UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) ) )

Transcription

1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Electric Quarterly Reports Docket No. RM Docket No. ER COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY ON THE DRAFT ELECTRIC QUARTERLY REPORTS DATA DICTIONARY Pursuant to the Notices of Electric Quarterly Reports Users Groups Meeting issued November 8, 2006 and November 20, 2006 and the request for Comments by Commission Staff at the November 29, 2006 User Group meeting, Southern California Edison Company ( SCE hereby submits its comments on the Staff Draft of the Data Dictionary. SCE appreciates the opportunity to comment, and is committed to working with Staff and other stakeholders to ensure that filing parties have the guidance necessary to submit accurate Electronic Quarterly Reports ( EQR based on the Data Dictionary definitions. I. COMMENTS A. SCE Supports EEI s Comments SCE has worked with Edison Electric Institute ( EEI and its member companies to review and comment on the Commission s draft Data Dictionary. SCE supports the suggested modifications and clarifications proposed by EEI, and urges the Commission to adopt those revisions. In addition, SCE has a concern not addressed by EEI, which is discussed below

2 B. The Time Zone Field Should Be Modified The proposed Data Dictionary proposes to define Field No. 55, Time Zone, as the time zone in which the sales will be made under the contract. SCE does not object to this definition. However, it appears from discussions at the November 29 th Users Group Meeting 1 that Staff may be proposing to require that Field Nos ( Transaction Begin Date and Transaction End Date also reflect the clock time and Time Zone (Field No. 55 for the control area controlling the point of delivery where the transactions occurred. This interpretation would fundamentally alter the nature of the transaction records which record energy trades/ schedules taking place from West to East across time zones. Thus, for example, the time for any Energy sold in Hour Ending ( HE 1, which is sourced from the Pacific Time Zone and delivered to the Mountain Time Zone, must be converted from HE 1 to HE 2; HE 2 transactions must be converted to HE 3, and so on. 2 To further complicate the issue, transactions in HE 24 would be pushed into HE 1 of the following day. This conversion would be a custom process, solely for the purpose of EQR filing. Moreover, this process would skew the pricing in the shoulder hours. For example, the last hour of Off-Peak in California will be translated to On-Peak in the Mountain Time Zone (except Arizona during Daylight Savings Time; the same problem occurs in reverse in the last hour of On-Peak in California, which becomes Off-Peak in the Mountain Time Zone. To illustrate: An Off Peak energy sale of 100 MW at $15/MWhr for hour 6 would become 100 MW "On Peak" for hour 7 at the point of delivery. After the shoulder hour the price would go up to the real On Peak value of $38 until the On Peak hour 22 which would become an Off Peak 1 Transcript of November 29, 2006 Users Group Meeting, at 140:18-141:3; 148: This is a substantial issue for SCE, which sells Energy from its share of Palo Verde generating facility into the Arizona market. Unlike the majority of the Mountain Time Zone, Arizona does not observe Daylight Savings Time, and therefore, when the Pacific Time Zone is observing Daylight Savings Time, the clock time in California and Arizona are the same, while the clock time in the rest of the Mountain Time Zone is one hour ahead of California. When the Pacific Time Zone is not observing DST, the clock time in Arizona (and all of the Mountain Time Zone is one hour ahead of California

3 Hour 23 with an abnormal price of $38, and then hour 24 of that specific trade day would be moved into Hour 1 of the next day. 3 Before making a change of this nature to the EQR filer s requirements, the Commission should study how their interpretation of the Date-Time Fields will alter the basic nature of the transaction data, and ensure it will not adversely affect its own internal reporting or analysis. The example presented above merely cites SCE s specific issues reporting trading across one Time Zone. Other filers may be trading across several time zones from generating source to load sink. It would also be prudent for the Commission to provide more accurate guidance regarding Date-Time Fields within the final data dictionary to ensure all EQR filing entities have a uniform understanding of what the Commission wants those fields to signify. Therefore, SCE urges the Commission to clarify that the time zone must be indicated only in Field No. 55, which causes no operational problems, and clarify that the Transaction Begin Date and Transaction End Date need not reflect the clock time of the time zone where the Energy was delivered. II. CONCLUSION For all the foregoing reasons, SCE respectfully requests that the Commission adopt the modifications and clarifications to the EQR Data Dictionary proposed by EEI. SCE further requests that the Commission not require that Field Nos reflect the clock time of the Time Zone where the Energy was delivered in each transaction. 3 As a further example, SCE sells at Mead, which is located in Nevada. Nevada is on Pacific Time. However, Mead is in the WALC control area, which is on Mountain Time. It is unclear how a sale at Mead would be handled. Furthermore, SCE sells at Four Corners, located in New Mexico. New Mexico is on Mountain Standard Time ( MST. Unlike Arizona, New Mexico observes Daylight Savings Time ( DST. The Control Area for Four Corners is Arizona Public Service ( AZPS, which stays on MST, like Arizona. It is unclear how SCE should handle a sale at Four Corners during DST, the time and time zone at the physical point of delivery, or the time of the control area doing the scheduling

4 Respectfully submitted, ERIN K. MOORE By: /s/ Erin K. Moore Attorney for SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California Telephone: ( Facsimile: ( Dated: January 12,

5 CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing COMMENTS OF SOUTHERN CALIFORNIA EDISON COMPANY ON THE DRAFT ELECTRIC QUARTERLY REPORTS DATA DICTIONARY upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated at Rosemead, California, this 12th day of January, /s/ Case Analyst SOUTHERN CALIFORNIA EDISON COMPANY 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770