Regional Transmission Plan Model Reserve PGRR PGRR 042 Requirement and Load-Generation Imbalance Number Title Methodology Date March 19, 2015 Submitter’s Information Name Charles DeWitt E-mail Address charles.dewitt@lcra.org Company Lower Colorado River Authority (LCRA) Phone Number 512-578-4199 Cell Number 512-434-9557 Transmission Planner Market Segment Comments LCRA supports efforts to increase transparency and refine processes used to develop the ERCOT Regional Transmission Plan. After reviewing proposed PGRR-042 and comments submitted by several market participants, LCRA respectfully submits the following comments: The guidelines for development of the Regional Transmission Plan must allow enough flexibility to meet the requirements of the NERC TPL-001-4 Reliability Standard. The ability to assess the range of load and system conditions required by Requirement 2.1 of NERC TPL-001-4 must be maintained. As stated in of the following conditions by R2.1.4, sensitivity analysis “must vary one or more a sufficient amount to stress the System within a range of credible conditions that demonstrate a measurable change in System The listed conditions response:” include load, expected transfers, generation additions, retirements, dispatch scenarios, and controllable loads and Demand Side Management. The extent to which any or all of these variations can be applied to establish a range of credible conditions depends upon the existing market rules or known market rule changes that are in effect at the time a study is performed. The range of conditions that must be studied precludes the adoption of a singular load forecast or specific percentage limits on the range of load forecasts by the ERCOT Nodal Protocols, ERCOT Operating Guides or ERCOT Planning Guides and must leave these items to the discretion of ERCOT in consultation with market participants. LCRA supports the revisions suggested by ERCOT subject to the following comments: Include references to the language from Protocols, Guides, or Procedures instead of re-stating the language.
PGRR Number 042 PGRR Title Regional Transmission Plan Model Reserve Requirement and Load-Generation Imbalance Methodology Date March 19, 2015 Submitter’s Information Name Charles DeWitt E-mail Address charles.dewitt@lcra.org Company Lower Colorado River Authority (LCRA) Phone Number 512-578-4199 Cell Number 512-434-9557 Market Segment Transmission Planner Comments LCRA supports efforts to increase transparency and refine processes used to develop the ERCOT Regional Transmission Plan. After reviewing proposed PGRR-042 and comments submitted by several market participants, LCRA respectfully submits the following comments: The guidelines for development of the Regional Transmission Plan must allow enough flexibility to meet the requirements of the NERC TPL-001-4 Reliability Standard. The ability to assess the range of load and system conditions required by Requirement 2.1 of NERC TPL-001-4 must be maintained. As stated in R2.1.4, sensitivity analysis “must vary one or more of the following conditions by a sufficient amount to stress the System within a range of credible conditions that demonstrate a measurable change in System response:” The listed conditions include load, expected transfers, generation additions, retirements, dispatch scenarios, and controllable loads and Demand Side Management. The extent to which any or all of these variations can be applied to establish a range of credible conditions depends upon the existing market rules or known market rule changes that are in effect at the time a study is performed. The range of conditions that must be studied precludes the adoption of a singular load forecast or specific percentage limits on the range of load forecasts by the ERCOT Nodal Protocols, ERCOT Operating Guides or ERCOT Planning Guides and must leave these items to the discretion of ERCOT in consultation with market participants. LCRA supports the revisions suggested by ERCOT subject to the following comments: Include references to the language from Protocols, Guides, or Procedures instead of re-stating the language.
042PGRR_06_LCRA_comments_031915.docx