Mark -

The ad hoc team's product is attached.  It is a suggested revision to the
NERC A3A1 time table for the WSCC.  Some basic points are:

*	Elimination of manually setting the WSCC pre-schedule flag.  The
table provides rules for the e-tag software to automatically set the flag.

*	The majority of our efforts were focussed on creating an incentive
mechanism to encourage timely tag submission and assessment.  The team
agreed that the best incentive mechanism would be a financial one (i.e.,
tags submitted close to the deadline would pay a high submittal fee - tags
submitted early in the hour would pay little or no submittal fee - approval
entities would receive compensation for assessing/approving late tags,
etc.).  But, a financial mechanism would  have to go through a cumbersome
review/approval process which would be too inflexible for the fast paced
world of E-Tag and NERC's electronic scheduling.  So, the suggested
incentive process increases the risk of a tag not being approved the closer
the submittal time is to the start time.  To do this, we considered three
parameters - the assessment window, deferred denial, and the default
composite status.

	*	The assessment window is a period time that the E-Tag
Authority Service gives the Approval Services to assess a submitted tag.
Each Approval Service is to check the tag for various things and respond
with a approved or denied vote back to Authority service who then set the
final composite status.

	*	Deferred denial is when a entity denies a tag, the composite
status does not immediately become Denied, but instead waits until the end
of the assessment window to set the composite status.  This allows the
denying approval entity time to reconsider their vote and change it, if
appropriate.

	*	The default composite status is a final stated reached at
the end of the assessment window when one or more approval entities fails to
actively approve or deny a tag.  Currently, tags submitted before a certain
deadline will have their final composite status default to Approved.  Tags
submitted after a certain deadline will have their final composite status
default to Denied.

	For real-time tagging, we cite the hour-ahead business where
Purchasing-selling entities trade products for delivery in the next hour.

	*	Tags submitted in the first half of the hour-ahead, referred
to 0 to 30 past, will have a 10 minute assessment window, are subjected to
deferred denial, and will default to Approved/Conditional.

	*	Tags submitted from 30 to 40 past, will have a 10 minute
assessment window, are not subjected to deferred denial (can be called
instant denial), and but will still default to Approved/Conditional.

	*	Tags submitted in the after 40 past, will have a 5 minute
assessment window, are not subjected to deferred denial (can be called
instant denial), and will default to Denied (thus assigned a composite
status of Late).

*	The table references specific times in the submittal and assessment
process which should all reference a consistent time zone standard.  The
team was divided on the best approach.  Some suggested all times on the
table be the prevailing time for the LCA.  This would require each CA to
include in the e-tag registry their time zone.  Some suggested  all times on
the table be in Pacific Prevailing Time.  And some suggested that all times
on the table be in Pacific Standard Time.  The conclusion is that a white
paper would be produced prior to the July ISAS meeting discussing the pros
and cons of each suggestion.

*	The group does not recommend basing submittal time on the tag
agent's time clock - submittal time should stay with the authority service.

*	Here's a big one - because the timing table allows for later
submittal times, the tag assessment process is encroaching on the start of
the WSCC standard ramp (i.e., currently starts at 10 minutes before the
hour).  We are recommending that ISAS request the OC to study the
feasibility of moving the WSCC standard ramp from a twenty minute duration
straddling the hour to 10 minute duration straddling the hour (i.e., starts
at 0:55 and ends at 0:05).  Such a change would align the WSCC with the
Eastern Interconnection and relieve some of the issues surrounding late tag
submittals.

*	There was some discussion on establishing a new regional practice
for the tariff deadline for schedule changes (most are set to 20 before the
start).  It was felt that there is little chance at getting all entities to
change their tariffs in a coordinated and timely manner.

*	The team did not want to address at this time issues concerning
multiple preschedule days and how they are not recognized in Policy 3 or the
E-Tag specifications.

*	Finally, the team can not stress enough that a composite status of
Late should not and does not mean automatic denial.  The Late designation
simple indicates that the default composite status is Denied.  Approval
entities should make every effort to assess all tags, Late or not.

Hurray for the team members, many, many thanks.

 <<tag time table draft_rev3.doc>>

Robert Harshbarger
Puget Sound Energy
OASIS Trading Manager
425.882.4643 (desk)
206.604.3251 (cell)

 - tag time table draft_rev3.doc