Entergy Comments on MC10032
Entergy Comments on MC10032
Minor Correction Request
Definition of ON-PEAK and OFF-PEAK
WEQ 2010 AP Item 1.a.i – Interim Solution for Parallel Flow Visualization
August 27, 2010
Ed Davis
September 8, 2010
Entergy is concerned that the definitions of On-Peak and Off-Peak contained in this Minor Correction could be considered somewhat vague and ripe for misinterpretation. The concept of On-Peak and Off-Peak has to do with the hours of the day, week and year. The Minor Correction does not seem to encompass the concept of hours of the day. The following is a short review of the industry understanding of the two terms, our understanding of what is being proposed in the Minor Correction, and our suggested definition of the two terms.
Historically and in general, On-Peak hours have been generally hour ending 0700 through hour ending 2200. All other hours of the week are defined as Off-Peak. Additionally, the hours of the day of six holidays have been defined as Off-Peak with the provision that if these holidays fall on a Saturday or Sunday then all the hours of the day of the following Monday will be considered Off-Peak (an Off-Peak day). These concepts and details are included in the NAESB standards, WEQ-007 Appendix A.
Note the current NERC definitions for these two terms are hours or periods:
Off-Peak / Those hours or other periods defined by NAESB business practices, contract, agreements, or guides as periods of lower electrical demand.On-Peak / Those hours or other periods defined by NAESB business practices, contract, agreements, or guides as periods of higher electrical demand.
Unfortunately, the definitions of On-Peak and Off-Peak contained in the Minor Correction could be interpreted to have the meaning of “Inadvertent Interchange payback”. The definitions contained in the Minor Correction are:
Off-Peak - Shall have the meanings for Inadvertent Interchange payback as defined in Business Practice Standards WEQ-007-A.
On-Peak - Shall have the meanings for Inadvertent Interchange payback as defined in Business Practice Standards WEQ-007-A.
In order to clarify the definitions we suggest these definitions be changed to the following:
Off-Peak- Shall have the meanings of Off-Peak hours included in Business Practice Standards WEQ-007-A Appendix A - Inadvertent Interchange On- and Off-Peak Periods.
On-Peak- Shall have the meanings of On-Peak hours included in Business Practice Standards WEQ-007-A Appendix A - Inadvertent Interchange On- and Off-Peak Periods.
Please modify the Minor Correction request and consideration of these definitions to allow for consideration of Entergy’s comments in the review and approval process by the Executive Committee.
Thank you.
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