Document RjzyRvBX5ddeVV3jnrebYYKxa

NorthWestern Erier g Delivering a Bright Future Figure 2: Import Available Transfer Capability (ATC: in MW) Yearly Firm ATC by Year (as of 2/23/2O23 BPA import Yearly Firm ATC 2023 2024 31 Path 8 2025 47 AVAT Import 2023 196 2024 162 2025 162 BROY Import 2023 59 2024 59 Path 18 Jeff Import 2C25 2023 72 2024 72 2025 72 YTP/Crossoverlmport Path 80 2023 2024 2025 Even when there is available capacity on a path, NorthWestern has to compete with other transmission customers/users. The operation of NorthWestern's transmission system is subject to regulation by FERC in accordance with North Western's ITRC-jurisdictional Open Access Transmission Tariff ("OATT"). As a result, NorthWestern is required to provide transmission scrvicc to several types of customers on a first come first serve basis, which means that there is competition for ATC among many potential users of the transmission system. NorthWestern's transmission system serves four types of customers -- retail, network, interconnection, and point to point ("PTP"). In addition to NorthWestern's retail customers, our FERC customers include electric cooperatives, federal marketing agencies (e.g. I-3PA and WAPA), and "choice" customers, who arc all customers that do not receive thcir electric supply service from North Western. This means that there arc many non-North Western entities within the North Western BAA that arc competing for available transmission, constraining transmission of power at critical peak times when customers need that power the most. Critically, this transmission competition is becoming much greater as in-state generation shuts down. As noted above, transmission capacity is awarded on a first-come, first-served basis. Of critical importance is that North Western's own "native" load does not receive any preference over other eligible customers. In addition, there are rules governing what is a valid transmission service request or network service designation. For example, long-term network transmission scrvicc designation requests must be tied to legitimate network resources with valid contracts for service in place. Figure 3 displays the current firm transmission imports that are reserved on a long-term basis by parties. Many of these reservations are not for service to NorthWestern's customers. This transmission capacity 17 Sierra Club FOIA 2025-EPA-04883 ED_018388_00000308-00018 SC_EVERSPLIT0006155