HomeMy WebLinkAboutC_Public_Comment_47.c_180614.email_attch2of2Supporting Attachment No. 4
To Comments made by Richard Lauckhart dated December 11, 2017
Copy of "Agreement on Disposals of the Canadian Entitlement within the United
States" covering the years 1998-2024 referred to in Supporting Attachment No. 3
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BCTC VITR CPCN AND
SEA BREEZE VIC CPCN — Exhibit B1-131
COLULM131A RIVER TREATY
ENTITY AGREEMENT
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ASPECTS OF THE
DELIVERY OF THE CANADIAN ENTITLEMENT
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APRIL 1, 11998 THROUGH SEPTEMBER 115, 2024
BETWEEN THE CANADIAN ENTITY AND THE UNITED STATES ENTITY
DATED 'MARCH 29, 1999
WHEREAS:
A. Canada and the United States are parties to the I reaty: and
B. The Canadian Entity (being, for purposes of this Agreement, British Columbia
Hydra and Poser Authority) and the United States Entity (collectively. the
"Entities") are designated as the entities under Article XJV of the Treatv for
certain Purposes tinder the "treaty; and
C Pursuant to Article V(2) of the Treaty, the United States is obligated to deliver to
Canada the Canadian Entitlement at a point on the Canada -United States
boundary near Oliver, British Columbia, or at such other place as the Entities may
agree upon, and
11 Pursuant to Article Vi11(1) of the Treaty. portions of the Canadian Entitlement
matt• be disposed of within the United States with the authorization of Canada and
the United States evidenced by an exchange of notes: and
F. By exchange of notes dated September 16, 1964, Canada and the United States
authorized the sale of the Canadian Entitlement �, ithin t;te United States of
America pursuant to Article V111 of the f rest}, the stile expires in steps occurting
March 31. 1998, k1larsh 11. 1999. and March 31. 2003: and
By are exchange of notes (the "1999 Exchange of dotes"). Canada and the United
States hate authorized or ►.•iil authorize disposals of'all or portions of the
Canadian Entitlement %--Oin the United States pursuant to Article V111 of the
Treaty Nvith delivery and other arrangements for such disposals to be made in
accordance with the Disposal Agreement; and
G_ Pursuant to Article X1V(2)U) of the Treaty, the Entities have the powers and
duties to make appropriate arrangements for delivery of the Canadian Entitlement
including such matters as load factors for delivery, tunes and points of delivery,
and calculation of transmission loss; and
H. The Entities wish to enter into this Agreement for the delivery of the Entitlement
Delivery Amount at pairGts on the Canada -United States boundary other than a
point near Oliver, British Columbia, and to resolve certain matters pertaining to
scheduling and calculation of tr=mission loss.
NOW THEREFORE in accordance with the Treaty the Entities agree as follows:
1. This Agreement shall be effective on the later of the date of execution or the
effective date of the Disposal Agreement and shall continue in full force and effect until
2400 hours on September 15, 2024. A]I then outstanding obligations shall continue until
satisfied. Execution of this Agreement supersedes and terminates the Columbia River
Treaty Entity Agreement on aspects of the Delivery of the Canadian Entitlement for
April 1, 1998 through September 15, 2024 between the Canadian Entity and the United
States Entity, dated November 20, 1996, and the Entity Agreement of the same name,
dated ,March 26, 1998, but never having reached its effective date.
2. For the purpose of this Agreement:
(a) "Annual U.S. Obligation" for any year shall mean the Transmission Cost
that the United States Entity would incur to deliver the relevant amounts
of Entitlement Delivery Amount at the Points of Delivery if the amounts
of Entitlement Delivery Amount had previously been continuously
delivered at the Points of Delivery pursuant to this Agreement; and
(b) "Bonneville" means the Administrator of the Bonneville Power
Administration not acting in its capacity as or on b-c5alf of the United
States Entity; and
(c) "Canadian Entitlement" at any time shall mean the downstream power
benefits to which Canada is entitled at that time as described in Article
V(1) and Article VI1 of the Treaty and determined in accordance with the
Treaty; and
(d) "deliver" shall mean make available in the case of electrical capacity or
deliver in the case of electrical energy, or both, as the context may rewire
and derivatives of "deliver' shall have corresponding meanings; and
(e) "Disposal Agreement shall than the '`Agreement on Disposals of the
Canadian Entitlement within the United States for April 1. 1998 through
September 15, 2024" between British Columbia (.'British Columbia") and
Bonneville Power Administration acting on behalf of the United States
Entity; and
(i "Entitlement Delivery Amount" at any time shall mean the Canadian
Entitlement less the amount described in Article Vl." t(a) and :article
V(2)(b) of the Treaty; and
(g) "Points of Delivery„ shall mean the Blaine No. 1 Point of Delivery. the
Blaine No. 2 Point of Delivery, the Nelway Point of Delivery and the
Waneta Point of Delivery. each as described in more particularity in
Attachment A; and
(h) "Transmission Cost" for any period shall mean (i) the cost of transmission
service, plus (ii) any cost, excluding transmission losses, which is
necessarily incurred to deliver Entitlement Delivery Amount for such
period, in each case based on published prices, plus (iii) any costs of
redispatch, construction or modification of transmission facilities as
determined by the regulatory methodology then applicable to the parties
involved; and
(i) "Treaty" shall mean the "Treaty between Canada and the United States of
America relating to cooperative development of the Water Resources of
the Columbia River Basin" including its Annexes A and B, signed at
Washington, District of Columbia, United States of America on the 17'
day of January, 1961, and the Protocol, brought into farce by exchange of
instruments of ratification and. an Exchange of Notes on September lb,
1964,
I
. Pursuant to Article V(2) and Article h1V(2)0) of the Treaty, the Entities agree
that the places of delivery of the Entitlement Delivery Amount for the period
corrunencing April 1, 1998. and ending at 2400 hours on September 15, 2024, shall be the
Points of Delivery. Subject to paragraphs 8 through 11, the United States Entity shall
make available, at no cost to Canada imposed in the United States, the Entitlement
Delivery Amount capacity at the Points of Delivery in the following amounts:
(a) 3114ths at the Nelway Point of Delivery and the Waneta Point of Delivery;
and
(b) l 1/14ths at the Blaine No, I Point of Delivery and the Blaine No. 2 Point
of Delivery.
Subject to paragraphs 8 through 11, the United States Entity shall deliver at no cost to
Canada imposed in the United States, and the Canadian Entity shall accept, the
Entitlement Delivery Amount energy at the Points of Delivery as scheduled by the
Canadian Entity pursuant to paragraph S. up to the capacity amounts referred to in
subparagraphs (a) and/or (b) of this paragraph 3.
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4. Deliveries of the Entitlement Delivery Amount shall not be interrupted or
curtailed except for reasons of uncontrollable force or maintenance and then only on the
same basis as deliveries of firm power from the Federal Columbia River Power System to
Pacific Northwest customers of Bonneville or any successor_ To the extent the Entities
are unable to effect delivery of that part of the Entitlement Delivery Amount referred to in
subparagraph 3_(a) to the Points of Delivery so specified in that subparagraph, the part not
able to be so delivered shall be added to the amount to be delivered to the Points of
Delivery so specified in subparagraph 3.(b). Notwithstanding the foregoing, the Entities
agree that at any time, and from time to time. the portions of the Entitlement Delivery
Arnount to be delivered to the respective Points of Delivery specified in subparagraphs
3.(a) and 3.(b) may be changed temporarily for operational reasons upon agreement by
the Columbia River Treaty Operating Committee representing the Entities.
5. During the period commencing on April 1. 1998, and ending on September 15.
42024. the Canadian Entity shall schedule the Canadian Entitlement pursuant to this
Agreement and the scheduling provisions set forth in Attachment B. The Canadian
Entity may appoint a suitably qualified "Scheduling Agent" to actually perform the
scheduling duties required under this Agreement, subject to the United States Entity's
approval. which shall not be unreasonably withheld.
6. During the period commencing on April 1, 1998. and ending sin September 15.
2024, the transmission loss referred to in .Article V(2xa) of the Treaty shall be calculated
as 3.4% of the Canadian Entitlement energy from which first has been subtracted the
amounts described in article V(?)(b) disposed of within the Unites! States pursuant to the
Exchange of Notes between Canada and the United States of America dated September
16, 1964. or pursuant to the 1999 Exchange of Notes authorizing such disposition.
7. During the period of time specified in Section 4.2(c) of the Disposal Agreement,
the United States Entity shall not have any obligation to maintain, purchase or reserve
transmission for future deliveries to the Points of Delivery as Entitlement Delivery
Amount of the portion of the Canadian Entitlement delivered within the United States
pursuant to Section 4 of the Disposal Agreement. provided that if the Canadian Entity
requests that the United States Entity purchase or reserve transmission for future
deliveries of such portion of the Canadian Entitlement as Entitlement Delivery Amount to
the Points of Delivery pursuant to this Agreement and agrees to pay all costs associated
with such actions, the United States Entity shall purchase or reserve the transmission,
requested by the Canadian Entity, if such transmission is available in the market for
purchase or reservation,
8. Canadian Entitlement that is being disposed of within the United States as
authorized by the 1999 Exchange of Notes shall. upon written notice from the Canadian
Entity pursuant to paragraph I 1 prior to expiry or suspension of the disposal, be delivered
at the Points of Delivery as Entitlement Delivery Amount in accordance with paragraph 3
upon expiry or suspension of the disposal to the extent that:
fa) firm transmission capacity required to deliver such Entitlement Delivery
Amount at the Points of Delivery is available for purchase by the United
States Entity. including by way of assignment: and
f h l the United States Entity's Transmission Cost in any year of delivering
such Entitlement Delivery Amount does not exceed the Annual U.S.
Obligation for such year,
Q_ If Brat transmission capacity required to deliver a portion of the Entitlement
Delivery Amount referred to in paragraph 8 at the Faints of Delivery is not available for
purchase by the United States Entity, the United States Entity shall so notiN the
Canadian Entity, and:
(a) the Canadian Entity may request a Iowa quality or quantity of delivery
than that specified in the Treaty and this Agreement, and if the
transmission required to deliver the requested Capacity and energy is
available for purchase, the United States Entity shall so deliver such
Entitlement Delivery A nount at the Points of Delivery; and/or
b) the Canadian Entity may notify the United States Entity that it wishes the
United States Entity to procure redispatch, construction or modification of
transmission facilities and, subject to the Canadian Entity agreeing to
reimburse the United States Entity- for any Transmission Cost that exceeds
the Annual U.S. Obligation, the United States Entity shall proctue such
redispatch. construction or modification and so deliver that portion of the
Entitlement Delivery Amount at the Points of Delivery.
10. If, for any rear_ the United States Entity's Transmission Cost of delivering the
portion of the Entitlement Delivery Amount referred to in paragraph 8 at the Points of
Delivery would exceed the Annual U.S. Obligation I()r such year and the Canadian Entice
agrees to reimburse the United States Entity for all of its Transmission Cost in excess of
the Annual U.S. Obligation, then the United States Entity shall purchase such
transmission and deliver such Entitlement Delivery Amount at the Points of Delivery.
It. The Canadian Entity shall notify the United States Entity in writing if it wishes all
or portions of the Canadian Entitlement being disposed of within the United States to be
delivered'as Entitlement Delivery Amount at the Points of Delivery pursuant to paragraph 8
upon expiry or suspension of any disposal. Within a reasonable period of time after receipt
of the foregoing notice or notice pursuant to paragraph 9, and before the United States
Entity purchases transmission or procures redispatch. construction or modification of
transmission facilities, the United States Entity shall notify the Canadian Entity of any
expected excess costs referred to in either subparagraph 9(b) or paragraph 10 or both.
Within a reasonable period of time after the United States Entity's notice, the Canadian
Entity shall notify the United States Entity in «citing whether the Canadian Entity agrees to
reimburse the United States Entity for all excess costs referred to in either subparagraph
9(b) or paragraph 10 or both. If the Canadian Entity agrees to reimburse the United States
Entity for such excess costs. the Canadian Entity shall be obligated to do so, whether or not
such transmission is used by the Canadian Entity. The Canadian Entity and the United
States Entity shalt from time to time at the request of the other pasty provide information
necessary to determine these excess costs and the Annual U.S. Obligation. Any portion of
the Canadian Entitlement that can not be delivered under paragraph 8 or paragraph 10 due
to failure of the Canadian Entity to notify the United States Entity to procure transmission
under paragraph 9 or to agree to reimburse the United States Entity tinder paragraph 11 for
excess costs shall be deemed delivered unless British Columbia arrattges disposal of such
portion of the Canadian Entitlement in the United States pursuant to the Disposal
Agreement.
12. Upon termination of the Disposal Agreement pursuant to Section 10 of the
Disposal :agreement, Canadian Entitlement being disposed of within the United States
shall be delivered at the Points of Delivery as Entitlement Delivery Amount in
accordance with paragraph'). Delivery at the Points of Delivery shall be made pending
any dispute about whether the Disposal Agreement has been properly terminated pursuant
to Section 10 of the Disposal Agreement. Any such dispute shall be resolved in
accordance with the Disposal Agreement.
13. Paragraphs S to 11 inclusive shall not apply to:
(a) Entitlement Delivery Amount required to be delivered at the Points of
Delivery as a result of the termination of the Disposal Agnc einent pursuant
to Section 10 of the Disposal Agreerent; or
(b) Entitlement Delivery Amount delivered under this agreement upon expiry
of an exchange or similar arrangement between British Columbia and
Bonneville whereby Entitlement Delivery Amount is exchanged for power
delivered to points of delivery in the United States.
Such Entitlement Delivery Amount referred to in this paragraph shall be delivered at no
cost pursuant to paragraph 3.
14, IF British Columbia has provided a written instrument as described in Section 3.2
of the Disposal Agreement, then the United States Entity shall accept the reductions
identified in Sections 3.2(b) and 3.2(c) of the Disposal Agreement of the obligation of the
person idenuifed in Section 3.2(a) of the Disposal Agreement and as soon as practicable
shall sign amendments to contracts with such person or other instruments necessary to
provide for such reductions.
13. Disputes under this Agreement shalt be resolved in accordance with the Treaty,
16. If any provision of this Agreement is determined to be unenforceable, that
provision shall be deemed severed from and shalt not affect the enforceability of the
remaining provisions.
17. This Agreemsttt shall not be construed to amend or moditl- the Treaty or the
obligations of Canada or of the United States under it_
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IN WITNESS ANEREOE the Entities have caused this Agreement to be executed as of
the day and year first above written,
Executed for the Canadian Entity
this 12 ay of &4, 1999
Brian R. D. Smith, Chairman
Executed for the United States Entity
this AG day of&-� 1999
By jL
Judith A. ohansen, Chair
By:
Robert H. Griffin, Member
Brigadier General, U.S. Army Corps of Engineers
ATTACHMENT A
POINTS OF DELIVERY
I . BI.ArNE NO. I POINT OF DELIVERY:
Location: The point at the border between the United States and Canada in the vicinity of
Blaine, Washington, where the 500 kV facilities of the U.S. Government and B.C. Hydro
are connected on the Custer-Ingledow No. 1 500 kV transmission line;
Voltage: 300 kV;
Mettrin2; at the B.C. Hydro Ingledow Substation. in the 300 kV circuit over which such
electric power flows;
Adjustments:
(1) Demands are tmatled with deliveries at the Blaine No. ? Point of Delivery;
(2) for losses between the paint of metering and the Point of Delivery.
?. BLAME NO.2 POI\-T OF DELIVERY:
Location: The point at the border between the United States and Canada in the vicinity of
Blaine. Washington, where the 500 kV facilities of the U.S. Government and B.C. Hydro
are connected on the Custer-Ingledow No. 2 500 kV transmission line;
Voltage: 500 kV
Metering: At the B.C. Hydro Ingledow Substation, in the 500 kV circuit over which such
electric power flows:
Adjustments:
(1) Demands arc totalled with deliveries at the Blaine No. I Point of Delivcry.
(2) for losses between the point of teetering and the Point of Delivery.
3. NEL kk'AY POFNT OF DELIVERY -
Location: The point at the border between the United States and Canada near Ne[way.
British Columbia, where the 230 kV facilities of the U.S. Government and B.C. Hydro
art connected on the Boundary-Nlelway 230 kV transmission Iine;
Voltage: 230 M
,ieterin : At the U.S. Government's Boundary Substation, in the 230 kV circuit ovC1
which such electric po%tier flows;
Adjustments: For losses between the point of metering and the Point of Delivery.
4. WANETA POINT OF DELIVERY:
Location: The point at the border between the United States and Canada in the vicinity of
Nelway, British Coktmbia, ►vhere the 230 kV facilities of the U_5. Government and
Cominco Ltd. are connected on the Boundary-Waneta 2')0 kV transmission line;
Voltaize: 230 kV;
Metering: At the U.S. Government's Boundary Substation, in the'_30 kV circuit over
which such electric power flows;
adjustments: For transmission losses between the point of metering and the Point of
Delivery.
ATTACHMENT B
C.-VVADiAN El"TLENIENT SCHEDULENG GUIDELINES
These guidelines implement the following Treaty provisions:
Article VII (3) and (4)
(3) The downstream power benefits to which Canada is entitled shall be delivered as
follows:
(a) dependable hydroelectric capacity as scheduled by the Canadian entity, and
(b) average annual usable hydroelectric energy in equal amounts each month, or in
accordance with a modification agreed upon under paragraph (4)
(4) Modification of the obligation in paragraph (3)(b) may be agreed upon by the
entities
Article XIV (2)0)
(2) In addition to the powers and duties dealt with specifically elsewhere in the Treaty
the powers and duties of the entities include;
0) making appropriate arrangements for the delivery to Canada of the downstream
power benefits to which Canada is entitled including such matters as load factors for
delivery, times and points of delivery, and calculation of umismission loss,
1. Interpretations
"Agreement" in this Attachment B means the "Columbia River Treaty Entity Agreement on
As is of the Delivery of the Canadian Entitlement for April 1, 1998 through September
15, 2024" between the Canadian Entity and the United States Entity, dated March 29, 1999.
Initially capitalized terms in this Attachment B will have the meaning ascribed to them in
the Agreement. If there is any conflict between this Attachment B and the Agreement, the
Agreement will prevail.
"Equal amounts each month" will be interpreted as "constant average kilowatts" which
means the amount of Canadian Entitlement energy for any given month is the average
annual Canadian Entitlement energy pro rated based on the number of days in that month.
All times stated in this Attachment B are Pacific Time.
Use of the word "scheduling" in conjunction with "Canadian Entitlement" shall mean
generation scheduling; use of the word "scheduling" with "transmission" shall mean
transmission scheduling; and use of "scheduling" on its orx-n shall mean both generation
and transmission scheduling.
y
2. The Canadian Entitlement will be scheduled on a daily pre -scheduled basis in accordance
v.-Ith and subject to the terms of this Attachment B. The Canadian Entity will use best
efforts to schedule in each month all orthe Canadian Entitlement energy for that month
unless prevented from doing so by a forced outage or emergency conditions at B.C.
transmission or generation facilities.
3. Prior to 1000 hours each Friday. or the last working day of the week if Friday is not a
«orking day. the Canadian Entity will provide the U.S. Entity %ith an estimate (the "Initial
Weekly Estimate") of the amount of Canadian Entitlement energy that will be scheduled
during the week commencing 2400 hours that day through 2.100 hours the folio%-.ing
Friday. Prior to 1000 hours each Monday, or the folio«Zng working day if Monday is not a
working day, the Canadian Entity will provide the U-S. Entity with a mid -week estimate
(the "Mid -Week Estimate") of the Canadian Entitlement energy that will be scheduled for
the balance of the week commencing 2400 hours that day, added to the actual energy
delivered or scheduled up to 2400 hours that day.
Prior to 1000 hours each Friday, or the last working day of the week if Friday is not a
working day, the Canadian Entity will notify the U.S. Entity of the amount, if any, of
available Entitlement Delivery Amount capacity that the Canadian Entity determines in
good faith that it does not require at the Points of Delivery specified in subparagraph 3(a)
of the Agreement during the following week, and the U.S. Entity will not, therefore, need
to make available such Entitlement delivery Amount capacity.
4. The Canadian Entity will each working day, on or before 0930 hours, provide the
U.S. Entity with schedules specifying the hourly Canadian Entitlement deliveries for the
following day. If the following day is not a working day, the Canadian Entity will also
provide the U.S. Entity with schedules for the day or days up to and including the next
following working day.
For the Entitlement Delivery Amount the schedules may specify hourly deliveries of any
amount up to the maximum set by the Entitlement Delivery Amount capacity specified in
either or both subparagraph 3(a) and/or subparagraph 3(b) of the Agreement.
5. Unless otherwise agreed by the Entities' operating personnel, schedules provided pursuant
to paragraph 4 will not be changed by the Canadian Entity, except as may be necessary or
advisable due to outage or emergency conditions on the transmission system of an electric
utility or other entity receiving deliveries of Canadian Entitlement.
6. The Entities acknowledge and agree that, except as may be agreed by the Entities' operating
personnel:
6.1 total deliveries of Canadian Entitlement in any hour will not exceed the Canadian
Entitlement capacity;
6.2 Canadian Entitlement capacity is fully discharged when the U.S_ Entity makes such
capacity available. whether or not the Canadian Entity schedules hourly deliveries up
to this capacity; and
6.3 to the extent that all of the Canadian Entitlement energy in respect of any month is
not or cannot be scheduled during that month by the Canadian Entity, then the
undelivered energy will be scheduled by the U.S. Entity for return at the Points of
Delivery. When the remaining energy to be delivered in any month exceeds the
amount of energy that can be scheduled by full use of the capacity available to the
Canadian Entity, the U.S. Entity may schedule delivery of excess energy to the Points
of Delivery. The U.S. Entity will endeavour to schedule such energy during the
month to the extent possible but may, at its option, schedule such energy up to 7 days
into the subsequent month. In making such deliveries, the U.S. Entity will take
reasonable account of constraints on the transmission and generation systems in B.C.
accepting such energy.
7_ To the extent that the Mid -Week Estimate differs from the Initial Weekly Estimate for that
week and notwithstanding reasonable efforts the U.S. Entity cannot accommodate the
expected daily schedules within existing contractual and system operating constraints, and
if the difference is more than the equivalent of change of 1,000 efs in flow in the
Columbia River at the international boundary, the U.S. Entity may request and the
Canadian Entity will, at the Canadian Entity's option, either:
7.1 provide or accept an amount of energy to accommodate the difference between the
Initial Weekly Estimate and the Mid -Week Estimate, or such other amount as may be
mutually agreed; or
7_2 make a mid -week flow change in lieu of the amount of energy described in
subparagraph 7.1 based on the appropriate total downstream water to power
conversion factor ("h/V) for the period under consideration.
Should actual deliveries consistently exceed or be exceeded by the Mid -Week Estimate, the
U.S. Entity may request now changes in addition to those above to cover such differences.
S. Energy delivered pursuant to subparagraph 7.1 will be scheduled by the delivering Entity.
unless adjustments are needed by the receiving Entity in order to accept the energy that day
due to system constraints. Energy received will be returned during the following week on
like hours, unless otherwise agreed. ,Each Entity will bear all costs of transmitting such
energy in its own country.
9. Cznadian Entitlement required to be delivered and not delivered due to uncontrollable force
will be delivered within 7 days following the outage at times and rates determined by the
Canadian Entity but limited by the Canadian Entitlement capacity, unless otherwise agreed.
Canadian Entitlement required to be delivered to points other than the Points of Delivery,
and not delivered due to uncontrollable force, may, at the option of the U.S. Entity, be
delivered to the Points of Delivery if possible and subject to adjustments needed by the
Canadian Entity in order to accept the energy that day due to system constraints.
Canadian Entitlement scheduled to be delivered to points other than the Points of Delivery,
which cannot be delivered due to recall of non -firm transmission, or due to failure by
British Columbia to schedule tansmission which it was responsible for arranging, shall be
deemed delivered.
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10. Losses associated with Canadian Entitlement deliveries %sill be dealt with as follows:
10.1 for deliveries of the Canadian Entitlement to the Points of Delivery the losses will be
deducted at the time of delivery, and the resulting net Canadian Entitlement will be
scheduled and delivered to the Points of Delivery;
10.2 for deliveries of the Canadian Entitlement to points other than the Points of Delivery,
the frill amount scheduled %sill be delivered -.tiiEh losses being scheduled for return
exactly 7 days later during the same hour as that during which the losses were
incurred. or as otherwise agreed by the Entities.
11. The Columbia River Treaty Operating Committee is empowered to act on behalf of the
Entities to modify or amcnd from time to time this :attachment B. Under emergency
conditions the operating personnel of the Entities are authorized to agree to deviate from
the terms and conditions of this Attachment B during the period of the emergency as may
be necessary or advisable.
12. Notice provisions for scheduling to points of delivery in the United States maybe covered
by the terms and conditions of agreements executed pursuant to the 1999 Exchange of
Notes.
13 All transmission schedules to points other than the Points of Delivery under this attachment
B must meet the requirements of the transmission provider that apply to all transmission
customers at the time of the schedule.
14. The Canadian and United States Entities agree to use best efforts to alleviate any
administrative difficulties created by scheduling under these guidelines.