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2017-07 Standards Alignment with Registration SAR

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Start Date: 08/01/2017
End Date: 08/30/2017

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Hot Answers

AZPS requests clarification to ensure that the directives to the SDT are clear and definitive.  To eliminate ambiguity, AZPS recommends that the following sentence be revised as indicated below.  

“The edits include updates to the BAL, CIP, FAC, INT, IRO, MOD, NUC, and TOP family of standards to:

  • Delete remove the references to Purchasing-Selling Entities (PSEs) and Interchange Authorities (IAs);
  • Revise references to the Load-Serving Entity (LSEs) by replacing these references with:
    • either the Distribution Provider (DP) or the Balancing Authority (BA);
    • Distribution Provider; or
    • Balancing Authority.”

In addition, AZPS requests clarification regarding how the determination will be made to replace LSEs with either DP or BA, DP, or BA.  For example, will the SDT be required to establish criteria to determine if LSE is replaced with a DP, BA, Option for Either or None (removal)?

Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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  1. We believe references to the reassignment of Load-Serving Entity (LSE) requirements should be broader instead of limiting the selection to either the Distribution Provider (DP) or the Balancing Authority (BA).  During previous standard development projects, other functions (e.g. Resource Planner) were identified as applicable instead of DPs and BAs.  Moreover, the objective should allow this Standard Drafting Team to revise the requirement to align with those functions’ capabilities.  Many registered entities may operate with smaller non-registered entities and end-user customers that are not obligated to provide such information to their utilities (e.g. rooftop solar PV resources).  We propose revising the objective to read “references to LSE requirements will be reassigned to applicable functions and revised to align with those functions’ capabilities.”
  2. An objective should be included to assess other requirements that could be deemed administrative or align with other Paragraph 81 criteria.  Over the past two years, industry and the ERO Enterprise have identified these requirements through a standards grading evaluation conducted by Regional Entity and NERC Technical Committee representatives.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 8/30/2017

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Other Answers

Rick Applegate, On Behalf of: Rick Applegate, , Segments 1, 3, 4, 5, 6

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We agree with the need to review the alignment issue, but reserve judgment on the proposed changes to the affected standards.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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Entergy/NERC Compliance, Segment(s) 1, 5, 3/1/2017

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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While AEP supports the proposed direction and scope of the drafting team as expressed in the two SARs, AEP seeks clarity as to why more than one SAR is being proposed for a single project. While a project’s SAR may certainly be revised over time as needed, we see no allowance within Appendix 3A (Standards Process Manual) for multiple, concurrent SARs to govern a single project.

 

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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Daniel Grinkevich, On Behalf of: Daniel Grinkevich, , Segments 1, 3, 5, 6

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SRP supports the objectives of Project 2017-07 as described in the SAR.

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Elizabeth Axson, On Behalf of: Elizabeth Axson, , Segments 2

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Michael Jones, On Behalf of: National Grid USA, , Segments 1, 3, 5

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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We agree with the proposed objectives of the SAR but believe the scope should be expanded to include a review of he Glossary. (The SAR form needs an additional box check  in the “SAR Type”  i.e. “Add, Modify or Retire a Glossary Term”. )

The terms Interchange Authority (IA), Load-Serving Entity (LSE)  and Purchasing-Selling Entities (PSE) are used in NERC Glossary definitions and NERC should make sure that these definitions are still valid and aligned with the standards in which they are used.

For example, the NERC Glossary uses  “Interchange Authority”  in the definitions of Arranged Interchange,  Confirmed Interchange, and Request for Interchange and these terms as well as  the definition of “Interchange Authority” itself do not necessarily align with the project on the INT standards where the BA took on the IA’s reliability tasks.

Also LSE is used in the definitions of Energy Emergency, Interruptible Load, DSM, etc

Nicolas Turcotte, On Behalf of: Hydro-Qu?bec TransEnergie, , Segments 1

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SPP Standards Review Group, Segment(s) , 8/30/2017

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David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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RSC, Segment(s) 0, 2, 4, 5, 6, 7, 1, 3, 8/30/2017

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Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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Hot Answers

Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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  1. The SAR type should include the retirement of a standard, as there is a possibility that all requirements of a standard could be retired as part of this project.
  2. The unique characteristics of the BES facilities that may be impacted by this proposed standard development project should be identified as “None” instead of not applicable.
  3. We believe two Reliability Principles are applicable to this standard development project.  This project will revise requirements for applicable entities that plan and operate interconnected bulk power systems in a coordinated manner.  Moreover, the project will revise requirements applicable to identifying information that is necessary for the planning and operation of interconnected bulk power systems and its availability for responsible entities.
  4. We thank you for this opportunity to provide these comments.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 8/30/2017

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Other Answers

Rick Applegate, On Behalf of: Rick Applegate, , Segments 1, 3, 4, 5, 6

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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Entergy/NERC Compliance, Segment(s) 1, 5, 3/1/2017

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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Daniel Grinkevich, On Behalf of: Daniel Grinkevich, , Segments 1, 3, 5, 6

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Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Elizabeth Axson, On Behalf of: Elizabeth Axson, , Segments 2

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Should PRC-005 be applicable to Distribution Providers and the sub-set UFLS-only DP?  For PRC-005, it may not be appropriate to replace Distribution Providers with the more limiting “UFLS-only DP” applicability.

Michael Jones, On Behalf of: National Grid USA, , Segments 1, 3, 5

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Within the Detailed Description section of the SAR, the clean-up effort of the standards are divided into three categories: (1) removal of the retired function and replacement by another function, (2) removal of the deregistered functional entities and their applicable requirements/references, and (3) initiatives that can address RBR updates through the periodic review process.

The second sentence of the Detailed Description states “The edits include updates to the BAL, CIP, FAC, INT, IRO, MOD, NUC, and TOP family of standards to remove the references to Purchasing-Selling Entities (PSEs) and Interchange Authorities (IAs); references to the Load-Serving Entity (LSEs) will be replaced by either the Distribution Provider (DP) or the Balancing Authority (BA).”

As currently written, the second sentence of the Detailed Description indicates removing and replacing references to the LSE with the DP as the only change that will be given consideration with respect to the LSE-related changes (Category 1 of the clean-up effort). It does not contemplate consideration of simply removing the applicable requirements with respect to and references to the LSE within relevant standards (Category 2 of the clean-up effort). To correct this misalignment or potential conflict within the Detailed Description, we recommend that the second sentence of the Detailed Description be revised to state:

“The edits include updates to the BAL, CIP, FAC, INT, IRO, MOD, NUC, and TOP family of standards to remove the applicable requirements with respect to and references to Purchasing-Selling Entities (PSEs), Interchange Authorities (IAs), and Load Serving Entities (LSEs) and their applicable requirements/references; or with respect to LSEs, remove the applicable requirements with respect to and replace the references to the LSE with either the Distribution Provider (DP) or the Balancing Authority (BA) or another functional role if appropriate.”

Additionally, we believe there is value in finalizing needed updates to the NERC Functional Model and the Functional Model Technical Document as posted to and commented upon by the industry in September 2016 prior to approving this SAR. Those documents are a useful guide in understanding the proper scope of the functional roles and how the elimination of certain functional categories can be addressed in the relevant reliability standards.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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Nicolas Turcotte, On Behalf of: Hydro-Qu?bec TransEnergie, , Segments 1

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The SPP Standards Review Group recommends that the drafting team review the definitions of the terms ‘Distribution Provider’ and ‘Balancing Authority’ in the NERC Glossary of Terms, RoP (Appendix 2) and the Functional Model. Through our observation, the definitions are properly aligned with only two of the three documents (The NERC Glossary of Terms and RoP) which can be reviewed in the definitions shown below.

DP (Glossary of Terms and RoP) - Provides and operates the “wires” between the transmission system and the end-use customer. For those end-use customers who are served at transmission voltages, the Transmission Owner also serves as the Distribution Provider. Thus, the Distribution Provider is not defined by a specific voltage, but rather as performing the distribution function at any voltage. 

DP (Functional Model) - The functional entity that provides facilities that interconnect an End-use Customer load and the electric system for the transfer of electrical energy to the End-use Customer.

BA (Glossary of Terms and RoP) - The responsible entity that integrates resource plans ahead of time, maintains load-interchange-generation balance within a Balancing Authority Area, and supports Interconnection frequency in real time.

BA (Functional Model) - The functional entity that integrates resource plans ahead of time, maintains generation-load-interchange-balance within a Balancing Authority Area, and contributes to Interconnection frequency in real time.

From our perspective, this doesn’t promote consistency in the NERC Documents. We recommend the drafting team develops a SAR to help initiate the proper alignment of the Functional Model with the other two NERC Documents since it’s referenced in the current SAR. However, if the drafting team feels that there is no need to align the Functional Model, we would recommend removing the use of the Functional Model from all NERC Documentation. At its current state, the document has the potential to cause confusion with the interpretation of other defined terms referenced in the two NERC Documents (Glossary of Terms and RoP).

SPP Standards Review Group, Segment(s) , 8/30/2017

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OPG is of the opinion that:

  1. Functional category removal has the potential to impact the newly designated applicable entity for the standard.  If applicable how will the impact be mitigated? Should this be taken into account as part of a revised implementation plan?

  2. Alignment category number 2 should include the currently existing, in progress, standards revision as part of the regional reliability standards revision driven by NPCC. Specifically NERC should coordinate with NPCC the revision of the standard PRC-006-NPCC-2 Automatic Underfrequency Load Shedding. For example Requirement Part 16.3 “Have compensatory load shedding, as provided by a Distribution Provider or Transmission Owner that is adequate to compensate for the loss of their generator due to early tripping.” should now be transferred to Underfrequency Load Shedding (UFLS)-only Distribution Provider (DP). In other words the NERC revision of standards should be coordinated with the regional entities to avoid having conflicting regulatory requirements in effect at the same time (i.e. different owners for the same regulatory requirement)

  3. There is a potential risk for conflicting regulatory requirements due to different timelines for the Periodic Review of various standards.

David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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a)      Functional category removal has the potential to impact the newly designated applicable entity for the standard.  If applicable how will the impact be mitigated? Should this be taken into account as part of a revised implementation plan?

b)      Alignment category number 2 should include the currently existing, in progress, standards revision as part of the regional reliability standards revision driven by NPCC. Specifically NERC should coordinate with NPCC the revision of the standard PRC-006-NPCC-2 Automatic Underfrequency Load Shedding. For example Requirement Part 16.3 “Have compensatory load shedding, as provided by a Distribution Provider or Transmission Owner that is adequate to compensate for the loss of their generator due to early tripping.” should now be transferred to Underfrequency Load Shedding (UFLS)-only Distribution Provider (DP). In other words the NERC revision of standards should be coordinated with the regional entities to avoid having conflicting regulatory requirements in effect at the same time (i.e. different owners for the same regulatory requirement)

c)      There is a potential risk for conflicting regulatory requirements due to different timelines for the Periodic Review of various standards.

 

 

The SAR form should check an additional box in the “SAR Type” i.e. “Add, Modify or Retire a Glossary Term”. The terms Interchange Authority (IA), Load-Serving Entity (LSE)  and Purchasing-Selling Entities are used in NERC Glossary definitions and the SAR or Standard drafting  team should make sure that these definitions are still valid. For example, the NERC Glossary uses  “Interchange Authority”  in the definitions of Arranged Interchange,  Confirmed Interchange, and Request for Interchange and these terms as well as  the definition of “Interchange Authority” itself do not necessarily align with the project on the INT standards where the BA took on the IA’s reliability tasks. Also LSE is used in the definitions of Energy Emergency, Interruptible Load, DSM, etc.

RSC, Segment(s) 0, 2, 4, 5, 6, 7, 1, 3, 8/30/2017

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Texas RE is concerned with the proposed change to the Applicability section in Reliability Standard PRC-005-6.  The SAR proposes to replace Distribution Provider (DP) with Underfrequency Load Shedding (UFLS)-only DPs.   This could result in section 4.1 conflicting with section 4.2.1, which includes Protection Systems and Sudden Pressure Relaying that are installed for the purpose of detecting Faults on BES elements.  This could include DPs that do not have UFLS.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Based on the proposed changes to the Applicability Section of PRC-005, Tri-State believes PRC-004 applicability should also be updated to replace Distribution Provider with UFLS-only DP. As currently written in the SAR, we believe the PRC-005 applicability would become inconsistent with the current version of PRC-004.

Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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