Gas Capacity Rights. The New York PSC told retail suppliers that to serve firm retail gas load they must have rights to firm, non-recallable, primary delivery point pipeline...
"solution" is a "best efforts" voluntary unaudited frequency control regime that unnecessarily overrides and is much costlier than and mathematically inconsistent1 with NERC's control performance standard CPS1, and this has already led one complaining Western BA to be granted occasional exemption. It still leaves opportunity for unfair financial gain from unpriced unscheduled power.
Furthermore, the NERC Resources Subcommittee is in the process of confirming whether correcting time-error is an obsolete service in the contemporary world of DC digital clocks. It's become just unfeasible in the Eastern Interconnection2 where it used to be done only monthly, then became weekly, and now has to be done daily by NERC, soon becoming the proverbial boy without enough fingers to plug the holes in the dyke fast enough.
Meanwhile, the indiscriminate FERC energy-imbalance tariff on BAs' constituents worsens frequency performance. The NERC JIITF white paper  does not prescribe pricing for the energy part of inadvertent interchange, other than to specify including a "transmission loading (congestion) component." But it does reject the old FERC Order No. 888/889 Schedule 4 & 5 "energy imbalance" tariffs for prescribing a single percentage penalty on the energy price both to the provider and to the taker of all "imbalance energy" regardless of whether the "imbalance energy" helps or hurts frequency. The JIITF rejected the FERC tariffs also for applying only outside a megawatt deadband where clearing is often mathematically impossible, or outside a frequency deadband that contains practically all the inadvertent that continues to accumulate or be paid back in kind inequitably and unreliably and to fuel the upward-frequency-drift crisis.
A WECC representative reported to me that the indiscriminate penalty of the FERC energy imbalance tariffs has been prompting generators in the Western Interconnection to disable the governors on their units, thereby actually exacerbating the West's governor response deterioration and the high cost to BAs of complying with auto time-error correction. One big Eastern BA formally has asked NERC for relief from high control costs due to the ineffectiveness of the FERC energy imbalance tariff on the behavior of its constituent generators.
- See end of endnote 9 above
- See end of endnote 1 above
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