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Summary of Compliance Filing Requirements


Order No. 890-A (Order on Rehearing and Clarification)
For a more detailed description of compliance obligations please refer to the Order on Rehearing and Clarification paragraph number. For further information related to the Final Rule, such as electronic versions of the pro forma OATT showing tariff changes adopted in the Order on Rehearing in redline/strikeout format.

Deadline (days after publication in Federal Register) Compliance Action Order on Rehearing Paragraph #
60
(03/17/2008)
Transmission providers that have not been approved as RTOs or ISOs, and whose facilities are not in the footprint of an RTO or ISO, to submit an FPA section 206 filing that contains the revised non-rate terms and conditions of the pro forma OATT stated in Appendix C. ¶38
90
(04/15/2008)
RTO and ISO transmission providers, transmission providers whose facilities are in the footprint of an RTO or ISO, and WSPP to submit an FPA section 206 filing that contains the revised non-rate terms and conditions of the pro forma OATT as stated within Appendix C. ¶38


Order No. 890 (Final Rule)
For a more detailed description of compliance obligations please refer to the Final Rule paragraph number. For further information related to the Final Rule, such as electronic versions of the pro forma OATT showing tariff changes adopted in the Final Rule in redline/strikeout format

Deadline (days after publication in Federal Register) Compliance Action Final Rule Paragraph #
30
(4/16/2007)
Optional Implementation FPA section 205 filings allowing transmission providers to propose previously approved variations from the pro forma OATT that have been affected by pro forma OATT Final Rule reforms to remain in effect subject to a demonstration that such variations continue to be consistent with or superior to the revised Final Rule pro forma OATT (non RTO/ISO transmission providers). Such optional filings must request a 90 day effective date to facilitate Commission review under section 205. ¶139
75
(5/29/2007)
Transmission Providers must post a “strawman” proposal for compliance with each of the nine planning principles adopted in the Final Rule. This may be posted on the Transmission Providers website or its OASIS site. ¶443
90
(6/13/2007)
NERC/NAESB status report and work plan for completion of ATC related business practices and standards. ¶223
NAESB status report and work plan for completion of OASIS functionality or uniform business practices (other than those related to ATC). ¶141
120
(7/13/2007)

Transmission providers that have not been approved as ISOs or RTOs, and whose transmission facilities are not under the control of an ISO or RTO, must  submit FPA section 206 filings that contain the non-rate terms and conditions set forth Order No. 890. These filings need only contain the revised provisions adopted in Order No. 890. Transmission providers utilizing the optional implementation FPA section 205 filing described above, need only submit tariff sheets necessary to implement the remaining modifications required under the Order No. 890, i.e., modifications related to tariff provisions that did not implicate previously-approved variations.

¶135
Order Granting Extension of Compliance Action Dates PDF
120
(7/13/2007)
Transmission Providers must submit redesigned transmission charges that reflect the Capacity Benefit Margin set-aside through a limited issue section 205 rate filing as part of their initial ATC related compliance filings ¶263
180
(9/11/2007)
Submit compliance filings with Attachment C (ATC) of the pro forma OATT ¶140
09/14/2007
Each transmission provider is directed to post a draft of the attachment toits OATT governing transmission planning on its OASIS, or on its website if it does not have an OASIS Order Extending Compliance Action Date and Establishing Technical Conferences PDF
210
(10/11/2007)
ISOs and RTOs, and transmission providers located within an ISO/RTO footprint, submit FPA section 206 filings that contain the non-rate terms and conditions set forth in the Final Rule.  These filings need only contain the revised provisions adopted in the Final Rule or a demonstration that previously approved variations continue to be consistent with or superior to the revised pro forma OATT. ¶157
¶161
210
(12/7/2007)
Submit compliance filings with Attachment K (Planning) of the pro forma OATT or RTOs and ISOs file a demonstration that their planning processes are consistent with or superior to the planning principles in the Final Rule ¶140
¶422
Order Extending Compliance Action Date and Establishing Technical Conferences PDF
N/A N/A Transmission Providers must file a revised Attachment C to incorporate any changes to NERC's and NAESB's reliability and business practice standards to achieve consistency in ATC within 60 days of completion of the NERC and NAESB processes. ¶325
N/A After the submission of FPA section 206 compliance filings, transmission providers may submit FPA section 205 filings proposing rates for the services provided for in the tariff, as well as non-rate terms and conditions that differ from those set forth in the Final Rule if those provisions are "consistent with or superior to" the pro forma OATT. ¶135


CONTACT
Travis McGee
Telephone: 202-502-8358
Email: travis.mcgee@ferc.gov

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Updated: June 28, 2010