Informal Comments Submitted by R. Martinko, FirstEnergy Service Company
-----Original Message-----
From: Robert Martinko
Sent: Thursday, August 14, 2008 2:53 PM
To:
Subject: Re: Request for Informal Comments on Update - Rollover Rights on Redirect - Due 8/15/08
To: ESS/ITS Subcommittee
Request No.: 2008 AP Item 2(a)(iv)(3)
Request Title: Rollover Rights on Redirect on a Firm Basis
Thanks for the opportunity to submit informal comments on the subject matter.
FirstEnergy believes that current business practices allow a transmission customer with a long-term firm point-to-point transmission service reservation to redirect its service to network integration transmission service (NITS). Therefore, such a transmission customer can indicate, through a request to redirect, their intent to convey rollover rights to the alternate points of receipt and delivery - in this case, points of the NITS - under 001-9.7 and subject to certain requirements.
One certain requirement, 001-9.7.1.1, says "The transmission service attributes of the Redirect request must correspond to a valid long-term firm transmission service offered by the Transmission Provider."
FirstEnergy believes that NITS is such a valid long-term firm transmission service and that the NAESB standard ought to explicitly include in a reference to NITS as being valid for all purposes of rollover rights on redirect.
Please let us know your thoughts on this comment.
Robert M. Martinko
Consultant, FERC Policy & Compliance
FirstEnergy Service Company
76 South Main Street
Akron, Ohio44308
07/18/2008 04:42 PM
To:
Subject Request for Informal Comments on Update - Rollover Rights on Redirect - Due 8/15/08
Dear NAESB WEQ Members and Interested Industry Participants,
During the July 15-16, 2008 Joint WEQ ESS/ITS conference calls, the subcommittee agreed to post the Recommendation for an informal comment period beginning today, July 18, 2008 and ending on August 15, 2008. The proposed business practice standards were drafted as a modification to
WEQ-001-9.7 to reflect clarifications in policy and to implement the necessary standards for treatment of rollover rights for requests to Redirect on a Firm Basis.
The document can be found on the NAESB website via the following link:
For further information on the development of the draft standards language, please reference the July 15-16, 2008 draft minutes, to be posted shortly on the WEQ ESS/ITS page at Comments submitted will be reviewed by the WEQ ESS/ITS during the August 20-22 meetings.
Please return any comments you have on the document to the NAESB Office ( or 713-356-0067 fax) by August 15, 2008. If you have any questions or need further assistance, feel free to contact the NAESB Office at 713-356-0060.
Best Regards,
Deonne R. Cunningham
NAESB
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