Comments on December 21, 2022 stakeholder call discussion

1. Please provide a summary of your organization’s comments on the December 21, 2022, stakeholder call discussion:

LineVision appreciates the recent December 21, 2022 stakeholder call, which was useful and informative.  LineVision supports the notion that many aspects of 881 implementation will benefit from the input and expertise of stakeholders across the industry. We encourage CAISO to create a stakeholder working group, which should operate with as much stakeholder input as possible.

2. Provide your organization’s comments on proposed project track 1: Real Time Reliability Applications:

LineVision encourages TOs to work with existing DLR  solutions providers on the process of creating AARs rather than creating customized in-house software. Furthermore, DLR can also be received/implemented in the same manner as AAR, whereas DLR has the ability to create more capacity on the transmission grid.

3. Provide your organization’s comments on the proposed project track 2: Operational/EMS Model Data and Applications:

No comment

4. Provide your organization’s comments on the proposed project track 3: Market Applications and Look Ahead Applications:

LineVision suggests that the collection of the baseline (Static or Seasonal) ratings should be included as part of an effort to substantiate the net improvement or changes associated with implementation of Order 881.  In addition, collection of the submitted ratings should include methodology options (e.g. AAR, DLR or other).  This ongoing comparison of ratings and methodology options used can help support deeper analysis of the effects of congestion on the system and respective markets.

5. Provide your organization’s comments on how and when the ISO can best coordinate with participating transmission owners to ensure consistency in development of transmission line rating methodologies:

LineVision suggests a monthly, or at minimum, quarterly report detailing the overall impact of the FERC-881 requirement.  From a methodology perspective, a deeper understanding of the weather forecasting model used for each line will also be critical in understanding the overall effectiveness of the calculation.

In addition to coordinating with TOs, LineVision also encourages CAISO to reach out to industry stakeholders like DLR solution providers to better understand particular nuances associated with AARs and how to most safely calculate the rating.

6. Provide your organization’s comments on how the forecasted ambient adjusted ratings should be calculated. Please provide examples.

LineVision recommends using conservative assumptions to reduce the possibility of overestimation of line ratings. This should involve utilizing the CIGRE recommended fixed values for windspeed assumptions that vary during daytime and overnight hours, localized weather data for ambient temperatures, and localized time of day values for solar heating gain.

7. Provide your organization’s comments on the proposed draft project timeline discussed on slide 12:

No comment

8. Provide your organization’s comments on how frequently the ISO should hold public calls to provide progress updates on the implementation of FERC Order 881:

LineVision suggests hosting a quarterly update call, which can be combined with the stakeholder working group, to optimize the process for sharing updates and allowing stakeholders the opportunity to ask questions related to ongoing implementation efforts and recent updates.

9. Provide any additional comments on the December 21, 2022 stakeholder call discussion, or any comments/questions you would like addressed during an upcoming stakeholder call:

No comment

1. Please provide a summary of your organization’s comments on the December 21, 2022, stakeholder call discussion:

SCE appreciates the opportunity to provide comments and feedback on Phase 2 of the FERC Order 881 Development update. While we have some concerns about the existing timelines and progress required to meet the July 2025 go-live date, we appreciate the complexity of the order and look forward to receiving more information via the upcoming project timeline, as well as supporting in development efforts where possible.  

2. Provide your organization’s comments on proposed project track 1: Real Time Reliability Applications:

SCE looks forward to receiving both updates within the upcoming implementation timeline and the whitepaper. 

3. Provide your organization’s comments on the proposed project track 2: Operational/EMS Model Data and Applications:

SCE looks forward to receiving more detailed methodologies via the upcoming white papers and process drawings.?However, SCE has current concerns on existing ICCP limitations regarding whether future requirements are compatible with the current systems. 

4. Provide your organization’s comments on the proposed project track 3: Market Applications and Look Ahead Applications:

SCE looks forward to receiving more information and updates on the requirements needed. 

5. Provide your organization’s comments on how and when the ISO can best coordinate with participating transmission owners to ensure consistency in development of transmission line rating methodologies:

With the upcoming release of additional scope information and continued development of business requirements through Q3, SCE would appreciate monthly updates on content development. In addition, SCE advocates for continued transparency of methodologies between utilities for effective collaboration. 

6. Provide your organization’s comments on how the forecasted ambient adjusted ratings should be calculated. Please provide examples.

SCE is in the initial stages of development of ambient adjusted ratings on transmission lines utilizing a methodology comprised of lookup tables for various IEEE 738 calculations based on input weather and cable specifications. This table data is spatially assigned to weather exposure data via online sources and available SCE weather stations. The current vision is to have these calculated and produced within a database structure for all forecasted ratings utilizing the existing Transmission Registry as a framework. 

However, SCE is not yet in a position to comment on recommended methodologies. We are currently in the process of evaluating calculation impacts of underlying assumptions, operational boundary conditions, equipment rating methodology, and the EMS system needs to tie these calculations and processed data to operational processes. 

7. Provide your organization’s comments on the proposed draft project timeline discussed on slide 12:

SCE looks forward to receiving a more detailed project timeline in January or February. As it stands, SCE has concerns with the existing timeline, especially regarding the scope definition required for the EMS development schedule compared to the current July 2025 go-live date. Historically, IT plant typically requires 18-24 months to internally develop and test for critical operational systems. 

8. Provide your organization’s comments on how frequently the ISO should hold public calls to provide progress updates on the implementation of FERC Order 881:

SCE would appreciate the opportunity for a minimum of monthly calls with the upcoming speed of development needed for Track 1 data submission and testing. 

9. Provide any additional comments on the December 21, 2022 stakeholder call discussion, or any comments/questions you would like addressed during an upcoming stakeholder call:

SCE has existing concerns about implementation timelines with the EMS development time required once clear scope is established.