To recommend approval of NPRR267 as revised by PRS
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This Nodal Protocol Revision Request (NPRR) removes references to pseudo devices from the Nodal Protocols.
The Nodal Protocols only allow Transmission Service Providers (TSPs) to submit Network Operations Model Change Requests (NOMCRs) for pseudo equipment.
The AEP corporate philosophy is safety first, compliance second and everything else follows. The introduction of pseudo equipment is a safety concern that we are uncomfortable with. The management of fake equipment can cause confusion on the part of our dispatchers resulting in safety concerns for our employees, contractors and general public especially during times of major system disturbances.
The Nodal Protocols also require TSP’s to model that same pseudo equipment in their systems and provide telemetry to ERCOT. AEP does not want to add pseudo equipment to their operations models as this can create safety issues with field personnel and also create confusion by dispatching staff, especially during storms or major weather events.
There is also a concern that although the use of pseudo equipment is not required that a TSP may not be able to energize equipment if ERCOT determines that pseudo equipment is needed for model transition. This NPRR will remove the use of pseudo equipment in the Nodal Protocols.