Message-ID: <19301987.1075851975173.JavaMail.evans@thyme>
Date: Fri, 13 Jul 2001 06:46:00 -0700 (PDT)
From: andy.rodriquez@enron.com
To: christi.nicolay@enron.com, lloyd.will@enron.com, richard.ingersoll@enron.com, 
	susan.scott@enron.com, kevin.presto@enron.com, 
	edward.baughman@enron.com, fletcher.sturm@enron.com
Subject: A MISO Victory - Wounding of the Source to Sink Beast
Cc: james.steffes@enron.com, richard.shapiro@enron.com
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Yesterday, at the Midwest ISO, we successfully managed to quash the MISO's 
"at least one source-to-sink reservation" proposal.

MISO has been attempting to figure out a way to do security analysis on 
transmission reservations, and felt that the Entergy Source/Sink policy was 
too restrictive, but the policy of not requiring source-to-sink at any point 
was too relaxed.  Their proposal was that "at least one" reservation on a 
tag/schedule must have the true source-to-sink; otherwise, the tag/schedule 
would be denied for improper use.

Representatives from CINergy, Duke, Dynegy, ACES, Ameren and LG&E worked with 
me to fight this concept, arguing that it was effectively identical to the 
Entergy Source/Sink policy in almost all cases.  After a meeting and two 
conference calls, in which the MISO ignored our comments and continually 
pressed for their option, we finally managed to convince them that it was 
unacceptable.  

The new policy that MISO is planning to operate under is as follows:

 1.) If, at the time a transaction is tagged/scheduled, the MISO reservation 
specified accurate source and sink, the tag/schedule will be approved.
 2.) If, at the time a transaction is tagged/scheduled, the MISO reservation 
did NOT specify accurate source and sink, but analysis indicates the 
transaction can flow without compromising reliability, the tag/schedule will 
be approved
 3.) If, at the time a transaction is tagged/scheduled, the MISO reservation 
did NOT specify accurate source and sink, and analysis indicates the 
transaction cannot flow without compromising reliability (i.e., the 
transaction will cause or contribute to a constraint), the tag/schedule will 
be denied

While this is not as unrestrictive as we might want, it allows us a great 
deal more flexibility that the Entergy Source/Sink barrier while at the same 
time allaying the MISO's reliability concerns.  Effectively, this allows us 
to redirect both firm and non-firm at the time of tagging/scheduling without 
a loss in transmission priority.  Not only will this give us more flexibility 
within MISO, but the MISO intends to sell it to the Alliance as well under 
the IRCA.  

This also can give us a cornerstone in proving to the FERC that the Entergy 
S/S policy is not required for reliability, as other entities are able to 
meet reliability goals without the stifling limits Entergy claims are 
necessary.

As an aside, we are also pressing the MISO for a Redirection policy that will 
allow for "partial" redirects of service on a short term basis (the Separate 
proposal referenced in the attached document).  This will allow us to 
accomplish the same goals as the new MISO policy, but reduce the availability 
risk by allowing us to redirect prior to the time the transaction is 
tagged/scheduled.  These two proposals, when combined, will allow us for much 
more flexible uses of transmission without ignoring the reliability mantra 
providers chant whenever we ask for innovation and change. 

A detailed write-up of the work accomplished is attached.  Proposal 4, 
Discussion item "Confusing POR/POD Naming," Discussion Item "MISO Proposal  
...time of scheduling," and the Resolutions should be of primary interest to 
those wishing to see more detail on the directions MISO is heading.

Andy Rodriquez
Regulatory Affairs - Enron Corp.
andy.rodriquez@enron.com
713-345-3771