LSE Registration ERCOT Region. By Derrick Davis Texas RE Corporate Counsel

Transcription

1 LSE Registration ERCOT Region By Derrick Davis Texas RE Corporate Counsel

2 Presentation Objectives Provide the history of LSE registration and appeals Direct Energy DOE Portsmouth NERC s request for re-hearing and clarification ERCOT region LSE CFR 2

3 Direct Energy Direct Energy Services, LLC, Sempra Energy Solutions LLC and Strategic Energy, L.L.C. (Direct) retail power marketers sell energy to retail end-use customers within the ReliabilityFirst region NERC refers to registration criteria for LSEs and states that each of these retail marketers has a peak load that exceeds 25 MW 3

4 Direct Energy continued Commission grants the appeals reverses NERC s determinations finds that the registration of the retail marketers as LSEs is not supported by the record or NERC s registry criteria Registration of retail marketers would result in inconsistent practices among Regional Entities The three appellants do not satisfy the threshold because they do not own or operate physical assets that are directly connected to the Bulk- Power System 4 DP/LSE Fall Workshop

5 NERC Compliance Filing (Direct) NERC s compliance filing provided a short- and a long-term plan to address the potential reliability gap Short-Term Plan Update the NERC Statement of Compliance Registry Criteria to state that a distribution provider whose system to which the electric loads in retail choice areas are connected will be registered as the LSE for all loads connected to its system Long-Term Plan 3-year Reliability Standards Development Plan NERC acknowledged the registration concerns unique to ERCOT s market structure committed to quickly resolving the matter joint arrangements working with the Regional Entity to develop other solutions 5

6 United States Department of Energy, Portsmouth/Paducah Project Office (DOE Portsmouth) DOE Portsmouth - NERC compliance registry transmission owner transmission operator distribution provider load serving entity NERC ordered to consider whether DOE Portsmouth was properly registered as a loadserving entity. 6

7 DOE Portsmouth continued DOE Portsmouth owns Portsmouth Gaseous Diffusion Plant near Piketon, Ohio a uranium enrichment plant includes two 345 kv switchyards (X530 and X533) have approximately 2,200 MW of capacity interconnected with the transmission system of the Ohio Valley Electric Cooperative (OVEC). allow power to be directed to load-serving stepdown transformers, to serve the Facility s load of approximately 45 MW, or be redirected to the regional power grid. 7

8 DOE Portsmouth continued Commission cannot determine whether DOE Portsmouth procures energy to serve end-use customers, under NERC s definition of loadserving entity. Commission finds additional information provided by NERC is insufficient to support registration of DOE Portsmouth as a load-serving entity. NERC has not supported its assertion that the lessees and contractors on the site are separate end-use customers served by DOE Portsmouth. 8

9 NERC Request Rehearing/Clarification (DOE) NERC requests that the Commission clarify that it did not intend to preclude registration as an LSE for entities that secure energy and transmission service and ALSO distribute the power that they consume, regardless of compensation. NERC explains that it has not registered OVEC for the LSE function, because DOE Portsmouth meets the criteria for registration as the LSE no significant gap in reliability will result from a delay in registering an entity as the LSE 9 DP/LSE Fall Workshop

10 LSE CFR for ERCOT Region On October 16, 2008 FERC issued an order approving revisions to the NERC Statement of Compliance Registry Criteria, as a short term solution allowed NERC to craft a longer-term solution provided for a DP to be registered as the LSE for the retail load directly connected to its distribution facilities recognized that registering DPs as LSEs in the ERCOT Region created certain problems unique to the ERCOT Region and suggested that joint registration might be necessary 10

11 LSE CFR for ERCOT Region Each entity that agrees to be responsible for any of the LSE standard requirements in the ERCOT Region will sign the Load Serving Entity Coordinated Functional Registration Agreement for the ERCOT Region ( LSE CFR Agreement ), designating whether it is agreeing to be responsible as an Entity A or an Entity B. Entity A: A Transmission Owner or Distribution Provider Entity B: An ERCOT Region Qualified Scheduling Entity (QSE) that provides (a) Load Acting as Resource and/or (b) Emergency Interruptible Load Service in the ERCOT Region with total registered capability of greater than 25 MW. 11

12 Questions? Derrick Davis (512)