NERC MOD-029 Update

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NERC MOD-029 Update

• SWAT MEETING
• May 19-20, 2009

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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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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 members asking
• 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

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FERC Activities

• NOPR published March 19
• Generally accepts the NERC standards as isbut
  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

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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

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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.

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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
• Its a waiting game with no clear path or timeline

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Questions

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