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Subject: Comments on Energy Interoperation Version 1.0 26/11/10

This is a well prepared document with definitions, narrative discussions and, logical interactions and UML models.   However, I have the following comments:


1.       Figure 1-1: Representative Communications for Energy Interoperations, is missing the distribution (and perhaps transmission) utility.  Consumers can directly interact with Generators only in regions that have Direct Retail Access (e.g., Texas), in other regions consumers but energy from their electric utility under a retail tariff.  ESPs/DRPs are typically in a DR aggregation business, only.  

Perhaps, Figure 1-1 should  be updated with inclusion of a cloud representing T&D Utility, as retail consumers are typically severed by a distribution utility.

2.       The EI specification places a strong emphasis on a Transactive Energy model with a (retail) market-based dynamic tariff.  This is a new emerging concept, and is not generally adopted by the PUCs/Utilities.   

It will be helpful if a clear distinctions between the tariff for energy consumption and the tariff for DR/distributed generation is made.   The Transactive model could well suite DR based products, e.g., feeder load relief, ancillary services, etc.  but it may be difficult to generalize it for basic energy consumption.


3.       Most of the discussions in the document imply that there is no distribution grid delivery constraints (i.e., no distribution congestion).  With unbalanced nature of the distribution grid in the North America, and with emergence of distributed generation and plug-in Electric Vehicles (PEV), the grid reliability will be playing an  important role in establishing pricing signals..  Similar to the wholesale markets that transmission congestion led to the concept of locational pricing (LMPs), distribution congestion (phase imbalances, voltage violations, overloads, etc.) could play an important role determining locational retail pricing signals as well.

I believe it will be helpful to make a reference to the distribution grid constraints and its impact on the pricing signals.  Furthermore, this is also related to comment 1. above, i.e., the distribution utility need to have visibility to the  DR/DER  schedules and will have an input to the retail pricing signals, even if the assets/resources are managed by an ESP/DRP.             


Best Regards,


Ali Ipakchi

Vice President, Smart Grid and Green Power

Open Access Technology International, Inc.

Office:  763-201-2003

Cell:     651-335-9867



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