March 25, 20131

Final Committee Report

Order 764 Task Force

By

Kathy Anderson

Order 764 Task Force Chair

Western Electricity Coordinating Council

March 25, 2013

Committee Report:

Order 764 Task Force

Committee’s Strategic Purpose

The Order 764 Task Force (Task Force) was tasked to assess the impacts of FERC’s Order 764 in relation to15 minute scheduling in the Western Interconnection and how identified impacts could affect the reliability and commercial activities of WECC.It conducted anin-depth analysis of the identified impacts of 15 minute scheduling over the past 6 months. This report reflects the compilation of the work completed by this Task Force.

Subgroups Developed

Subgroups were developed to work on issues to bring back to the larger task force. Each group was lead by a member of the Task Force.

One subgroup reviewed the changes needed in the coordination of Balancing AuthoritiesNet Schedule Interchange (NSI) checkouts. Questions addressed by the group included whether NSI checkoutsshould occur at every 15 minute interval in all scheduling horizons (pre-schedule, real time, and after-the-fact) and what value would be checked out (hourly integrated MW value vs. non-integrated MW value) for the 15 minute horizon. Once these questions were answered, the next issue resolvedwas determining how often these checkouts should occur.

Another subgroup was created to determine if modifications were required in the current transmission preemption process. Currently, many Transmission Providers in WECC that allow intra-hour scheduling do not allow a Request for Interchange (RFIs) (e-Tag) submitted intra-hour to pre-empt or “bump” existing RFIs. The transaction would only be accepted if, by doing so,the result would not create a reliability adjustment (curtailment). Order 764 did not preserve this practice. FERC maintained that transactions submitted intra-hour could displace a lower NERC transmission priority transaction, even if that lower transmission priority transaction was already flowing. One question this group addressed included,the type of action required for intra-hour transactions if the path becomes overscheduled. Another question addressed the obligation to reload previously curtailed transactions in each 15 minute scheduling interval if it could be accommodated in the path scheduling limit.

A third subgroup was created to monitor the market structures and seams issues with the CAISO in relation to 15 minute scheduling. The CAISO is undergoing a stakeholder process for discussion on 15 minute scheduling. This group followed those proceedings and reported activity updates back to the Task Force. CAISO continues to work through its stakeholder process. More information on that process can be found on the CAISO website.

Additionally, a thorough review of existing NERC, WECC,and NAESB Standards was completed to determine if any modifications were required to implement the FERC Order. During the documentation reviews, it was noted that the timing tables in the NERC INT Standards (and mirrored in the NAESB WEQ Standards)could create a situation where an intra-hour RFI(e-Tag) would be considered Late. This was flagged as an issue and forwarded to the appropriate NERC/NAESBJoint Electronic Scheduling Subcommittee (JESS). An effort to revise these timing tables through the NERC Standards processis currently underway. Once the NERC Standards are revised, the NAESB standards should follow. TOP-007-WECC-1 requires Net Scheduled Interchange not to be above the path’s SOL when the Transmission Operator implements its real time schedules for the next hour. This may need to be revised if we want to move to view scheduling intervals rather than hours.

Task Force Recommendations

The Task Force developed a set of suggested recommendations that related to 15-minute scheduling in the WECC. The recommendationsdocument as developed is Attachment A to this report. Each recommendation is discussed below.

Recommendation #1 – Intra-hour scheduling intervals: WECC scheduling intervals shall be defined as xx:00 – xx:15, xx:15-xx:30, xx:30-xx:45, and xx:45-xx:00. Intra-hour profiling on a Request for Interchange (e-Tag) shall be in intervals with start and stop times of xx:00, xx:15, xx:30, and xx:45. Schedules will be allowed in 15 minute, 30 minute, 45 minute, 1-hour or longer blocks provided the start and stop times are as reflected above. (For example, a customer may have an e-Tag that starts at xx:15 and ends at xx:00, for a 45 minute e-Tag.)The exception to this rule is the start/stop time for curtailed and re-loaded e-Tags which are determined by reliability related reasons and outside the scope of this document.

Recommendation #2 –Requests for Interchange submitted within the hour will allow the use of firm or non-firm Transmission Service Reservations, and Network Integration Transmission Servicerights, including but not limited to the use of Point-to-Point Redirect reservations, Point-to-Point Resale reservations, orOriginal reservations. The FERC order allows intra-hour scheduling to all transmission customers taking service under the OATT.

Recommendation #3 – Requests for Interchange submitted within the hour will allow the use of new or existing Transmission Service Reservations. The FERC order did not mandate that a customer only use transmission rights purchased prior to the hour, and also did not mandate that TSPs allow for the acquisition of transmission rights within the hour. The recommendation allows a customer to purchase transmission service during the hour if there is Available Transfer Capability.

Recommendation #4 – Pre-emption of Requests for Interchange (e-Tags): e-Tags utilizing firm transmission capacitywould preempt an e-Tag utilizing non-firm transmission capacityif the e-Tag was submitted at least 20 minutes before the impacted scheduling interval. E-Tags utilizing non-firm transmission capacity with a higher OATTtransmission priority would preempt e-Tags utilizing a lower OATT transmission priority non-firm transmission capacity if the e-Tag wassubmitted at least 20 minutes before the impacted scheduling interval. This recommendation eliminates the “no bumping” rule that many WECC Transmission Providers currently have in Business Practices.

Recommendation #5 – Requests for Interchange Timing – A Request for Interchange (e-Tag) must be submitted at least 20 minutes prior to the start of the impacted WECC scheduling interval to be considered “On Time”. A request submitted less than 20 minutes prior the impacted WECC scheduling interval is considered “Late” and will be marked “Late” by the Interchange Authority. “Late” e-Tags may be accepted at the discretion of the Transmission Service Provider. The current NERC INT Standards and companion NAESB Standards include Timing Tables that define when Requests for Interchange must be submitted to obtain an “On Time” time classification by the Interchange Authority. These timing tables will need to be modified to ensure the timing classifications recommended here are assigned. An effort is underway to modify these timing tables and move these through the NERC and subsequently through the NAESB approval processes.

Recommendation #6 – Intra-hour scheduling profiles submitted in Pre-Schedule: Requests for Interchange submitted in the Pre-schedule horizon may be submitted usingthe WECC intra-hour scheduling intervals. This is at the customer’s discretion and is not required.

Recommendation #7 - Curtailments: If needed, Reliability Limits (curtailments)will occur prior to the top of the hour (as they do today) for all scheduling intervals in the upcoming hour that exceed a path scheduling limit, and Reliability Limits (curtailments/reloads) will occur within the hour as needed.

Recommendation #8 – ATC Calculation: At a minimum, ATC will continue to be calculated as Transmission Service Providers currently calculate today. Order 764 neither requires Transmission Service Providers to provide an intra-hour transmission product nor requires more frequent calculations of ATC than what occurs today. However, FERC did not preclude a Transmission Service Provider from offering a sub-hourly product if it chooses. Transmission Providers should note that 15-minute scheduling may require more frequent calculation of their hourly transmission than the minimum current requirements due to schedules adjusted or transmission sold during the hour potentially impacting impact ATC on the path.

Recommendation #9 – Ramp Rates: The top of the hour ramp will remain 20 minutes. Ramp duration for the intra-hour scheduling intervals willbe a 10-minute straddle ramp. There was concern in the Task Force that if volume is heavy and there is a large NSI change for the intra-hour intervals, a 10minute ramp may not be sufficient time to fully ramp in expected values. It is recommended that a re-evaluation of the ramp duration be performedapproximately 6 months after the implementation of 15-minute scheduling (or at such time as there is sufficient intra-hour scheduling volume to create a data sample set) to ensure the ramp rates are appropriately set.

Recommendation #10 – Net Scheduled Interchange Accounting and Sub-Hourly Schedule Integration: Net Scheduled Interchange will remain as it is today, integrating to an hourly value at the end of each hour. Schedules with duration of less than 1 hour will integrateusing currently defined rounding rules per NAESB WEQ-004-19.1. The Task Force circulated a survey to determine if any change to the rounding of schedules less than an hour of duration should occur. Of the 20 responses received, 60% selected the option to retain the current practice and25% indicated they would like to see intra-hour schedules integrate to a 1/10 MW value (i.e. 2.2MW, 2.5MW) to allow for greater granularity in the value. There was also indication from some of the 60% that responded to retain the current practice that they also would like for the JGC to assign the task of reviewing the possibility of allowing intra-hour schedules to integrate to a 1/10 MW value (i.e. 2.5MW, 2.3MW) to one of the Standing Committees to allow for greater granularity. The Task Force thought the proper committee would be the Operating Committee but will leave it to the JGC to determine.

Recommendation #11 – Coordinated Checkouts of Balancing Authorities: The Task Force recommends that Balancing Authority Checkouts should occur for Net Scheduled Interchange values as reflected below:

Net Schedule Interchange
Horizon / Value / Check Out
Preschedule – 15:00 PPT / Hourly MW Integrated Value / Always check out
Real Time Before-the-Hour / Hourly MW Integrated Value and non-integrated MW Values for each scheduling interval within the hour. / Only upon a value change
Real Time Intra-Hour XX:00-XX:15 / Non-integrated MW Value / Only upon a value change
Real Time Intra-Hour XX:15-XX:30 / Non-integrated MW Value / Only upon a value change
Real Time Intra-Hour XX:30-XX:45 / Non-integrated MW Value / Only upon a value change
Real Time Intra-Hour XX:45-XX:00 / Non-integrated MW Value / Only upon a value change
Real Time Reliability Curtailments / Hourly Integrated Value / Check after Hour Completes
Real Time After-the-Hour – Hrly NSI / Hourly Integrated Value / Always check out
After-the-Fact – Hourly NSI / Hourly Integrated Value / Only upon a value change

The Net Scheduled Interchange value being checked out before and after the hour is the integrated hourly MW value we use today. The Net Scheduled Interchange value being checked out for the individual intra-hour scheduling intervals will be a non-integrated 15-minute MW value.This is to ensure the adjacent BAs are driving to the same NSI value for each schedule interval as required by NERC standards.

The Task Force recommended that the checking of Net Actual Interchange remains unchanged conducted on the Hourly MW Value.

Net Actual Interchange
Horizon / Value / Notes
Real Time After-the-Hour / 60 Min. Hourly MW Value / Check after Hour Completes
After-the-Fact – Hourly NAI / 60 Min. Hourly MW Value / Only Upon Change

Impacts on Unscheduled Flow

The Task Force discussed how the WECC Unscheduled Flow process will work with the addition of 15-minute scheduling. The UFAS Chair, Robin Chung, noted that UFAS does not plan on moving from the current hourly process to a 15-minute interval. Any new schedules submitted in the hour will be assessed by the webSAS tool to determine the impact on the current USF Event. If the tool determines that the transaction creates a negative impact based on the TDF of the transaction, the intra-hour transaction will be curtailed by the tool. This is how it works today for any hourly e-Tag submissions. The tool will work the same for any intra-hour e-Tag as well.

Impact on Existing Tools

The Task Force reviewed existing tools used today in the WECC. Two primary tools utilized where an impact could occur are the WIT and any e-Tagging software. The WIT currently has the ability to perform intra-hour checkouts. The functionality was added in 2012 to accommodate mid-hour checkout requirements. The current e-Tag specs allow for a variation of scheduling intervals on the e-Tag. Scheduling intervals are not limited to starting and stopping at the top of an hour. Based on the review of these tools, the only change expected for compliance with Order 764 is the Timing Tables used to identify Late e-Tags that will assign a late status to intra-hour tags. WECC Members are encouraged to discuss any impacts the additional scheduling intervals will have on software utilized by their own company with theirproduct vendor(s). Analyzing the impact of 15 minute scheduling on individual company tools was outside the scope of this Task Force.

Impacts on EMS Systems

The Order 764 Task Force recognizes that some entities will need to modify how often the NSI value is pulled into their EMS systems and controlled to. With the implementation of 15-minute scheduling, entities should ensure their EMS systems are pulling in NSI valuesupon change to control to these value changes within the hour.

Conclusion

The Order 764 Task Force was tasked with assessing the impacts of 15-minute scheduling in the Western Interconnection and how identified impacts could affect the reliability and commercial activities of WECC. Responsibilities included identifying and analyzing potential scheduling issues resulting from FERC Order 764 requiring15-minute scheduling in the Western Interconnectionincluding, but not limited to:

  • seams issues;
  • a thorough review of WECC, NERC and NAESB requirements that may be impacted by Order 764;
  • analyzing the effect of 15-minute scheduling on existing tools used in the Western Interconnection;
  • coordinating the activities of other WECC committee and subcommittee efforts (e.g. UFAS) to assess impacts 15 minute scheduling may have on their processes;
  • and exploring the need to establish guidelines addressing fixed start times for scheduling intervals, default ramp rates, preschedule submission, coordination of Net Scheduled Interchange (NSI) check outs, and transmission preemption, transmission curtailments and reload responsibilities.

The Task Force has reviewed all of these items with recommendations as outlined in this paper. The Task Force alsoproposes that all recommendations be reviewed approximately 6 months after the implementation of the FERC Order once experience with 15-minute scheduling is gained.

Attachment A

WECC 15-Minute Scheduling Recommendations Document

Developed by the Order 764 Task Force

3-31-2013

  1. WECC scheduling intervals shall be defined as xx:00 – xx:15, xx:15-xx:30, xx:30-xx:45, and xx:45-xx:00. Intra-hour profiling on a Request for Interchange (e-Tag) shall be in intervals with start and stop times of xx:00, xx:15, xx:30, and xx:45. Schedules will be allowed in 15 minute, 30 minute, 45 minute, and 1-hour blocks or longer blocks provided the start and stop times are as reflected above. (For example, a customer may have an e-Tag that starts at xx:15 and ends at xx:00, for a 45 minute e-Tag.)The exception to this rule is the stop time for curtailed and reloaded e-Tags which are determined by reliability related reasons and outside of the scope of this document.
  1. Requests for Interchange submitted within the hour will allow the use of firm or non-firm Transmission Service Reservations, and Network Integration Transmission Service rights, including but not limited to the use of Point-to-Point Redirect reservations, Point-to-Point Resale reservations, or Original reservations. The FERC order allows intra-hour scheduling to all transmission customers taking service under the OATT.
  1. Requests for Interchange submitted within the hour will allow the use of new or existing Transmission Service Reservations. The FERC order did not mandate that a customer only use transmission rights purchased prior to the hour, and also did not mandate that TSPs allow for the acquisition of transmission rights within the hour. The recommendation allows a customer to purchase transmission service during the hour if there is Available Transfer Capability.
  1. Requests for Interchange using firm transmission capacity would preempt Requests for Interchange using non-firm transmission capacityif submitted at least 20 minutes before the impacted scheduling interval. Requests for Interchange using non-firm transmission capacityof a higher priority would preempt Requests for Interchange using non-firm transmission capacityof a lower priority if submitted at least 20 minutes before the impacted scheduling interval.
  1. Requests for Interchange (e-Tags) must be submitted at least 20 minutes prior to the start of the impacted WECC scheduling interval to be considered ”On-Time” (not “Late”). A Request for Interchange that is “Late” (submitted with less than 20 minutes prior to the impacted WECC scheduling interval’s start time) will be marked as Late by the Interchange Authority, but may be accepted at the discretion of the Transmission Service Provider.
  1. Requests for Interchange submitted in Pre-schedule may be submitted using the WECC intra-hour scheduling intervals (customer discretion).
  1. If needed, Reliability Limits (curtailments/reloads) to Requests for Interchange will occur prior to the top of the hour (as it does today) for all scheduled intervals in the hour that exceed a path scheduling limit, and Reliability Limits (curtailments/reloads) will occur within the hour as needed.
  1. At a minimum, ATC will continue to be calculated as Transmission Service Providers currently calculate today. Order 764 neither requires Transmission Service Providers to provide an intra-hour transmission product nor requires more frequent calculations of ATC than what occurs today. However, FERC did not preclude a Transmission Service Provider from offering a sub-hourly product if it chooses. Transmission Providers should note that 15-minute scheduling may require more frequent calculation of their hourly transmission than the minimum current requirements due to schedules adjusted or transmission sold during the hour potentially impacting impact ATC on the path.
  1. The top of the hour ramp would remain 20 minutes. Ramp duration for the 15-minute scheduling intervals would be a 10-minute straddle ramp.
  1. NSI accounting will remain in whole MWHs with current rounding rules applied as it stands today complying with NAESB WEQ-004 19.1
  1. Balancing Area Checkouts will occur as follows:

Net Scheduled Interchange
Horizon / Value / Check Out
Preschedule – 15:00 PPT / Hourly MW - Integrated Value / Always
Real Time Before-the-Hour / Hourly and XX:00-XX:15 / Only Upon Change
Real Time Intra-Hour XX:00-XX:15 / MW Value / Only Upon Change
Real Time Intra-Hour XX:15-XX:30 / MW Value / Only Upon Change
Real Time Intra-Hour XX:30-XX:45 / MW Value / Only Upon Change
Real Time Intra-Hour XX:45-XX:00 / MW Value / Only Upon Change
Real Time Reliability Curtailments / Hourly Integrated Value / Check after Hour Completes
Real Time After-the-Hour – Hrly NSI / Hourly Integrated Value / Always
After-the-Fact – Hourly NSI / Hourly Integrated Value / Only Upon Change
Net Actual Interchange
Horizon / Value / Notes
Real Time After-the-Hour / 60 Min. Hourly MW Value / Check after Hour Completes
After-the-Fact – Hourly NAI / 60 Min. Hourly MW Value / Only Upon Change

WESTERN ELECTRICITY COORDINATING COUNCIL •