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NERC MOD-029 Update

NERC MOD-029 Update. SWAT MEETING May 19-20, 2009. MOD-029 – what is it?. One of three NERC Methodologies to calculate ATC Flowgate (MOD-030) Rated System Path(MOD-029) Area Interchange (MOD-028) MOD-029 based on WECC Rated System Path Methodology Not yet entirely approved by FERC .

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NERC MOD-029 Update

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  1. NERC MOD-029 Update SWAT MEETING May 19-20, 2009

  2. MOD-029 – what is it? • One of three NERC Methodologies to calculate ATC • Flowgate (MOD-030) • Rated System Path(MOD-029) • Area Interchange (MOD-028) • MOD-029 based on WECC Rated System Path Methodology • Not yet entirely approved by FERC

  3. Issues with MOD-029 • March 2009 CATS-EHV meeting discussed issues with TTC calculation : • Time consuming to perform the study • Power flow, Post Transient, Transient Stability analyses • Lower TTC values than historically seen • Could result in TTC lower than lower than grandfathered fixed price contracts • How to allocate reductions among multiple owners? • More transmission built can reduce TTC (more paths for power to flow on) • Significant impact if pre-1994 existing ratings are not allowed under the final MOD-029 standard • If re-study is necessary, which existing paths get higher priority to keep their rating?

  4. WECC Activities • TEP/SRP contacted WECC to highlight MOD-029 concerns at March 11 meeting • Committee re-formed (working group of Market Interface Committee-MIC) • Lead by Shannon Black • Meetings have occurred to discuss issues/implementation • Shannon Black 4/23/09 e-mail encouraged commenting on NOPR and express support for existing ratings • Shannon distributed a survey to the working group membersasking: • Separate from the Paths listed in the WECC Path Rating Catalogue with an "Existing Rating", how many "ATC Paths" (i.e. paths posted on OASIS) would your firm have to rate/ re-rate if the protections of MOD-29-01, R2.7 were removed? • How many "ATC Paths" do you have with an "Existing Rating" classification in the WECC Path Rating Catalogue for which you post the "Existing Rating" as your TTC for that path? • How long to rate/rerate paths identified in the questions above • Survey lacked participant response

  5. FERC Activities • NOPR published March 19 • Generally accepts the NERC standards as is—but questions grandfathering of existing ratings (among other concerns)! • Comments due to NERC on May 26th • If MOD-029 approved “as is” in June 2009, (before August break) and removes grandfathering of existing ratings then • Possible re-study and re-rating of all WECC rated paths needed by 3rd quarter 2010

  6. Recent Activities • WECC will not submit comments to FERC regarding NOPR • Utilities encouraged to submit individual comments to NERC • TSS collecting comments on NOPR • LPPC and APPA submitting comments to NOPR

  7. Recent Activities • Conference Call May 12, 2009 discussed: • Grandfathering (R2.7) • Scope creep: FERC expanding jurisdiction through NERC reliability standards. • Scope creep: Network Service, designated, non/designated resources • To retain R2.7, must show that there is a TECHNICAL reason for grandfathering. Policy arguments will likely not be successful.

  8. Next Steps • FERC reviews NOPR Comments • FERC will either • Approve standard, with its recommended changes • Remand the standard back to NERC for revisions • If approved with FERC changes= no grandfathering • If remanded to NERC = standard drafting team should be reconvened to modify standard to make it acceptable • It’s a waiting game with no clear path or timeline

  9. Questions • Should SWAT submit comments? • Due to short timeframe, participants will have to generally agree to SWAT Steering Committee’s comments (yet to be drafted) • Is TSS filing comments on behalf of participants? • Other questions?????

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