Comments
Description
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AESO Response
Comments from Stakeholders on Settlement Zone Accuracy (POD Aggregation) AESO Response Name EPCOR Utilities Inc. Carmen Piercey Issue Settlement Zone Accuracy (POD Aggregation) Comments Conceptual Framework Responses to be published soon. The accuracy and reliability of system level data is impacted at a number of levels, given the physical nature of the system. Meters are used to calculate zone load. Zone load in each time period is then disaggregated into components consisting of classes of data, resulting in the series of calculations that is load settlement. Since those meters that measure the total load in a zone are relatively few, their effect on load settlement accuracy is much greater than other data. June 28, 2005 Given these interrelationships and linkages, EPCOR suggests it would be instructive and helpful to group the various issues related to system level data into three general categories as follows. 1. Physical Reality of Electric System – There are metering devices connected at various points to energized wires. The wiring itself determines the utility of related meter data. A number of physical facts impact the use of meter data, including required meter types, loss compensation, PT and CT ratios, redundant wires, check and backup meters. 2. Status of Meter Devices – Each meter point used in the context of transmission is represented by a single line drawing, often represented in a generally accepted industry model called a Meter Point Definition Record (“MPDR”). These models establish agreed conventions on how physical reality will be reflected in data use. It is noteworthy that the MPDR model does not extend to include distributed generation, distribution interchange and other constructs not directly related to transmission tariffs. Meter Data Provision – Meter pulses are converted to “readings” data by software systems. Meter readings are aggregated according to MPDR rules by software systems. Meters are assigned “system level” status and a system level model of each interval is constructed by software systems. Software systems create load settlement from these data. This is the domain of “meter data management”, if the above two classifications are right, and of lost effort if they are not. System level meter data is used both to describe load shapes and load magnitudes as well as to provision data for transmission tariff purposes. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 1 of 19 Name EPCOR Utilities Inc. (continued) Issue Settlement Zone Accuracy (POD Aggregation) Comments The relationships among these categories, and the degree to which they depend on and affect one another, can also be viewed as follows: Meter Data Provision Carmen Piercey Status of Meter Devices June 28, 2005 Physical Reality of Electric System AESO Response Responses to be published soon. This layer indicates the data provided to market business processes. This layer is useful only if the layers below are sound. This layer contains standards for meter accuracy, reading frequency, and rules for measurements. This layer is sound only if it accurately reflects reality At this level are the physical characteristics of the measurement devices, including PT/CT ratios, actual point at which measurements are taken, and resulting totalizations. This layer is right if engineering is sound relative to the purpose and intent of measurements needed. Within this framework, it is evident that failures can have a cascading effect in that data problems within any level may create difficulties at any of the three (or all three) levels. Categorization of Issues The three “strata” described above can be used to drive a table-based review of the matter. In the table in Appendix A we have captured each of the issues listed in the Settlement Zone Accuracy issue paper, and then mapped it into this general conceptual model. The issues list from the issue paper is extensive, and due to the need to be comprehensive, it contains numerous repetitions. EPCOR has attempted to restate these issues organized according to the three categories described above in order to enhance the understanding of the problem. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 2 of 19 Name EPCOR Utilities Inc. (continued) Carmen Piercey June 28, 2005 Issue Settlement Zone Accuracy (POD Aggregation) Comments Physical Electric System 1. Responsibility for data veracity is ambiguous where MDM and LSA are separate parties. 2. Distributed Generation metering standards are inadequate. 3. Distribution Interchange metering standards are inadequate. AESO Response Responses to be published soon. Status of Meter Devices 4. Data exchange standards have weaknesses where both TA and LS streams are used. 5. A need exists for generally agreed business process rules for some metering constructs. MPDR – like disciplines have a TA focus insufficient to describe LS needs. 6. System Level data are not reconciled or validated on a daily basis. 7. There are many timing problems. Timing is an issue: a. Where TA and LS system level data are reporting on different schedules. b. Where SL meter data are permitted to be restated but load shapes are required to freeze. c. Where SL estimations are permitted to be used. Meter Data Provision 8. Distributed Generation data standards are inadequate. 9. Distribution Interchange data standards are inadequate. 10. System level data restatements are in conflict with profile freezing requirements. 11. Data validation, in the sense of QA analysis and data controls is not standardized, not transparent, and apparently not adequate. Validating TA measurements against LS data streams (or the reverse) will not add value until timing and data rules are coordinated. Other 12. Accountability does not exist without enforcement adequate to change behaviour. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 3 of 19 Name EPCOR Utilities Inc. (continued) Issue Settlement Zone Accuracy (POD Aggregation) Comments It was not clear that “POD Aggregation” was related to the published issues in any direct way, except in areas affected by distributed generation or distribution interchange. EPCOR believes the issues above reflect the primary issues and factors relating to settlement zone accuracy that ought to be considered in this process. With respect to these issues, EPCOR further believes that continued and intensified standards work is directly indicated as a least-cost approach to resolution. Carmen Piercey Concluding Comments June 28, 2005 The paper seems to presume that direct operational involvement with meter data by the AESO might be of value. EPCOR proposes that the issues listed above be resolved before any consideration is given to moving the responsibility to the AESO. Moving the current processes at this time would likely exacerbate, rather than resolve the problem. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 AESO Response Responses to be published soon. Page 4 of 19 Name Issue Direct Energy Settlement Zone Accuracy (POD Aggregation) Christina Davidson July 4, 2005 Comments The AESO has requested feedback on the following: AESO Response Responses to be published soon. “Comments and input to clarify the issue stated in this document, any corrections to issues information” DEML notes that the issue as identified: “To improve the accuracy, reliability, and dependability of the settlement zone totals used by the LSA’s for settlement” is actually not an issue but an action item or objective required as a result of a number of outstanding settlement issues. DEML respectfully submits that in order to comment appropriately, the AESO provide the LSBAC members a flowchart of the current settlement zone reconciliation process and highlight the key issues that are currently affecting the AESO’s ability to facilitate this reconciliation. Once the issues have been clearly identified DEML proposes that the LSBAC committee members will be in a far better position to add value in terms of addressing these issues and moving ahead with effective resolution. “Comments and input to clarify the scope and objectives of this initiative” Please see comments above. “Comments and input on the process, timelines, and schedules. Provide suggestions on the proposed TBD windows” DEML notes with some concern that the proposed dates appear to extend well into October 2005. DEML respectfully suggests that the issues as detailed in this discussion paper are not new issues for the AESO. They are a continuation of a host of issues raised by industry since the beginning of electricity deregulation in 2001. As a result, DEML proposes that the AESO is well equipped to provide LSBAC members the information requested above well before the end of August. “Additional comments” DEML has recognized this issue as a priority for industry and commits to working with the AESO in determining the best steps on moving these items effectively forward. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 5 of 19 Name ATCO Electric Blair Morton Issue Comments Settlement Zone Accuracy (POD Aggregation) Although the referenced document requests specific feedback, ATCO Electric believes that a more general issue needs to be addressed before specific feedback can be constructively provided. The issue, as described in the referenced document is very similar to an issue currently being addressed by the Metering Service Providers group also lead by the AESO. Confusion and unproductive efforts will result if the initiative called, “Daily System Measurement Implementation Plan” is not coordinated with the referenced issue. The DSM Implementation Plan has progressed to a point where a solution is defined. The referenced issue is yet to be defined. AESO Response Responses to be published soon. June 28, 2005 Based on this new information, ATCO Electric believes that the referenced issue should be deferred until the DSM Implementation is completed and that the Load Settlement Group should support the implementation of this initiative. Once it has been implemented, should the AESO still believe there is an issue, the Load Settlement Group should address it at that time. The following is ATCO Electric’s response to the specific requests made in the referenced document. Requested Action: “Comments and input to clarify the issue stated in this document, any corrections to issues information.” ATCO Electric does not have any specific feedback for reasons stated previously. Requested Action: “Comments and input to clarify the scope and objectives of this initiative.” ATCO Electric believes that the scope and objectives should be revisited once the DSM Implementation has been completed. Requested Action: “Comments and input on the process, timelines and schedules. Provide suggestion on the proposed TBD windows.” ATCO Electric believes the DSM implementation should precede any action with respect to this issue. Requested Action: “Comments and input to clarify or correct any of the reference information included in this document.” Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 6 of 19 Name Issue Comments ATCO Electric (continued) Settlement Zone Accuracy (POD Aggregation) ATCO Electric would like to respectfully clarify their position on the priority of this issue. Based on the new knowledge as noted in the opening paragraphs, ATCO Electric believes this issue to be a “low” priority. Also note that ATCO Electric does support the DSM Implementation Plan initiative. Blair Morton June 28, 2005 AESO Response Responses to be published soon. Requested Action: “Comments and concerns for supporting or not supporting moving forward.” As stated earlier, ATCO Electric does not support moving forward at this time and believes that the “DSM Implementation Plan” initiative should be completed before any more effort goes into this initiative. Requested Action: “Any other comments related to this issue or the process.” ATCO Electric has no further issues. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 7 of 19 Name Issue EnCana Power Settlement Zone Accuracy (POD Aggregation) Comments Item # 1 and Item # 2 - Issue Clarity; Scope and Objectives AESO Response Responses to be published soon. EnCana supports the AESO in that the issue is not physical metering but an absence of comprehensive consistent and enforceable standards for gathering, transferring and processing settlement zone meter data. Marie Gallant Item # 3 - Process and Timelines June 16, 2005 EnCana encourages the AESO to expedite addressing this issue as much as possible. There has been a great deal of progress already made in identifying feasible options with the System Level MDMs. The LSBAC is now in the enviable position to take advantage of work already done and move quickly towards the solution stage. Items # 4, # 5 and # 6 - Support for Moving Forward EnCana is a strong proponent of moving this issue forward. Zone level measurement accuracy is fundamental to a system that provides for over $3 Billion annually in financial settlement. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 8 of 19 Name FortisAlberta Nguyen Tran June 29, 2005 Issue Comments Settlement Zone Accuracy (POD Aggregation) FortisAlberta supports the AESO’s Settlement Zone Accuracy initiative to have timely, consistent and reliable system level data. FortisAlberta submits that the following clarifications are necessary in order to support this market data accuracy initiative. AESO Response Responses to be published soon. Issue FortisAlberta agrees with the issues as presented and submits the following: 1. Late updates to system level data are an issue. If system level data is delayed to the extent that such data is not received prior to the creation of such period’s frozen profile, there is the potential for a divergence between the profile as created and what the profile should have been had such system level data been present. This divergence results in a difference between the zone load and settled load and is allocated as UFE. 2. Accuracy of system level data is an issue. The current classification of transmission meter points as either Point of Delivery (POD) or Point of Supply (POS), precludes the capability to recognize that the meter point may act as one or the other given the meter point’s proximity to distributed generators at any one point in time. Such classification results in an inability to accurately define the Settlement Zone Load. The potential for this situation to intensify grows as the trend towards ever larger distributed generators continues. Initiatives such as the Daily System Measurement (DSM), while being beneficial to the accuracy of system level data, does not address this fundamental inconsistency as presently defined. 3. Inconsistent treatment of distributed and interchange points between LSAs needs to be addressed with the intent of defining a single standard. 4. Inconsistent system level data between transmission and settlement needs to be addressed to determine the root cause of any such differences, with the intent of eliminating those differences. 5. There is a need for clarification of the ‘Need to better assign aggregate wholesale zones’ issue as raised. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 9 of 19 Name FortisAlberta (continued) Nguyen Tran Issue Settlement Zone Accuracy (POD Aggregation) Comments Current Developments FortisAlberta submits that it is of benefit to coordinate initiatives identified by MDM stakeholders (DSM, standardization of distributed generation/interchange, single data stream for system level data, etc.) as they each have an impact on Settlement Zone Accuracy. AESO Response Responses to be published soon. Objectives FortisAlberta agrees with the objectives as presented. June 29, 2005 Scope FortisAlberta submits that resolution of the Settlement Zone Accuracy issue would be best achieved through a holistic approach that includes discussion of all factors, including physical metering standards and processes and appropriate revisions to the SSC as well as the Daily System Measurement (DSM) transaction. A synchronized approach would allow the market to leverage proposed transaction standards and ensure that they are best utilized to provide the market with an accurate settlement zone. This approach would also reduce the costs associated with any potential changes to system implementations. Schedule FortisAlberta submits that it is beneficial to include two additional processes; the first before Activity 6: Seek input from industry on potential alternatives / solutions to issues labeled ‘Validation of the specific concerns’, so that the concerns contributing to the issue are explored to provide a basis for more effective alternatives / solutions; and after Activity 11: Development of a final recommendation and business case labeled ‘Stakeholder review of final recommendation and business case’, in order that all stakeholders have the opportunity to evaluate the proposal for completeness, prior to the development of an implementation plan. FortisAlberta agrees with all other scheduled time frames as proposed and suggests that it is practical to exclude actual dates at this time as this is an iterative process whereby the completion of each milestone is dependent on the one before it. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 10 of 19 Name FortisAlberta (continued) Issue Settlement Zone Accuracy (POD Aggregation) Comments Concerns FortisAlberta submits that there exists an inconsistency between the Daily System Measurement Implementation Plan v2.0, June 21, 2005 (DSM transaction sent to all parties directly) and that of the stakeholder view on Settlement Zone Accuracy as presented to the LSBAC on March 23, 2005: AESO Response Responses to be published soon. Nguyen Tran June 29, 2005 ‘AESO to handle the responsibility for all System Level Metering transactions between the MSPs, MDMs and the LSAs’ This inconsistency has the potential to impair the development of a complete solution, and may cause additional systems development and/or manual processes to circumvent any limitations in the inherent design. In closing, FortisAlberta asserts that the key goals of timeliness, accuracy, data integrity and audit visibility is better managed through a central entity that is responsible for the control and publishing of all system level data. FortisAlberta supports this approach to improving Settlement Zone Accuracy. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 11 of 19 Name Issue MIDAS Metering Services Ltd. (MIDAS) Settlement Zone Accuracy (POD Aggregation) Tim Raines June 29, 2005 Comments Intent This document is the MIDAS Metering Services Ltd. (MIDAS) response to the Alberta Electric System Operator (AESO) request for input relative to their Settlement Zone Accuracy (POD Aggregation) issue definition document dated June 8, 2005. AESO Response Responses to be published soon. Executive Summary Prior to the opening of the retail market the Transmission Administrator (initially GridCo and later, in 1998, ESBI Alberta Ltd.) received transmission system interface measurement point data (IMP, EXP, GEN and LOD) from what it termed, in it’s Measurement System Standard documentation, to be Metering Data Providers (namely transmission facility owners, transmission-connected generators, etc…) so that it could administer it’s mandate, apply it’s tariffs and pass an extract of this data on the Power Pool Of Alberta for wholesale energy settlement purposes. When the retail market opened up in 2001, the Transmission Administrator (then ESBI Alberta Ltd.) took no real interest or role in the retail load settlement process and so a somewhat redundant and non-cohesive set of ‘system level’ metering and data standards was developed as part of the System Settlement Code (SSC). Unfortunately, as with most process failures, the issues began to arise at the interfaces, most notably the common transmission – distribution interface. Both transmission and distribution (retail) reconciliation and settlement processes depend upon the transmission-to-distribution point-of-delivery measurement point interval data as it represents the energy that crosses this important interface. The reconciliation of the net flows across the bulk transmission system or the establishment of distribution system settlement zone totals cannot be completed without the timely delivery and use of consistently accurate point-of-delivery measurement data. Since all downstream load and financial settlement processes depend upon settlement zone totals it is imperative that the calculation of the settlement zone totals not only be correct, accurate and complete but that the settlement zone total data be made available for load settlement in a timely manner. Unfortunately, and largely as the result of the nature of what has been a relatively longterm evolution of industry change, the transmission and distribution data management standards and processes relative to that mutual interface have been developed in isolation resulting in a non-cohesive collective. The establishment of the AESO and it’s mandate to address load settlement Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 12 of 19 Name Issue MIDAS Metering Services Ltd. (MIDAS) (continued) Settlement Zone Accuracy (POD Aggregation) Tim Raines Comments AESO Response presents an opportunity for this industry to rectify this situation by addressing what we contend are the two fundamental issue categories: o o Responses to be published soon. metering data path issues metering data management issues It is our contention that until all settlement zone totals are calculated and provided to the LSAs by the AESO that this industry will never be able to complete reliable energy reconciliations across the bulk electrical system or overcome the crippling data management issues that have lead to the problems that continue to plague load and financial settlement in this industry. June 29, 2005 Issues Metering Data Path Issues The multiple metering data path effect occurs when two separate internal, or distinct external, processes are used to manage transmission interface metering data for the purposes of transmission administration from that used to manage system-level metering for the purposes of retail load settlement. Meter Data Management Processes Meter Data Management Processes Transmission Data Management Process X Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Distribution Data Management Process AESO Y Page 13 of 19 Name MIDAS Metering Services Ltd. (MIDAS) (continued) Tim Raines June 29, 2005 Issue Settlement Zone Accuracy (POD Aggregation) Comments One would expect both data paths/processes to produce the same end results given that they both have as their basis the original raw interval metering data and yet, either as the result of processing or timing differences, they very often do not. These differences are difficult, if not impossible, to resolve and have resulted in significant reconciliation issues between what appears to be energy delivered from the transmission system and what appears to be energy consumed by the distribution system. AESO Response Responses to be published soon. The WO/WSP organizations, in most cases, undertake a number of roles within the industry, namely that of MDP, MDM, LSA. When dealing with these organizations it is difficult, if not impossible, to differentiate between these roles. In addition, because of internal non-standard, non-transparent data processes it is not altogether possible to examine the constituent data that forms the basis for the aggregate settlement zone total data utilized by the LSA associated with that organization. Metering Data Management Issues The Measurement System Standard (formerly the Gridco G302 document) has been developed since 1995 to define all of the metering system and data management standards associated with the transmission system interfaces. The System Settlement Code was developed in response to the opening of the retail market in 2001 to define all of the data management standards associated with the distribution system interfaces. There is a significant over/underlap between these two standards with respect to what the SSC terms as the system-level meters. Differences in file formats, time stamps, delivery frequencies, validation methodology exist among many others. It is these differences that create confusion between market participants affected by, or subject to, such standards. The SSC document is, in many respects, written in a manner that leaves significant discretion to the WO/WSP as to how, or if, they interpret/implement the standards leaving the rest of the industry (or those that must interface with them) to deal with numerous data management exceptions. Besides creating a barrier to entry for new market participants, this situation fosters the development and use of non-standard ‘work-around’ processes that fragment the integrity of the overall data management effort. If the AESO, in keeping with it’s load settlement oversight mandate, is going to monitor and enforce compliance to the SSC then this industry needs to clearly and unambiguously define the standards so that they apply to all market participants equally. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 14 of 19 Name MIDAS Metering Services Ltd. (MIDAS) (continued) Issue Settlement Zone Accuracy (POD Aggregation) Comments Resolution AESO Response Responses to be published soon. Metering Data Path Issue Resolution The metering data path issues can be addressed by: o o o eliminating the potential for multiple data paths, and creating data and data path transparency, and centralizing settlement zone total calculations. Tim Raines Appendix I provides a data flow diagram that meets the above criteria. June 29, 2005 Appendix II provides an overview of all of the applicable electrical system metering interfaces. Appendix III provides the calculation methodology needed to complete the settlement zone totals. Appendix IV provides the rough timing for the delivery of the constituent data and final settlement zone total data. Metering Data Management Issue Resolution The metering data standards issues can be addressed by: o o o consolidating the ‘system level’ metering data management standards, and eliminating ambiguity within the consolidated metering data management standards, and enabling the AESO to monitor and enforce compliance to the consolidated standard. Appendix I: Measurement Point & Settlement Zone Total Data Flow The following diagram illustrates the data flow required to translate raw metering point data into the settlement zone total data required for load settlement purposes: Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 15 of 19 Name MIDAS Metering Services Ltd. (MIDAS) (continued) Issue Settlement Zone Accuracy (POD Aggregation) Comments M1 Mx · MDM1 DSM MDMy MPDR · · · SZDR AESO Metering point interval data collected , verified, validate estimated, edited and stored by MDM/MDPs. Measurement point interval data calculated , in accorda with Measurement Point Definition Records (MPDR) d and provided by the AESO, using validated/estimated metering point data. Measurement point data transferred to the AESO in DS format. DSM Tim Raines June 29, 2005 · AESO Response SZDR · SZT SZT LSA1 LSAz · Measurement point interval data received , verified and stored by the AESO. Settlement zone total interval data calculated , in accor with Settlement Zone Definition Records (SZDR) deve and managed by the AESO, using verified measureme point interval data. Settlement zone total interval data transferred to the LS SZT file format. LSAs use settlement zone total data for load settlemen processing. Appendix II - Alberta Electrical System Metering Interfaces The following diagram is a depiction of the Alberta interconnected electrical system that shows all of the possible ‘system-level’ measurement point 1 interfaces. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 16 of 19 Responses to be published soon. Name Issue MIDAS Metering Services Ltd. (MIDAS) (continued) Settlement Zone Accuracy (POD Aggregation) Comments AESO Response 1 A distinction is made between a ‘metering point’ (a physically realizable point on the electrical system where a meter exists) and a ‘measurement point’ (a point that may or may not be physically realizable on the electrical system where the data for that point is derived from the algorithmical manipulation of the data from one or more metering points) Distribution Connected Generator Transmission Connected Generator Tim Raines June 29, 2005 2 Non-AIES Transmission System 1 6 4 Transmission System 3 Distribution System (ZoneX) 8 Non-AIES Distribution System 7 5 Distribution System (ZoneY) Transmission Direct-Connect Facility 1. 2. 3. 4. 5. 6. 7. 8. Import/export interconnection with the bulk transmission system Transmission connected (co)generation facility Transmission connected, direct connect load facility Transmission to distribution point of delivery (ZoneX) Transmission to distribution point of delivery (ZoneY) Distribution connected generation facility Distribution system interchange point Import/export interconnection with the bulk distribution system Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 17 of 19 Responses to be published soon. Name Issue MIDAS Metering Services Ltd. (MIDAS) (continued) Settlement Zone Accuracy (POD Aggregation) Comments AESO Response System-level measurement points 1, 2 and 3 have nothing to do with the calculation of settlement zone totals. System-level measurement points 4, 6, 7 and 8 are required to complete the calculation of the settlement zone X total while measurement points 5 and 7 are required to complete the calculation of the settlement zone Y total. 1 Tim Raines A distinction is made between a ‘metering point’ (a physically realizable point on the electrical system where a meter exists) and a ‘measurement point’ (a point that may or may not be physically realizable on the electrical system where the data for that point is derived from the algorithmical manipulation of the data from one or more metering points) June 29, 2005 Appendix III: Settlement Zone Total Calculations The following diagram is that of a hypothetical settlement zone: Generation (GEN) ~ Import (IMP) Settlement Zone Export (EXP) ~ Load + Loss (LOD) where the net load (including distribution system losses) can be calculated as: LOD = IMP + GEN – EXP where IMP and EXP represent the collective effect of both point-of-delivery and point-ofinterchange energy exchanges. Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 Page 18 of 19 Responses to be published soon. Name Issue Comments MIDAS Metering Services Ltd. (MIDAS) (continued) Settlement Zone Accuracy (POD Aggregation) Appendix IV: Settlement Zone Total Data Delivery Timing Timing must be such that settlement zone totals are delivered to the LSAs prior to their using those to ‘back-stop’ their load settlement processes. Conceptually, this could look as follows: 0 Tim Raines Day Of Flow June 29, 2005 Comments – Settlement Zone Accuracy (POD Aggregation), Created on July 6, 2005 1 ... AESO Response n-2 n-1 n Metering Data Delivery For The Day Of Flow For All Settlement Zone Interfaces From MDMs To The AESO Settlement Zone Total Processing & Delivery For The Day Of Flow By The AESO To The LSAs Load Settlement Processing For The Day Of Flow By The LSAs Page 19 of 19 Responses to be published soon.