NAESB WEQ Update Interchange Scheduling and Accounting Subcommittee May 21, 2019 - BPA - Western Electricity Coordinating Council

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NAESB WEQ Update Interchange Scheduling and Accounting Subcommittee May 21, 2019 - BPA - Western Electricity Coordinating Council
NAESB WEQ Update
Interchange Scheduling and Accounting Subcommittee
                   May 21, 2019

                  Mike Steigerwald
                        BPA
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Objective

    • Provide a broad overview of the activities of the
      NAESB Wholesale Electric Quadrant across the
      lifecycle of standards development.

    • Disclaimer: Presenter does not represent
      NAESB. I am BPA’s representative to the
      NAESB WEQ Executive Committee. I am also a
      co-chair of the OASIS subcommittee.

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NAESB WEQ Standard Development Lifecycle
                                                                        Industry
                   Industry                                        Formal Comment
             Informal Comment                                        to NAESB EC                                         EC considers:
                  to NAESB                                             (30 days)                       WEQ
                                             Subcommittee                                                                1. Standards approved by the
                  (30 days)                                                                          Executive
                                               Standard                                                                      subcommittee in step 2.
                               2a            Development                      3                     Committee            2. Formal comments filed by
                                               and Vote                                                Vote                  industry in step 3.
                                                           2                                4
                    Industry
                                                                                    NAESB
                                                                                   Approval                         WEQ
                   NERC                WEQ
                                                                                     and                         Membership
                                    Triage and
                                     Prioritize
                                                   1       Initiation             Publication           5       Segment Vote
                     SRS             Request                                                                      (30 days)

                                                                        FERC
                 Standard development
                     Directive to NAESB
                                                            8                                   6
                                                                                                   Standards    Voluntary for jurisdictional
                                                  FERC                        7                   Published & entities until ‘adopted by
                                                  Order                                         filed with FERC reference’ by FERC Order.
             9     Implementation
                                                                           FERC                    (1-2 years)
                                                                          Issues
                 Directive to Industry
                                                                         NOPR to
                                                                         Industry      Industry has 60 days to comment to
                                                                                       FERC on proposed standards.

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1                                                                                                          Approved in the
    Subcommittee Development Backlog                                                                       2019 Annual Plan.

        Topic        Sub Description and Status
                                 Investigate whether standards are needed to apply DLT (eg, blockchain) to utility
    Distributed                  accounting functions such as power trading and Renewable Energy Certificates
      Ledger                     (REC). API 7a and 7b.
                     WEQ
    Technology
       (DLT)                     Kickoff meeting June 7 from 1:00 to 3:30 central and a follow-up meeting on June 24
                                 from 10-12 central.
                                 Review WEQ-004 and other tagging standards in light of NERC proposal to retire the
        INT
                     CISS        following: INT-004-3.1 and INT-010-2.1 in their entirety, as well as INT-006 (R3.1,
    Retirements
                                 R4, R5) and INT-009 (R2).
       MOD                       Review WEQ-023 Modeling standard in light of NERC proposal to retire MOD
                     BPS
    Retirements                  standards (including withdrawal of MOD-001-2).
                                 Annual review of the Authorized Certification Authorities (ACA) accreditation (API
         ACA         Cybr
                                 4a).
    NERC CIP         Cybr        Annual review of the NERC CIP standards (API 4b).

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2
    Subcommittee Development In-progress
        Topic        Sub Description and Status
                                  Modifications to the original NITS standards based on learnings from the NITS
        NITS             OS       industry implementation (API 3c). Completed first phase dealing with minor
                                  corrections. Now considering more substantive changes.
        NITS             OS       Define rollover rights for NITS (API 3e).

         EIR             OS       Require OASIS to use EIR to validate request information (API 3a).
                                  Posting of additional curtailment information on OASIS per FERC Order 890 (API
                                  2.a). Will establish NAESB standards that extend existing FERC posting
    Curtail Info     OS
                                  requirements under 18 CFR 37.6 e3. Draft standards will only be applicable for
    on OASIS         BPS
                                  interconnection-wide curtailment events.
                                  • Informal Comment period closed 03/19/19.
                                  Request to clarify tag timing requirements in WEQ-004. TPs and BAs are not
                                  meeting the strict approval windows defined in NAESB WEQ-004 and NERC INT-
                                  006 due to misapplication of these timing requirements. (API 3h)
    Tag Timing       CISS
                                  •       Voted out of the Coordinate Interchange Scheduling Subcommittee 02/12/19.
                                  •       Send back to the CISS on 03/26/19 by Executive Committee to coordinate with
                                          NERC.

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2a                                                                                                       Subcommittee still
     Pending Informal Comment                                                                            actively working.

         Topic        Sub Description and Status

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3                                                                                                       Subcommittee
    Pending Formal Comment                                                                              passed to the EC.

        Topic        Sub Description and Status

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4                                                                                                       Next EC meeting
    Pending Executive Committee Vote                                                                    will be Oct’19.

        Topic        Sub Description and Status
                             Improve transmission planning models by making visible a complete path associated
                             with long-term firm interchange when partial path requests are made (API 3d). The
                             eastern regional coordination committee driving this has since found other ways of
    Interchange
                     OS      getting the needed planning information.
      Modeling
                             •   “No Action” recommendation passed by OS on 04/17/19.
                             •   Formal Comment period closed on 05/20/19.

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5                                                                                                       30 day vote by all
    Pending Membership Segment Vote                                                                     NAESB members

        Topic        Sub Description and Status

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6                                                                                                            No publication date
    Pending NAESB Publication                                                                                announced.

         Topic           Sub Description and Status
                                   Redispatch Cost Posting to allow for posting on OASIS of 3rd party offers of
                                   Planning Redispatch services per FERC Order 890 (API 2.a.i.2). The TP is
     3rd Party                     obligated to provide the posting mechanism on OASIS for 3rd party offers of
                         OS
     Planning                      Planning Redispatch. There is no obligation for any party to use this functionality.
                         BPS
    Redispatch                     • Voted out of the OASIS and Business Practice Subcommittees on 01/23/18.
                                   • Voted out of the Executive Committee on 04/24/18.
                                   • Voted out of the Segment Membership on 05/25/18.
                                   Update OASIS Query/Response templates to allow more flexible and efficient
                                   queries for some templates (API 3b).
        Templates        OS        • Voted out of the OASIS subcommittee on 06/19/18.
                                   • Voted out of the WEQ Executive Committee on 08/21/18.
                                   • Voted out of the Segment Membership vote on 09/24/18.
                                   Update OASIS to ensure that capacity reserved for untagged Pseudo-ties is
                                   preserved for that purpose (API 3e). The basic requirement does not apply to BPA
                                   as Pseudo-ties are tagged in the west. But the proposed standards define a
     Untagged                      generic way to encumber a TSR for ad-hoc use (i.e., beyond Resale, Redirect, etc).
                         OS
    Pseudo-ties                    BPA may indeed find a use for such a capability in the future.
                                   • Voted out of the OASIS subcommittee on 08/22/18.
                                   • Voted out of the Executive Committee on 10/09/18.
                                   • Voted out of the Segment Membership on 11/15/18.
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6                                                                                                            No publication date
    Pending NAESB Publication (continued)                                                                    announced.

          Topic            Sub Description and Status
                                    Automatically notify customers when PTP renewal deadline approaches (API 3b).
                                    • Voted out of the OASIS Subcommittee 11/17/18.
    PTP Rollover
                           OS       • Formal Comment period closed 12/28/18 with no opposition.
     Notification
                                    • Voted out of the Executive Committee on 03/26/19.
                                    • Voted out of the Segment Membership on 04/30/19.
                                    Updates to the Dynamic Notification (email) on OASIS to provide a more generic
                                    notification capability (API 3.f). Developed in conjunction with updates for PTP
                                    Rollover Notification above (API 3f).
         Dynamic
                           OS       • Voted out of the OASIS Subcommittee 11/17/18.
        Notification
                                    • Formal Comment period closed 12/28/18 with no opposition.
                                    • Voted out of the Executive Committee on 03/26/19.
                                    • Voted out of the Segment Membership on 04/30/19.
                                    Modify Next Hour Market (NHM) service to be more applicable to the western EIM
                                    (API 3.g). Draft changes make it clear that the tag priority 0-NX can be used for
                                    purposes other than Next-hour Market (NHM) service, such as EIM.
           NHM             OS       • Voted out of the OASIS Subcommittee 02/19/19.
                                    • Formal Comment period closes 03/20/19.
                                    • Voted out of the Executive Committee on 03/26/19.
                                    • Voted out of the Segment Membership on 04/30/19.

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FERC NOPR issued on 05/16/19 on NAESB v3.2
    •    NOPR: Notice of Proposed Rulemaking
    •    60 day industry comment period opens once published in the Federal Register
    •    Scope of the NOPR:
          – NAESB standards v3.2 (published12/08/17).
          – Also includes NAESB standards v3.1 (published 09/30/15). The v3.1 standards
            already went through a NOPR that closed back in Sept 2016. However, FERC
            never issued a Final Rule on the v3.1 standards. FERC says it is not necessary to
            refile comments on the v3.1 standards.
          – It seems likely that FERC intends to issue a Final Order that includes both v3.1 and
            v3.2 standards.
    •    Out of Scope:
          – The NAESB Modeling/ATC standards (WEQ-023) are in a separate docket.

    •    The one area in which entities may wish to file further comments on the v3.1
         standards is related to the Dynegy ruling involving Redirects.
          – The NOPR leaves open the question of whether a Redirect is permitted from a
            parent reservation that is conditional (still subject to preemption and competition).
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7                                                                                                               v003.2 published by
    FERC NOPR on 05/16/19                                                                                       NAESB 12/08/17.

         Topic              Sub Description and Status
                                       New OASIS request type that will be used to consolidate multiple “like” reservations
                                       into a single reservation for easier tagging. Replaces current practice of customers
    Consolidation           OS
                                       reselling TSR’s to themselves. Aggregation of Resales will still be allowed, but
                                       Reseller and Assignee must be different customers. Approved by NAESB Nov’16.
                                       Changes needed to WEQ-002 (S&CP), WEQ-004 (Coordinate Interchange), and
         Market
                            CISS       Electric Industry Registration (EIR) to support the Market Operator role for eTag
        Operator
                                       1.8.3. Approved by NAESB Sep’16.
                                       Remove all NERC references from WEQ-022 (which govern the EIR). Approved by
              EIR           CISS
                                       NAESB Mar’17.
                                       Retire WEQ-006 (Manual Time Error Correction) due to NERC retirement of BAL-
    Manual Time
                                       004. Approved by NAESB Mar’17.
       Error                BPS
     Correction
                                       Separate FERC NOPR closed fall 2018.
        Dynamic &                      Modify WEQ-004 following proposed retirement of NERC INT-004-3.1 (API 1.d.i).
        Pseudo-tie          CISS       NAESB standards to require RFI for Dynamic and Pseudo-ties mimic the previous
         Tagging                       NERC standards. Approved by NAESB Sept’17.
                                       Modifications to WEQ-008, which are the TLR standards that only apply to the
    Eastern TLR             BPS
                                       Eastern Interconnection.

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7                                                                                                           v003.2 published by
    FERC NOPR (continued)                                                                                   NAESB 12/08/17.

        Topic            Sub Description and Status
                                   Five year effort to develop standards for Short-term Preemption and Competition
                                   was completed per FERC Order 890. Approved by NAESB Nov’17.
    Short-term
    Preemption/          OS        This includes a late amendment pushed by the west and led by BPA to resolve a
    Competition                    gap in how certain Defenders with ROFR were treated if they were unable to
                                   exercise ROFR. Amendment adopted by the EC despite opposition from Duke and
                                   Southern.
                                   In July, the OASIS subcommittee also approved various changes to OASIS
    Consistency                    standards (WEQ-001, 002, 003, and 013). These are considered “consistency”
                         OS
     Changes                       changes to remove NERC references, ensure language alignment between
                                   NERC/NAESB, etc. Approved by NAESB Nov’17.
                                   In Aug, the DSM-EE subcommittee approved various changes to WEQ-015, 018,
    Consistency          DSM
                                   and 020. These are also “consistency” changes to ensure alignment between
     Changes             -EE
                                   NERC/NAESB. Approved by NAESB Nov’17.

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8                                                                                                               v003.1 published
    Pending FERC Final Order                                                                                    09/30/15. NOPR
                                                                                                                closed Sept’16.

         Topic          Sub Description and Status
        Entergy /                    Standards for treatment of Parent reservation when Redirect is lost to Preemption
                            OS
        Dynegy                       and Competition per FERC Order 676-H. Lots of NOPR comments to FERC.
       ATC                           NAESB standards to complement NERC ATC MOD A. In the NOPR, FERC declined
                        BPS
    Standards                        to adopt these NAESB standards pending separate ATC proceedings.
         DUNS               OS       Make the use of DUNS numbers optional. Little NOPR comment.

     WEQ-004            CISS         Modify WEQ-004 to require tagging of intra-BA transactions (replace INT-011-1).

    Source/Sink             OS       Source/Sink will be unmasked once a TSR is in any final state.

        AFC/TFC             OS       Updates templates for posting of AFC and TFC information (like ATC/TTC).

        Resales             OS       Resales will now be submitted as ACCEPTED rather than CONFIRMED.

          CF                OS       TP’s will be able to extend the period for Biennial Reassessment of Conditional Firm.

    1d Narrative            OS       Clarifies that TP’s will have 1 business day to post a narrative for zero ATC.
    Secondary                        Clarifies that a TP may invalidate a request to terminate Secondary Network service
                            OS
     Network                         that exceeds the capacity that is unscheduled.
                                     Clarifies how reservations included in a Coordinated Request are handled if
        SAMTS               OS
                                     displaced.
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9
    Implementation In-progress
        Topic        Sub Description and Status

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9
    Implementation Complete
        Topic        Sub Description and Status

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    Contact
                                 With questions or feedback

                                        Mike Steigerwald
                                         (360) 418-2113
                                     mlsteigerwald@bpa.gov

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    Background

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North American Energy Standards Board (NAESB)

                                                            Wholesale                                  Retail
    • An industry forum for
      the development and                        Wholesale Electric Quadrant                 Retail Electric Quadrant
      promotion of                                         (WEQ)                                      (REQ)
      standards which will
      lead to a seamless    Electric                           Co-chairs:
                                                            Roy True (ACES)
      marketplace for                                      Josh Phillips (SPP)

      wholesale and retail
      natural gas an
      electricity.
                                                     Wholesale Gas Quadrant                      Retail Gas Quadrant
    • 4 quadrants                                            (WGQ)                                      (RGQ)
    • BPA participates in
      the Wholesale            Gas
      Electric Quadrant
      (WEQ).

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Summary of WEQ Subcommittees
    •       OASIS (OS): Owns processing of TSR’s and posting requirements on OASIS.
             –   By far the most active subcommittee in WEQ.
             –   Standards and communication protocols for OASIS (WEQ-000, 001, 002, 003, 013).

    •       Coordinate Interchange Scheduling (CISS): Owns tagging.
             –   Interchange scheduling (tagging) standards (WEQ-004) and the e-Tag Functional Specification.
             –   Standards and enhancements to the Electric Industry Registry (EIR).

    •       Cybersecurity (CSS): Ensure secure exchange of market data across the internet.
             –   Owns the Public Key Infrastructure (PKI) standards (WEQ-012) and the Accreditation Specification that
                 together govern vetting of Authorized Certificate Authorities (ACA).
             –   Also performs Annual Reviews of NERC/CIP.

    •       Demand-side Management/Energy Efficiency (DSM-EE): Emerging standards.
             –   Standards for Demand Response, SmartGrid, and Energy Efficiency (WEQ-015, 018, 020, 021).

    •       Business Practice (BPS): Owns standard development for areas not covered above.
             –   Takes the lead for standards development not clearly owned by another subcommittee.

    •       Standards Review (SRS): Support for other standard development subcommittees.
             –   Reviews changes to NERC standards in order to assess impact on NAESB WEQ standards.
             –   Reviews proposed WEQ standards for consistency and uniformity.
    •       Other subcommittees are ad-hoc or process-related: Annual Plan, Parliamentary, Triage, FERC Forms, etc.

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                                                                                                          Implementation of
Prior Implementation Complete                                                                             major NAESB items.

    Topic          Sub Description and Status
                                April 2015: Changes to tagging and Curtailment Manager to manage overlapping
eTag 1.8.2         CISS
                                Reliability Limits from different TP’s.
                                May 2015: Enables customers to coordinate transmission requests across multiple
    SAMTS              OS
                                TP’s per FERC Order 676-H.
    Rollover                    May 2015: Grants Rollover Rights to firm Redirects per FERC Order 676-H. Also
                       OS
     Rights                     allows a customer to explicitly waive such rights.
                                March 2017: Implementation of wide-ranging standards for Network Integration
     NITS              OS
                                Transmission Service.
                                Oct 2017: Functional Specification approved to split Market Operator out as a new
eTag 1.8.3         CISS         role, separate from TP and BA. Implemented industry-wide on 10/10/17. eTag
                                1.8.2 retired on 11/07/17.

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