Parallel Flow Visualization and

Flowgate Allocations

Parallel Flow Visualization and

Flowgate Allocations

Equity Concerns of

Non-Market

Transmission Owners

Equity Concerns of

Non-Market

Transmission Owners

Parallel Flow Visualization – For reliability

Parallel Flow Visualization – For reliability

• Objectives– Meet needs of Reliability Coordinator, RC– Observe impacts on congested flowgates– Provide IDC with current information– Increase accuracy of Gen to Load impacts

(timely updates)– Observe magnitude and source of all impacts

• Objectives– Meet needs of Reliability Coordinator, RC– Observe impacts on congested flowgates– Provide IDC with current information– Increase accuracy of Gen to Load impacts

(timely updates)– Observe magnitude and source of all impacts

Parallel Flow Visualization – Non-Market priorities

Parallel Flow Visualization – Non-Market priorities

• Objectives– Accurately prioritize certain non-market GtL

flows in real time that today may be inappropriately treated as firm, due to shortcomings in the IDC (e.g. Non-designated network resources)

• Objectives– Accurately prioritize certain non-market GtL

flows in real time that today may be inappropriately treated as firm, due to shortcomings in the IDC (e.g. Non-designated network resources)

Parallel Flow Visualization – Centralized calculationsParallel Flow Visualization – Centralized calculations

• Objectives– Perform impact calculation at a central location

for both the market flows as well as the non-market GtL flows

– Presently, the non-market BA GtL impact calculation is performed at a central location (IDC), whereas the market flow impact on flowgates is calculated by each market entity, then uploaded to the IDC.

• Objectives– Perform impact calculation at a central location

for both the market flows as well as the non-market GtL flows

– Presently, the non-market BA GtL impact calculation is performed at a central location (IDC), whereas the market flow impact on flowgates is calculated by each market entity, then uploaded to the IDC.

Parallel Flow Visualization - Equity Concerns

Parallel Flow Visualization - Equity Concerns

• This desire to have a centralized calculation seems to have been interpreted by some as a REQUIREMENT that the impact calculation and prioritization for the market flow and the non-market GtL flow must be the SAME.

• This has significant equity implications, and NAESB should consider this change carefully.

• This desire to have a centralized calculation seems to have been interpreted by some as a REQUIREMENT that the impact calculation and prioritization for the market flow and the non-market GtL flow must be the SAME.

• This has significant equity implications, and NAESB should consider this change carefully.

Concept being proposedConcept being proposed

• DNR designation is being proposed as the basis for determination of firm usage.

• Under this concept, what is designated as firm usage by the non-market BAs doesn’t conceptually change. Therefore, may be reasonable for non-market BAs.

• This would be a significant change from what is presently being done for prioritization of market flow. Is the DNR designation an equitable basis of firm usage for the market?

• DNR designation is being proposed as the basis for determination of firm usage.

• Under this concept, what is designated as firm usage by the non-market BAs doesn’t conceptually change. Therefore, may be reasonable for non-market BAs.

• This would be a significant change from what is presently being done for prioritization of market flow. Is the DNR designation an equitable basis of firm usage for the market?

How we got to where we are today..

(our view of history, and why it is relevant)

How we got to where we are today..

(our view of history, and why it is relevant)

• Section 28.3 Language obligates the Transmission Provider to;

…provide Firm Transmission Service over the Transmission System to the Network Customer for the delivery of Capacity and Energy from its designated Network Resources to service its Network Loads…[emphasis added]

• Section 28.3 Language obligates the Transmission Provider to;

…provide Firm Transmission Service over the Transmission System to the Network Customer for the delivery of Capacity and Energy from its designated Network Resources to service its Network Loads…[emphasis added]

Network Integration Transmission Service

(NITS)

Network Integration Transmission Service

(NITS)

Example: Historical “Tariff” Area

Example: Historical “Tariff” Area

Network Load

NetworkResource

Section 28.3 (NITS)Firm Transmission

RTO / Market AreasRTO / Market Areas

Historic Control (Tariff) Areas

Historic Control (Tariff) Areas

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Example: Historical “Tariff” Area

Example: Historical “Tariff” Area

Network Load

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Section 28.3 (NITS)Firm Transmission

RTO / Market AreasRTO / Market Areas

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RTO / Market AreasRTO / Market Areas

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• Historically, the system was not planned nor built for firm deliveries between historic Control Areas

• Historically, the system was not planned nor built for firm deliveries between historic Control Areas

RTO / Market AreasRTO / Market Areas

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CONSTRAINTS..!!If System Constra

ints -

Can all of th

is market

dispatch from DNRs be

firm?

RTO/Market AreasRTO/Market Areas

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Constraints – Internal & External

Issue not just internal to the market

footprint

Issue not just internal to the market

footprint

Market Start-upMarket Start-up

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Constraints – Internal & External• Central dispatch across the entire

market footprint (internal to and across historic CAs) without tagging.

• There wasn’t enough firm transmission to justify that “all market generation” was firm to “all market load”. (For example, generation in Indiana couldn’t service XCEL loads in Minnesota due to constraints)

• Central dispatch across the entire market footprint (internal to and across historic CAs) without tagging.

• There wasn’t enough firm transmission to justify that “all market generation” was firm to “all market load”. (For example, generation in Indiana couldn’t service XCEL loads in Minnesota due to constraints)

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CONSTRAINTS..!!

Constraints – Internal & External• It was recognized that the non-markets

would be adversely and in-equitably impacted if markets didn’t constrain the centralized dispatch

• Some approach was needed to properly set the priority of the broader market footprint dispatch, while recognizing the transmission rights within the market

• It was recognized that the non-markets would be adversely and in-equitably impacted if markets didn’t constrain the centralized dispatch

• Some approach was needed to properly set the priority of the broader market footprint dispatch, while recognizing the transmission rights within the market

Equitable Prioritization – On Market Start-up??

Equitable Prioritization – On Market Start-up??

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CONSTRAINTS..!!

Constraints – Internal & External• The “Markets” documented firm rights

on the system based on:• Firm GtL delivery internal to historic CAs• Existing historic Firm PtP between historic

CAs.

• An “Allocation” process was developed based on these historic firm rights to define limits for a firm centralized market dispatch

• The “Markets” documented firm rights on the system based on:• Firm GtL delivery internal to historic CAs• Existing historic Firm PtP between historic

CAs.

• An “Allocation” process was developed based on these historic firm rights to define limits for a firm centralized market dispatch

Allocation Process Allocation Process

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CONSTRAINTS..!!

Constraints – Internal & External• Markets were allowed to dispatch centrally

(without tagging between historic CAs), but the market flow impact on flowgates was prioritized based on the historic firm usage

• The allocation process divides the market flow on a flowgate into three priorities (Firm-7, ED-6/NN-6, and ED-2/NH-2)

• Updating allocations for system changes/additions is necessary

• Markets were allowed to dispatch centrally (without tagging between historic CAs), but the market flow impact on flowgates was prioritized based on the historic firm usage

• The allocation process divides the market flow on a flowgate into three priorities (Firm-7, ED-6/NN-6, and ED-2/NH-2)

• Updating allocations for system changes/additions is necessary

Allocation Process (cont.)Allocation Process (cont.)

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CONSTRAINTS..!!

Constraints – Internal & External• MISO has consolidated historic

CAs/BAs into one BA• No significant transmission additions

have occurred to span the historic CAs• The non-markets believe that there is

still NOT sufficient firm transmission available for any market gen to be delivered to any market load

• MISO has consolidated historic CAs/BAs into one BA

• No significant transmission additions have occurred to span the historic CAs

• The non-markets believe that there is still NOT sufficient firm transmission available for any market gen to be delivered to any market load

Since then ..Since then ..

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CONSTRAINTS..!!

Constraints – Internal & External• The need for “Allocations” has not been eliminated

• The “desire to have the same GtL calculation” and “complexity in updating the allocations” are not sufficient justification to disregard the recognition that there was and still is limited firm transmission to transfer between the historic market CAs

• Use of DNR status only doesn’t properly reflect delivery capability across a broad market

• The need for “Allocations” has not been eliminated

• The “desire to have the same GtL calculation” and “complexity in updating the allocations” are not sufficient justification to disregard the recognition that there was and still is limited firm transmission to transfer between the historic market CAs

• Use of DNR status only doesn’t properly reflect delivery capability across a broad market

Since then .. (cont.)Since then .. (cont.)

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CONSTRAINTS..!!

Constraints – Internal & External• Before the “DNR designation” be allowed as the basis of firm usage of the market, the market needs to demonstrate to NAESB that they have sufficient firm transmission to deliver from their market gen to their market load across their entire footprint on a comparable basis to the non-markets.– This wasn’t the case on market start-up– What has changed that would allow this use of

footprint-wide DNR designation in markets?• There is a Significant equity issue on all market

impacted flowgates, if market flow is prioritized as firm solely based upon DNR status, if firm transmission really doesn’t exist.

• Before the “DNR designation” be allowed as the basis of firm usage of the market, the market needs to demonstrate to NAESB that they have sufficient firm transmission to deliver from their market gen to their market load across their entire footprint on a comparable basis to the non-markets.– This wasn’t the case on market start-up– What has changed that would allow this use of

footprint-wide DNR designation in markets?• There is a Significant equity issue on all market

impacted flowgates, if market flow is prioritized as firm solely based upon DNR status, if firm transmission really doesn’t exist.

NAESB / Need to ensure Equity

NAESB / Need to ensure Equity

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CONSTRAINTS..!!

Constraints – Internal & External• Assuming the allocations are maintained, MISO has argued that the non-market GtL flow should be prioritized based on allocations during congestion, just like the market flow… However;– For the non-market, transmission service

priority (for GtL and PtP) is set based on the service that has been demonstrated and granted. Priority should be based upon that TP designation.

– For the non-market, the allocations are considered during the granting of such firm service.

• Assuming the allocations are maintained, MISO has argued that the non-market GtL flow should be prioritized based on allocations during congestion, just like the market flow… However;– For the non-market, transmission service

priority (for GtL and PtP) is set based on the service that has been demonstrated and granted. Priority should be based upon that TP designation.

– For the non-market, the allocations are considered during the granting of such firm service.

Allocations – Impact to non-markets

Allocations – Impact to non-markets

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CONSTRAINTS..!!

Constraints – Internal & ExternalAlso; other equity concerns..– Markets have documented to NERC that they do

not currently achieve their assigned curtailment obligations – that transfers the impact to the non-market uses (equity concern as well as reliability)

– The non-markets are required to meet their curtailment obligations, or they are found non-compliant. The non-markets cannot avoid a curtailment due to it being too large.

– Non-markets have not disagreed that non-firm resources should be prioritized as non-firm during congestion, and presumed that those uses of the system will be prioritized correctly during congestion based upon IDC improvements.

Also; other equity concerns..– Markets have documented to NERC that they do

not currently achieve their assigned curtailment obligations – that transfers the impact to the non-market uses (equity concern as well as reliability)

– The non-markets are required to meet their curtailment obligations, or they are found non-compliant. The non-markets cannot avoid a curtailment due to it being too large.

– Non-markets have not disagreed that non-firm resources should be prioritized as non-firm during congestion, and presumed that those uses of the system will be prioritized correctly during congestion based upon IDC improvements.

Allocations – Impact to non-markets

Allocations – Impact to non-markets

Non-market requests to NAESB

Non-market requests to NAESB

• NAESB ensure that any change to the prioritization of the market flow consider whether it is equitable to both market/non-market to make such change.– Use of DNRs in the market to set market flow priority

would adversely and in-equitably impact the non-markets.

• NAESB not recommend or endorse elimination of allocations to set the market flow priorities until such time as the markets have clearly demonstrated that allocations are no longer needed.

• NAESB consider the parallel operation/test mode (existing IDC versus Parallel Visualization effort) before implementing changes that impact equity

• NAESB ensure that any change to the prioritization of the market flow consider whether it is equitable to both market/non-market to make such change.– Use of DNRs in the market to set market flow priority

would adversely and in-equitably impact the non-markets.

• NAESB not recommend or endorse elimination of allocations to set the market flow priorities until such time as the markets have clearly demonstrated that allocations are no longer needed.

• NAESB consider the parallel operation/test mode (existing IDC versus Parallel Visualization effort) before implementing changes that impact equity