Agreed.

 -----Original Message-----
From: 	Ingersoll, Richard  
Sent:	Thursday, July 19, 2001 10:42 PM
To:	Rodriquez, Andy
Cc:	Nicolay, Christi; Baughman, Edward D.; Sturm, Fletcher J.; Steffes, James D.; Presto, Kevin M.; Will, Lloyd; Shapiro, Richard; Scott, Susan
Subject:	RE: A MISO Victory - Wounding of the Source to Sink Beast

Andy,  based  on my interpretation of your memo we are not tracking each other.  I believe we should have the right to sink just as the load control areas do.  This is an absolute must to level the playing field.  They have a huge advantage on any thing going to implementation.  We may need to go back to FERC or even the courts and,in my opinion we should not do any thing to weaken this stance.  If we get something better than ENTERGY take it but do not support it.  Let everyone know that we expect to be treated like any other player including the affiliates, Control Areas, and anyone else in the market place.  This is not the time to support a position that allows for discrimination.  You may want to discuss this in house.  But this is the position I think we should take on most issues as we go into the RTO era.  Sounds unbending but we must get a level playing field.  Now you know why I am not to popular in some meetings and some times with NERC staff.  So be it..




	Andy Rodriquez/ENRON@enronXgate 07/19/2001 06:19 PM 	   To: Richard Ingersoll/HOU/ECT@ECT  cc: Christi L Nicolay/HOU/ECT@ECT, Edward D Baughman/ENRON@enronXgate, Fletcher J Sturm/ENRON@enronXgate, James D Steffes/ENRON@enronXgate, Kevin M Presto/ENRON@enronXgate, Lloyd Will/ENRON@enronXgate, Richard Shapiro/ENRON@enronXgate, Susan Scott/ENRON@enronXgate  Subject: RE: A MISO Victory - Wounding of the Source to Sink Beast	


Dick,

I am assuming you are referring to the "at-least-one" proposal?  I think that is a given that the "at-least-one" proposal is gone.

If you are referring to the alternate proposal "no S2S required, evaluate impacts at time of scheduling," that is essentially going to be the best we can get besides "no analysis and use TLR to solve the problems of over scheduling,"  and there is no way we will get that implemented.

I think based on you statement about FIST (they don't need the schedules until they reach implementation) means we are the same page here, but let me know if that is not correct.

Andy Rodriquez
Regulatory Affairs - Enron Corp.
andy.rodriquez@enron.com
713-345-3771 

 -----Original Message-----
From: 	Ingersoll, Richard  
Sent:	Wednesday, July 18, 2001 7:11 AM
To:	Rodriquez, Andy
Cc:	Nicolay, Christi; Baughman, Edward D.; Sturm, Fletcher J.; Steffes, James; Presto, Kevin M.; Will, Lloyd; Shapiro, Richard; Scott, Susan
Subject:	Re: A MISO Victory - Wounding of the Source to Sink Beast

Andy, this is some what short of the ENTERGY restrictions but still much to restrictive to allow effective parking.  TheFIST program has shown that they do not need these schedules until they reach implementation.  The utilities within the MISOare not showing Source and Sink .  They are using there own systems to hide there true S$S.  I do not think we should support this solution even if we can not get it changed.  It will undermind other efforts to eliminate the advance requirement for source and sink.





	Andy Rodriquez/ENRON@enronXgate 07/13/2001 11:46 AM 	   To: Christi L Nicolay/HOU/ECT@ECT, Lloyd Will/ENRON@enronXgate, Richard Ingersoll/HOU/ECT@ECT, Susan Scott/ENRON@enronXgate, Kevin M Presto/ENRON@enronXgate, Edward D Baughman/ENRON@enronXgate, Fletcher J Sturm/ENRON@enronXgate  cc: James D Steffes/NA/Enron@Enron, Richard Shapiro/NA/Enron@Enron  Subject: A MISO Victory - Wounding of the Source to Sink Beast	



Yesterday, at the Midwest ISO, we successfully managed to quash the MISO's "at least one source-to-sink reservation" proposal.

MISO has been attempting to figure out a way to do security analysis on transmission reservations, and felt that the Entergy Source/Sink policy was too restrictive, but the policy of not requiring source-to-sink at any point was too relaxed.  Their proposal was that "at least one" reservation on a tag/schedule must have the true source-to-sink; otherwise, the tag/schedule would be denied for improper use.

Representatives from CINergy, Duke, Dynegy, ACES, Ameren and LG&E worked with me to fight this concept, arguing that it was effectively identical to the Entergy Source/Sink policy in almost all cases.  After a meeting and two conference calls, in which the MISO ignored our comments and continually pressed for their option, we finally managed to convince them that it was unacceptable.  

The new policy that MISO is planning to operate under is as follows:

	1.) If, at the time a transaction is tagged/scheduled, the MISO reservation specified accurate source and sink, the tag/schedule will be approved.
	2.) If, at the time a transaction is tagged/scheduled, the MISO reservation did NOT specify accurate source and sink, but analysis indicates the transaction can flow without compromising reliability, the tag/schedule will be approved
	3.) If, at the time a transaction is tagged/scheduled, the MISO reservation did NOT specify accurate source and sink, and analysis indicates the transaction cannot flow without compromising reliability (i.e., the transaction will cause or contribute to a constraint), the tag/schedule will be denied

While this is not as unrestrictive as we might want, it allows us a great deal more flexibility that the Entergy Source/Sink barrier while at the same time allaying the MISO's reliability concerns.  Effectively, this allows us to redirect both firm and non-firm at the time of tagging/scheduling without a loss in transmission priority.  Not only will this give us more flexibility within MISO, but the MISO intends to sell it to the Alliance as well under the IRCA.  

This also can give us a cornerstone in proving to the FERC that the Entergy S/S policy is not required for reliability, as other entities are able to meet reliability goals without the stifling limits Entergy claims are necessary.

As an aside, we are also pressing the MISO for a Redirection policy that will allow for "partial" redirects of service on a short term basis (the Separate proposal referenced in the attached document).  This will allow us to accomplish the same goals as the new MISO policy, but reduce the availability risk by allowing us to redirect prior to the time the transaction is tagged/scheduled.  These two proposals, when combined, will allow us for much more flexible uses of transmission without ignoring the reliability mantra providers chant whenever we ask for innovation and change. 

A detailed write-up of the work accomplished is attached.  Proposal 4, Discussion item "Confusing POR/POD Naming," Discussion Item "MISO Proposal  ...time of scheduling," and the Resolutions should be of primary interest to those wishing to see more detail on the directions MISO is heading.

Andy Rodriquez
Regulatory Affairs - Enron Corp.
andy.rodriquez@enron.com
713-345-3771 
 << File: MISO PPRSG ReviewV4-FINAL.doc >>