Message-ID: <24911443.1075848082572.JavaMail.evans@thyme> Date: Wed, 3 May 2000 07:32:00 -0700 (PDT) From: christi.nicolay@enron.com To: joe.hartsoe@enron.com, richard.shapiro@enron.com, sarah.novosel@enron.com, elizabeth.sager@enron.com, kevin.presto@enron.com, bill.rust@enron.com, lloyd.will@enron.com, patrick.hanse@enron.com, greg.woulfe@enron.com, tom.dutta@enron.com, richard.ingersoll@enron.com, charles.yeung@enron.com, mark.palmer@enron.com, marchris.robinson@enron.com, jeff.king@enron.com, clint.dean@enron.com, rogers.herndon@enron.com, steven.kean@enron.com, john.moore@enron.com, dwatkiss@bracepatt.com, bcarr@bracepatt.com, sbuchheit@bracepatt.com, richard.sanders@enron.com Subject: TVA and Entergy respond to S&S protests Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Christi L Nicolay X-To: Joe Hartsoe, Richard Shapiro, Sarah Novosel, Elizabeth Sager, Kevin M Presto, Bill Rust, Lloyd Will, Patrick Hanse, Greg Woulfe, Tom Dutta, Richard Ingersoll, Charles Yeung, Mark Palmer, Marchris Robinson, Jeff King, Clint Dean, Rogers Herndon, Steven J Kean, John Moore, dwatkiss@bracepatt.com, bcarr@bracepatt.com, Sbuchheit@bracepatt.com, Richard B Sanders X-cc: X-bcc: X-Folder: \Steven_Kean_June2001_4\Notes Folders\Discussion threads X-Origin: KEAN-S X-FileName: skean.nsf TVA and Entergy filed answers to the numerous protests to Entergy's source and sink filing. TVA responded specifically to Enron and VEPCO's filings basically stating that the NERC letter was limited to the TVA/Enron dispute and inapplicable to the Entergy issue. TVA also made accusations that Enron in effect secretly talked with NERC to get a task force made up of members "predisposed to Enron's point of view." TVA said that the task force ignored TVA's requests to meet with it and that the task force went beyond current NERC policy. Finally, TVA understands that "Enron has prevented SERC" from bringing the matter to NERC ADR. Entergy's answer largely cites past FERC orders that approved the source and sink on tags (and denied Enron's Capacity Reservation Tariff) and basically states that the protests are a collateral attack on Order No. 888 (as we have known, the OATT does require ultimate source and sink on firm and allows them on non-firm). Entergy's filing, however, is lacking in substantive reasons why reliability would be so much better served by requiring this at the reservation level, when NERC has stated it is not necessary for reliability until the 20/30 minute ahead tag. Entergy says it can do a better job of listing actual ATCs and will prevent Entergy from overselling its system (although since Entergy's ATCs are usually low or 0 coming in over the ties, I question how many times Entergy has oversold Firm transmission.) Entergy also states that it and the Security Coordinators can police the IDC tags, in case the marketer puts the wrong priority information on the tag (how often does this happen?). [[I also don't know how Entergy is going to have time to check all this, when we called FERC hotline on them last year for lack of timely responses to reservation and tags]]. Although the IDC does not even analyze specific bus bars (and generator source and sink are optional on the tags now), Entergy says this is "irrelevant", but TLRs will be improved. Entergy cites FERC's 1998 OASIS orders that "EPSA has not made a compelling argument that disclosure would harm liquidity." I think that the compelling arguments are being made now about the discrimination. Although FERC approved the source and sink, transmission providers have not been using them and the tags don't require them. Entergy notes that when FERC issued the OASIS order, specific bus bar information was required on the tag -- now it is optional on the tag. Even so, Entergy states that requiring it on the reservation does not make it inconsistent with the tag. (I disagree.) Finally, Entergy says that we can always put in "anticipated" source and sink, but if it changes, our priority may change. It is my understanding that even the smallest change in source and sink will make some change in the power flows, so you effectively would always go to the lowest priority. We are considering filing a response that states the lack of evidence on the reliability issues when NERC doesn't think this is required is a material issue of fact that should be set for hearing, at least.