TVA and Entergy respond to S&S protests

TVA and Entergy filed answers to the numerous protests to Entergy's source
and sink filing.

TVA responded specifically to Enron and VEPCO's filings basically stating
that the NERC letter was limited to the TVA/Enron dispute and inapplicable to
the Entergy issue. TVA also made accusations that Enron in effect secretly
talked with NERC to get a task force made up of members "predisposed to
Enron's point of view." TVA said that the task force ignored TVA's requests
to meet with it and that the task force went beyond current NERC policy.
Finally, TVA understands that "Enron has prevented SERC" from bringing the
matter to NERC ADR.

Entergy's answer largely cites past FERC orders that approved the source and
sink on tags (and denied Enron's Capacity Reservation Tariff) and basically
states that the protests are a collateral attack on Order No. 888 (as we have
known, the OATT does require ultimate source and sink on firm and allows them
on non-firm). Entergy's filing, however, is lacking in substantive reasons
why reliability would be so much better served by requiring this at the
reservation level, when NERC has stated it is not necessary for reliability
until the 20/30 minute ahead tag. Entergy says it can do a better job of
listing actual ATCs and will prevent Entergy from overselling its system
(although since Entergy's ATCs are usually low or 0 coming in over the ties,
I question how many times Entergy has oversold Firm transmission.) Entergy
also states that it and the Security Coordinators can police the IDC tags, in
case the marketer puts the wrong priority information on the tag (how often
does this happen?). [[I also don't know how Entergy is going to have time to
check all this, when we called FERC hotline on them last year for lack of
timely responses to reservation and tags]]. Although the IDC does not even
analyze specific bus bars (and generator source and sink are optional on the
tags now), Entergy says this is "irrelevant", but TLRs will be improved.

Entergy cites FERC's 1998 OASIS orders that "EPSA has not made a compelling
argument that disclosure would harm liquidity." I think that the compelling
arguments are being made now about the discrimination. Although FERC
approved the source and sink, transmission providers have not been using them
and the tags don't require them.

Entergy notes that when FERC issued the OASIS order, specific bus bar
information was required on the tag -- now it is optional on the tag. Even
so, Entergy states that requiring it on the reservation does not make it
inconsistent with the tag. (I disagree.)

Finally, Entergy says that we can always put in "anticipated" source and
sink, but if it changes, our priority may change. It is my understanding
that even the smallest change in source and sink will make some change in the
power flows, so you effectively would always go to the lowest priority.

We are considering filing a response that states the lack of evidence on the
reliability issues when NERC doesn't think this is required is a material
issue of fact that should be set for hearing, at least.