery, and the siting and permitting
process.

With this understanding, the Transmission Report identifies next steps
designed to help the region to capture the practical benefit of the work
embodied in the Transmission Report. These next steps build on the
Transmission Report's analytical framework, which looks at the western
transmission system in its entirety, rather than in fragments dictated
by political boundaries or facility ownership. Significant additional
work will be needed to identify the specific facilities that would best
support the region's interests, as viewed through multiple dimensions of
policy and economic considerations. The Transmission Report provides a
solid foundation from which this work can proceed.

> c\. *How the Transmission Planning and Expansion Study Work and
> Resulting Report Were Completed*

The Transmission Report reflects great effort over many months, relying
on voluntary contributions of SSG-WI Participants' employees, interested
stakeholders from across the West, representatives of state regulatory
commissions and energy agencies, and the support of consultants engaged
by the Western RTOs. An open, inclusive public process enabled the
participants to cooperatively develop the analytical approach and
modeling assumptions; to collect, organize, and run appropriate data
through the study models; and to evaluate and draw conclusions from the
modeling.

The Planning Work Group established three objectives to guide its work
on the Transmission Report:

1.  To identify opportunities where the development of additional power
    transmission facilities could further facilitate competitive and
    efficient markets;

2.  To provide policymakers with information about transmission impacts
    of various energy policies being considered by state, provincial,
    and federal entities; and

3.  To identify for generation developers major transmission additions
    that might be needed to deliver a wide range of generation resources
    to load.

The Transmission Report developed analyses based on western power system
conditions in two future years: 2008 and 2013. The 2008 study, which was
designed to act as a base case for comparing 2013 results, included a
range of analyses using an average load forecast. The average load
assumptions were then plugged into a multi-pass modeling process to
identify anticipated capital investment costs and production cost
savings for low, average, and high hydro conditions and a number of
price ranges for natural gas. The 2008 study included only those
additional transmission facilities that were reasonably expected to be
in place by 2008. The 2008 study provides a benchmark for a 2013 load
forecast by identifying congestion problems likely to occur if new
resources and transmission were not developed.

The 2013 study looked at three possible approaches to future generation
development, which were intended as conceptual "bookends." These were
used to evaluate the transmission infrastructure that would be needed to
support each of the assumed future generation mixes. The three
approaches were:

> a\. A gas-fired scenario that assumed 86 percent of new generation
> would be fueled with natural gas and located near load centers;
>
> b\. A coal scenario that assumed 66 percent of the new generation
> added between 2008 and 2013 would be coal-fired; and
>
> c\. A renewable energy scenario that assumed that 72 percent of new
> generation added between 2008 and 2013 would be from renewable
> resources. The renewable energy scenario contains enough renewable
> energy generation to satisfy the renewable portfolio standards that
> four states within the Western Interconnection have enacted.

Like the 2008 study, the 2013 study included analyses based on an
average load forecast measured against low, average, and high hydro
conditions and a number of price ranges for natural gas. These different
assumptions sets were then used to identify expected capital investment
costs and production cost savings for each scenario.

As noted above, using a system-wide perspective and comparing different
assumption sets for the generation infrastructure development, hydro
conditions, and natural gas prices yielded a great deal of useful
information, which can help guide the direction and framework for more
detailed future analyses. Because some future transmission
infrastructure needs were common to all the assumption sets, the
Transmission Report also points to how further efforts might be
logically prioritized.

> d\. *Summary Description of SSG-WI Planning Process*

Another important accomplishment of the Planning Work Group during 2003,
which was reflected in the development of the Transmission Report, was
to define a consensus process for SSG-WI planning activities. The SSG-WI
planning process, which was approved by the Steering Committee on August
5, 2003, contemplates an open, collaborative effort involving all
interested stakeholders. It relies not only on the Planning Work Group,
but on subregional planning groups (such as those that currently exist
in the Northwest, the Desert Southwest, the Rocky Mountain region, and
California), the WECC, and the Western RTOs (recognizing that RTO West
and WestConnect are not yet operational). The SSG-WI planning process
identifies the responsibilities of each of the different contributors
and their relationships to each other, and also envisions active
cooperation and consultation with appropriate state, provincial, and
tribal regulators and siting and environmental agencies.

The Planning Work Group intends that the process it developed and used
to produce the Transmission Report will continue in the future to
address western transmission expansion issues. The joint efforts of the
organizations, subregional groups, and stakeholders engaged in the
SSG-WI planning process will identify and develop plans for expansion of
the western interconnected transmission system. SSG-WI will focus on
higher-level West-wide needs. The Planning Work Group plans to issue
future transmission reports on an annual basis. The role of the
subregional planning groups will be to perform more in-depth planning
studies that both feed into and build from the West-wide perspective at
the SSG-WI level.

2\. [SSG-WI Congestion Management Alignment Work]{.underline}.

The overarching focus of the Congestion Management Alignment Work Group
is to anticipate and offer strategies for mitigating any operational or
commercial inefficiencies that might result at the interfaces among the
Western RTOs because of differences in their approaches to congestion
management. The Congestion Management Alignment Work Group has
approached this challenge from the perspective of maintaining, as far as
possible, the basic attributes of each RTO's congestion management
model.

One of the Congestion Management Alignment Work Group's efforts during
2003 has been to analyze whether a mixed model of physical and differing
financial rights is manageable for both system operators and
transmission users. The Congestion Management Alignment Work Group has
also begun work on assessing whether, if redispatch is used to manage
congestion at the interfaces among the Western RTOs, it is necessary to
have a single set of congestion clearing prices across the seams. There
is general agreement within the work group that there should be a single
set of prices, whether generated explicitly by a locational pricing
congestion management scheme or as an iterative step in a physical
rights congestion management scheme (or perhaps some combination of the
two). The Congestion Management Alignment Work Group is working to
develop mechanisms by which prices across the three Western RTOs can be
converged in a day-ahead market. The work group has not yet addressed
other markets (such as hour-ahead, real-time, etc.).

In evaluating whether the Western RTOs can employ physical models of the
western transmission system that differ in the degree of detail they
provide, the Congestion Management Alignment Work Group has reached
general agreement. It has concluded that each of the RTOs should use a
single, relatively detailed physical model of the entire interconnection
for its scheduling and congestion management activities. Although each
RTO may enhance the basic model to include additional internal detail
for transmission elements that do not affect or are not affected by
external transactions, the work group believes that the common model
should accurately reflect the impact of each RTO's transactions on flows
across all significant paths in the interconnection.

Finally, in its ongoing work to develop consensus on the core elements
of a seamless western electricity market, the Congestion Management
Alignment Work Group has broadened its initial objective. The work group
now seeks to identify not only the core elements, but to describe a
process that will enable the Western RTOs to create a seamless market
while maintaining the characteristics of their own market designs as
filed with the Commission. As part of this more ambitious undertaking,
the Congestion Management Alignment Work Group has been collaborating
with the Common Systems Interface Coordination Work Group through a task
group (the Single Market Interface Task Group). The Single Market
Interface Task Group's goal is to develop straw proposals for
implementing a single market interface that will enable transmission
customers, on a day-ahead basis, to schedule transmission on and bid
into markets operated by the three Western RTOs with a single pass
("one-stop shopping"). The task group has identified approaches for
incorporating energy trading hubs into the Western RTOs congestion
management schemes as part of its straw proposal development process.

3\. [SSG-WI Market Monitoring Work]{.underline}.

\[***[NOTE TO REVIEWERS]{.underline}:*** *This draft* *reflects* *the
drafting group's effort to* *provide* *the level of detail that all
SSG-WI Participants* *will* *find appropriate (trying not to overstate
the degree of resolution of outstanding concerns related to the
"umbrella" market monitoring proposal while at the same time conveying a
message of substantial progress since January 7, 2003). We welcome
comments to help us make sure that everyone is comfortable that the
information provided to the Commission in* *this filing* *is
constructive and accurate, and we will make whatever changes in emphasis
or level of detail are needed to address any concerns of parties*
*signing* *this filing.*\]

On October 17, 2003, the Market Monitoring Work Group presented to the
Steering Group a consensus proposal for how a West-wide market
monitoring function could be carried out through an "umbrella" market
monitoring entity. The basic elements of the proposal contemplate that
the umbrella form of West-wide market monitor would be an independent,
Commission-jurisdictional entity that would monitor West-wide wholesale
transmission markets and related market activity. The umbrella entity
would coordinate closely with local market monitoring units (those
responsible for individual Western RTOs) and would rely in the first
instance on the local units' work product concerning local RTO markets.

The Market Monitoring Work Group's proposal outlines the general roles
of the umbrella entity, including its reporting relationship to the
Commission; to state, provincial, Mexican, and local regulatory,
oversight, and enforcement agencies; and to the Boards of Directors of
the Western RTOs. The proposal does not provide for the umbrella entity
to have mitigation or enforcement authority, but it would be able to
monitor market participants' compliance with Commission and RTO
mitigation measures where they have implications for the seams among the
Western RTOs.

After discussing the Market Monitoring Work Group's proposal, the
Steering Group adopted a resolution in which the Steering Group:

-   Reaffirmed its support for the development and implementation of a
    West-wide market monitoring function;

-   Supported further development and definition of the "umbrella"
    proposal, as set forth in the Market Monitoring Work Group's October
    17 recommendations; and

-   Directed the Market Monitoring Work Group to further explain and
    develop the issues identified in the Steering Group's discussion.

There were numerous areas that the Steering Group identified for further
Market Monitoring Work Group attention, including: clearer delineation
of the relationship between the umbrella entity and RTO-specific market
monitoring units; the umbrella entity's access to data; procedural
safeguards governing investigations undertaken by the umbrella entity;
creating an appropriate balance between the umbrella entity's
independence and its accountability to those that provide its funding;
and how the umbrella entity should be funded. These are illustrative
examples; the Steering Group's directions to the Market Monitoring Work
Group covered a wide range of additional issues.

The Marketing Monitoring Work Group intends to respond to the Steering
Group's instructions as expeditiously as it can. The Market Monitoring
Work Group's next action will be to meet jointly with representatives of
CREPC and the Commission's Office of Market Oversight and Investigations
in Las Vegas on November 4, 2003.

4\. [SSG-WI Common Systems Interface Coordination Work]{.underline}.

As noted in the highlights of the Congestion Management Alignment Work
Group's activities above, the Common Systems Interface Coordination Work
Group has co-sponsored the Single Market Interface Task Group to develop
a straw proposal for a single market interface for transmission service
and market participation across the three Western RTOs. The work to date
has been mainly conceptual. The Single Market Interface Task Group
initial focus has been to build a strong foundation for future work by
gaining a clear understanding of what parties will be served through the
single market interface and what functions will be required to meet the
needs of both market participants and system operators.

The Common Systems Interface Coordination Work Group also began work on
business process modeling as scheduled in the Initial SSG-WI Report. The
work group's focus in this area has been on the settlement process and
on actively reviewing and commenting on proposals developed through the
Electronic Scheduling Collaborative. A subgroup originally set up under
the Common Systems Interface Coordination Work Group, the Business
Architecture Development Group, has recently become a free-standing work
group under SSG-WI, with a goal to improve consistency of transaction
processes and terminology among the Western RTOs.

There are other important aspects of the Common Systems Interface
Coordination Work Group's initial scope, particularly implementation and
simulation coordination, that will become more active as development
activities of the Western RTOs progress in the future. The group has
defined and prioritized a work plan that addresses multiple aspects of
seamlessness between the Western RTO systems. Each of these will be
accomplished as it is appropriate in the development of the Western
RTOs.

5\. [SSG-WI Pricing Reciprocity Work]{.underline}.

The Pricing Reciprocity Work Group has moved forward with the work
designated for the first three quarters of 2003. On April 7, 2003, the
work group completed and posted on the SSG-WI Website a high-level of
comparison of the pricing proposals for each of the Western RTOs.[^13]
In August 2003, the work group completed the process of compiling,
checking, and coordinating one month's data on transactions across the
seams between the Western RTOs (the month selected was September 2002).
Based on its evaluation of this initial data, the Pricing Reciprocity
Work Group concluded that it would be appropriate to collect data
related to an entire year's worth of transactions across the RTO regions
in the West, and is proceeding with this effort.

Over the past several months, the Pricing Reciprocity Work Group has
revisited and refined the four options it had previously developed, and
has also added a variation on one of the options. The work group
concluded that some reconsideration was appropriate in light of the
Commission's April 28, 2003 White Paper on Wholesale Power Market
Platform.

The Pricing Reciprocity Work Group completed, ahead of schedule, one of
the items designated for the fourth quarter of 2003: definitions of
evaluation criteria to be applied to each of the pricing reciprocity
options it develops. Definitions for four evaluation criteria (eliminate
trade barriers between RTOs, mitigate cost shifts, equal treatment, and
simplicity) were posted on the SSG-WI Website[^14] on April 7, 2003. The
Pricing Reciprocity Work Group expects to continue efforts to further
define options (including advantages and disadvantages), develop
evaluation criteria, and compile data needed to evaluate the options in
the coming months, and to identify issues related pricing seams with and
services offered to parties that are not RTO participants.

As noted in the overview to this filing, SSG-WI representatives have
been working actively not only within the Western Interconnection, but
in broader arenas as well. In particular, they have attended joint
meetings of the existing and proposed RTOs in North America through an
*ad hoc* ISO/RTO markets committee.

At least one high-level operations representative from each existing or
proposed ISO or RTO in North America attended the ISO/RTO markets
committee's second meeting on October 7, 2003. Among the areas the
committee may explore in future meetings are: coordination with other
seams-related organizations (such as the North American Energy Standards
Board and the Standards Review Committee of the ISO/RTO Council);
approaches to a wide range of market operation issues, such as credit
and billing procedures, handing financial losses, day-ahead congestion
management, forward markets, hubs, and trading exchanges; market
monitoring issues, resource adequacy (particularly through capacity
markets); and tools for market design simulation.

The SSG-WI Participants believe that coordination and
information-sharing among the ISOs and RTOs in North America has
tremendous value. SSG-WI intends to participate in and strongly support
future activities of the ISO/RTO markets committee.

Respectfully submitted,

SIGNATURES

DATED the \_\_^th^ day of October 2003

THE CALIFORNIA ISO CORPORATION

By: Elena Schmid

Vice President, Corporate

and Strategic Development

THE RTO WEST FILING UTILITIES:

> AVISTA CORPORATION
>
> By: Randall O. Cloward
>
> Director, Transmission Operations
>
> BONNEVILLE POWER ADMINISTRATION
>
> By: Allen L. Burns
>
> Executive Vice President
>
> Industry Restructuring
>
> BRITISH COLUMBIA TRANSMISSION\
> COMPANY
>
> By: Yakout Mansour
>
>    Senior Vice-President
>
>     System Operations and Asset Management
>
> IDAHO POWER COMPANY
>
> By: James L. Baggs
>
> General Manager, Grid Operations\
> and Planning
>
> NORTHWESTERN ENERGY
>
> By: Ted D. Williams
>
> Director, Transmission Marketing
>
> PACIFICORP
>
> By: John Carr
>
> Managing Director, Major Projects
>
> PORTLAND GENERAL ELECTRIC
>
> By: Stephen R. Hawke
>
> Vice President, System Planning
>
> and Engineering
>
> PUGET SOUND ENERGY, INC.

By: Kimberly Harris

> Vice President, Regulatory Affairs
>
> NEVADA POWER COMPANY and
>
> SIERRA PACIFIC POWER COMPANY
>
> By: Carolyn Cowan
>
> Executive Director, Transmission Policy
>
> and Operations

THE WESTCONNECT APPLICANTS

> Deborah R. Scott
>
> Senior Counsel
>
> Tucson Electric Power
>
> One South Church Ave., Suite 200
>
> P. O. Box 711
>
> Tucson, AZ 85702
>
> *Attorney for Tucson Electric Power Company*
>
> John D. McGrane
>
> Stephen M. Spina
>
> Morgan, Lewis & Bockius LLP
>
> 1800 M St., N.W.
>
> Washington, DC 20036
>
> *Attorneys for Arizona Public Service Company*
>
> David B. Raskin
>
> Steptoe & Johnson LLP
>
> 1330 Connecticut Ave., N.W.
>
> Washington, DC 20036
>
> *Attorney for El Paso Electric Company*
>
> John T. Stough, Jr.
>
> Hogan & Hartson LLP
>
> 555 Thirteenth Street, N.W.
>
> Washington, D.C.  20004
>
> *Attorney for Public Service Company of New Mexico*

# 

**D. List of Attachments.**

Attachment A -- Executive Summary to SSG-WI Transmission Report --
Framework for Expansion of the Western Interconnection Transmission
System -- October 2003

Attachment B -- Summary of Progress on High-Priority SSG-WI Work Group
Activities Since January 7, 2003

[^1]: *See* Report of the California ISO, the RTO West Filing Utilities,
    and the WestConnect Applicants Concerning Activities of the Seams
    Steering Group - Western Interconnection, filed with the Commission
    in Docket Nos. ER02-1656, RT01-35, RT02‑1, and EL02-9 on January 7,
    2003 (the "Initial SSG-WI Report").

[^2]: The WestConnect Applicants include only the
    Commission-jurisdictional public utilities that have participated in
    the development of WestConnect. The WestConnect Applicants note that
    the Salt River Project Agricultural Improvement and Power District,
    the Western Area Power Administration, and the Southwest
    Transmission Cooperative, Inc. also participated in WestConnect's
    development.

[^3]: *See* Initial SSG-WI Report at 2--4 for a summary of the orders
    and notices to which the Initial SSG-WI Report was responding.

[^4]: *Regional Transmission Organizations*, Order No. 2000, 65 Fed.
    Reg. 809 (Jan. 6, 2000), FERC Stats. & Regs. ¶ 31,089 (1999), *order
    on reh'g*, Order No. 2000‑A, 65 Fed. Reg. 12,088 (Mar. 8, 2000),
    FERC Stats. & Regs. ¶ 31,092 (2000), *aff'd sub nom. Pub. Util.
    Dist. No. 1 of Snohomish Cty., WA v. FERC*, Nos. 00-1174, et al.
    (D.C. Cir. 2001).

[^5]: The California ISO, RTO West filing utilities, and WestConnect
    Applicants are each making filings in their respective dockets, and
    are not by this joint filing making filings in each other's dockets.
    The parties have prepared a joint filing for administrative
    convenience only. The California ISO is submitting this filing
    solely in Docket No. ER02-1656. Avista Corporation, Bonneville Power
    Administration, the British Columbia Transmission Company, Idaho
    Power Company, Nevada Power Company, NorthWestern Energy (formerly
    the Montana Power Company), PacifiCorp, Portland General Electric
    Company, Puget Sound Energy, Inc., and Sierra Pacific Power Company
    (collectively the RTO West filing utilities) are submitting this
    filing solely in Docket No. RT01-35. Arizona Public Service Company,
    El Paso Electric Company, Public Service Company of New Mexico, and
    Tucson Electric Power Company (collectively the WestConnect
    Applicants) are submitting this filing solely in Docket Nos. RT02‑1
    and EL02-9.

[^6]: *See* Initial SSG-WI filing at 9--11.

[^7]: *See id.* at Attachment A.

[^8]: For example, while the Common Systems Interface Coordination Work
    Group's initial charge was to coordinate the market design
    implementation schedules for RTOs in the West, this is not the best
    use of the work group's talents at this time. Furthermore,
    redirecting its immediate focus has allowed the Common Systems
    Interface Coordination Work Group to engage in national discussions
    concerning standards development, which are of enormous importance
    to all system operators in the West. Until the Common Systems
    Interface Coordination Work Group became involved in this arena, the
    West did not have a ready means to participate in this forum.

[^9]: *Id.* at 5.

[^10]: *See id.* at 16--17 and Attachment A.

[^11]: *See* WGA Report executive summary at 3, available on the
    Internet at
    \<<http://www.westgov.org/wga/initiatives/energy/transmission_rpt.pdf> \>.

[^12]: Generation scenarios for the 2008 and 2013 studies were chosen
    intentionally the highlight potential differences in transmission
    implications for distinct resource types and locations. The Planning
    Work Group did not attempt to choose a projected future generation
    mix based on expectations of what was likely to occur (which might
    have suggested using intermediate, rather than "bookend" scenarios).

[^13]: This high-level comparison is available on the SSG-WI Website at
    \<[http://www.ssg-wi.com/GeneralWorkGroupDetails.asp?wg_id=4&wg_name=Price%20Reciprocity](http://www.ssg-wi.com/GeneralWorkGroupDetails.asp?wg_id=4&wg_name=Price Reciprocity)\>.

[^14]: \<
    http://www.ssg-wi.com/GeneralWorkGroupDetails.asp?wg_id=4&wg_name=Price%20Reciprocity\>.