FERC Filings
EPSA Comments on Available Transfer Capability Information Requirements
Background and Overview
Generally, EPSA applauds the work of the LTATF and appreciates the attention the Commission is giving to these important issues. The purpose of the LTATF was “to develop a report and specific recommendations for the calculation and coordination of AFC/ATC to increase market liquidity and enhance reliability.” Among the noteworthy aspects of the LTATF’s work is its threshold recognition that the industry has evolved in significant respects since Order No. 888. Among other developments that have changed the nature of ATC calculations and coordination, the LTATF mentions the emergence of centralized markets resulting in market to non-market interfaces, and agreements involving ISOs/RTOs and transmission providers that have enhanced operational coordination and the processing of transmission service requests.
Most important, in its report, the LTATF acknowledged the overall lack of progress since Order No. 888’s mandates for the sale of transmission service, requiring the explicit calculation of ATC, were issued:
Furthermore … the lack of standardization and, more significantly, limited coordination can negatively impact both the market, through the need for a large number of Transmission Loading Relief (TLR) actions (or curtailments in WECC), and, on occasion, reliability when even the use of TLRs provides insufficient relief on some critical interfaces.”
EPSA agrees with the LTATF’s conclusion that “[t]here is still a need for further industry-wide improvement because of continuing outages, curtailments, TLRs and other reliability and commercial concerns.
Indeed, reaching back five years, EPSA has addressed issues and raised concerns relating to ATC and CBM, and proposed measures to improve both reliability and competitive market operations. In May, 2000, the Commission issued a Notice of Interim Procedures to Support Industry Reliability Efforts and Request for Comments (Notice) . The purpose of the Notice was “to identify practical steps the Commission and others can take to support the industry’s efforts to ensure the continued reliability of the electric power system.”
Among other things, the Commission proposed to take actions “supporting efforts to maximize the amount of Available Transmission Capability (ATC).” Particularly, the Commission stressed the need for accurate ATC calculations and OASIS postings, noting that, “[a]ccurate ATC is crucial to facilitating power sale transactions that can relieve stress on the Nation’s electric systems.” In its comments, EPSA agreed, stating that:
[t]here is growing concern in the competitive power industry that ATC calculation and posting continues to be problematic. More than four years have elapsed since the requirement for OASIS and ATC posting was established in Order No.889…[a]ll concede that ATC problems continue to hound the industry, making many OASIS sites difficult, if not impossible, to use.
Despite some industry effort in the years since the Notice, the Commission has become increasing aware of unresolved problems and the threats they pose to the objectives set forth in Order Nos. 888 and 889. EPSA shares the concern that the Commission expressed in its NOI that “[t]ransmission providers have incentives to understate ATC on those paths valuable to power sellers that are competitors to a transmission provider’s own (or its affilliate’s) power sales.” Further, EPSA agrees that “the lack of clear and consistent methodologies for calculating ATC can allow transmission providers the discretion to control the transmission system to favor their own power sales or those of their affiliates” …and that…”variations in the way ATC is calculated provide opportunities for undue discrimination and create obstacles to doing business.”
As explained below in response to the specific questions posed in the NOI, EPSA generally supports the direction the Commission urges the industry to take. Rather than immediately standardizing all aspects of ATC calculations, however, EPSA believes the most urgent interim step is for the Commission to insist that every aspect in the ATC calculation process be open, transparent and uniform. Also, EPSA has concerns regarding the potential adverse impacts of the CBM calculation and implementation process, particularly in non-RTO areas. Finally, EPSA appreciates the efforts to date to coordinate the development of relevant reliability and business practice standards.