Peak Reliability invites feedback on the proposed ECC design. Question 1
Peak Reliability invites feedback on the proposed ECC final state design described in ECC Final State Design Summary Document and the more technical ECC Final State Design Technical White Paper. Feedback on these eight questions is invited.
Feedback is due by Friday, December 15, 2017 at 5:00 p.m. Pacific time.
Please note that all comments are public.
1 Element Definition
Element – Any ECC-created single equipment or grouping of equipment that is being monitored for situational awareness.
Impact Threshold – The percentage of flow contribution that, when exceeded, allows for shared mitigation responsibilities through the ECC.
Elements can be monitored pre-contingency against equipment limits or post-contingency for loss of other Bulk Electric System (BES) equipment. While any equipment on the BES modeled in the ECC can be visualized, only certain Elements that have an Impact Threshold above a certain level will be subject to relief obligation requirements. All other Elements will use existing TOP and Peak practices when exceeding and mitigating an SOL exceedance. The Elements in ECC will be defined in accordance with Peak’s SOL methodology.
Does your entity agree with these Element definitions for ECC usage?
WPTF appreciates Peak’s efforts to define Elements and
Impact Thresholds within the ECC. WPTF generally supports the definitions that
have been proposed.
ISO Comment: Yes to these concepts, but the definition of Impact threshold should be clarified to refer to PTDF to avoid interpretations that the threshold would mean percentages of the total flow on an Element. (If the threshold were to mean percentages of the total flow, an Element with a large capacity could have many schedules that are excused due to not having a large MW size, thus placing unfair relief obligations on a small number of transmission users.)
Grid Group agrees that these definitions provide an equitable foundation for
ultimately determining relief obligations.
The element definitions provided seem appropriate.
SMUD/BANC Operator Repsonse: Yes, provided the monitored elements and equipment are reviewable and that the BA and TOP having primary oversight may request a review process to make revisions to the Element and associated Impact Threshold, with an appeal opportunity if needed. The ECC Final State Design White Paper of 11/22/2017 references periodic review and this should be built-in to the ECC Design at some initial periods followed by an on-demand review, if requested.
Yes, these definitions provide an equitable foundation for ultimately determining relief obligations.
Natural Resources Defense Council (NRDC)
BPA agrees generally, but recommends a slight wording change as the elements are “defined in ECC.” Further, not all defined Elements are “being” monitored by Peak or BAs/TOPs at all times, but once defined, are capable of being monitored. BPA understands ECC monitors a subset of the possible defined elements. BPA supports the following definition, as modified.
Element – Any ECC-created single BES equipment or grouping of BES equipment that is defined in ECC and capable of being monitored for situational awareness.