Laidlaw Energy Group, Inc.(fka LLEG)

[Matilda007]

Well I think FERC has already adressed the catch 22 problem.

ATC is the transfer capability remaining on a transmission provider’s transmission
system that is available for further commercial activity over and above already committed
uses. Transmission providers currently calculate the ATC for their systems using
different assumptions and methodologies.


After concluding that the absence of a consistent ATC methodology increases the
discretion of transmission providers and the opportunities for undue discrimination in the
application of the pro forma OATT, in the Final Rule the Commission requires:

o consistency in all ATC calculation components and some data inputs and
modeling assumptions, as well as consistency in the exchange of data between
transmission providers

o public utilities, working through the North American Electric Reliability
Corporation (NERC) and the North American Energy Standards Board (NAESB),
to develop appropriate standards within 9 months and 12 months of the Final Rule,
respectively

o increased transparency of ATC calculations through the inclusion in each
transmission provider’s OATT of its specific ATC calculation methodology, and
through posting of relevant data and models on each transmission provider’s open
access same-time information system (OASIS)

o transmission providers to post on OASIS metrics relating to transmission requests
that are approved and rejected.

COORDINATED, OPEN AND TRANSPARENT TRANSMISSION PLANNING

The Commission concludes that transmission providers have a disincentive to
remedy increasing transmission congestion on a nondiscriminatory basis and that the
current pro forma OATT does not adequately address this problem. Therefore, the Final
Rule requires that:

o Transmission providers participate in a coordinated, open and transparent planning
process on both a local and regional level

o Each transmission provider’s planning process meet the Commission’s nine
planning principles, which are coordination, openness, transparency, information
exchange, comparability, dispute resolution, regional coordination, economic
planning studies, and cost allocation

o Each transmission provider must describe its planning process in its tariff

o The Commission will allow regional differences in planning processes.


PRICING OF IMBALANCES

Differences between the scheduled and the actual delivery of energy to a load
(energy imbalances) and differences between the energy scheduled for delivery from a
generator and the amount of energy actually generated in an hour (generator imbalances)
are both corrected by transmission providers to keep the system in balance. Existing
policies for pricing energy and generator imbalances provide wide discretion in the
development of these charges and allow the potential for undue discrimination. The
Commission finds that existing energy and generator imbalance charges are excessive,
too varied, and otherwise unrelated to the cost of providing the service and, therefore,
reforms energy and generator imbalance pricing as follows:

o The Commission revises the existing pro forma OATT Schedule 4 for energy
imbalances and adopts a new Schedule 9 for generator imbalances to require
imbalances to be based on a tiered structure similar to the imbalance provision
used by Bonneville. In these new provisions, imbalance charges escalate as the
imbalance increases and are based on incremental cost. Intermittent resources are
exempt from the highest deviation band.

o Any deviations from these provisions must be consistent with or superior to the
pro forma OATT as modified by this Final Rule and must meet the following
criteria: the charges must (1) be related to the cost of correcting the imbalance, (2)
be tailored to encourage accurate scheduling behavior, such as by increasing the
percentage of the adder as the deviations become larger, and (3) account for the
special circumstances presented by intermittent generators.


REQUESTS FOR FIRM POINT-TO-POINT SERVICE

The Commission concludes that the existing methods for evaluating requests for
long-term firm point-to-point transmission service are no longer just, reasonable and not
unduly discriminatory. This is so because a transmission customer may be denied service
when its transaction is not deliverable during as little as one hour of the service period,
while transmission providers need not eliminate otherwise economic options under
similar conditions. To remedy this problem, the Commission modifies the pro forma
OATT, as follows:

o The Commission adopts a “conditional firm” component to long-term firm point-
to-point service that requires the transmission provider to identify either defined
system conditions or an annual number of hours during which service will be
conditional, and allows the customer to select one of them

o Transmission providers also have an obligation to evaluate the provision of
redispatch from their own resources and provide customers with information on


the capabilities of other generators to provide redispatch

o The duration of both service options is limited to a time period over which service
can be reasonably provided without impairing reliability

o After the end of each month, transmission providers must post certain information
associated with the actual cost of redispatch services provided that month.

ROLLOVER RIGHTS

The Commission revises the rollover provision in the pro forma OATT, which
grants an ongoing right to transmission customers to renew or “rollover” their contracts,
to apply to contracts that have a minimum term of five years, rather than the current
minimum term of one year. A customer must provide notice of whether or not it will
exercise its right of first refusal to renew the contract no less than one year prior to the
expiration date of the transmission service agreement, rather than within the current 60-
day period. These reforms promote consistency between the rights of rollover customers
and the resulting obligations of transmission providers to plan and upgrade the system to
accommodate rollovers.

http://www.ferc.gov/industries/electric/indus-act/oatt-reform/order-890/fact-sheet.pdf