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Functional Model Advisory Group

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Start Date: 08/03/2018
End Date: 09/19/2018

Associated Ballots:

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Hot Answers

BPA believes the FM needs to be updated to bring the model current with the Planning, Operations and Cyber processes and standards.  The FM is a foundational document that standards developers use as a reference document when determining standard and requirement applicability.  The FM is also used as a resource document when explaining the reliability-related functions, their roles and general responsibilities.

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

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NO - We do not believe the addition of the Cyber protection tasks are needed as they are only a means to assure access to tools used for BES reliability – not BES reliability in and of itself.  Physical protection could be argued either way; as essential to reliability or not depending on what asset it is applied to.  For example; physical security of a substation or switchyard is essential to BES reliability because of the multitude of equipment within the fence.   However physical security of a single transmission tower is not since the transmission lines have protective relays and switches to assure safety and reliability and do not depend on additional safeguards to provide reliable service.

Additionally, the posted FM incorrectly notes that Planning Coordinators are responsible for protection system coordination.  While some PCs might do this because they are also facility owners, the PC role is supposed to be wide-area coordination.  PCs have some oversight responsibility of SPS/RAS.  While they have general awareness of protection systems, they are not in the loop of ensuring individual protection packages are coordinated. 

SRC, Segment(s) 2, 1, 8/8/2018

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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John Seelke, On Behalf of: John Seelke, , Segments 1

LSPT Q1 Comments.docx

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Scott Miller, On Behalf of: MEAG Power - SERC - Segments 1, 3, 5

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AEP believes there is an opportunity here to define Functional Entity obligations and the expected interactions among Functional Entities.  The content of the FMTD could be incorporated into the FM to improve clarity.  Some modification to the NERC Glossary definitions may be necessary to maintain alignment.  For example, the distinction separating the GO from the GOP appears to be in the communication of certain information to the TOP, BA and RC.  AEP performs the GOP function centrally and dispatches generation for a diverse fleet over a wide geographic area within three RTOs.  Generating resources are mainly “operated” by personnel at the specific generating resource locations as the GO.  On the other hand, some entities perform the communications, dispatch and “operate” their generating resources locally (essentially, the operator is performing the functions of both the GO and the GOP).  Reliability Standards and Guidelines often use the term “operate” in regards to a generating resource.  Since it is not always clear which entity is responsible, additional clarity is needed in describing the distinctions between the GO and GOP functions.

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

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See comments provided for Question 8.

Barry Lawson, On Behalf of: Barry Lawson, , Segments 3, 4

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AECI supports comments provided by NRECA

AECI, Segment(s) 1, 3, 6, 5, 4/30/2018

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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PGE FCD, Segment(s) 5, 1, 3, 9/11/2018

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The information within the FM and FMTD should be updated further to support delineation of functions within the industry. Specifically, reliability vs. business/market functions. This information is valuable to the industry for determining what functions and associated activities are within the scope of NERC Reliability Standards and which Functional Entity is responsible.

The FM incorrectly notes that Planning Coordinators are responsible for protection system coordination.  While some PCs might do this because they are also facility owners, the PC role is supposed to be wide-area coordination. The PCs have some oversight responsibility of SPS/RAS.  While they have general awareness of protection systems, they are not in the loop of ensuring individual protection packages are coordinated. 

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

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Currently, it shows the Planning Coordinator and Generator Owner has having “Protection System” responsibility; the Planning Coordinator has little, if any responsibility in this, and the Transmission Owner and Distribution Provider have extensive responsibilities (not reflected in the FM), as illustrated in the associated Standards.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

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We do not believe that the FM and FMTD need to be revised at all, other than the definitions of some terms to align with the NERC Glossary

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

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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Duke Energy believes that the Functional Model is an important document that serves a vital purpose, and should be updated and kept current to industry practices. The FM and the FMTD are critical for helping to define the various Functional Entities as well as the critical tasks (functions) performed by these Entities. We agree that the Functional Model should remain, and updated.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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

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RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 9/17/2018

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The FM does not reflect changes in recent standards. In particular, the new reliability tasks have not been updated in the proposed FM.

As an example, recent standards have introduced the notion of a Transmission Owner that operates equipment  as a function distinct from the TOP function. This notion should be fleshed out in the FM.

 

 

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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We believe that the FM needs to contemplate the development of DER that are aggregated to act in wholesale markets. There are several options for the tasks required of them so it is imperative that NERC be proactive.

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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The SPP Standards Review Group (SSRG) recommends the Functional Model Advisory Group (FMAG) remove the term “Protections Systems” from the definition that’s applicable to the PC/PA. Additionally, the SSRG feels that the original definition was sufficient and should be added back into the document. Finally, the SSRG would recommend that the term “Protection Systems” be included in the definitions of the entities that install, operate, maintain and coordinate a status with asset owners (for example TO, GO, and/or DP). 

SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 9/18/2018

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Southern Company believes the Functional Model and associated Functional Model Technical Document define and describe the roles and responsibilities of functional entities in sufficient detail. In order to ensure consistency, proposed updates to either document must preserve this level of detail.

Where proposals are being raised for the FMAG’s consideration, Southern is concerned with implications to functional registration and applicability of the Reliability Standards. More specifically, if the information in the FM is moved to Appendix 5B (Statement of Compliance Registry Criteria), it is not clear if non-registration functions will be included since the appendix is related to functional registration.

Additionally, with respect to the potential integration of the FM into the Rules of Procedure, it is not clear if such a change would have any impact on applicability of the Reliability Standards. Recall the FM is considered a guidance document and not to be used to determine a standard’s requirements applicability. Southern believes the FMAG should carefully consider such a change when collecting stakeholder comments.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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While AZPS’s stance is that the Functional Model should be retired, if the Functional Model is not retired, then AZPS recommends the following actions:

1.        The Functional Model should be updated to reflect the functions represented in the current body of reliability standards, e.g., frequency reserve sharing group;

2.         Additional clarity should be added to address the relationship between the GO and TOP, GO and TP, and GO and PC.  For example, are the GO’s TOP, TP and PC responsible for the Transmission Facilities that the Generator is interconnected into or to facilities that are owned by the GO? Further clarification and guidance on the GO to TP relationship is critical to ensure that there is a clear understanding as to the relationship, obligations, and responsibilities.  Further, AZPS notes that it has observed that many GOs requesting to be mapped to the TP at their Point of Interconnection were denied. This relationship is critical to MOD-026 and MOD-027 standards, but, without clarity, it is unlikely to be as effective and efficient as it should be.

3.         Additional clarity should be added to distinguish expected tasks/activities from actual relationships, e.g., coordination is a task – not a relationship;

4.        Additional revisions to achieve consistency with those functions contained in the NERC Rules of Procedure, e.g., removal of functions such as standards developer; and

5.       Develop and incorporate (as appropriate) an ongoing process to ensure that consistency is maintained and that revisions are applied in a timely manner on an ongoing basis.   

 

Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

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Junji Yamaguchi, On Behalf of: Junji Yamaguchi, , Segments 1, 5

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Reclamation recommends retiring the term “Planning Authority” from the NERC Glossary and relacing it in all instances with “Planning Coordinator.” Defining roles, responsibilities, and relationships within the FM will improve clarity.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Dominion Energy recommends retirement of the Functional Model (FM) and migration of the useful content to Appendix 5B (Statement of Compliance Registry Criteria of the Rules of Procedure) and all references to the FM throughout NERC documents (including Reliability Standards, processes, procedures, and other reference documents) be eliminated.  Dominion Energy believe this will be a more effective and efficient use of NERC and industry resources to focus on maintaining one document.

 

 If NERC and the FMWG should decide not to retire the FM and migrate the appropriate FM content to Appendix 5B, then the FM needs to be updated to avoid misalignment and inherent confusion with Appendix 5B and all other documents that reference the FM. Substantial changes have occurred to functional entities’ roles and responsibilities since the FM was last updated. These changes were made through the Risk Based Registration initiative together with the initial comments provided to NERC in the 2016 Comment period for the FM. The alignment of terms and definitions, as provided in the proposed draft, is an important first step; however, the FM needs comprehensive updating. This is particularly important now because of the growing number of new entrants (e.g., non-traditional resources, aggregators) and an increasing number of less seasoned industry staff.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

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NCEMC supports comments provided by NRECA

Kagen DelRio, On Behalf of: North Carolina Electric Membership Corporation - SERC - Segments 3, 4, 5

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EEI recommends retirement of the Functional Model (FM) and migration of the useful content to Appendix 5B (Statement of Compliance Registry Criteria of the Rules of Procedure) and all references to the FM throughout NERC documents (including Reliability Standards, processes, procedures, and other reference documents) be eliminated. The information contained within the FM holds an important role in ensuring the industry has a common understanding regarding functional entity tasks, responsibilities, and relationships.  As a result, we recommend transitioning the useful content from the FM to Appendix 5B. We believe this will be a more effective and efficient use of NERC and industry resources to focus on maintaining one document.

If NERC and the FMWG should decide not to retire the FM and migrate the appropriate FM content to Appendix 5B, then the FM needs to be updated to avoid misalignment and inherent confusion with Appendix 5B and all other documents that reference the FM. Substantial changes have occurred to functional entities’ roles and responsibilities since the FM was last updated. These changes were made through the Risk Based Registration initiative together with the initial comments provided to NERC in the 2016 Comment period for the FM. The alignment of terms and definitions, as provided in the proposed draft, is a level of improvement; however, the FM needs comprehensive updating. This is particularly important now because of the growing number of new entrants (e.g., non-traditional resources, aggregators) and an increasing number of less seasoned industry staff.

Mark Gray, On Behalf of: Edison Electric Institute, FRCC, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1

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Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E/KU) supports comments submitted by EEI.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 9/6/2018

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Hot Answers

BPA uses the FM as a reference document.

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

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NO - We recommend useful information for registered entities be transferred to Rules of Procedure. The information used by standards drafting teams for explaining intent of functions can be memorialized in a technical document.

 

SRC, Segment(s) 2, 1, 8/8/2018

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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The documents are not useful as resources for training or reference unless all unregistered “ghost” Functional Entities are removed.

John Seelke, On Behalf of: John Seelke, , Segments 1

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Scott Miller, On Behalf of: MEAG Power - SERC - Segments 1, 3, 5

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Among other applications, AEP has used and continues to refer to the FM and FMTD to help identify and categorize Cyber Systems for its CIP compliance processes.

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

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Barry Lawson, On Behalf of: Barry Lawson, , Segments 3, 4

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AECI supports comments provided by NRECA

AECI, Segment(s) 1, 3, 6, 5, 4/30/2018

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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PGE FCD, Segment(s) 5, 1, 3, 9/11/2018

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Yes, the information in the FM and FMTD is useful as a guide in delineating reliability functions vs. business/market functions for the purpose of monitoring compliance to NERC Reliability Standards. It is also useful for Cyber Asset categorization for CIP-002 where multiple functions are performed in a central location (Control Center) or utilize a common data center. This information can be an entity’s basis to determine what function/task the Cyber Asset supports (RC, BA, TOP, GOP, Market, etc.).

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

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Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

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We use the FM and FMTD to design the training tasks/responsibilities – it is an important resource to us.

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

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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The FM and FMTD are used as reference and/or resource for the industry. The FM and FMTD is used to train employees on the tasks, purposes, and relationships between the various functional entities as well as ensuring a solid understanding of company responsibilities based on registration.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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

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RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 9/17/2018

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We are heavy users of both functional model documents.

We are a large enterprise exercising numerous functions and we have a number of functional delegation agreements in place. Also, we file NERC standards for approval by the Régie de l'énergie. The NERC functional model is essential during these filings for explaing to the Régie and to entites the application of these standards.

 

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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Yes, the FM is helpful in dealing with other registered entities to prove responsibility in the cases when the standards are less clear as to the role.

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 9/18/2018

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As a general matter, the division of responsibilities for a given function are dictated by an entity’s organizational function. Accordingly, entities find the FM and FMTD useful for a variety of purposes. Southern Company uses the FM and FMTD as reference documents. They provide a broader context for actions performed for compliance purposes and for business operations.  

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

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Junji Yamaguchi, On Behalf of: Junji Yamaguchi, , Segments 1, 5

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Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Dominion Energy uses the FM as a reference document and to assist in training.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

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NCEMC supports comments provided by NRECA

Kagen DelRio, On Behalf of: North Carolina Electric Membership Corporation - SERC - Segments 3, 4, 5

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EEI member companies use of the FM and Functional Model Technical Document (FMTD) varies from those that fully rely on these documents as useful references and training documents; and those that rely more on the less detailed information provided within Appendix 5B.  Regardless of how the documents are used it has been communicated to EEI that nearly all stakeholders believe that the FM and FMTD include useful information that should be retained.

Mark Gray, On Behalf of: Edison Electric Institute, FRCC, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1

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Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E/KU) supports comments submitted by EEI.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 9/6/2018

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Hot Answers

BPA believes that the FM needs to be kept relevant with today’s operating and planning practices. BPA does not see as much value in the FMTD.

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

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NO - These documents need to be reviewed periodically but changes should be minimal as they should stand for any market structure. 

SRC, Segment(s) 2, 1, 8/8/2018

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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The stated purpose of the FM on p. 7 is not “to reflect current industry practices.” If the enforceable and future enforceable Reliability Standards do not “reflect current industry practices,” the FMAG may submit a SAR to address the matter. Otherwise, the FMAG should stay within its stated purpose and Section 302.1 of the ROP for registered Functional Entities.

John Seelke, On Behalf of: John Seelke, , Segments 1

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Scott Miller, On Behalf of: MEAG Power - SERC - Segments 1, 3, 5

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Yes, we believe there is value in maintaining these documents, though as stated in response #1, we believe it would be advantageous for them to exist as a single document. The existing patchwork quilt of Industry and NERC obligations should be periodically reassessed, and models developed and applied across the board.

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

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The FM and FMTD should be maintained only to the extent necessary to determine the applicability of reliability standards. 

Barry Lawson, On Behalf of: Barry Lawson, , Segments 3, 4

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AECI supports comments provided by NRECA

AECI, Segment(s) 1, 3, 6, 5, 4/30/2018

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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PGE FCD, Segment(s) 5, 1, 3, 9/11/2018

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The information within the FM and FMTD is valuable to the industry for two purposes. First, it provides an understanding of what activities are performed for the purpose of reliability vs. market/business purposes. There are various organizational structures (vertical and separated) and regional differences for assigning responsibility for the various functions. The information within the FM and FMTD is useful guidance to determine what function the activity supports. Second, the information is valuable as a guide in determining the scope of the Reliability Standards. If the FM and FMTD clearly describe or delineate functions that are necessary for reliability from those that aren’t, then we ensure non-reliabilty activities don’t get included in the Reliability Standards. For example, it is helpful to have the Market Operation included in the FM and FMTD for guidance on what separates market activity vs. reliability or Market Operator vs. Balancing Authority/Reliability Coordinator/Generator Operator.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

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See Question 1 comments.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

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The FM is a general description of the functions needed or related to reliability. It should be reviewed periodically but changes should be minimal as they should stand for any market structure.  Not all functions or tasks need to be encoded in a standard, and not all tasks need to be performed by registered entities.

 

It should not be updated to align with current registration practices (i.e., deactivation of LSEs and PSEs).   Functional entities need to be registered if and only if they are held to compliance with standards.

 

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

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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As stated in the previous sections, the FM serves a vital purpose in the development and revision of Reliability Standards, as well as used throughout the industry for training employees on tasks, purposes, and relationships between the functions. Based on these uses, the FM and FMTD should be updated to reflect current industry practices.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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

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RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 9/17/2018

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Definitely. See previous answers. In particular, we support the maintenance of the current content of both documents. They could be merged however.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 9/18/2018

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Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

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Junji Yamaguchi, On Behalf of: Junji Yamaguchi, , Segments 1, 5

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Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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The FM and Appendix 5B provide similar information while fulfilling some parallel needs, roles, and purposes.  However, Appendix 5B lacks the more granular and often more useful information, such as the relationships with other Functional Entities. Also, due to the continual change and rapid evolution of the industry (e.g., increased dependence on renewable resources and natural gas, increased use of energy storage, resource aggregation), it is increasingly important that foundational information such as contained in the FM is maintained, enhanced, and refined to ensure that non-traditional functional entities (e.g., aggregators, new market entrants, non-traditional energy resources) as well as less seasoned staff maintain a common understanding of the responsibilities and relationships necessary to maintain BES Reliability. Consolidating this information in one location—Appendix 5B—will make it more effective for these and current stakeholders to understand their roles. It is for these reasons that we recommend migrating the useful FM content to Appendix 5B rather than maintaining two documents that, in part, contain similar information but are also not fully aligned. 

Dominion, Segment(s) 3, 5, 1, 4/6/2017

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NCEMC supports comments provided by NRECA

Kagen DelRio, On Behalf of: North Carolina Electric Membership Corporation - SERC - Segments 3, 4, 5

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The FM and Appendix 5B provide similar information while fulfilling some parallel needs, roles, and purposes.  However, Appendix 5B lacks the more granular and often more useful information, such as the relationships with other Functional Entities, which continues to be used and useful by many entities. Also, due to the continual change and rapid evolution of the industry (e.g., increased dependence on renewable resources and natural gas, increased use of energy storage, resource aggregation), it is increasingly important that foundational information such as contained in the FM is maintained, enhanced, and refined to ensure that non-traditional functional entities (e.g., aggregators, new market entrants, non-traditional energy resources) as well as less seasoned staff maintain a common understanding of the responsibilities and relationships necessary to maintain BES Reliability. Consolidating this information in one location—Appendix 5B—will make it more effective for these and current stakeholders to understand their roles. It is for these reasons that we recommend migrating the useful FM content to Appendix 5B rather than maintaining two documents that, in part, contain similar information but are also not fully aligned. 

 

Mark Gray, On Behalf of: Edison Electric Institute, FRCC, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1

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Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E/KU) supports comments submitted by EEI.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 9/6/2018

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Hot Answers

BPA believes the LSE function is not a low risk to reliability.  For the BPA system, which has a large footprint in the NW section of WECC, 52% of the load BPA serves is now unregistered.  This makes collecting modeling information on loads much more difficult.

Getting absolute MW and MVAR values is not the issue, as BPA meters and forecasts this basic information.  However, the dynamic load models that use the composite load model require knowledge of the actual load and its composition.  This is something only our customers can provide.  Furthermore, as Distributed Energy Resources (DER) become more prevalent in the NW, it will be important to capture this modeling information as well.  The LSE function needs to be reinstated as a registered function with at least a few mandatory reliability requirements associated with it.

BPA believes the Interchange function needs to be retained, as the task and relationships associated with balancing ACE have a direct impact to reliability.

 

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

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YES - The level of risk is irrelevant to the need for any function.  If there is a purpose to the grid that cannot be fulfilled by another function, then that function is essential and should be retained.

SRC, Segment(s) 2, 1, 8/8/2018

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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If a function is to be performed by an unregistered “Functional Entity,” it has no place in the FM.

John Seelke, On Behalf of: John Seelke, , Segments 1

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It is confusing for the lessor expeinced utility employee to see these categories and definitions withing NERC documents when they have been retired. Leave the utility education to the utilities. NERC should only focus on the legislated mission.

Scott Miller, On Behalf of: MEAG Power - SERC - Segments 1, 3, 5

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

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The FM and FMTD should be maintained only to the extent necessary to determine the applicability of reliability standards. 

Barry Lawson, On Behalf of: Barry Lawson, , Segments 3, 4

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AECI supports comments provided by NRECA

AECI, Segment(s) 1, 3, 6, 5, 4/30/2018

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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PGE FCD, Segment(s) 5, 1, 3, 9/11/2018

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Having information on low risk or non-essential reliability functions included in the FM and FMTD is valuable to the industry for delineating activities that are within the scope of NERC Reliability Standards and the appropriate responsible Functional Entity.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

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These are market-based activities that SHOULD BE irrelevant to reliability; thus they should not be reflected in the FM.  If it is necessary, NAESB should define.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

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The level of risk is irrelevant to the need for any function.  See our comment for Q3.

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

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

The intent of the FM is to identify the reliability-related tasks that the individual functional entities perform to ensure that the Bulk Electric System (BES) is planned and operated in a reliable manner. The FM should outline and explain all Functions that are necessary to operate the BES, notwithstanding any perceived level of risk.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

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

- 0 - 0

RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 9/17/2018

- 0 - 0

These low risk functions help contrast the essential functions.

 

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

- 0 - 0

faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

- 0 - 0

Yes, Identifying all the tasks and functions is necessary to ensure that no gaps exist. Additionally, low-risk entities often have the least experience with standards so being able to refer such an entity to the FM allows those entities to understand their role(s).

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

- 0 - 0

SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 9/18/2018

- 0 - 0

If the FM is retained, all functions referenced should be well defined even if they are considered low risk to reliability.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

While AZPS’s stance is that the Functional Model should be retired, if the Functional Model is not retired, then it should retain only those functions that are retained in the reliability standards and the NERC Rules of Procedure.

Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

- 0 - 0

Junji Yamaguchi, On Behalf of: Junji Yamaguchi, , Segments 1, 5

- 0 - 0

Reclamation recommends all functions be defined in the FM. Defining these functions may be necessary if their risk changes in the future. Further defining how Interchange occurs within the FM will improve clarity.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

- 0 - 0

Dominion Energy continues to maintain the same position as stated in our September 2016 comments. Dominion Energy continues to question the justification of maintaining the PSE, IA, and LSE functions within the FM based on Commission determinations made in the March 19, 2015 FERC Order on Risk Based Registration. In that Order, the Commission agreed with NERC that the PSE did not perform any reliability functions that would have a consequential impact on BPS Reliability. Relative to the IA function, the Commission was persuaded by NERC that any possible reliability functions performed would be covered through the continued registration of BAs and RCs. The LSE functions are not performed under Section 215 of the Federal Power Act (FPA) due to the deregistration of this function but continue under tariffs and contracts. Therefore, if the FM is updated, it should eliminate or at least separate this function from other FPA Section 215 functions.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

- 0 - 0

NCEMC supports comments provided by NRECA

Kagen DelRio, On Behalf of: North Carolina Electric Membership Corporation - SERC - Segments 3, 4, 5

- 0 - 0

As stated in our comments back in September 2016, we continue to question the justification of maintaining the PSE and IA functions within the FM based on Commission determinations made in the March 19, 2015 FERC Order on Risk Based Registration. In that Order, the Commission agreed with NERC that the PSE did not perform any reliability functions that would have a consequential impact on BPS Reliability. Relative to the IA function, the Commission was persuaded by NERC that any possible reliability functions performed would be covered through the continued registration of BAs and RCs. Therefore, EEI submits that any reliability function attributed to the IA should be reallocated to the BA and RC moving forward.

Relative to the LSE, EEI acknowledges that the LSE continues to have tasks that are necessary for the reliability of the BPS, however, such functions are not performed under Section 215 of the Federal Power Act (FPA) due to the deregistration of this function but continue under tariffs and contracts. Therefore, if the FM is updated, it should separate this function from other FPA Section 215 functions. 

Mark Gray, On Behalf of: Edison Electric Institute, FRCC, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1

- 0 - 0

Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E/KU) supports comments submitted by EEI.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 9/6/2018

- 0 - 0

Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

- 0 - 0

Hot Answers

BPA believes Standards Development and Compliance Enforcement are different functions that need to remain separate. BPA suggests modifying the Reliability Assurer function to reflect current operating practices.

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

- 0 - 0

NO - The Standards Development and Compliance Enforcement represent only one way of assuring reliability – namely the FERC ERO construct.  Other constructs could fill the Reliability Assurance need too. The roles of NERC and the Regional Entities are defined in the Rules of Procedure, Delegation Agreement, etc…  Summarizing what NERC and the Regional Entities do in the FM simply is unnecessary given the level of detail in the Rules of Procedure.  All three functions (RA, SD & CE) could simply refer to the applicable section of the ROP.

SRC, Segment(s) 2, 1, 8/8/2018

- 0 - 0

Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

- 0 - 0

The FM should be updated in accordance with its stated purpose on p. 7 and Section 302.1 of the ROP for registered Functional Entities.

John Seelke, On Behalf of: John Seelke, , Segments 1

- 0 - 0

There is value in keepoing the Standards Development, Compliance Enforcement and Reliability Assurance separate to facilitate understanding and communication. The beginner and moderately experienced utility employee working with NERC issues, it would be confusing to simply try and talk about Reliability Assurance as a single category. The three categories have comprehensive responsibilities and functions.

Scott Miller, On Behalf of: MEAG Power - SERC - Segments 1, 3, 5

- 0 - 0

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

- 0 - 0

Barry Lawson, On Behalf of: Barry Lawson, , Segments 3, 4

- 0 - 0

AECI supports comments provided by NRECA

AECI, Segment(s) 1, 3, 6, 5, 4/30/2018

- 0 - 0

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

- 0 - 0

PGE FCD, Segment(s) 5, 1, 3, 9/11/2018

- 0 - 0

If the purpose of the information within the FM and FMTD is to provide guidance to the industry on what tasks and functions are within the scope of the CMEP and where to assign applicability to the NERC Reliability Standards, then descriptions of ERO functions could be transferred to the NERC Rules of Procedure or other governing document.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

- 0 - 0

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

We do not agree with consolidating the ERO-related functions into the single function, Reliability Assurance.  It is a term too far reaching to reflect NERC’s responsibilities, given that other regulatory bodies and functional entities perform roles to assure reliability.  The term Reliability Assurance does not appropriately reflect NERC’s legislative responsibilities as a standard setting authority.

 

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

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

We decline to answer question #5 at this time. It is not explicitly clear on who the Reliability Assurance Function is attributed to. This ambiguity is referenced in the FMTD on page 30:

“While the specific role of the Reliability Assurer is not fully developed at the present time,”

It is difficult to respond to this question on consolidating these other Functions into the Reliability Assurance Function, if the Reliability Assurer is not “fully developed at the present time.”

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

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

- 0 - 0

RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 9/17/2018

- 0 - 0

These functions are not alway exercised by the same entity. In particular, the ERO is not the only entity that exercises these three functions. Therefore, their consolidation could cause confusion.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

- 0 - 0

faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

- 0 - 0

The current separation seems unnecessarily complex and introduces some confusion over things like RA and RC.

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

- 0 - 0

SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 9/18/2018

- 0 - 0

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

While AZPS’s stance is that the Functional Model should be retired, if the Functional Model is not retired, then it should be updated to retain only those functions that are referenced in the reliability standards and the NERC Rules of Procedure.

Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

- 0 - 0

Junji Yamaguchi, On Behalf of: Junji Yamaguchi, , Segments 1, 5

- 0 - 0

Reclamation supports separately defining the ERO-related functions of Standards Developer, Compliance Enforcement Authority, and Reliability Assurer.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

- 0 - 0

Dominion, Segment(s) 3, 5, 1, 4/6/2017

- 0 - 0

NCEMC supports comments provided by NRECA

Kagen DelRio, On Behalf of: North Carolina Electric Membership Corporation - SERC - Segments 3, 4, 5

- 0 - 0

As stated in EEI comments on September 2016, we continue to support updating the FM with the intent to consolidate ERO-related functions into a single function, Reliability Assurance, which can be added to the end of Appendix 5B as an entity that is not a candidate for registration.

Mark Gray, On Behalf of: Edison Electric Institute, FRCC, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1

- 0 - 0

Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E/KU) supports comments submitted by EEI.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 9/6/2018

- 0 - 0

Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

- 0 - 0

Hot Answers

BPA believes the FM should be updated and kept current to reflect current planning processes and roles.

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

- 0 - 0

YES - We support clarification to first paragraph of Sec 4. Transmission Planner as the existing language could create an overlap or and gap between Planners.  This viewpoint is not supported by ISO NE. This is not a concern for ISO-NE.  ISO-NE and the NE TOs registered as Transmission Planners have clearly laid out who does what in our TOA, Planning Procedures and Summary Guides on the Split/Sharing of Responsibilities.

SRC, Segment(s) 2, 1, 8/8/2018

- 0 - 0

Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

- 0 - 0

This task is better suited for the NERC Planning Committee.

John Seelke, On Behalf of: John Seelke, , Segments 1

- 0 - 0

Under a separate activity the OP Committee should be responsible for this task and issue a white paper explaining the differences and allow industry to modify its registrations to align with the OP guidance.

The FMWG should be disbanded and the work should be carried on as may be needed through the OC, OP and SC.

 

Scott Miller, On Behalf of: MEAG Power - SERC - Segments 1, 3, 5

- 0 - 0

AEP believes clarification of differences and interrelationships among all functional entity types would be helpful.  Please see our comments made in response to Question #1.

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

- 0 - 0

Barry Lawson, On Behalf of: Barry Lawson, , Segments 3, 4

- 0 - 0

AECI supports comments provided by NRECA

AECI, Segment(s) 1, 3, 6, 5, 4/30/2018

- 0 - 0

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

- 0 - 0

PGE FCD, Segment(s) 5, 1, 3, 9/11/2018

- 0 - 0

This information would be helpful to the industry for ensuring applicability within the NERC Reliability Standards is properly assigned.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

- 0 - 0

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

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

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

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

- 0 - 0

RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 9/17/2018

- 0 - 0

We currently have no issues with the PC and TP functions. We do not oppose added clarification of these two functions. However, we do not see a need to clarify the difference between transmission planning and coordination and the RP function which seems clear to us.

 

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

- 0 - 0

faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

- 0 - 0

The clarification would benefit the industry by ensuring that no gaps exist, nor any overlaps, that might create confusion or potentially jeopardize reliability.

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

- 0 - 0

SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 9/18/2018

- 0 - 0

If the FM is retained, the FM should thoroughly define the responsibilities and tasks performed by each of the three planning functional entities.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

While it is AZPS’s stance that the Functional Model should be retired, if the Functional Model is not retired, then it should be updated to clarify and identify the differences in the tasks performed by the three planning functional entities, the Planning Coordinator (PC), Transmission Planner (TP), and Resource Planner (RP).  The Function Model should allow for flexibility, coordination, and cooperation regarding the scope and activities of these functions as agreed upon by the individual entities pursuant to TPL-001-4, R7.

Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

- 0 - 0

Junji Yamaguchi, On Behalf of: Junji Yamaguchi, , Segments 1, 5

- 0 - 0

Reclamation supports the proposed FM v5.1 with the incorporation of the comments provided in 1 through 5 above to add clarity.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

- 0 - 0

Dominion, Segment(s) 3, 5, 1, 4/6/2017

- 0 - 0

NCEMC supports comments provided by NRECA

Kagen DelRio, On Behalf of: North Carolina Electric Membership Corporation - SERC - Segments 3, 4, 5

- 0 - 0

Consistent with EEI Comments filed in 2016, we continue to support changes that update, clarify, and identify the differences between the tasks performed by the three planning functional entities (i.e., Planning Coordinator (PC), Transmission Planner (TP), and Resource Planner (RP)), as well as updating the other functions.

Mark Gray, On Behalf of: Edison Electric Institute, FRCC, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1

- 0 - 0

Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E/KU) supports comments submitted by EEI.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 9/6/2018

- 0 - 0

Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

- 0 - 0

Hot Answers

BPA believes the reliability piece of interchange is covered under INT-006-4.  BPA suggests a task being added that covers methods of interchange to ensure they are correctly designed and managed so BA’s can maintain load generation balance, a key to reliable operation.

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

- 0 - 0

NO - The proposed redline changes to Sec 7. Interchange Coordinator – are only name changes replacing “Coordinator” with “Authority”. Although this provides consistency with names of other functions, this is an unnecessary change with little value added as there is no confusion wth the current term.

SRC, Segment(s) 2, 1, 8/8/2018

- 0 - 0

Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

- 0 - 0

Interested entities can consult with NAESB on this topic. Alternatively, the NERC Operating Committee could undertake this topic.

John Seelke, On Behalf of: John Seelke, , Segments 1

- 0 - 0

The OC Committee should issue a white paper describing all of these activities if its membership believes it is needed.

The FMWG should be disbanded and the work should be carried on as may be needed through the OC, OP and SC.

Scott Miller, On Behalf of: MEAG Power - SERC - Segments 1, 3, 5

- 0 - 0

AEP believes clarification of interrelationships among functional entity types would be helpful. Please see our comments made in response to Question #1.

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

- 0 - 0

Barry Lawson, On Behalf of: Barry Lawson, , Segments 3, 4

- 0 - 0

AECI supports comments provided by NRECA

AECI, Segment(s) 1, 3, 6, 5, 4/30/2018

- 0 - 0

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

- 0 - 0

PGE FCD, Segment(s) 5, 1, 3, 9/11/2018

- 0 - 0

The information within the FM and FMTD should be updated to delineate reliability vs. after-the-fact analysis/accounting aspects of the Interchange function.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

- 0 - 0

As noted above, these are market-based functions, and should be irrelevant to reliability.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

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

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

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

- 0 - 0

RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 9/17/2018

- 0 - 0

Most responsabilities for the Interchange are commercial and the description of how the various functions interact should be addressed in the associated commercial forums, rather than in the functional model.

However, so long as the current INT standards are in force, the FM should reflect that the BA is responsible for interchange transactions rather than the IA.

 

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

- 0 - 0

faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

- 0 - 0

This would be beneficial if it can be done succinctly. If the explanation can't be done in for example ½ page, it would be better to leave it out of the FM in lieu of other documents.

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

- 0 - 0

SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 9/18/2018

- 0 - 0

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

How the various functions and functional entities work together to perform Interchange is incorporated into and addressed within the existing reliability standards and, therefore, does not need to be addressed within the Functional Model.

Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

- 0 - 0

Junji Yamaguchi, On Behalf of: Junji Yamaguchi, , Segments 1, 5

- 0 - 0

Reclamation supports the proposed FM v5.1 with the incorporation of the comments provided in 1 through 5 above to add clarity.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

- 0 - 0

The Interchange Coordinator/Authority should be removed from the FM since this functional entity was deregistered as part of Risk Based Registration (See FERC Order dated October 15, 2015).  Nevertheless, Dominion Energy continues to see value in providing clarifying information regarding how Interchange occurs and how various functions and functional entities work together to perform Interchange.  Additionally, this information should be provided within a section that is separated from FPA Section 215 activities.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

- 0 - 0

NCEMC supports comments provided by NRECA

Kagen DelRio, On Behalf of: North Carolina Electric Membership Corporation - SERC - Segments 3, 4, 5

- 0 - 0

EEI believes that The Interchange Coordinator/Authority should be removed from the FM since this functional entity was deregistered as part of Risk Based Registration (See FERC Order dated October 15, 2015).  Nevertheless, we see value in providing clarifying information regarding how Interchange occurs and how various functions and functional entities work together to perform Interchange.  Additionally, this information should be provided within a section that is separated from FPA Section 215 activities.

Mark Gray, On Behalf of: Edison Electric Institute, FRCC, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1

- 0 - 0

Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E/KU) supports comments submitted by EEI.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 9/6/2018

- 0 - 0

Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

- 0 - 0

Hot Answers

  • BPA suggests condensing the disclaimer language. BPA recommends reviewing the necessity of all of the disclaimers.

  • BPA suggests that the FM be a binding document for NERC, as it supports the Standard Development process. To ensure standards and requirements are aligned with the FM,  Standards Drafting teams should use the FM as a resource document.

  • BPA believes Cyber tasks should be added in the individual function sections (e.g., TP, PC, TOP, TO etc.) Currently the FM lacks Cyber focus.

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

- 0 - 0

 

 

SRC, Segment(s) 2, 1, 8/8/2018

- 0 - 0

Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

- 0 - 0

The FMAG should make it clear whether or not it intends the FM and FMTD to be acceptable reference documents in support of an Interpretation (as that term defined in the ROP).

John Seelke, On Behalf of: John Seelke, , Segments 1

- 0 - 0

The FMWG should be disbanded and the work should be carried on as may be needed through the OC, OP and SC.

Scott Miller, On Behalf of: MEAG Power - SERC - Segments 1, 3, 5

- 0 - 0

Special Protection Systems are referenced multiple times in these documents, however that term has since been replaced by Remedial Action Schemes.

 

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

- 0 - 0

Reliability Functional Model

General issues – The FMAG should provide context/reasoning for revising each of the Functional Entity definitions.  Without that, it’s unclear why these were revised.  The word “functional” was removed from the definition of several Functional Entities – was the intent to replace it with “responsible” in the definition?  If yes, there are several definitions that need such a change.

p. 21 and 22 – It’s unclear who or what the Reliability Assurer is – this needs to be significantly clarified or removed.  Is the Reliability Assurer a Regional Entity, NERC or FERC?  Is it a registered entity?

p. 24 – Why was the “generally one year and beyond” language removed from the Planning Coordinator definition?

p. 32 – It is my understanding that the IROL definition is being retired.  Should it also be removed from the Reliability Coordinator definition as well? 

Reliability Functional Model Technical Document

p. 30 –The description of Reliability Assurer is confusing and unclear.  As stated in the description “the specific role of the Reliability Assurer is not fully developed at the present time” and “representative of the tasks that might be performed” – this seems to demonstrate that the Reliability Assurer concept is not complete or fully understood.  Is the Reliability Assurer a Regional Entity, NERC and/or FERC?  Is it a registered entity?  I would recommend significantly clarifying this or removing it. 

Barry Lawson, On Behalf of: Barry Lawson, , Segments 3, 4

- 0 - 0

AECI supports comments provided by NRECA

AECI, Segment(s) 1, 3, 6, 5, 4/30/2018

- 0 - 0

The discussion of reliability areas and boundaries in the FMTD is insufficient.  It introduces a vague concept of an Area over which a Functional Entity is responsible.  However, it does not provide any guidance as to how one determines an Area, or what facilities are included, other than the self-referential note that “… use of the specific BES assets provides an adequate basis for defining Areas/boundaries.”  The use of the words “area” and “boundary” imply that the Planning Coordinator area, Transmission Operator area, and other Areas are contiguous areas of responsibility rather than an intermingled web of individual BES assets.   But there is nothing to help someone reading the FM understand what the Planning Coordinator area actually represents.

This has led to standards which are similarly vague, requiring that a FE comply with instructions from “its Transmission Operator”, or provide data to “its Transmission Planner”, with no formal guidance on what that means.  This lack of guidance leads to confusion as to what an entity’s responsibilities actually are.

Clarifying the meaning of Area in the FM and FMTD will help guide future standards development to also be more clear about the interconnecting responsibilities of the various FEs. 

 

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

- 0 - 0

Overall Comment:

A number of functions no longer are relevant and other functions (IA, Market Operator) are performed by other registered entify functions and should be removed.  Also clean up is required where the document switches back and forth in its use of the terms “Planning Authority Area” and “Planning Coordinator Area.”

PGE FCD, Segment(s) 5, 1, 3, 9/11/2018

- 0 - 0

The proposed SAR for Phase 1 of the Standards Efficiency Review project is attempting to remove many requirements that were considered more appropriate to a market or business function and not necessary for reliability. There are concerns on how the industry can ensure non-reliability functions stay out of new or modified Reliability Standards in the future. The information within the FM and FMTD should utilized within the Standards Development Process to address this concern.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

- 0 - 0

The concern noted above regarding Protection Systems has been in place since the inception of the FM.  When the RRO was performing initial organizational registration, this concern resulted in many organizations registering as PC (then PA) for this reason alone. It should be resolved at the earliest opportunity!

Also, in the FM, the table listing the Function Name and Functional Entity (page 10 of the redline; page 9 of the clean version) has a typographical error (i.e., there is an "r" at the end of the word "Authority" where Interchange Authority is listed).

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

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

- 0 - 0

The functional model is foundational and should not be "updated."

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

Duke Energy reiterates its support and the importance of an up to date FM and FMTD which are critical for helping to define the various Functional Entities as well as the critical tasks (functions) performed by these Entities , and the vital role that they should play for Standards Drafting Teams in the Standards Development process.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

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

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RSC no Dominion, Segment(s) 10, 2, 4, 5, 7, 1, 3, 6, 0, 9/17/2018

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As commented in question 1, we would like the FM to reflect recent standards development. For example, we would like further clarification of the Transmission Owner function for Transmission Owners with limited operating responsabilities.

Also, the functional model does not address reliability impacts on the BES of large end-use customers. Should a function be added to the FM to capture these issues? For example, protection system coordination of large customers, real-time operations coordination during events and event recovery, outage planning.

 

 

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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Glenn Barry, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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We believe that the added language relative to IROL for both RC and TOP should be revised. Clearly an RC has a wide area view. But the issue is not IROL identification which requires wide area analysis but rather operations with defined IROLs (per the Standards.) The RC and the TOP both must respect IROLs in their area. If a TOP does not have the ability in every case for an IROL in its area to have the right view, then in our opinion the Standards are in error and should reflect no such responsibility for the TOP. We feel this is not the desired solution, the FM should be revised to properly reflect the need by both to respect IROLs.

 

Additionally, the roles of BA and TOP do not reflect the hierarchy envisioned in Standard TOP-001 during normal operations. The BA in the FM appears to only take direction from the RC, and in some cases give direction to the TOP. The latter scenario is not envisioned anywhere in the Standards. The FM should be clear that the BA must follow Instructions from the TOP.

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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The SSRG recommends that the SDT set a consistent review schedule in place for the FM and FMTD, so it remains aligned with the NERC Standards, the NERC Glossary of Terms, and the NERC Rules of Procedure (RoP). Additionally, the SSRG further suggests that the FMAG include, as part of its review scope, assurance that the FM and FMTD are consistent with the roles and responsibilities required by these other governing documents.

SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 9/18/2018

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Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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AZPS remains concerned that, given the overlap and potential for conflict between the Functional Model and the NERC Rules Of Procedure, the maintenance of the Functional Model is an administratively burdensome task that provides little value to the industry. Although the Functional Model is referenced in the NERC Rules of Procedure, the Functional Model is not an enforceable document and there is not a process for its ongoing maintenance as the reliability standards and NERC Rules of Procedure are developed, revised, retired, etc.  For this reason, the Functional Model is currently out-of-date.

Additionally, the Functional Model is duplicative of portions of the content contained in the NERC Rules of Procedure.  While APS believes that there is value in portions of the Functional Model, consolidation of such content into the Rules Of Procedure would consolidate all function and registration-related content into one document that could more easily be kept in compliance with the NERC Rules of Procedure. 

AZPS suggests that the Rules of Procedure be revised to include the meaningful content contained within the Functional Model and that the Functional Model be retired.   Such would reduce any potential for confusion and would facilitate comprehension and administration of the overall regulatory framework associated with functions, functional entities, etc.

Kelsi Rigby, On Behalf of: Kelsi Rigby, , Segments 1, 3, 5, 6

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Special Protection Systems will no longer be used in PRC-012-2 and replaced by Remedial Action Scheme

Junji Yamaguchi, On Behalf of: Junji Yamaguchi, , Segments 1, 5

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Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Dominion Energy continues to support the Commission’s position that the Functional Model is a guidance document without “firm rights and responsibilities” and that approved reliability standards are the “ultimate determination of applicability.”  (See Order 693, P127).  In this light, Dominion Energy believes that, if retained,  modifications to the content of the FM are necessary to ensure this document once again becomes an effective guidance document for the development of Reliability Standards as well as ensuring all affected entities maintain a common understanding of their responsibilities in maintaining BES Reliability.

 

Specific concerns include a lack of meaningful changes that describe and clarify changes identified in the Risk Based Registration Orders (March 19 & October 15, 2015).  In those orders, FERC approved the deregistration of some functional entities (LSE, PSE & IC/IA) decoupling those entities from direct responsibilities associated with the reliable operation of the BES.  That fact is not clear in the FM.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

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NCEMC supports comments provided by NRECA

Kagen DelRio, On Behalf of: North Carolina Electric Membership Corporation - SERC - Segments 3, 4, 5

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Consistent with the comments EEI submitted in September 2016 on an earlier draft of the FM, we continue to support the Commission’s position that the Functional Model is a guidance document without “firm rights and responsibilities” and that approved reliability standards are the “ultimate determination of applicability.”  (See Order 693, P127).  In this light, EEI believes that, if retained, modifications to the content of the FM are necessary to ensure this document once again becomes an effective guidance document for the development of Reliability Standards as well as ensuring all affected entities maintain a common understanding of their responsibilities in maintaining BES Reliability.

Specific concerns include a lack of meaningful changes that describe and clarify changes identified in the Risk Based Registration Orders (March 19 & October 15, 2015).  In those orders, FERC approved the deregistration of some functional entities (LSE, PSE & IC/IA) decoupling those entities from direct responsibilities associated with the reliable operation of the BES.  That fact is not clear in the FM.

 

 

Mark Gray, On Behalf of: Edison Electric Institute, FRCC, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1

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Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E/KU) supports comments submitted by EEI.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 9/6/2018

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Page 24- remove “and Protection Systems” from the definition of Planning Coordinator. 

Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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