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2017-07 Standards Alignment with Registration | Revised Standards Authorization Request

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Start Date: 02/01/2018
End Date: 03/02/2018

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Hot Answers

The Exelon companies request that the SAR team provide additional detail regarding the changes to the SAR. We did not see anything in previous revisions or comments about the Planning Coordinator role.

Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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ACES Standards Collaborators, Segment(s) 1, 3, 4, 5, 3/2/2018

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Other Answers

UFLS should be well defined to reduce the confusion and subjectivity of assureing perfomance.  There is a lot of inconsistency in how UFLS is currently being identified.  This has resulted in a lot of subjectivity in auditing against these standards. 

Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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

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Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

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  1.  Utility Services agrees that a definition for UFLS and/or UFLS Program should be considered to be included in the NERC Glossary of Terms.

  2. The FERC Order approving the Risk Based Registration Initiative did not include provisions for examining the consistent use of the term Planning Coordinator.  We suggest this effort should be addressed as part of the Standards Efficiency Review project.

Brian Evans-Mongeon, On Behalf of: Utility Services, Inc., , Segments 4

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AEP has no objections to the standard drafting team considering adding a definition for UFLS to the NERC Glossary of Terms.

 

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

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The California ISO supports the comments of the ISO/RTO Council Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - 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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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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The IRC SRC supports adding a definition for UFLS into the Glossary of Terms.  We do not agree that the review of all NERC standards for consistent use of the term Planning Coordinator is fruitful until the Standards Effiency Review (SER) process is complete.  This process may result in siginificant reductions and/or modifications to the NERC reliability standards.  In fact, it would be more efficient to assess the consistency of “Planning Coordinator” if and when SARs are issued from the SER process. Unless there is a known problem with compliance and/or with ensuring reliabitliy of the grid due to the lack of consistent application of the term, we see no need to undertake such a review at this time.

 

SRC, Segment(s) 2, 1, 3/2/2018

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

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Hien Ho, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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

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Texas RE is not opposed to defining UFLS, as long as it focuses on the technical side of UFLS and does not attempt to narrow the scope of applicability.

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

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The SPP Standards Review Group is in support of the SAR drafting team considering the inclusion of a definition for UFLS into the NERC Glossary of Terms. However, we would also ask the drafting team to take into consideration adding both the manual and automatic load shedding processes into their preliminary discussions for the development of the UFLS definition. From our perspective, the two processes need to be considered in order to maintain integrity and flexibility to the UFLS process as well as help the industry meet their functional roles pertaining to the reliability of the BES.  As we reviewed standards like PRC-006-3, we observed that the term “UFLS Program” is mentioned throughout the document, however, it’s not defined in the NERC Glossary of Terms. Additionally, we reviewed the UVLS Program definition and our interpretation would have us believe that this definition is only addressing the automatic load shedding process. Finally, our research helped us identify that there is no definition in the NERC Glossary of Terms pertaining to manual load shedding. At this point of the process, we would like to suggest two options that could be used in your discussion in reference to the UFLS definition (see below).

Option 1 

We suggest developing definitions for both terms “manual load shedding” and “UFLS Program” as well as including them in the NERC Glossary of Terms. This option may require developing a definition for manual load shedding as well UFLS Program.

Option 2 

We suggest developing a definition for “UFLS Program” as you could use the “UVLS Program” definition as a foundational anchor and modify the definition to incorporate “manual load shedding” (see example below). However, this proposed action may require coordination with the UVLS drafting team (which may be out of scope) and may require the revision of the UVLS Program definition in the future.

Undervoltage Load Shedding Program (original definition) - An automatic load shedding program, consisting of distributed relays and controls, used to mitigate undervoltage conditions impacting the Bulk Electric System (BES), leading to voltage instability, voltage collapse, or Cascading. Centrally controlled undervoltage-based load shedding is not included.

Underfrequency Load Shedding Program (modified proposed definition) - Manual  and automatic load shedding programs, consisting of distributed relays and controls, used to mitigate underfrequency conditions impacting the Bulk Electric System (BES), leading to voltage instability, voltage collapse, or Cascading. Centrally controlled undervoltage-based load shedding aer not included.

 

SPP Standards Review Group, Segment(s) 5, 3/2/2018

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 3/2/2018

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Hot Answers

Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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ACES Standards Collaborators, Segment(s) 1, 3, 4, 5, 3/2/2018

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Other Answers

Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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

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Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

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  1. Utility Services agrees that references to PRC-004 ad PRC-008 are out of scope for this project, and, it should be noted that these two Standards were never part of the original FERC Order approving the Risk Based Registration Initiative.

Brian Evans-Mongeon, On Behalf of: Utility Services, Inc., , Segments 4

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AEP has no objections to removing PRC-004 and PRC-008 from the proposed SAR for Project 2017-07.

 

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

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The California ISO supports the comments of the ISO/RTO Council Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - 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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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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SRC, Segment(s) 2, 1, 3/2/2018

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

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Hien Ho, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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

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Reliability Standard PRC-008 is not scheduled to be retired until 2027, as part of the PRC-005-6 implementation plan.  Texas RE recommends including PRC-008 until it is fully retired.

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

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SPP Standards Review Group, Segment(s) 5, 3/2/2018

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 3/2/2018

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Hot Answers

Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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  1. We believe the SAR Type should include the option of withdrawing or retiring a Reliability Standard. If the SDT is assigned to implement the recommendations from a periodic review process, these could include the retirement of specific standards.
  2. Under the detailed description of the proposed SAR, references to the FAC, INT, MOD, and NUC standard families are missing from the list of clean-up efforts to modify the Reliability Standard applicable entities (category #2).  We ask the SDT to include these references under the specific clean-up effort category.
  3. We believe a clarification is necessary regarding the intentions to review Reliability Standards and ensure consistent use of Planning Coordinator.  A resolution to the long-standing debate between Planning Authority versus Planning Coordinator is long overdue, and we believe a separate clean-up effort should be identified.  We propose the inclusion of “Modifications to existing standards and NERC Glossary Terms that replace references to Planning Authority with Planning Coordinator” to the list.
  4. We thank you for this opportunity to provide these comments.

ACES Standards Collaborators, Segment(s) 1, 3, 4, 5, 3/2/2018

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Other Answers

Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1

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

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Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

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  1. The redline edit of the phrase ‘the appropriate applicable entity’ in the Detailed Description section has been changed to ‘the appropriate functional entity’ in this SAR posting, however this does not sufficiently clarify that the reassignment of applicability will only be to ‘the appropriate NERC registered entity’ as suggested by commenters in the previous posting.  This phrase should be clarified to indicate only NERC registered entities will be potentially reassigned applicability. 

Brian Evans-Mongeon, On Behalf of: Utility Services, Inc., , Segments 4

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

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The California ISO supports the comments of the ISO/RTO Council Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - 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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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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SRC, Segment(s) 2, 1, 3/2/2018

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

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Hien Ho, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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

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As stated in the previous comment period to this SAR, Texas RE recommends the SAR drafting team consider adding UFLS-only DPs to the applicability and requirement section of additional standards than were listed in the SAR.  Texas RE does not agree that these standards are out of scope for this project and there is a reliability risk associated with not including UFLS-only DPs to the applicability and requirements sections of the standards described below.  Texas RE notes the SAR does include reviewing the standards to ensure consistent use of the term Planning Coordinator.  Texas RE respectfully requests the SAR drafting team describe how these standards are not in scope of this project.  Furthermore, why is it in scope to review the standards to ensure consistent use of the term Planning Coordinator, but out of scope to review the standards listed below for consideration of adding UFLS-only DPs?  Texas RE suggests it would be more efficient to consider making these changes now, while there is an open project related to applicability, rather than later, when there may or may not be an open project related to these standards.

 

Texas RE requests consideration of the following standards:

  • EOP-004 – Add UFLS-only DPs as an entity with Reporting Responsibility in Attachment 1 to the following Event Types:

    •  Automatic firm load shedding ≥ 100 MW (via automatic undervoltage or underfrequency load shedding schemes, or RAS) – If the event occurs to a UFLS-only DP, should be expected to have reporting responsibility.  If it is not required, the UFLS-only DP may not report the event and thus there would be no opportunity to analyze it and make improvements in the future.

    • Damage or destruction of a Facility - UFLS DPs should have reporting responsibilities since one of the last lines of reliability defense is underfrequency relaying entities.  If it is not required, the UFLS-only DP may not report the event and thus there would be no opportunity to analyze it and make improvements in the future.      

  • FAC-002 - FAC-002 needs to include UFLS-only DPs in the applicability section so new or materially-modified existing Facilities are coordinated and studied appropriately.  If FAC-002 does not include UFLS-only DPs, the UFLS-only DP may not coordinate and cooperate on studies with its Transmission Planner or Planning Coordinator in accordance with FAC-002-2 Requirement R3.

  • IRO-010 – If the UFLS-only DPs are not included, they may not provide data to its Reliability Coordinator in accordance with Requirement R3.  This standard should include UFLS-only DP entities so that an RC can fully understand post-contingent projected system conditions (i.e. OPA and RTA) that may recognize a possible underfrequency event and corresponding reaction to said event.  If the RC does not have the UFLS information available that analyses will be incomplete.  The same issue applies to TOP-003.   

  • COM-002 – If UFLS-only DP is not added to the applicability, that entity may not do the training required by COM-002-4 Requirement R3 or three-part communication as required by COM-002-4 Requirement R6.  A UFLS-only DP may receive Operating Instructions to coordinate the re-energization of underfrequency relay equipped load.  That would indicate the need for proper communications between the appropriate parties.  Furthermore, during a Blackstart scenario the UFLS-only DP may be required to not re-energize load (through an Operating Instruction) to help coordinate the stabilization of the grid during restoration.

     

    Texas RE suggests modifying the SAR language to include these additional standards:  “Additionally, the project will include adding Underfrequency Load Shedding (UFLS)-only DPs to the Applicability Section and to the applicable Requirement language of COM-002, EOP-004, FAC-002, IRO-010, TOP-003, PRC-005, PRC-006 and other standards noted during this project.  The project will also include reviewing and revising adding UFLS-only DP as appropriate to the Applicability Sections and Requirement language for PRC-004 and PRC-008 and any other Standard to which this issue may apply.”

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

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N/A

SPP Standards Review Group, Segment(s) 5, 3/2/2018

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 3/2/2018

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