MOD Standards Experiences. David Lemmons EthosEnergy Group

Transcription

1 MOD Standards Experiences David Lemmons EthosEnergy Group

2 EthosEnergy Group Overview Ethos operates approximately 40 BES plants across 6 of the 7 NERC regions. Ethos provides NERC services to approximately 35 BES plants Plants are located in ERCOT, ISO-NE, NYISO, PJM, and SPP markets as well as outside centrally dispatched markets Soon to be in CAISO EIM footprint

3 MOD-025 Experiences Transmission Planners, Market Operators and Generators do not seem to be on the same page when it comes to testing Is the purpose to test the generator s capability or something else? Different entities treat the data submittal differently Some entities never respond, some entities acknowledge the submittal but provide no feedback, some provide feedback GO Information provided may never be used but must be supplied for compliance Significant confusion around MOD-025 testing and Real/Reactive Power testing for market purposes Unless the market test provides every data point required in MOD-025 Attachment 1, a market test does not adequately address MOD-025 for compliance purposes.

4 MOD-026 and MOD-027 Experiences Not Recommended does NOT mean Not Acceptable Grandfathered for existing models. May not be used for any new facility submitted? Does this mean a plant built in 2000 can continue to use it? Or does this mean it needs updated in the MOD process? TP list of acceptable models is actually a reference to NERC list with two other documents discussing what is or is not acceptable Each TP seems to have different requirements for what documentation and data means to them Example: some want a dyr file, some do not TP response addresses Market Rules and not MOD-026/027 requirements Example: Generator test provides governor model but states OLC does not allow governor to respond. TP only tells generator that this is a violation of market rules. TP has not met its requirements under MOD-027 R5

5 MOD-032 Process Experience Centralized Market processes tend to be much more complicated and harder to interpret/follow than others. In some areas, GO entity cannot get to model data because GO is not the registered market entity Lack of Coordination seems to occur when multiple parties are registered as TP in single PC footprint. As much an issue with the standard as anything else R1 Jointly develop reporting requirements and procedures R2 Provide data per the procedures PC procedure tells GO to provide information to it and TP if TP wants it, TP does not have procedure so do they want it? M2 says show that data was provided to TP and PC, which does not match R2 language

6 MOD-032 Bad Experiences Inconsistency across different PCs/TPs At least one entity requesting data quarterly with multiple follow-ups to all entities that provide information Process to get data is flawed Use lists for multiple purposes instead of data issues only 71 s in 75 days; two related to MOD-032 data Requests for data not being sent to significant number of entities with obligation List of responsible entities missing contact information for 50 entities PC asks GO to work through TO to provide data, but the procedure is not written such that this will meet the requirement to provide the data Not to mention M2! Change of generator ownership/name causes confusion at the TP

7 MOD-032 Good Experiences Plant provides data to registered merchant and it is uploaded through market portal, not even knowing it was MOD-032 related Granted, this caused some concern until the process was understood TP/PC asks plant to confirm the attached information is correct and has not changed Compared to being asked to confirm nothing has changed without being shown what is there

8 MOD Audit Experience - Ongoing MOD-026 and MOD-027 Auditors asking for data pertaining to each sub-bullet under 2.1 be highlighted and annotated in the report provided to TP as proof that all required data is provided MOD-032 Asking for the data provided, regardless of when it was provided, not just confirmation MOD-032 Asking for any follow-up requests from TP or if submittals were approved by TP (evidence provided shows approved date) MOD-032 Asking for attestation from TP stating that GO followed process and procedure. MOD-032 Asking for proof that new units data has been provided New units did not go commercial until after data submittal deadline. Does that make it GO or RP responsibility?

9 Recommendations Market Operators should review the tests required of generators to see if these can be streamlined To reduce confusion, PPMVTF needs to review the model list and remove the category Not Recommended and have only Acceptable or Not Acceptable TP/PCs also need to review their lists for clarity and simplicity Revise the MOD suite of standards related to GO/TP/PC to reduce the duplication, extraneous data and confusion There is a good deal of compliance failure related to MOD standards. Most of these errors appear to be a documentation issue and not a reliability issue TPs, PCs, Market Operators and Generators need to sit down and structure what is needed and how to efficiently get that information

10 Questions?