FERC Filings
EPSA Comments on Available Transfer Capability Information Requirements
Specific Questions
(1) The definitions of AFC, ATC, CBM and TRM
« CBM
As with all other processes associated with the management and operation of the bulk power transmission system, EPSA¡¦s overarching concern is that transmission providers¡¦ reliance on CBM not operate to limit competitive power suppliers market entry or otherwise disadvantage them. EPSA¡¦s concerns relating to CBM are largely focused on its use in non-RTO regions, as well as the implications for interface transactions involving neighboring RTOs. Indeed, within RTOs/ISOs such as PJM, for example, CBM has proven to be a useful mechanism that contributes to reliability and provides consumer savings by reducing the installed generation reserve requirement.
In non-RTO regions, however, questions exist regarding the transparency, validity and impact of the assumptions underlying CBM calculations. Of particular concern is the apparent disconnect between the planning and expansion process and the assumptions transmission providers use to calculate CBM (and TRM), which then feed into ATC calculations. At a minimum, it is inappropriate for a transmission provider or RTO to post negative AFC numbers and then fail to account for that when assessing necessary expansion projects. Therefore, if CBM and TRM are used in AFC/ATC calculations and result in a denial of transmission service requests, then a transmission provider must use the same assumptions in its transmission planning process to determine when to
reinforce and expand the system.
Beyond that, EPSA supports the Commission¡¦s suggestion that the assumptions underlying CBM and transmission reliability margin calculations (TRM) must be periodically reassessed to ensure that ATC postings are accurate. While important, merely requiring transmission providers to calculate CBM more clearly does not address fundamental questions pertaining to discrepancies between CBM/TRM/ATC calculations and system expansion decisions. In the near term, EPSA recommends that, at a minimum, the Commission provide guidance to all parties involved in NERC standards development processes, such as the Standards Authorization Request (SAR) drafting team in its consideration of what, if any, actions are required to ensure the uniform and consistent use of assumptions underlying both the CBM and planning/expansion processes.
Another immediate, practical first step EPSA recommends is that the Commission provide guidance on standards that should be developed requiring transmission providers to notify the Commission in writing and post a notice on their OASIS within 24 hours of a transmission provider¡¦s use of CBM to import emergency power. Further, the amount of CBM reserved for each interface should be posted on OASIS. Such a posting would be consistent with the Commission's 24-hour notification and posting requirements when transmission providers waive the Order No. 889 Standards of Conduct during an emergency. Similar posting and notification requirements would promote transparency and allow the Commission and other transmission customers to more effectively monitor CBM use by transmission providers and to more effectively request and utilize such reserved CBM on a non-firm basis when it is not being used by the vertically-integrated transmission providers during an emergency.
« TRM
With respect to TRM, EPSA believes that there is no legitimate reason for transmission providers to utilize different formulas for TRM calculations. The Commission should provide guidance to ensure that all transmission providers adopt a uniform formula for all TRM calculations, while allowing for the continued use of different assumptions underlying the ultimate TRM value.
(2) The advisability of revising and standardizing AFC, ATC, TRM and
CMB values
EPSA agrees with the Commission¡¦s suggestion that the ideal approach to ATC-related concerns is to standardize all aspects of the calculation methodology. However, achieving that goal, while possible and ultimately necessary, is likely to require extensive and time-consuming negotiations and collaboration given the existing regional variations, particularly at the interface of a market with a non-market region. Therefore, in the near term EPSA urges the Commission to take all actions necessary to ensure that the calculation of ATC and related terms is conducted in an open, transparent and uniform manner, subject to independent verification. In this connection, EPSA agrees with the Commission¡¦s view that ¡§[i]t is important that the ATC component (TRM and CBM) assumptions are stated and posted so that recalculated ATC values are transparent and not devised to produce an unduly discriminatory result.¡¨