UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Mandatory Reliability Standards for the ) Docket Nos. RM08-19-000
Calculation of Available Transfer Capability, ) RM08-19-001
Capacity Benefit Margins, Transmission ) RM09-5-000
Reliability Margins, Total Transfer Capability, ) RM06-16-005
and Existing Transmission Commitments )
and Mandatory Reliability Standards for the )
Bulk-Power System )
COMMENTS OF THE SOUTHWEST AREA TRANSMISSION
SUBREGIONAL PLANNING GROUP
The Southwest Area Transmission Subregional Planning Group (“SWAT”)
respectfully submits these comments pursuant to the Federal Energy Regulatory
Commission (“FERC”) Notice of Proposed Rulemaking on Mandatory Reliability
Standards for the Calculation of Available Transfer Capability (“ATC”), Capacity Benefit
Margins (“CBM”), Transmission Reliability Margins (“TRM”), Total Transfer Capability
(“TTC”), and Existing Transmission Commitments (“ETC”). SWAT is a voluntary
collaborative subregional study group open to all parties with an interest in participation
on a stakeholder process for the development of a robust transmission system in
Arizona, New Mexico, and parts of Colorado, west Texas, southern Nevada and the
Imperial Valley area of California. SWAT exists for the benefit of its members and the
value they derive in achieving SWAT goals, which include, among other things, efficient
use of the transmission system, development of new transmission facilities, operational
reliability and coordination with other Western Electricity Coordination Council (“WECC”)
subregional planning groups. Participants in SWAT subcommittees, work groups, task
forces, and projects include the Arizona Attorney General‟s Office, Arizona Corporation
Commission, Arizona Power Authority, Arizona Public Service Company, California
Independent System Operator, Central Arizona Water & Conservation District , Dine
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 1
Power Authority, El Paso Electric Company, Electrical Districts 2, 3 and 4 of Pinal
County (Arizona), Gila River Generating Station/Entegra, Imperial Irrigation District, New
Mexico Attorney General‟s Office, New Mexico Public Regulation Commission,
PacifiCorp, Public Service Company of New Mexico, Navajo Tribal Utility Authority, NV
Energy , Rocky Mountain Reliability Center, Salt River Project, Sithe Global, Southern
California Edison Company, Southwest Transmission Cooperative, Southwestern Power
Group, Tri-State Generation and Transmission Association, Tucson Electric Power
Company, Western Area Power Administration, a number of municipalities from affected
states, numerous resource developers, environmental advocate groups, environmental
planners, and other interested parties. SWAT meetings are open to the public, and all
interested parties are invited to attend and participate in SWAT meetings and planning
activities. SWAT members are variously registered with the North American Electric
Reliability Corporation (“NERC”) Compliance Registry as Transmission Owners and
Operators, Generator Owners and Operators, Resource Planners, and Balancing
Authority Areas among other categories: all of which make the SWAT members subject
to applicable NERC Reliability Standards. All SWAT members share a common goal to
protect and improve the reliability of the Bulk-Electric System (“BES”).
Through this NOPR the Commission has invited comments on the standards and
it has targeted certain requirements under several of the standards as candidates for
remand to NERC for modifications. In response, SWAT‟s comments address the
importance of retention of R2.7 in MOD-029-1 (the “Existing Path Rating” provision).
I. Communications
All communications, including any correspondence, pleadings or other
documents, related to this matter should be directed to the following individual:
Robert E. Kondziolka
Salt River Project
Manager of Transmission Planning and
Chairman of SWAT
PO Box 52025
MS POB 100
Phoenix, Arizona 85072-2025
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 2
(602) 236-0971
rekondzi@srpnet.com
II. MOD-029-1 R2.7 is an Integral Technical Aspect of this Standard and
Should Be Retained as Developed by the Standards Development Team and as
Approved by NERC.
In its NOPR, the Commission seeks comment on “whether it should direct the
ERO to develop a modification to the Rated System Path Methodology (MOD-029-1) to
remove Requirement R2.7 as unsupported.” (NOPR at P.115) The Commission is
concerned that inclusion of R2.7 will result in outdated assumptions and arbitrary
exemptions from the rating process of specified paths. SWAT welcomes the
opportunity to explain the foundation for inclusion of R2.7 and the necessity for retaining
this requirement as an essential aspect of the WECC‟s long-standing and operationally-
successful Rated System Path (“RSP”) program.
Before detailing the technical reasons for inclusion of MOD-029-1 R2.7, SWAT
would like to remind the Commission that NERC-approved mandatory reliability
Standards are developed by industry experts with a goal to improve reliability while
incorporating requirements that are both technically feasible and efficient in meeting the
standard‟s objectives. Given that industry experts develop the proposed standards, the
Energy Policy Act of 2005 expressly directs the Commission to “give due weight to the
technical expertise of the Electricity Reliability Organization with respect to the content
of a proposed standard.”1 Congress further ordered the Commission, when it was
considering any modification of a proposed standard to “give due weight to the technical
expertise of the Electricity Reliability Organization with respect to the content of a
proposed standard.”2
1
H.R. 6-350, Title XII – Electricity, Subtitle A, Reliability Standards. Section „d‟
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_cong_bills&docid=f:h6enr.txt.pdf
2
H.R. 6-350, Title XII – Electricity, Subtitle A, Reliability Standards. Section „d‟
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_cong_bills&docid=f:h6enr.txt.pdf
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 3
SWAT notes that MOD-029-1 is the product of technical consultation between
and among the WECC Market Interface Committee (“MIC”), the Market Issues
Subcommittee (“MIS”), and the Available Transmission Capacity Task Force (“TF”), all
of which met repeatedly to solicit the technical input of members all across WECC.
Additionally, WECC communicated and solicited input on MOD-029-1 through WECC
standing committee meetings and a special workshop that included a focus on
TTC/ATC. As a result, when the “Comment Report Form for 3 rd Draft of MOD-01; 2nd
Draft of MOD-004, MOD-008, MOD-28, MOD-29, MOD-30, Project 2006-2007” (Form 3)
was presented to the industry for comment, numerous entities made specific and
affirmative comments that R2.7 should be retained in MOD-29-1.3 NERC‟s final filing on
November 21, 2008 provides:
“AFFIRMATIVE COMMENTS:
The NERC Team and those listed above are reminded that the WECC
MIC MIS ATC TF Drafting Team has solicited its responses face-to-face
from 50+ individuals on 11/28/07 in Portland (attendance sheet retained
by WECC and can be made available on request) and has also been
supported by the ongoing technical support from the 40+ members of the
WECC MIC MIS ATC Advisory Panel (16 separate entities) over the last
year of drafting. As such, the WECC Team comments have been widely
vetted and represent a substantial base of technical knowledge and
veracity and are not merely the comments of a single entity. The WECC
Team and those listed above make the following “positive” proactive
comments that the below listed features and attributes are essential to the
standards as proposed and should be retained in the event a
counterposition may be suggested by any singular entity.”
The report concluded by indicating that “[t]he Team and those listed above
strongly support retention of the requirement(s) in R2.7 allowing the retention of
3
NERC Final Filing. November 21, 2008.
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 4
existing and operationally proven TTCs without requiring a superfluous and
redundant re-rating.” Form 3 at 225-226.
In addition to the WECC TF comments, NERC received specific comments to
retain R2.7 from a range of entities including public and private power, ISOs, RTOs, and
federal agencies, including the ISO/RTO Council; PacifiCorp; SRP; WAPA; APS;
Clearwater Power Corp; Columbia Grid; Consumer Power Inc.; Falls River; Flathead;
Modesto Irrigation Dist.; PacifiCorp; Grant PUD; Salmon River; Snohomish; Tacoma
Power; and WestConnect. In contrast to the significant record of support for R2.7, only
three parties have suggested R2.7 not be retained in its current form. SWAT suggests
that the combined expertise of the supporting entities, representing multiple segments
of the industry, constitutes a strong record that the substantive content of MOD-29-1
R2.7 has been reviewed in depth by the industry and determined to be a required
feature of that standard.
The Commission also noted that it “is concerned that requiring pre-1994 total
transfer capability values to remain in place without adequate explanation essentially
exempts certain paths from the total transfer capability requirements in the Rated
System Path Methodology and may result in total transfer capability values that are
incorrectly based on stale assumptions and criteria.”4 SWAT now explains the sound
technical basis for R2.7.
The WECC Rated System Path Methodology drafted into MOD-029-1 is based
on the current TTC methodology used throughout WECC. The first three requirements
of MOD-029-1 (R1, R2 and R3) reflect the existing, successful practice in place in the
WECC today.5
4
NOPR, P. 114.
5
“Within the Western Interconnection, a wide area approach is used to determine TTC on a path basis
using the Rated System Path method discussed in WECC‟s “Procedures for Regional Planning Project
Review and Rating Transmission Facilities” and NERC‟s “Report on Available
Transfer Capability Definitions and Determination”. Determination of Available Transmission Capacity
within the Western Interconnect. June 2001. Section 61. Page 6.
http://wecc.biz/documents/library/procedures/ATC-apprdec01.pdf
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 5
6
MOD-29-1, R2.7 provides:
“For ATC Paths whose path rating, adjusted for seasonal variance, was
established, known and used in operation since January 1, 1994, and no action
has been taken to have the path rated using a different method, set the TTC at
that previously established amount.” MOD-29-1 R2.7.
R2.7 is derived from the WECC term “Existing Path” as used by WECC since
1994.7 Currently there are 69 Existing Paths from all subregions within WECC. Each
such path is reviewed on a regular basis - most recently in the January 2009 WECC
Path Rating Catalog, as prepared by the WECC Technical Studies Subcommittee under
the auspice of the WECC Planning Coordination Committee (“PCC”).8 In addition to
review by the WECC PCC, these Existing Paths are reviewed annually by the WECC
Operating Transfer Capability Policy Committee to assign an appropriate seasonal
System Operating Limit (“SOL”) for each path. Thus, while a path may have an
“Existing Path Rating,” any such rating is subject to regular review for operations and
planning purposes. The seasonal SOL is typically a value that is less than or equal to
Overview of Policies and Procedures for Regional Planning Project Review, Project Rating. Revised April
2005.
http://www.wecc.biz/documents/library/procedures/planning/Overview_Policies_Procedures_Regi
onalPlanning_ProjectReview_ProjectRating_ProgressReports_07-05.pdf
6
NOPR, P. 115
7
R2.7 is modeled after the definition of an “Existing Rating” defined as: “Transmission path ratings that
were known and used in operation as of January 1, 1994. (Reference: Procedures for Regional Planning
7(
Project Review and Rating Transmission Facilities.)” Overview of Policies and Procedures for Regional
Planning Project Review, Project Rating. Revised April 2005. Section 4.3.5, Application to Existing
Systems. Page 43.
http://www.wecc.biz/documentslibrary/procedures/planning/Overview_Policies_Procedures_Regio
nalPlanning_ProjectReview_ProjectRating_ProgressReports_07-05.pdf
8
WECC January 2009 Path Rating Catalogue. Table of Contents. Part VI. Item 1 – v.
http://wecc.biz/documents/library/reports/2009/Path2009_Final.pdf
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 6
the Existing Path Rating. This rigorous review of Existing Path Ratings ensures
assigned TTC values have been fully vetted throughout WECC with broad public
participation. Thus SWAT believes that the Commission‟s concerns that R2.7
effectively exempts certain paths from the TTC requirements of the MOD-29-1 are
unfounded.
Moreover, an “Existing Path Rating” does not mean such ratings become
obsolete or inaccurate over time. Indeed, as the transmission system changes and new
facilities are added, engineering studies are conducted to ensure new facilities do not
pose operational or reliability risks to the transmission system. Such studies focus on
the existing system as a baseline, including all Existing Path Ratings. Under the
auspices of peer review, these engineering studies are performed to ensure that the
addition of new facilities does not negatively impact the reliability or capability of pre-
existing transmission facilities and systems. If a potential negative impact is identified
during the study process, the new project must mitigate any such negative impacts.
This dynamic process, studying new facilities against the baseline of existing facilities
and systems, means that all path ratings are “built” upon and coordinated with pre-
existing path ratings so that the ratings are, at all times, current and coordinated.
As a result of the R2.7 protection of Existing Path Ratings, proposed new
transmission facilities must both deliver incremental improvements to the BES while
avoiding or mitigating any negative impacts to the existing BES transmission
components. Removing the R2.7 protections may result in proposed new additions that
narrowly focus on maximum flows on the new facilities while failing to deliver
incremental improvement to the interconnected BES and even reducing capacity of
existing facilities.
Moreover, R2.7 specifically provides a process for review and change of Existing
Path Ratings. Any interested party can request a WECC review of any given Existing
Path Rating. Upon any such request, WECC will review and re-set the subject TTC in
accordance with the requirements set forth in MOD-29-1, R1, R2 and R3, but without
deference to R2.7. Thus, R2.7 reasonably retains Existing Path Ratings, which have
been reliably and successfully used for decades, while allowing for review and re-
establishment of TTC upon request.
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 7
Besides the compelling technical and reliability reasons stated above for
maintaining the rating provision in R2.7, SWAT urges that FERC be mindful of the
multitude of transmission contracts among Transmission Providers premised upon
Existing Path Ratings. If R.2.7 were removed and re-ratings resulted in new
transmission capacity allocations among multiple transmission lines and transmission
owners, the WECC would face at least two major threats to reliability and operational
procedures. First, rejection of the pre-existing path ratings will disturb the mitigation
processes implemented as a result of decades of reliability studies to ensure both the
build-out of the BES while avoiding adverse impacts to pre-existing facilities. New
ratings will surely conflict with the comprehensive coordination of existing ratings and
mitigation procedures and, while WECC and the industry struggle to replace the current,
efficient and successful system with new processes, transmission capacity will likely be
reduced and operational certainty put at risk.
Secondly, a wholesale rejection of Existing Path Ratings would compel a
comprehensive simultaneous re-examination of the terms and conditions of numerous
existing transmission contracts. These forced re-negotiations are likely to have
significant and far-reaching impacts on pricing and could dramatically alter the well-
defined existing contract rights between parties. There is no compelling reason to
cause such large-scale disruptions in contracts - especially contracts soundly based on
well-established and successful path ratings and related contract provisions. SWAT
urges FERC to honor and leave undisturbed all such existing contract rights.
//
//
//
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 8
III. Recommendation
For the reasons provided above, SWAT respectfully requests that the
Commission defer to the technical development and preparation of this Standard and
accept MOD-29-1 R2.7 as proposed by WECC and NERC.
Respectfully submitted by,
__________________________
Robert E. Kondziolka
Salt River Project
Manager of Transmission Planning and
Chairman of SWAT
PO Box 52025
MS POB 100
Phoenix, Arizona 85072-2025
(602) 236-0971
rekondzi@srpnet.com
Dated: 26 May 2009
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 9
CERTIFICATE OF SERVICE
I hereby certify that I have this day served a copy of the foregoing document on
each party named in the official service list in this proceeding.
Dated at Phoenix, AZ, the 26th day of May 2009.
Sincerely,
_______________________
Margaret A. Rostker
Salt River Project
Senior Attorney
SWAT Comment FERC ATC NOPR_FINAL_26 May 2009 10