Review of Informal Comments
Priority / Category / Entity / Description / Status1 / Coordination Arrangements / Two-Tier Firm Curtailment / Discussion / Want a discussion on the sources of Parallel Flows - Impact of system conditions and accuracy of the data / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / Duke Energy / Remove all business practice standards associated with Coordination Arrangements and two-tier curtailments. These rules create an uneven playing field for Transmission Service customers who have no control over the curtailment status of their firm transactions. These are also unnecessary in light of the current NERC standards for ATC/AFC calculations and they introduce considerable complexity in the standards for minimal, if any, results. Duke believes most providers will meet the hurdles which are established to attain Last-to-Curtail status rather quickly, which will effectively result in the current curtailment methodology while causing considerable expense and aggravation for Transmission Providers as well as considerable expense for the SDX, IDC and Operator functions. / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / Entergy / Revise Definition for First to Curtail and Last to Curtail / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / Entergy / Suggests using curtail schedule priority in 008-2.1.8 rather than using Curtailment Order in section 002-4.3.4.1 / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / Entergy / Sections 008-1.10 and 008-1.10.1 suggest changing from “receiving Last-to-Curtail” to “avoiding First-to-Curtail” / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / Entergy / Suggest adding First-to-Curtail (FTCF and FTCFN)and possibly Last-to-Curtail (LTC) as codes in Priority 7 Section 008-2.1.8 / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / FRCC / The proposed NAESB standard “Transmission Loading Relief (TLR) – Eastern Interconnection – WEQ-008 For Coordination Agreement is unnecessary and may conflict with the NERC MOD standards. / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / FRCC / The proposed NAESB standard “Transmission Loading Relief (TLR) – Eastern Interconnection – WEQ-008 standard for First to Curtail is unnecessary and may conflict with FERC policy and Open Access Transmission Tariffs. / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / MISO / Strike “higher priority” in the last sentence of WEQ 008-3.7.1.5.
008-3.7.1.5To continue mitigation of the SOL or IROL for the beginning of the next hour, the RC shall curtail additional Interchange Transactions and Intra-BA Transactions using Firm Transmission Service to provide transmission capacity for Interchange Transactions and Intra-BA Transactions using Firm Transmission Service or Interchange Transaction and Intra-BA Transactions using higher priority Firm Transmission Service utilizing the Reallocation procedures as specified in Business Practice Standard WEQ-008-3.6.
Need to look at potential changes to 3.6.2.3, with regards to First-to-Curtail/Last-to-Curtail, and with TLR 5A / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / New York ISO / Request the following language be removed.
“A Coordination Agreement between two or more Transmission Service Providers shall include, but is not limited to, the following requirements:
- A description of the process for respecting the constraints of the other Transmission Service Providers’ system by limiting the provision of Transmission Service.
- For off-path impacts a Coordination Agreement Transmission Service Provider shall utilize the same system conditions including constraints and facility loadings as used by the other Transmission Service Provider(s) to the Coordination Agreement when granting Transmission Service on its system. This shall be applicable for both short-term and long-term Transmission Service.”
1 / Coordination Arrangements / Two-Tier Firm Curtailment / New York ISO / The Draft Standards should make clear that it is not appropriate or permissible for a bilateral (or multi-party) Coordination Agreement to require or authorize the imposition of additional mitigation on entities that are not parties to that Coordination Agreement. / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / North Carolina Electric Membership Corp. / As an LSE that is a transmission dependent utility, NCEMC is concerned by the Two-Tier Firm Transmission Service Curtailment Process. NCEMC feels that firm transmission service is just that and a firm transaction should not be subordinate to another firm transaction just because a Transmission Service Provider may or may not have a Coordination Agreement or Reciprocity with a neighboring Transmission Service Provider (TSP). This process could adversely affect an LSE’s ability to reliably serve its load in cases where its firm transactions could be assigned First-to-Curtail priority because one or more of its TSPs do not have coordination agreements in place. This could place LSEs at a curtailment priority disadvantage because of actions of a TSP that are out of the LSE’s control. / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
1 / Coordination Arrangements / Two-Tier Firm Curtailment / TVA / TVA believes that adding two tiers of firm service to the IDC is not the correct way to get TSPs to have coordination agreements. We understand the benefits to coordination agreements and believe that data sharing is an important part of having an efficient transmission system.
Also, two tier firm curtailment penalizes the wrong entities. Transmission customers get penalized by having their firm service the first to cut, because the TSP decides not to enter a coordination agreement. That doesn't make sense to penalize the transmission customer because they have no control if the TSP signs a coordination agreement or not. Also adding two tiers of firm service will add a significant amount of complexity and expense to the IDC with no real benefit. / See motion 43 to remove Coordination Arrangements and Two-Tier-Firm Curtailment. The recommendation team will make changes to the recommendation.
2 / Pseudo Ties / Duke Energy / Pseudo-ties should be recognized as Interchange Transactions and be tagged accordingly. / Hold until it is determined how /what coordination will occur between NERC and NAESB
2 / Pseudo Ties / FRCC / The definition of “Intra-BA transaction” says Pseudo-Ties are Intra-BA and also that transfers that do not cross boundaries are Intra-BA transactions.
Is a Pseudo-Tie that crosses BAA boundaries an Intra-BA Transaction? / Hold until it is determined how /what coordination will occur between NERC and NAESB
2 / Pseudo-Tie / Duke Energy / Depending on the decision on Pseudo-Ties the definition for Intra-BA transaction may need to be modified to exclude Pseudo-Ties. / Hold until it is determined how /what coordination will occur between NERC and NAESB
2 / Pseudo-Tie / Duke Energy / e-tags should be used so that all transmission providers can monitor the use of PTP transmission service reservations using current methods of analysis. Permitting the use of Generator Proritization method forces transmission providers to expand their analyses of unreserved use calculations to gather data from either the SDX or the IDC.
Alternately, the BPS could establish a new type of PTP reservation which is dedicated for exclusive use with pseudo-ties that cannot be redirected for other purposes. / Hold until it is determined how /what coordination will occur between NERC and NAESB
2 / Pseudo-Tie / Duke Energy / Duke asks that NAESB recognize that there are no specific tagging rules for pseudo-ties and recommends that there be additional discussions on how to best tag pseudo-ties, and in particular pseudo-tied generation, without creating unintended consequences. The current rules for dynamic tags may be adequate for pseudo-tied load but appear to be overly restrictive for pseudo-tied generation dispatch. The tagging requirements should, at a minimum, identify the capacity allocations that are being set-aside for each transmission reservation over time. Since pseudo-ties cross BAA boundaries, the impacts of the tags on ATC calculations may need to be reviewed. (For instance, should these tags show the upper limit of the generation that may be used for each hour and that value set aside as tagged in non-firm ATC calculations, or are there other approaches that would work?) Near-real time actual generation output could be used by the IDC for curtailment purposes. / Hold until it is determined how /what coordination will occur between NERC and NAESB
2 / Pseudo-Tie / MISO / According to the Appendix E, if a BA declares Tag Secondary Network Service method, a tag is needed for a pseudo-tie transaction using firm transmission service. This should be a requirement in addition to appearing in Appendix E. / Hold until it is determined how /what coordination will occur between NERC and NAESB
2 / Pseudo-Ties / Duke Energy / a.Pueudo-ties cross BA boundaries and should not be considered as intra-BA transactions (see markup of the Intra-BA Transaction definition).
b.008-1.8.2.6 states, “The Sink BA declaration will be used in determining which method shall be used for submitting data for the Pseudo-Tie.” The use of Generator Priority Schedules for documenting the transfer across BA boundaries impedes with the normal method of checking for unreserved use of transmission service by creating a requirement that relies on information in the SDX rather than information in the e-tagging system. In order to perform fair evaluation of unreserved use for all reservations, this change will necessitate that the SDX entries and all subsequent changes in these entries be made available to each TSP which is being utilized. The definition of Capacity Available for Redirect will need to be modified to include encumbrances due to Generator Priority Schedules and the TSP validation process will need to be modified to incorporate the SDX data. The use of SDX data for documenting transactions across BA boundaries may need to be included in the reporting sections of WEQ-001 associated with reporting of schedules.
Duke Energy believes Pseudo-ties should be tagged. / Hold until it is determined how /what coordination will occur between NERC and NAESB
3 / Recognize Existing Seams Agreement / SPP / SPP proposes to revise Section 008-1.10, Establishing Coordination Agreements, to allow entities to submit flowgate limits that are pursuant to a Coordination Agreement. The proposed language will recognize currently effective and new Coordination Agreements that limit the amount of firm flow rights on flowgates. Flow in excess of this limit should be treated as non-firm GTL. Additionally, new or revised Coordination Agreements may require the flexibility to limit the amount of Last-to-Curtail firm GTL that a neighboring TSP may have on their flowgate. The current Section 008-1.10 does not address these concerns. The following draft language would recognize the terms of existing and new Coordination Agreements that provide requirements for firm GTL flow allowed on flowgates, and flexibility to limit the amount of +Last-to-Curtail firm GTL.
008-1.10.3Firm Flow Entitlement Limit
Transmission Service Provider(s) may have requirements in their Coordination Agreement(s) with other Transmission Service Provider(s) that limit the amount of firm GTL flow allowed on a flowgate(s). Any GTL flow in excess of this limitation will be treated as non-firm GTL flow. The Transmission Service Provider(s) that have this requirement in their Coordination Agreement(s) are responsible for entering any firm flow entitlement limit into SDX.
008-1.10.4 Last to Curtail Flowgate Limit
Transmission Service Provider(s) may have requirements in their Coordination Agreement(s) with other Transmission Service Provider(s) that limits the amount of Last-to-Curtail firm GTL on a flowgate(s). Any remaining firm GTL would be First-to-Curtail. The Transmission Service Provider(s) that have this requirement in their Coordination Agreement(s) are responsible for entering Last-to-Curtail flowgate limit into SDX.
Renumber sections for Reciprocity and Unilateral Declaration.
Add the following language at the end of section 008-1.11.2.1 “First-to-Curtail is assigned to any remaining firm that is over the limit of the Last-to-Curtail flowgate limit as specified in WEQ-008-1.10.4.”
Add the following language at the end of section 008-1.11.2.2 “and is not over the Last-to-Curtail flowgate limit as specified in WEQ-008.1.10.4.”
This will also require changes to the IDC User’s Manual and the SDX User’s Manual. / Hold for proposal to be presented at July 17th meeting.
3 / Recognize Existing Seams Agreements / Basin Electric Power Cooperative / The PFV proposal should be modified to include the capability to prioritize the flows of the CMP markets per the CMP allocation process, or to address the issue(s) that the allocations in the CMP were intended to address; that being, the CMP markets have the right to put firm flows on the system comparable to what they were prior to market integration (i.e., at a magnitude comparable to its traditional BA firm GtL impacts and traditional firm PtP impacts). The CMP markets are allowed to do least-cost dispatch across their entire footprint without tagging between their traditional BAs, but the priority of the impacts of the subsequent flows are established by the allocation process. It seems inappropriate and inequitable to develop a tool that ignores this requirement, or presumes that it will go away. SPP’s proposal to place a limit on Firm GtL flow and on Last-to-Curtail Firm GtL flow is one way to try to recognize this requirement. / Hold for proposal to be presented at July 17th meeting.
3 / Recognize Existing Seams Agreements / TVA / Coordinated Flowgates (CF) and Reciprocally Coordinated Flowgates (RCF) are used in the Congestion Management Process (CMP) that limits market flows based on the April 2004 freeze date. How does removing CFs and RCFs from the IDC affect the CMP requirements? / Hold for proposal to be presented at July 17th meeting.
3 / Recognize Existing Seams Agreements / Westar Energy / The PFV proposal basically ignores the limits of firm flows (eg. FFE) on transmission facilities contractually agreed-to between two or more parties. These limitations can be set either by the transmission service itself or through coordination agreements between Transmission Providers. Westar strongly supports SPP’s comments for continued use of market flow calculations on Reciprocal Coordinated Flowgates (RFCs), thus limiting neighboring RTO market flows and their respective FFE rights in a manner that appropriately reflects the actual rights the various parties have with respect to those facilities. The proposed PFV instead allocates flows based upon flawed internal logic and in likely violation of legally binding contractual rights for service and compensation. NAESB cannot implement a policy that, in effect, abrogates previously agreed-to contract allocations of capacity on transmission facilities, compensation rights under those agreements, or provisions in the FERC approved Tariffs that make such contractual rights enforceable. This would be placing any party to such agreements in the position of either ignoring the instructions from the PFV or violating its legal obligations under such agreements. The PFV should be capable of accepting such contractual limits and making curtailments in accordance with them and the prevailing Tariff requirements. / Hold for proposal to be presented at July 17th meeting.
3 / Recognize Existing Seams Agreements / Westar Energy / Although Westar is in general agreement with the PFV proposal, Westar’s concern with some of the provisions of the current PFV proposal is because the PFV ignores the contractual rights transmission customers have to capacity on the system. Ignoring such rights (e.g. Firm NITSA, Firm PTP, & Firm Flow Entitlement “FFE” along SEAMs) can have a detrimental impact on business being conducted by the various Transmission Providers, result in increased dispatch costs, and create the potential of transmission customers with non-firm rights to be granted the Bsame interruption status as those that purchased firm transmission rights. / Hold for proposal to be presented at July 17th meeting.