Comments Submitted by the ISAS Leadership Team (ISAS LT)
on NAESB WEQ 2013 Annual Plan Items 3.b.i-iii Recommendation
From: Ambrosi, Brenda
Sent: Friday, April 05, 2013 12:02 PM
To: naesbmail
Subject: NAESB Wholesale Electric Quadrant Request for Formal Comments – Due April 5, 2013
Importance: High
To Whom It May Concern,
Please confirm that the ISAS Leadership’s comments, below, have been received within the comment period and by the appropriate party(ies) within the NAESB office for response. If I have not submitted these comments to appropriate NAESB party(ies), please provide me with the appropriate email address for submission purposes.
Regards,
Brenda
COMMENTS ON ETAGGING SPECIFICATION VERSION 1.8.2
The ISAS Leadership Team (ISAS LT) appreciates the opportunity to comment. The ISAS LT would like the JESS to recognize that WECC Reliability Curtailments and Reload, INT-004-WECC-RBP-2, Regional Business Practice (RBP) passed WECC Board of Directors approval and becomes effective on July 1, 2013 or upon implementation of software. This RBP is located at http://www.wecc.biz/Standards/Development/WECC-0077/Shared%20Documents/Final%20for%20Ballot/INT-004-WECC-RBP-2%20BOD%203-13-2013.pdf.
ISAS LT is concerned with WR4 of the RBP, which states:
“WR4. Each Balancing Authority and each Transmission Service Provider that initiates a Curtailment shall ensure that each Reliability Adjustment RFI meets each of the following:
1. Releases its own reliability limit profile on the Interchange Transaction Tag, when the reliability event allows for the reloading of the transaction, without releasing the reliability limit of other Balancing Authorities and Transmission Service Providers;
2. The current level on the Interchange Transaction Tag shall not be greater than the most limiting reliability limit. (See guidance section for narrative regarding the “current level.”) “
“As to WR4, the intent of the Requirement is to ensure that when multiple curtailments and reliability limits are set by Balancing Authorities and Transmission Service Providers, that those limits are adhered to by parties on the e-Tag. The multiple reliability limits that are set by each Balancing Authority and Transmission Service Provider should be managed by each entity and should be released by each entity when the reliability event is over. However, the overall reliability limit should be based on the most limiting level set across all Balancing Authorities and Transmission Service Providers.
The “current level” referred to in WR4 is a reference to that defined term in the e-Tag specification document. The “current level” should not exceed the most limiting reliability event. This ensures that once an e-Tag is reloaded by one entity, another entity such as a Balancing Authority or Transmission Service Provider does not need to initiate a curtailment to reset the reliability limit.”
ISAS LT requires that the e-Tag specification address the issue surrounding reliability limits being overwritten by subsequent curtailments and reliability limits. It is imperative, as defined in the RBP, that the most limiting reliability limit stay effective until a more stringent reliability limit is set. Once a reliability limit is lifted by the curtailing entity, the second most limiting reliability limit should become effective. The current situation of allowing reliability limits to be overwritten can cause reliability issues where tags are reloaded past expected levels and curtailments have to be re-issued. The JESS should require all vendors to adopt such measures as defined in the RBP in order to ensure reliable operations.
If the JESS amends the e-Tag specification to address the above issue, can the JESS provide an estimate as to when this software change will be implemented with the RBP effective time in mind?
The ISAS LT looks forward to the JESS’ response.
______
Brenda Ambrosi, ISAS Chair
Wholesale Market Services Manager,T&D Grid Operations
BC Hydro
Fraser Valley Office
Office:604.455.1858
Mobile:604.312.7391
Email:
bchydro.com
______
-----Original Message-----
From: [mailto:
Sent: Thursday, March 07, 2013 1:59 PM
To: Anderson, Kathleen
Subject: NAESB Wholesale Electric Quadrant Request for Formal Comments – Due April 5, 2013
NAESB Wholesale Electric Quadrant Request for Formal Comments – Due April 5, 2013
An industry comment period begins today, March 7, 2013 and ends at the close of business on April 5, 2013 for the following Wholesale Electric Quadrant recommendations that are posted on the NAESB web site:
Recommendations:
2013 Wholesale Electric Quadrant Annual Plan Item Nos. 3.b.i, 3.b.ii, and 3.b.iii – Review e-Tag specifications and make modifications as needed
Recommendation: http://www.naesb.org/pdf4/weq_2013_ap_3bi-iii_rec.doc
Attachment 1 – e-Tagging Specification Version 1.8.2 (Clean): http://www.naesb.org/member_login_form.asp?doc=weq_2013_ap_3bi-iii_rec_attach_clean.doc
Attachment 2 – e-Tagging Specification Version 1.8.2 (Redline): http://www.naesb.org/member_login_form.asp?doc=weq_2013_ap_3bi-iii_rec_attach_redline.doc
Request R12010 – Request for requirements for scheduling interchange in 15 minute intervals to comply with requirements in FERC order 764
Recommendation: http://naesb.org/pdf4/r12010_rec.doc
All interested parties, regardless of membership status within NAESB, are eligible to submit comments for consideration. The Wholesale Electric Quadrant Executive Committee will review the recommendations and comments during the next scheduled meeting following the end of the comment period and consider the recommendations for vote. This meeting is open and we encourage those who submit comments to attend.
All comments received by the NAESB office by end of business on April 5, 2013 will be posted on the Request and Standards Activity Applicable to Wholesale Electric Quadrant page: http://naesb.org/weq_request.asp and forwarded to the Wholesale Electric Quadrant Executive Committee members for their consideration. If you have difficulty downloading the recommendation, please call the NAESB office at (713) 356-0060.
Best Regards,
Caroline Trum
cc: Rae McQuade, President
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