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2017-04 Periodic Revew of Interchange Scheduling and Coordination Standards | Templates

Description:

Start Date: 01/10/2018
End Date: 02/23/2018

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End

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Hot Answers

Brandon Gleason, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

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SPP Standards Review Group, Segment(s) , 2/23/2018

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Other Answers

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Laurie Williams, On Behalf of: Laurie Williams, , Segments 1, 3

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PJM agrees with the PRT's recommendation to retire this standard and each of its associated requirements.  However, PJM recommends that the retirement of R3 be contingent upon the implementation of a new NAESB WEQ-004 requirement which necessitates the coordination of Pseudo-ties between impacted entities prior to implementation. This coordination is important for accurate accounting of interchange and ensuring that any related congestion can be properly managed.  Without this coordination, the reliability of the system could be impacted.  

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Duke Energy generally agrees with the SME stakeholder team’s conclusions that the requirements in INT-004-3.1 should be retired. However, we believe that the retirement of those requirements should be be contingent upon the adoption of the corresponding NAESB standards.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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BPA agrees that the requirement ‘R1’ can be retired although the NAESB WEQ 004-1 and/or WEQ 004-5 need modifications to capture the intent of INT-004.3.1.R1.

Measurement 1: The Purchasing-Selling Entity shall have evidence (such as dated and time-stamped electronic logs or other evidence) that a Request for Interchange was submitted for Dynamic Schedules and Pseudo-Ties as an on-time Arranged Interchange to the Sink Balancing Authority for the Dynamic Schedule or Pseudo-Tie. For Pseudo-Ties included in congestion management procedure(s) via an alternate method, the Purchasing-Selling Entity shall have evidence such as Interchange Distribution Calculator model data or written / electronic agreement with a Balancing Authority to include the Pseudo-Tie in the congestion management procedure(s).

BPA agrees that the requirement ‘R2’ can be retired after FERC approves and adopts the language into the CFRs. As this language has not been adopted by FERC, compliance applications are missing.

BPA agrees that the requirement ‘R3’ can be retired assuming that the NERC Pseudo Tie Coordination Reference Document is retained and IRO-010 Applicability Entities remain unchanged.

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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The California ISO supports the comments of the ISO/RTO Council Standards Review Committee

Richard Vine, On Behalf of: Richard Vine, , Segments 2

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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ISO RTO Council's Standard Review Committee , Segment(s) 2, 2/23/2018

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R1:

  • RFI is needed for the IDC to work correctly

  • NAESB does not have authority over all entities (governmental entities such as TVA, BPA)

  • e-Tags are a critical part of congestion management in east

  • SOCO recommends keeping R1 and changing PSE to each BA that facilitates energy transaction on behalf of a distribution provider to serve load…

  • Not all entities in North America are obligated to follow NAESB Standards

R2:

  • SOCO recommends keeping R2 and changing PSE to each BA that facilitates energy transaction on behalf of a distribution provider to serve load…

  • RFI needed for the IDC to work correctly

  • NAESB does not have authority over all entities (governmental entities such as TVA, BPA); e-Tags are a critical part of congestion management in the east

  • Not all entities in North America are obligated to follow NAESB Standards

R3:

  • SOCO recommends modifying from BA to RC, BA, and TSP shall only…

  • NERC Pseudo-Tie Coordination document is not binding and does not cover all concerns with modeling of Pseudo-Ties

  • The Data Specification was never meant to be used to govern the modelling of Pseudo-Ties; it governs modelling for reliability assessment but not congestion management

  • Pseudo-Ties are important to congestion management, must be modeled in IDC correctly

  • EIR is used for transparency into Pseudo-Ties

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 2/23/2018

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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We thank the SDT for their due diligence in identifying supportive reasons for retiring this standard and all its requirements.

ACES Standard Collaborations, Segment(s) 5, 6, 1, 3, 2/23/2018

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Hot Answers

ERCOT signs on to the following comments of the ISO/RTO Council (IRC) Standards Review Committee (SRC):

We support the retirement of these requirements.  However, we do question the rationale implying that the NAESB e-Tagging Specification is FERC approved.  The NAESB e-Tagging Specification is not submitted to FERC for approval.  Additionally, it should be noted that some entities which are required to follow the NERC reliability standards are not required to follow the NAESB standards.  

Brandon Gleason, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

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SPP Standards Review Group, Segment(s) , 2/23/2018

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Other Answers

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Laurie Williams, On Behalf of: Laurie Williams, , Segments 1, 3

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PJM agrees with the PRT's recommendation to retire requirements R3.1, R4 and R5. The compliance obligations of these requirements, particularly R4 and R5, are currently assigned to the sink Balancing Authority.  This is not appropriate, as this is not the entity actually fulfilling the requirement.  However, it should be noted that the e-Tag specification is not an enforceable document, and is therefore not an ideal justification for retirement of these requirements.  It should also be noted that the retirement of these requirements could create a situation whereby a reliability event resulting from a failure to follow the e-Tag specifications has no responsible party.    

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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Louisville Gas and Electric Company and Kentucky Utilities Company (LKE) agrees that INT-006-4 Requirement R3, Part 3.1, Requirement R4, and Requirement R5 should be retired under Paragraph 81 criteria.  Additionally, LKE proposes retirement of INT-006-4 Requirements R1 and R2, and full retirement of R3 because the timing requirements outlined in INT-006-4 Attachment 1 are captured in the NAESB WEQ004 Business Practice Standard.  The ability to manage Interchange should be considered as part of a BA certification process, not a reliability standard.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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The California ISO supports the comments of the ISO/RTO Council Standards Review Committee

Richard Vine, On Behalf of: Richard Vine, , Segments 2

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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We support the retirement of these requirements.  However, we do question the rationale implying that the NAESB e-Tagging Specification is FERC approved.  The NAESB e-Tagging Specification is not submitted to FERC for approval.  Additionally, it should be noted that some entities which are required to follow the NERC reliability standards are not required to follow the NAESB standards.

ISO RTO Council's Standard Review Committee , Segment(s) 2, 2/23/2018

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R3:

  • SOCO does not agree that R3 should be retired since not all Reliability Coordinators are notified because not all Reliability Coordinators have access to the e-Tagging software (can be validated by a survey)

  • If R3 is retired then it is recommended to ensure that NERC requires all Reliability Coordinators to have access to e-Tagging software

R4:

  • The NAESB e-Tag Specifications are not FERC approved

  • All entities in North America are not obligated to follow NAESB Standards

R5:

  • SOCO is ok with removal of R5 5.4 and R5 5.5 but R5 5.1-5.3 should be kept, Balancing Authorities are required to checkout on composite value so if R5 5.1-5.3 is removed then INT-009-2.1 R1 could not be met

  • The NAESB e-Tag Specifications are not FERC approved

  • All entities in North America are not obligated to follow NAESB Standards

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 2/23/2018

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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We thank the SDT for their due diligence in identifying supportive reasons to retire the identified requirement of this standard

ACES Standard Collaborations, Segment(s) 5, 6, 1, 3, 2/23/2018

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Hot Answers

ERCOT signs on to the following comments of the ISO/RTO Council (IRC) Standards Review Committee (SRC), and also provides additional supplemental comments, below:

The term “Reliability Assessment” does not need to be added into the standard requirement because Part 1.1 and 1.2 of Requirement 1 already make clear the conditions under which a BA must deny or curtail an Arranged Interchange—namely, when the BA determines that it cannot support the Approved Interchange or that the schedule path is invalid.  Inserting new language in R1 requiring a “Reliability Assessment” could create confusion as to whether the BA’s analysis must consider conditions beyond those specified in Parts 1.1 and 1.2.   We would prefer to avoid that confusion.    

ERCOT submits the following additional comments:

ERCOT is concerned that removing the terms “emergency” and “on-time” would necessarily imply that all Arranged Interchanges—including late, non-emergency, Arranged Interchanges—must be approved by the BA.  ERCOT, like at least some other ISOs, does not allow approval of late Arranged Interchanges (i.e., those submitted within 15 minutes of ramp start).  BAs should not be subject to penalties for failing to approve or deny late submissions within ten minutes, which would be the result of the revised language.  Moreover, for ISOs that do not permit late Arranged Interchange submissions, requiring denial of a late Arranged Interchange serves no purpose.  Although one might argue that requiring a BA to deny the Arranged Interchange serves the purpose of notifying the PSE that the Arranged Interchange was late and will not be permitted, the PSE already receives notification of the late status via the OATI interface.  Consistent with these comments, ERCOT would also suggest that the first two rows (corresponding to ATF and Late submission) in Attachment 1 should be deleted.

Brandon Gleason, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

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SPP Standards Review Group, Segment(s) , 2/23/2018

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Other Answers

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Laurie Williams, On Behalf of: Laurie Williams, , Segments 1, 3

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The PRT’s recommendation of removing the terms ‘on-time’ and ‘emergency’ would actually expand the intended scope of the requirements to include non-emergency RFIs with a Time Classification of ‘Late’ as defined by INT-006-4 Attachment 1.  PJM does not feel the requirements should cover these RFIs.  PJM would prefer to retain these terms, and better define them within the standard, including references to Attachment 1 as needed.  PJM would also prefer not to incorporate the term Reliability Assessment as this would require further definition.  Although it is true that the act of approving or denying an RFI does not directly serve a reliability purpose, the sub-requirements of R1.1, R1.2 and R2.1 do, in fact, define reliability criteria upon which the approval or denial must be issued.  

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Duke Energy generally agrees with the stakeholder team that ambiguity does exist with the use of the terms “emergency” and “on-time”, however, we feel that complete removal may create more confusion than currently exists. We recommend considering revising the current language, rather than a complete removal. Also, it is unclear how the team plans to reintegrate the term “Reliability Assessment” into the standard. More information is needed before we can agree with this proposal.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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Louisville Gas and Electric Company and Kentucky Utilities Company (LKE) agrees that the terms “emergency” and “on-time” in Requirements R1 and R2 should be removed from INT-006-4; however, we do not agree that the term “Reliability Assessment” is the reliability task being performed in Requirements R1 and R2 and thus, should not be reintegrated into the requirements.  The purpose of performing a “Reliability Assessment” is to ensure that the Arranged Interchange (i.e., tag) is filled out properly and that there is enough available transmission capacity (ATC) on the system for the tag to flow.  As stated in the Guidelines and Technical Basis (GTB), this is supported by a software application (absent from any operator involvement) and is rarely done manually by an operator.  The important reliability task is not running the “Reliability Assessment” – it is ensuring that each of the entities have agreed on the Composite Confirmed Interchange (Net Scheduled Interchange) before it is used in the ACE equation (INT-009-2.1 R1).  The term “Reliability Assessment” is not defined in the NERC glossary.  Additionally, the term is ambiguous when used in the purpose statement of INT-006-4 (e.g., “To ensure that responsible entities conduct a reliability assessment of each Arranged Interchange before it is implemented”) and relies on clarification from the GTB to understand what is meant by the term.  As NERC and FERC have communicated in regards to other reliability standards, the GTB are not part of a reliability standard and will be considered for removal in future versions.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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The California ISO supports the comments of the ISO/RTO Council Standards Review Committee

Richard Vine, On Behalf of: Richard Vine, , Segments 2

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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The term “Reliability Assessment” does not need to be added into the standard requirement because Part 1.1 and 1.2 of Requirement 1 already make clear the conditions under which a BA must deny or curtail an Arranged Interchange—namely, when the BA determines that it cannot support the Approved Interchange or that the schedule path is invalid.  Inserting new language in R1 requiring a “Reliability Assessment” could create confusion as to whether the BA’s analysis must consider conditions beyond those specified in Parts 1.1 and 1.2.   We would prefer to avoid that confusion.

ISO RTO Council's Standard Review Committee , Segment(s) 2, 2/23/2018

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R1:

  • SOCO believes that reliability assessment should be not reintegrated here, rather R2

  • SOCO agrees with removing emergency but not on-time (clean up the arranged interchange wording since there would be two instances)

R2:

  • SOCO believes that reliability assessment should be reintegrated

  • Agreement with removing emergency but not on-time (clean up the arranged interchange wording since there would be two instances)

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 2/23/2018

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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We concur that the undefined and ambiguous terms “emergency” and “on-time” can be removed, as they do not provide additional clarity or add reliability benefit to the requirements.  We believe the reference to “Reliability Assessment” listed within the purpose of the standard is sufficient, as it establishes that the requirements as a whole provide the parameters necessary to constitute the reliability assessment during interchange processing.

ACES Standard Collaborations, Segment(s) 5, 6, 1, 3, 2/23/2018

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Hot Answers

Brandon Gleason, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

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SPP Standards Review Group, Segment(s) , 2/23/2018

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Other Answers

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Laurie Williams, On Behalf of: Laurie Williams, , Segments 1, 3

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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The California ISO supports the comments of the ISO/RTO Council Standards Review Committee

Richard Vine, On Behalf of: Richard Vine, , Segments 2

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Texas RE appreciates the good work that the SME stakeholder team has undertaken in evaluating these standards and does not disagree with the recommendations. However, Texas RE would like to respectfully request that more details related to the analysis be included in the “rationale” section for each recommendation. Specifically, the rationale currently includes conclusory assertions that a requirement is redundant or duplicative and the allegedly comparable regulation/rule. Texas RE recommends that the rationale also include the specific language from the comparable regulation/rule that was considered to be redundant or duplicative in contrast to the requirement language under review and also the specific reliability tasks that the team has determined to be redundant or duplicative. The ERO Enterprise relies heavily on these documents and Texas RE believes that these types of details if included in the record would increase the value of these documents. If by chance, these types of details or analysis are located in a different document, please advise.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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ISO RTO Council's Standard Review Committee , Segment(s) 2, 2/23/2018

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Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 2/23/2018

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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We thank the SDT for their due diligence in identifying supportive reasons to retire the identified requirement of this standard.

ACES Standard Collaborations, Segment(s) 5, 6, 1, 3, 2/23/2018

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Hot Answers

Brandon Gleason, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

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SPP Standards Review Group, Segment(s) , 2/23/2018

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Other Answers

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Laurie Williams, On Behalf of: Laurie Williams, , Segments 1, 3

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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Richard Vine, On Behalf of: Richard Vine, , Segments 2

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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We recommend keeping INT010-2.1.  See Comments under #6. California ISO and ERCOT have not signed on to this comment.

ISO RTO Council's Standard Review Committee , Segment(s) 2, 2/23/2018

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SOCO agrees to the revision of R1 however, if INT-010-2.1 is not retired the reference needs to remain.

 

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 2/23/2018

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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We thank the SDT for their due diligence in identifying supportive reasons to retire the identified requirement of this standard.

ACES Standard Collaborations, Segment(s) 5, 6, 1, 3, 2/23/2018

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Hot Answers

Brandon Gleason, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

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SPP Standards Review Group, Segment(s) , 2/23/2018

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Other Answers

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Laurie Williams, On Behalf of: Laurie Williams, , Segments 1, 3

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PJM agrees with the PRT's recommendation to retire this standard and each of it's associated requirements.  However, PJM recommends that the retirement of the standard be contingent upon the a new NAESB WEQ-004 requirement becoming effective, which allows interchange fitting the current INT-010-2.1 criteria to be implemented without an RFI.  Such a requirement is currently published as WEQ-004-1.7 under the NAESB WEQ version 3.2 standards. However, the WEQ-004-1.7 requirement would need to be revised. Without this NAESB requirement, a Balancing Authority would not be able to implement interchange transactions described in INT-010-2.1 without an associated RFI which could jeopardize the reliability of the transmission system.

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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Richard Vine, On Behalf of: Richard Vine, , Segments 2

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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We are concerned that the removal of INT010-2.1 removes the ability for an RC to direct a change to the interface flow before an Arranged Interchange is approved under the INT-006 Standard.  Removal of INT-010-2.1  and the reference in INT-009-2.1 creates an issue with the requirement to submit tags, after the fact, for reliability adjusted Confirmed Interchanges and those that are required for reliability reasons such as emergency.   Additionally, any changes to INT010-2.1 R1 should be coordinated with NAESB .  NAESB Business Practice Standard WEQ-004-1.7 specifically references INT010-2.1 R1.  California ISO and ERCOT have not signed on to these comments.

ISO RTO Council's Standard Review Committee , Segment(s) 2, 2/23/2018

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R1:

  • In the absence of this requirement entities may choose to not tag after 60 minutes

  • Not all entities in North America are obligated to follow NAESB Standards

 

R2:

  • Not all entities in North America are obligated to follow NAESB Standards

 

R3:

  • Removal of R3 would cause a reliability concern because this new transaction needs to be included in the IDC (congestion management) thus it must be tagged, thus there needs to be a NERC requirement

  • Not all entities in North America are obligated to follow NAESB Standards

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 2/23/2018

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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We thank the SDT for their due diligence in identifying supportive reasons for retiring this standard and all its requirements.

ACES Standard Collaborations, Segment(s) 5, 6, 1, 3, 2/23/2018

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Hot Answers

ERCOT signs on to the following comments of the ISO/RTO Council (IRC) Standards Review Committee (SRC):

We also recommend that as part of the INT periodic review effort that INT011-1.1 be formally retired.  We understand the standard is list as inactive.  However, it is still a FERC approved standard.

Brandon Gleason, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

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SPP Standards Review Group, Segment(s) , 2/23/2018

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Other Answers

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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Yes Seminole-Electric agrees

Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Laurie Williams, On Behalf of: Laurie Williams, , Segments 1, 3

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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The California ISO supports the comments of the ISO/RTO Council Standards Review Committee

Richard Vine, On Behalf of: Richard Vine, , Segments 2

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Texas RE does not have comments on this question.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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We also recommend that as part of the INT periodic review effort that INT011-1.1 be formally retired.  We understand the standard is list as inactive.  However, it is still a FERC approved standard.

ISO RTO Council's Standard Review Committee , Segment(s) 2, 2/23/2018

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Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 2/23/2018

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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Thank you for the opportunity to comment.

ACES Standard Collaborations, Segment(s) 5, 6, 1, 3, 2/23/2018

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