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2017-07 Standards Alignment with Registration SAR | MOD-032-1

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

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End

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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. We believe references to the reassignment of Load-Serving Entity (LSE) requirements should be broader, as several previous standard development projects identified other alternative functions (e.g. Resource Planner) instead of one single function (i.e. Distribution Provider).  Moreover, the objective should allow this Standard Drafting Team to revise the requirement to align with those functions’ capabilities.  We caution the use of references to model distribution facilities, as these are outside the scope of the BES definition and Risk-based Registration.  Furthermore, 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 limiting the language of the scope and objectives to only focus on the reassignment of LSE requirements with applicable functions and revising such requirements 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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None

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

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

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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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The project scope proposes to remove Load Serving Entity (LSE) from Attachment 1 and the Applicability Section (4.1.3) of MOD-032-1 and replace with Distribution Provider (DP) as the applicable entity. The inclusion of the LSE in MOD-032-1 was to allow Planning Coordinators (PC) and Transmission Planners (TP) to request Demand data from the LSE (see Attachment 1 to MOD-032-1). To replace the LSE with DP is not effective because Demand data is information that a DP does not have. If the LSE is replaced with the DP in MOD-032-1, in order to comply, a DP would need to request the LSE data (i.e., Demand) from the Transmission Owner (TO) who would obtain the LSE data through their OATT processes. This process is unnecessarily cumbersome. Since Planning Coordinators and Transmission Planners can request LSE data from Transmission Owners our suggestion is to simply remove LSE from the Applicability Section (4.1.3), requirements R2 and R3, and Attachment 1 of MOD-032-1 (but replace LSE with the TO where Demand data is listed in Attachment 1).

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

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

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

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MOD-032 requires data be provided by applicable entity functions that have been retired.  For this standard, this data is critical and the industry cannot rely on getting data from a functional entity that has no compliance obligation to provide it.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

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

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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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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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None

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

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

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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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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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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?

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

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The SPP Standards Review Group recommends that the Standards Authorization Request (SAR) author capitalizes the term ‘ bulk power system’ which is mentioned in the Purpose or Goal Section of the document (page 1). From our perspective, the term is defined in the NERC Glossary of Terms and not capitalizing it may create confusion on the terms purpose and intent.

Additionally, we recommend that the drafting team review the definition of the term ‘Distribution Provider’ in the NERC Glossary of Terms, RoP (Appendix 2) and the Functional Model. Through our observation, the definition properly aligns 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.

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 term or terms referenced in the two NERC Documents (Glossary of Terms and RoP).

The SPP Standards Review Group has concerns in reference to the DP replacing the LSE in MOD-032. 

Currently there is not a DP contact to obtain modeling data, so the data might not be submitted to SPP in a timely manner or at all.  SPP would need time to establish the DP contacts.

Also, we feel that there may be jurisdictional issues pertaining to an entity sharing modeling data if they aren’t registered with NERC as a DP.

Finally, there is a concern in reference to the DP not providing the modeling data on the behalf of the LSE due to the perception they aren’t responsible to provide the LSE Modeling data.

 The SPP Standards Review Group would ask that the drafting team takes into consideration the addition of the Underfrequency Load Shedding (UFLS) - only DPs to MOD-32-1 Standard Applicability Section. We feel that this entity may have an impact on the role and responsibilities of providing data to help create productive models.

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

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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?

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

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The SPP Standards Review Group recommends that the Standards Authorization Request (SAR) author capitalizes the term ‘ bulk power system’ which is mentioned in the Purpose or Goal Section of the document (page 1). From our perspective, the term is defined in the NERC Glossary of Terms and not capitalizing it may create confusion on the terms purpose and intent.

Additionally, we recommend that the drafting team review the definition of the term ‘Distribution Provider’ in the NERC Glossary of Terms, RoP (Appendix 2) and the Functional Model. Through our observation, the definition properly aligns 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.

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 term or terms referenced in the two NERC Documents (Glossary of Terms and RoP).

The SPP Standards Review Group has concerns in reference to the DP replacing the LSE in MOD-032. 

Currently there is not a DP contact to obtain modeling data, so the data might not be submitted to SPP in a timely manner or at all.  SPP would need time to establish the DP contacts.

Also, we feel that there may be jurisdictional issues pertaining to an entity sharing modeling data if they aren’t registered with NERC as a DP.

Finally, there is a concern in reference to the DP not providing the modeling data on the behalf of the LSE due to the perception they aren’t responsible to provide the LSE Modeling data.

The SPP Standards Review Group would ask that the drafting team takes into consideration the addition of the Underfrequency Load Shedding (UFLS) - only DPs to MOD-32-1 Standard Applicability Section. We feel that this entity may have an impact on the role and responsibilities of providing data to help create productive models.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

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

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