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2018 Bulk Electric System Definition Reference Document

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Start Date: 08/07/2018
End Date: 09/10/2018

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Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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For I2, part “b”, as shown on pg.5, the language used is “plant/facility”, rather than “site”.  The document used to use “site” in a number of places and as part of this update the term was replaced with “plant/facility”.  The first example of this change shows up on pgs. 9/10.  However, “site” was not replaced with “plant/facility” throughout the document.  There are still numerous instances where the word “site” remains in the I2 section of the document, including new language in the I2 section.  So, the decision need to be made on the term to be used and the document made consistent with that decision.  Specific instances of “site” that remain in the I2 section:

 

Pg. 5, bottom, new text.

Pg. 10, text box under drawing

Pg. 11, text box under drawing, bottom of drawing itself

Pg. 12, text box above drawing, bottom of drawing itself

Pg. 15, text box above drawing, bottom of drawing itself

Pg. 16, text box to right of drawing

Pg. 17, text box above drawing, text box to right of drawing, bottom of drawing itself

Pg. 19, text box above drawing, bottom of drawing itself

 

Then, in the section for I4, the word “site” only is used again.  Is there a difference between “site” and “plant/facility”?  Since different parts of the document are now using different terms, the difference needs to be understood.  If they are the same, then why are the changes being made to some parts of I2?

John Pearson, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

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Other Answers

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

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

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

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Figures I2.4, I2.8, and I2.9 displays the generation and associated dedicated step-up transformers as BES (colored blue), then states it might not be BES under E2; this is confusing.  Further, Figures I2.8 and I2.9 are confusing in that the illustrations appear to depict two plants within a single plant, and implies each generator must have a dedicated retail meter.  In many cases, the “generator aggregation/interconnection” bus may have multiple load and generator step-up transformers where two retail meters will be located on the source transmission (outgoing lines with arrow ends); the retail metering is calculated as the algebraic sum of the two meters.  In the end, placement of these illustrations in this chapter do not add clarity, but create more questions.  Generation is always behind metering; the standard drafting team simply saw no reason to show the metering unless it represents retail metering serving as the means to track retail sale of power for end-user load and generation associated with dedicated step-up transformers.  In such cases the metering is more commonly known as net-metering, but this term also includes low voltage residential metering of load/generation of which the standard drafting team’s intent is to exclude by default.  Finally, some industrial plants will have substantial generation buried deep in the medium-voltage (typically 13.8 kV three-phase) distribution system.  Again, net-metering is required, but such generation is not considered as each generator is not associated with a dedicated step-up transformer connected at 100 kV or greater (see Figure I2.11).

Russell Noble, On Behalf of: Cowlitz County PUD, , Segments 3, 5

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The NSRF recommends there be a diagram of a behind-the-meter generator connected at <100kV (i.e. 14kv to 69kV) and stating that it is a non-BES asset.

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

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

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Jack Stamper, On Behalf of: Clark Public Utilities, , Segments 3

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I support the comments of Russell Noble of Cowlitz County PUD.

Steve Alexanderson, On Behalf of: Steve Alexanderson, , Segments 3, 4

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PPL NERC Registered Affiliates requests clarification of whether the generators referenced in Figure I2.4 (PDF Page 14) would be required to register with NERC as a GO or GOP.

PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 9/6/2018

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No comment.

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

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Peak agrees with the decision to include the examples of 'behind-the-meter" generation.

Scott Downey, On Behalf of: Scott Downey, , Segments 1

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

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Comments: With the increasing use of photovoltaics, please add a drawing similar to I2.7, but include a photovoltaic bank over 20MVA and the total summing to less than 75MVA. 

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Manitoba Hydro, Segment(s) 5, 3, 6, 1, 8/8/2017

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  • In general, for all proposed modifications, clarity should be made to Figure I2.1, which attempts to define what is considered a “single point of interconnection”. Further clarification is attempted under the heading Common Point of Connection.  Neither provide full clarity and need to be improved.
    • Does the configuration represent the breaker scheme, a substation, or a line?
    • Does breaker configuration matter? If breaker configuration prevents a cascade outage on both generators, should they be added together?

We believe the breaker configuration does matter. If a breaker separates two generators from the BES within the same substation, then they should not be considered the same point of interconnection. A line and substation versus bus bar and breakers does not provide for any addition to reliability.

Cooper Compliance Corp, Segment(s) 3, 5, 1, 9/7/2018

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

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p. 5, Chapter I2 – The new paragraph regarding behind the meter generation is not consistent with BES definition.  It will be potentially confusing to retail customers of all sizes if their behind the meter generation must first be determined whether such generation is BES or not.  The current Inclusion I2 does not state in any way that behind the meter generation must be considered in this manner.  Exclusion E2 is the only part of the BES definition that specifically identifies behind the meter generation, and it’s clear in Exclusion E2 alone how to determine which behind the meter generation is BES or not BES.  Figures I2-4, I2-5, I2-8 and I2-9 need to be revised to remove the new text regarding how behind the meter generation is evaluated under the BES definition.

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

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National Grid supports Edison Electric Institute’s (EEI) comments. 

National Grid, Segment(s) 1, 3, 10/30/2017

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Douglas Johnson, On Behalf of: Douglas Johnson, , Segments 1

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ELCON appreciates the examples and diagrams added by the BEPWG to clarify the assessment of behind-the-meter generation.  We could find no issue with the processes described that determine whether such generation should initially be considered part of the BES (or not).

However, there was not a clear correspondence between the configurations shown in Inclusion I2 versus those in Exclusion E2.  This is particularly important for those I2 assessments that result in a positive outcome (i.e.; the behind-the-meter generation is part of the BES).  Since those must be subsequently evaluated under the E2 criteria, a one-to-one correlation would help immensely.

As an example, Diagram I2.8 shows two separately metered behind-the-meter generators located at a single plant.  Both have been identified under I2 as part of the BES.  However, the most closely matching diagram under Exclusion E2 is E2.3 – and it shows both generators are served by a single meter.  ELCON believes that the total net MVA delivered to a single point of interconnection is the key factor; which is not affected by the number of meters.  However, it may be better if both configurations are illustrated in I2 and E2 to eliminate any confusion on the topic.

John Hughes, On Behalf of: John Hughes, , Segments 7

ELCON Comments - Definition of the BES 9-7-18.docx

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Rebecca Baldwin, On Behalf of: Transmission Access Policy Study Group, NA - Not Applicable, Segments 4

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

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

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In diagram I2.11, the transformer between the bar serving load and the transmission system should be included through I1. The SDT may want to mention that point even if the illustration does not explicitly include or exclude it.

Also, this example highlights that a generator, regardless of its size, that interconnects to load at an intermediate bus lower than 100 kV is excluded. This can be problematic in rare circumstances when a medium sized generator is stepped up in stages and interconnects load. I2.11 should have a capacity measure on the final transformer state. i.e. if net capacity at the interconnecting transformer, that is, generation capacity minus min. load, is greater than 75 MVA, the generator should be included in the BES.

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

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APPA does not agree with the Figures I2.4, I2.8, and I2.9 associated with Inclusion I2, that are used to explain behind the meter generation and, associated dedicated step-up transformers as BES (colored blue). The diagrams are not clear. Specifically, Figures I2.8 and I2.9 appear to depict two plants within a single plant and implies each generator must have a dedicated retail meter. In many cases, the “generator aggregation/interconnection” bus may have multiple load and generator step-up transformers where two retail meters will be located on the source transmission (outgoing lines with arrow ends); the retail metering is calculated as the algebraic sum of the two meters. Consequently, these illustrations do not add clarity, but create more questions. 

Importantly, the text regarding behind the meter generation is not consistent with BES definition standard.  The BES standard drafting team did not see a reason to show the metering unless it specifically represented retail metering.  Such metering was used to track retail sale of power for end-user load and generation associated with dedicated step-up transformers.  Therefore, it will be confusing to retail customers whether they first need to distinguish if their behind the meter generation is BES, or not. The current Inclusion I2 does not specifically state that behind the meter generation must be considered in this manner. Exclusion E2 is the only part of the BES definition that specifically identifies behind the meter generation, and how to determine which behind the meter generation is BES, or not.  The text regarding how behind the meter generation is evaluated under the BES definition should be removed from Figures I2-4, I2-5, I2-8 and I2-9. 

Jack Cashin, On Behalf of: American Public Power Association, , Segments 4

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

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Duke Energy recommends that the BEPWG consider expanding or clarifying what is meant by use of the term “retail” when referencing “behind the retail meter generators” throughout the Inclusion diagrams as well as Exclusion E2. Does “retail” as referred to in the document pertain to a customer, or a system? Is “retail” supposed to mean the opposite of “wholesale”? Further clarification on the use of the term would be beneficial for the industry.

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

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We support comments provided by ELCON.

Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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Southern Company, Segment(s) 1, 3, 5, 6, 10/30/2017

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Figures I2.4, I2.8, and I2.9 are confusing because they show generators that are included in the BES; however, the descriptions provide that “the generator may be a candidate for exclusion based on the criteria established in Exclusion E2.” Reclamation recommends each figure and description clearly state what is or is not included in the BES and not provide scenarios for “what might be.”

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

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Tri-State agrees with the comments made by the NRECA. 

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

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The SPP Standards Review Group (“SSRG”) appreciates the work of the BEPWG and agrees the proposed revisions to include examples and diagrams will provide clarification in the application of the BES definition; however, the examples could be improved by citing to the sub-parts of the applied definition. For example, the value of Figure I2-1 would be greatly increased by stating that the facility is included “[b]y application of Inclusion I2.a...” Citing to the specific sub-parts of the pertinent definition should be applied to all examples contained in the document. 

Additionally, the SSRG recommends that the figure descriptions more clearly explain how the inclusion/exclusion process is applied. For example, Figure I2-3 may be confusing because it is provided in the inclusionary section (I2) even though the end-result is exclusion under the exclusionary section (E2). Stating that the generator “may” be excluded without providing further details is ambiguous. To remedy the confusion, Figure I2-3 would be better structured (and more accurate) by removing the Retail Load from the figure to illustrate that it is includable as BES under I2. Current Figure I2-3 (with the Retail Load) should be placed in E2 with a statement that although the generator meets the inclusion criteria under I2, the generator is excluded because it serves retail load and the net capacity to the BES is less than 75 MVA. 

SPP Standards Review Group (SSRG), Segment(s) 2, 1, 3, 5, 6, 9/10/2018

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FMPA agrees with the following comments submitted by APPA:

{C}1.     APPA does not agree with the Figures I2.4, I2.8, and I2.9 associated with Inclusion I2, that are used to explain behind the meter generation and, associated dedicated step-up transformers as BES (colored blue). The diagrams are not clear. Specifically, Figures I2.8 and I2.9 appear to depict two plants within a single plant and implies each generator must have a dedicated retail meter. In many cases, the “generator aggregation/interconnection” bus may have multiple load and generator step-up transformers where two retail meters will be located on the source transmission (outgoing lines with arrow ends); the retail metering is calculated as the algebraic sum of the two meters. Consequently, these illustrations do not add clarity, but create more questions.

 

Importantly, the text regarding behind the meter generation is not consistent with BES definition standard.  The BES standard drafting team did not see a reason to show the metering unless it specifically represented retail metering.  Such metering was used to track retail sale of power for end-user load and generation associated with dedicated step-up transformers.[1] Therefore, it will be confusing to retail customers whether they first need to distinguish if their behind the meter generation is BES, or not. The current Inclusion I2 does not specifically state that behind the meter generation must be considered in this manner. Exclusion E2 is the only part of the BES definition that specifically identifies behind the meter generation, and how to determine which behind the meter generation is BES, or not.  The text regarding how behind the meter generation is evaluated under the BES definition should be removed from Figures I2-4, I2-5, I2-8 and I2-9.

 

{C}[1] In such instances, the metering is commonly known as net-metering, but this term also includes low voltage residential metering of load/generation of which the standard drafting team’s intent is to exclude by default. Also, some industrial plants will have substantial generation buried deep in the medium-voltage (typically 13.8 kV three-phase) distribution system.  Again, net-metering is required, but such generation is not considered as each generator is not associated with a dedicated step-up transformer connected at 100 kV or greater (see Figure I2.11).

FMPA, Segment(s) , 10/23/2017

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

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Occidental Chemical Corporation (Oxy) appreciates the examples and diagrams added by the BEPWG to clarify the assessment of behind-the-meter generation.  We could find no issue with the processes described that determine whether such generation should initially be considered part of the BES (or not).

However, there was not a clear correspondence between the configurations shown in Inclusion I2 versus those in Exclusion E2.  This is particularly important for those I2 assessments that result in a positive outcome (i.e.; the behind-the-meter generation is part of the BES).  Since those must be subsequently evaluated under the E2 criteria, a one-to-one correlation would help immensely.

As an example, Diagram I2.8 shows two separately metered behind-the-meter generators located at a single plant.  Both have been identified under I2 as part of the BES.  However, the most closely matching diagram under Exclusion E2 is E2.3 – and it shows both generators are served by a single meter.  OXY believes that the total net MVA delivered to a single point of interconnection is the key factor; which is not affected by the number of meters.  However, it may be better if both configurations are illustrated in I2 and E2 to eliminate any confusion on the topic.

Oxy, Segment(s) 7, 5, 9/6/2016

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

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Hot Answers

Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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It is helpful to have the wording added to the description that all generation with a common point of connection configuration is considered when making the determination whether a facility is BES or not.

John Pearson, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

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Other Answers

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

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

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

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Referring to the revised Summary, paragraph one, the following is stated: “Ownership or operational responsibilities do not impact the application of the BES definition. As reflected in Order No. 773, ‘the NERC registration process uses element criteria to identify and register functional entities, not the actual equipment. In contrast, the focus of the bright-line definition is the facilities, not the owners or operators of the facilities.’” The illustration of multiple owner application implies a contradiction of the revised Summary.  Highly recommend this illustration be abandoned as it may raise questions on sub-ownership of facilities aggregated at a single point greater than 75 MVA where the sub-owner’s total name plate aggregated generation is less than 20 MVA. If the BEPWG continues to develop such an illustration, it is most important to emphasize the distributed generation boundaries (“plant”), not ownership, is the defining point.  Thus, in the case for distributed generation, it is the point of aggregation greater than 75 MVA, which is ultimately delivered via a dedicated system to a point operated at or above 100 kV that defines the “plant” – not ownership (see Figure I4.1).  An outline encompassing all distributed generation before this point is drawn with an explanation box of the reason for the “plant” line including a statement that segmented ownership within the plant is not to be considered.  Conversely, the illustration should display an example where a “plant” is not included in the BES.  Using Figure I4.1, the addition of another <100kV/≥100kV step-up transformer with distributed generation aggregating at or below 75 MVA behind this transformer would provide a non-BES example.

Russell Noble, On Behalf of: Cowlitz County PUD, , Segments 3, 5

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To provide clarity, the NSRF recommends that a breaker symbol be added between the BES Bus and the last BES generator (wind turbine), which would be green in color (non-BES) for Figure I4-1.

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

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

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Jack Stamper, On Behalf of: Clark Public Utilities, , Segments 3

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I support the comments of Russell Noble of Cowlitz County PUD.

Steve Alexanderson, On Behalf of: Steve Alexanderson, , Segments 3, 4

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PPL NERC Registered Affiliates requests clarification of whether the generators referenced in Figure I4.3 (PDF Page 25) would be required to register with NERC as a GO or GOP.

Additionally, we request clarification of Figure I4.1 (PDF Page 23). For example, it is unclear whether, if a collector string aggregates to greater than 75 MW along the string itself, the BES point would be where it aggregates to 75 MW or whether the entire string is treated as BES as it would be if the E1 Generation Only approach were used to make the determination. As illustrated in the E1 Generation Only Figure E1.9, if the collector string is at 34.5 kV and step up transformers are required for all of the turbines, it is unclear whether the transformers would still rule out even if the string becomes BES. If so, we suggest adding a statement to the I4 Section that says “the E1 Generation Only assessment technique may be applied to individual collector strings of a dispersed power resource facility” to add clarity.

PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 9/6/2018

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Figures I4-1 through I4-4 previously included the individual step up transformers at each wind turbine or PV cell/inverter showing clear distinction in blue that they were included in the BES. The newly revised I4-1 though I4-6 figures omit this detail; BPA believes this leaves it ambiguous and confusing as to whether or not all the individual pad mount low voltage step-up transformers ARE included as BES with the individual generator units or if they are NOT included as BES with the collector system.

Proposed revision: Include all individual low voltage step-up transformers in all figures I4-1 through I4-6 with a clearly identifiable blue or green distinction, as the 2014 guidance previously included.

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

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Peak agrees with the decision to include the examples and diagrams associated with dispersed power producing resources with multiple owners.  Peak does have a concern with both the application to multiple owners and the original dispersed generation site example Figure I4-2. Peak agrees with the general principal of the both diagrams. However the statement “configuration not relevant to the determination” is problematic. Recent events with solar facilities has indicated that where a common inverter issue can impact each individual unit and thus the entire output the exclusion of the individual generators would exempt them from having to respond to any standard. This should perhaps be addressed under the <25MVA definition for a generator exclusion by a statement that unless there is a common mode failure that would impact more than 25MW.

Scott Downey, On Behalf of: Scott Downey, , Segments 1

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

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Comments:  The concept of adding those drawings is good, however, we find I4.4, I4.5, and I4.6 to be confusing.   Please limit the use of 20MVA Photovoltaic banks in the example.  It makes it confusing as to whether the 20MVA photovoltaic banks are included as BES under I2 vs. I4.  

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Manitoba Hydro, Segment(s) 5, 3, 6, 1, 8/8/2017

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Cooper Compliance Corp, Segment(s) 3, 5, 1, 9/7/2018

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

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

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National Grid supports Edison Electric Institute’s (EEI) comments.

National Grid, Segment(s) 1, 3, 10/30/2017

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Douglas Johnson, On Behalf of: Douglas Johnson, , Segments 1

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John Hughes, On Behalf of: John Hughes, , Segments 7

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Rebecca Baldwin, On Behalf of: Transmission Access Policy Study Group, NA - Not Applicable, Segments 4

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

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

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

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The Summary associated with the Section II.4 BES Inclusion I4 is confusing and does little to make the point that the diagrams focus on facility elements and their operation, rather than on ownership. While the illustration of the multiple owner application has the intent of demonstrating the assessment of facilities, it erroneously includes ownership as part the example. Ownership should be left out of the illustration. Inadvertently, the illustration raises questions on sub-ownership of facilities aggregated at a single point greater than 75 MVA where the sub-owner’s total name plate aggregated generation is less than 20 MVA. Should the Bulk Electric System Process Working Group (BEPWG) decide to use the illustration, it is most important to be clear that the distributed generation boundaries (“plant,” not ownership), is the defining point for BES/not BES.  Thus, in the case for distributed generation, it is the point of aggregation greater than 75 MVA, which is ultimately delivered via a dedicated system to a point operated at or above 100 kV that defines the “plant” – not ownership (see Figure I4.1).  An outline encompassing all distributed generation before this point is drawn with an explanation box of the reason for the “plant” line including a statement that segmented ownership within the plant is not to be considered.  Conversely, the illustration should display an example where a “plant” is not included in the BES.  Using Figure I4.1, the addition of another <100kV/≥100kV step-up transformer with distributed generation aggregating at or below 75 MVA behind this transformer would provide a sufficient non-BES example.

Jack Cashin, On Behalf of: American Public Power Association, , Segments 4

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

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Duke Energy agrees with the revisions proposed to I4.

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

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Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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Southern Company, Segment(s) 1, 3, 5, 6, 10/30/2017

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As stated in the revision to the Summary, “Ownership or operational responsibilities do not impact the application of the BES definition.” This statement is confusing when used in conjunction with subsequent examples and diagrams intended to illustrate how facilities with multiple owners should be evaluated. Reclamation recommends the reference document abandon the illustrations (Figures I4.3 and I4.6) of multiple owners and focus on defining the facility/equipment boundaries.

Reclamation also recommends ownership of the point of interconnection be the basis for determining included in the BES. In Figures I4.3 and I4.6, the generation should be non-qualifying unless the generator owners also co-own the point of interconnection.

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

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

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SPP Standards Review Group (SSRG), Segment(s) 2, 1, 3, 5, 6, 9/10/2018

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FMPA agrees with the following comments from APPA: {C}1.     The Summary associated with the Section II.4 BES Inclusion I4 is confusing and does little to make the point that the diagrams focus on facility elements and their operation, rather than on ownership. While the illustration of the multiple owner application has the intent of demonstrating the assessment of facilities, it erroneously includes ownership as part the example. Ownership should be left out of the illustration. Inadvertently, the illustration raises questions on sub-ownership of facilities aggregated at a single point greater than 75 MVA where the sub-owner’s total name plate aggregated generation is less than 20 MVA. Should the Bulk Electric System Process Working Group (BEPWG) decide to use the illustration, it is most important to be clear that the distributed generation boundaries (“plant,” not ownership), is the defining point for BES/not BES.  Thus, in the case for distributed generation, it is the point of aggregation greater than 75 MVA, which is ultimately delivered via a dedicated system to a point operated at or above 100 kV that defines the “plant” – not ownership (see Figure I4.1).  An outline encompassing all distributed generation before this point is drawn with an explanation box of the reason for the “plant” line including a statement that segmented ownership within the plant is not to be considered.  Conversely, the illustration should display an example where a “plant” is not included in the BES.  Using Figure I4.1, the addition of another <100kV/≥100kV step-up transformer with distributed generation aggregating at or below 75 MVA behind this transformer would provide a sufficient non-BES example.

FMPA, Segment(s) , 10/23/2017

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

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Oxy, Segment(s) 7, 5, 9/6/2016

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

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Hot Answers

Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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There is inconsistency in the use of Note 2 for the E1 exclusion and more detail on the hierarchy used to make the determination may be necessary.  Note 2 states that the presence of a contiguous loop, operated at a voltage level of 50 kV or less, between configurations being considered as radial systems does not affect this exclusion.  The new Figure E1.4 is inconsistent with existing Figure E1.2.  Figure E1.2 indicates that because there is a loop below 50 kV, that the figure illustrates a single point of connection to a radial system (as explained through Note 2).  In Figure E1.3, the same configuration is then considered to have multiple points of connection at a voltage level of 100 kV or higher because the loop is greater than 50 kV.  Figure E1.4 is effectively the same as Figure E1.2 because the loop is less than 50 kV and there are then several single points of connection.  Similar concerns also exist in Figures E3.6 on pg. 96, E3.7 on pg 100, E3.10 on pg 103, and E3.11 on pg. 105.

John Pearson, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

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Other Answers

As stated in FERC Order No. 733 paragraph 155 states: "Thus, the Commission, while disagreeing with NERC’s interpretation, does not propose to include the below 100 kV elements in figure 3 in the bulk electric system, unless determined otherwise in the exception process.” 

Figure E1.4 is a new figure which changes the previous understanding established by Figure E1.18 which notes that looped Subsystems < 50kV do not effect E1. BES definition E1 Note 2 specifically states “The presence of a contiguous loop, operated at a voltage level of 50 kV or less, between configurations being considered as radial systems, does not affect this exclusion.” In addition Figure E1.18  States:  “The presence of the sub 50 kV loop will not prevent the owner or operator from using this exclusion” which is in direct contradiction to the text for Figure E1.4.

Sub - 50kV loops should not be included in local network Exclusion evaluations but are sufficiently addressed in the BES definition Exemption E1 note 1.

 

 

 

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

BES Definition Comments.pdf

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

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

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The absence of examples or discussion of facilities networked by lines operated under 100 kV with more than two (2) connections at 100 kV in the definition or FERC orders should not follow expansion of the BES Definition by default.  The proposed revision endeavors to interpret the definition and intent of the SDT; this requires a SAR.  All of the above “examples and diagrams” (illustrations) will require the Regional Entity to obtain detailed distribution one lines from responsible entities to verify application of these illustrations since there is no low voltage limit defined.  Section 215 of the Power Act clearly excludes distribution systems from applicability, and it is probable that responsible entities will refuse such a data request from their Regional Entity.  Therefore, it is highly questionable whether these illustrations can be enforced. 

FERC Order No. 773 was silent on making any effort to define distribution systems. Discussion in the Order focused on systems “in the grey” between distribution and transmission.  Further, where distribution was clearly involved with the BES (black start and cranking paths), the discussion was not centered on using the distribution to define the BES, but that its inclusion into the BES is unnecessary.  Rather, the Commission remanded that interconnection systems operated under 100 kV should be considered when defining local networks.  It can be safely assumed FERC was referring to the Bulk Power System elements operated under 100 kV, not distribution systems.  Although the voltage constraint for those systems clearly identified as distribution is not defined, it can be argued that any system distributing power to residential end-use transformers is clearly not BPS. 

Assuming NERC prevails in enforcing data submittals of distribution systems, the resulting impact on Reliability will be adverse.  Resources available for compliance and enforcement are limited; any expenditures on compliance and enforcement related to requirements lacking any reliability benefit will ultimately detract from the greater reliability effort.  Therefore, it is paramount that technical justification be established for inclusion of the figures, of which it is highly doubtful this can be attained for the following reasons.

  1. If the BES SDT and the Commission intended to limit the number of interconnected radial systems for E1 as depicted in the illustrations, it should have been clearly stated.  In Paragraph 42 of RD14-2-00, the Commission states: “Accordingly, we conclude that NERC’s technical analysis for including a 50 kV threshold for excluding certain looped facilities is well supported.”  The Commission does not state: between two (2) looped facilities.  Further the Commission quotes the NERC petition: “[t]he standard drafting team conducted technical analysis including modeling the physics of loop flows through sub-100 kV systems, in order to determine an appropriate threshold.”  Again, the preceding does not state: loop flows through sub-100 kV systems between two radial systems operated above 100 kV.  The BEPWG is providing an interpretation that arguably is in conflict with the standard drafting team’s intent.  Such interpretation questions must be addressed via a SAR, resulting in a revised definition.

  2. Many distribution system feeders operate at 12.47 kV, with a maximum capacity of 400 to 600 amps at the source substation.  This equates to 8.6 to 13 MVA, falling well below any substantial theoretical flow through capability of a system operated between 50 to 100 kV.  This ignores tapering down of conductor size as the feeder progresses away from the substation.  Further, if medium and low voltage networks can be technically justified as impacting the BES, then a similar argument should be proposed for generation resources at any voltage and capability.  Therefore, there is no justification to extend the BES definition into systems at or below 50 kV.  A SAR should be developed to address the lack of clarity in Exclusion E3.

  3. It is highly unusual for a distribution feeder to be operated fully networked (no normal open between two or more independent sources) as depicted in Figure E1.4. Such a connection requires extensive planning to avoid conductor overload under all possible contingencies.  For medium voltage distribution (typically less than 15 kV) as illustrated in Figure E1.4, the reliability capability is very limited. Conductor sizing to allow 20 MVA flow through and support a modest 5 MVA local load would require 1272 kcmil AAC conductors.  Many entities do not even have construction standards to handle such large distribution conductors.  If network connection do exist as depicted in Figure E1.4, it is highly likely the three connections at 100 kV or greater is a single bus connection at a common substation – not three separate substations with independent transmission sources.  For such connections at a single substation bus, requiring the entity to consider the “network” under Exception E3 serves no practicable reliability objective.

  4. Figure E1.20 disallows a normal open switch between two distribution feeders.  This forces a capricious and arbitrary assumption that the normal open can be closed indefinitely.  Such closure would violate protection system design, and safety requirements.  Normal open switches in distribution systems are strictly for temporary closure to allow removal of elements from service without disruption of service to end-users.  Such closures should last as short a duration as possible to limit risk of a fault during switching. Further, normal opens are closed with care to assure no substantial current flow will proceed across the switch.  Many switches can’t be opened or closed under load, and the switching operation must be postponed if such condition is present. For networks below 50 kV, the question is not what it can do the BES, but what the BES can do to the distribution.  Requiring network expansion over distribution normal opens below 50 kV serves no reliability objective; a SAR should be advanced to revise the definition to avoid nuisance exception requests.

  5. Generation plants will normally have several backup station service normal opens to allow fast restoration of plant service power after a failure of the main station service. Operational voltage of plants frequently are 480 volts three-phase.  Backup power can be sourced from a nearby distribution system having no direct association with the generation transmission other than the normal open(s) between the station service step-down transformers sourced from the generator output bus.  The proposed revised reference document implies such opens shall be considered closed.  This is clearly an unintended expansion of the definition.

  6. Many of the BES self-determined notices (SDN) did not account for normal opens in the distribution at or below 50 kV.  The Regional Entities and NERC did not require fully detailed distribution one lines.  The proposed revision will add compliance burden not specified in the definition, the current BES Definition Reference Document, or the FERC orders.

  7. Not all normal opens can be closed into a network condition.  Forcing responsible entities to consider normal opens as closed when such action would cause a system fault is technically unsound.  Further, requiring responsible entities to submit an Exception for such opens presents unnecessary bureaucratic paperwork. For normal opens that separate two systems at differing voltages or which will not phase – example, delta/wye system to wye auto transformer system – should be considered always open; network flow in such cases is not possible.

Russell Noble, On Behalf of: Cowlitz County PUD, , Segments 3, 5

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Page 88.  For clarity the NSRF recommends that the non-BES generators in figure E3-1, E3-2, and E3-3 be colored green.

NSRF disagrees with diagram E1.20 showing a copy of diagram E1.18 with an additional third source with a normal open switch. This diagram is in conflict with the language at the beginning of this section (shown below).

Normally Open Switching Device

Radial systems should be assessed with all normally open (N.O.) devices in the open position. N.O. devices installed at any voltage level will not prevent the owner or operator from using this exclusion. The N.O. device(s) must be identified as such on prints and one-line diagrams that are used by the operating entity.

E1.20 should be removed since a normal open switch is to be treated as normally open. The added third source is radial and does not impact the networked other two sources.  The other two sources should then be treated as the same as E1.18.

In the alternative, if the normally open is removed and the diagram is changed so the third source is connected to the first two, then the diagram would provide useful information.

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

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

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The idea that a sub-100 kV loop (< 50 kV) with multiple points of connection (more than two 2) invalidates the BES Exclusion E1 is not supported by any of the text of the Exclusion E1. There is no mention of the number of connection points in Note 2. It simply states that “the presence of a contiguous loop, operated at a voltage level of 50 kV or less, between configurations being considered as radial systems, does not affect this exclusion. There is no mention of or limitation to the number of connections in the <50 kV system that provide for the contiguous operation. The concept that more than 2 such connections at <50 kV results in some internal network that affects the BES (and should invalidate the radial status of the connected transmission facilities) seems to be the product of the BEPWG and has no basis in any technical studies. The diagrams are included in the Bulk Electric System Reference Document to, as stated on page 1, “only show application of the definition to the specific Element in question.” The use of a diagram that clearly deviates from the E1 definition is not only confusing, it is harmful if the intent of the BEPWG is to actually propose a revision to the E1 definition without actually vetting the proposed language change to the Exclusion. All occurrences in the proposed Bulk Electric System Reference Document (August 2018) where a diagram deviates from the clear text of the E1 definition should be eliminated or revised in favor of the text. That would include Diagrams E1.3, E1.4, E1.20.

Clark believes that any sub-100 kV loop (<50 kV) operated in a looped fashion with multiple points of connection (more than two 2) has no impact on the validity of utilizing a radial exclusion for connected transmission facilities. Technical reasoning for Note 2 was addressed in the original BES Definition proceedings. Until additional technical reasoning is produced and made available to the balloting body for review that demonstrates that looped facilities operating at <50 kV with more than 2 connections do provide some impact on a radial exclusion, Clark will oppose any attempt to invalidate this Exclusion either by actual proposed changes to the E1 Exclusion text or by the use of confusing and incorrect diagrams such as Figure E1.4.

A major problem with these diagrams is that it will compel Transmission Owners and Distribution Provides to provide detailed maps of their systems that are operating at <50 kV to prove that there are no more than 2 connections in the loop. Since it has already been demonstrated that looped systems operating at <50 kV do not have an impact on any radial transmission systems these loops are connected to, the main result of these diagrams will be the production of many detailed diagrams of distribution system connections that are irrelevant to the safe and reliable operation of the BES.

It appears the BEPWG would prefer that entities seeking exclusions based on E1 instead utilize E3 for sub-100 kV loop (<50 kV) operated in a looped fashion with multiple points of connection (more than two 2). This may have no effect on the eventual exclusion of a specific transmission element however, E3 has additional requirements to demonstrate that a local network exists (i.e. power flows in but not out). E1 only requires that a facility be connected at a single point and only serve load (or have limited generation connections). Clark believes that if for some reason a utility prefers to seek an E3 exclusion for a facility rather than an E1 exclusion, that should be the decision of the TO or DP but as long as the text of exclusion E1 does not prevent such a determination, the BES Definition diagrams should not be used to provide a change to the Exclusion. Clark believes the main purpose of Exclusion E3 is for an exclusion of facilities that do not meet the textual definition of Exclusion E1 but still do not provide adverse impacts to the BES when operated in a looped fashion. This would be applicable to looped systems up to 300 kV. Since a <50 kV looped system with multiple connections has already been shown to have no adverse impact on a radial exclusion, there is no need for a TO or DP to go through the effort of producing technical justification for this exclusion.

Jack Stamper, On Behalf of: Clark Public Utilities, , Segments 3

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I support the comments of Russell Noble of Cowlitz County PUD.

Steve Alexanderson, On Behalf of: Steve Alexanderson, , Segments 3, 4

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Figures E3.6, E3.8, E3.10, and E3.12: (PDF Pages 72, 74, 76, and 78):

Figures E3.6 and E3.10 have bullets speaking specifically to the assumption that BES Generation Inclusions have been considered and do not apply; however, Figures E3.8 and E3.12 do not have similar bullets. If BES Generation Inclusion tests are applicable to all E1 and E3 assessment types, please update diagrams for consistency.

PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 9/6/2018

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BPA believes the illustration and comments in figures E1-4, E1-20, E3-6, E3-7, E3-10, and E3-11 appear to directly contradict FERC Order 773 regarding <50 kV looped facilities and the written Definition guidance for Exclusion E1.

Note 2 in the Introduction regarding Exclusion E1, and page 33 in Chapter E1 states:

“– The presence of a contiguous loop, operated at a voltage level of 50 kV or less, between configurations being considered as radial systems, does not affect this exclusion.”

This is reiterated in Chapter E1 on page 33 when referencing FERC Order 773:

“FERC Order No. 773 directed implementation of the revised BES definition to take into account the impact of sub-100 kV looped Facilities regardless of voltage level altering previous guidance on the evaluation of radial systems. This meant that if there was a connection at the sub-100 kV level between two systems that would previously have been considered as radial, said systems could not be evaluated for possible radial system exclusion. However, the drafting team developed a technical justification establishing 50 kV as a threshold value for sub-100 kV looped facilities. If the sub-100 kV loop is 50 kV or less, it was shown that it would not have an impact on the BES, and thus an entity could still apply Exclusion E1 to the configuration. If the loop in question was greater than 50 kV, then an entity could not consider the systems as radial and would need to evaluate them under the criteria of Exclusion E3 if seeking to exclude the Facilities from the BES.”

Based on this language, the <50 kV loops depicted in figures E1-4, E1-20, E3-6, E3-7, E3-10, and E3-11 should be irrelevant and not preclude utilization of E1. The figures seem to be incorrect and very misleading. They should be removed to prevent causing unnecessary work and documentation.

Common industry practice is to keep transmission level onelines (i.e. 230 kv, 115kV…) separate from detailed distribution level onelines (i.e. 13.8kV, 12.5kV). When making BES determinations, the transmission onelines are used. A radial line will usually show as far as the distribution substation, the low voltage (<50 kV) bus at 12.5 kV for example, and simply be “Load” from there on. Under the written definition, this is sufficient documentation to justify analyzing an E1 exclusion. However if these new figures are directing the full distribution onelines to be created or obtained and provided and potentially two years of integrated hourly SCADA data to be analyzed and provided, now all these former E1 exclusions would require a tremendous amount of time and resources to prove their exclusion under the E3 Exclusion criteria. The industry practice is to operate distribution lines radially and avoid creating parallel transmission paths so as to ensure small distribution line conductors do not inadvertently become parallel transmission paths and overload. Because of this, in the end, the results of being excluded would be the same, but the time and resources wasted on completely unnecessary documentation steps simply because of a misleading figure revision would be an unjustified burden on the utility industry, especially when FERC Order 773 already deemed it irrelevant.

Proposed revision: Delete figures E1-4, E1-20, E3-6, E3-7, E3-10, and E3-11 and their respective comments as they seem to contradict the written Definition guidance as well as defy FERC Order No. 773 and the drafting team’s technical justification that loops below 50 kV do not have an impact on the BES, and thus an entity could still apply Exclusion E1 to the configuration.

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

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Peak agrees with adding the diagrams. While Peak understands the local network exclusion it fundamentally disagrees with the concept as not being strict enough in how a local network is defined and feels the concept can be too easily misapplied.

Scott Downey, On Behalf of: Scott Downey, , Segments 1

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

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Comments: Diagrams E1.4 and E1.20 contradict the NERC Glossary Definition.   They show that sub 50 kV loops between substations disqualify those substations from using exclusion E1.  However, the NERC Glossary Definition of BES under E1 states “Note 2 – The presence of a contiguous loop, operated at a voltage level of 50 kV or less, between configurations being considered as radial systems, does not affect this exclusion.”    Please revise these diagrams.

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Manitoba Hydro, Segment(s) 5, 3, 6, 1, 8/8/2017

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Do the boxes in figure E3.3 represent a breaker configuration or a substation configuration? We believe the breaker configuration does matter. If a breaker separates two generators from the BES within the same substation, then they should not be considered the same point of interconnection. A line and substation versus bus bar and breakers does not provide for any addition to reliability.

Cooper Compliance Corp, Segment(s) 3, 5, 1, 9/7/2018

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The revision to Section III.1 BES Exclusion E1 has added example diagrams that do not correlate with the BES Exclusion E1 based on the plain reading of the exclusion.  Specifically, example diagram shown in Figure E1.4 shows three transmission lines that emanate from different points in the system, but are connected by a sub-50kV loop.  The example diagram explains that Exclusion E1 cannot be used, which appears to be contradictory to   the language of the BES Exclusion E1, which does not limit the number of points through which a contiguous loop operated at 50 kV or less connects to the BES.  The orange explanation box associated with Figure E1.4 seems to imply, but does not state, that the reason for not being able to use BES Exclusion E1 is the fact that there are more than two (2) points of connection for the sub-50kV loop and the BES. 

A plain reading of BES Exclusion E1 does not readily identify a limitation on the number of points of connection for a sub-50kV loop nor are points of connection specifically defined or discussed.  Further, Figure E1.2 depicts an application for BES Exclusion E1 that is identical with the exception of the number of points of interconnection, e.g., two points of connection vs, three points of interconnection.  Again, AZPS notes that it could not identify any language within BES Exclusion E1 that indicates that its applicability is reliant or dependent upon a certain number of interconnection points.  Accordingly, the number of points of interconnection appears to be and should be irrelevant for eligibility of facilities to utilize BES Exclusion E1, e.g., BES Exclusion E1 should apply regardless of whether there are two points of connection or three points of connection associated with a sub-50kV loop.

Accordingly, based on the language of Exclusion E1, all three lines of Figure E1.4 that are associated with the sub-50kV loop would be excluded because any connection between the three lines is through a network with a voltage less than 50 kV, which by definition is not a factor.  AZPS is concerned that the example diagram provided in Figure E1.4 does not accurately reflect the written definition of BES Exclusion E1 and, therefore creates confusion and ambiguity for Registered Entities as to whether facilities that are configured similarly would qualify for BES Exclusion E1.   While the plain language of BES Exclusion E1 does not address the number of connections as either a limitation or criteria, Figure E1.4 appears to be attempting to modify BES Exclusion E1 to artificially narrow its applicability.  A similar diagram is found in Figure E1.20. 

AZPS respectfully requests that these diagrams be reviewed and either modified or removed to ensure consistency with the plain language of BES Exclusion E1.

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

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p. 40,  Fig. E1-4 – The changes proposed in this figure (and other figures identified below) significantly changes how sub-50kV loops (see Note 2) impact whether certain facilities satisfactorily meet Exclusion E1 for excluding certain radial facilities from the BES.  Such a significant change to how Exclusion E1 is used, cannot simply be done through a revised reference document.  A change of this magnitude must be addressed in a Request for Interpretation or through a proposed SAR to revise the BES definition.  Simply stated, sub-50kV loops (see Note 2) between radial systems do not constitute looped interconnections under the BES definition.  The BES definition drafting team performed significant analysis regarding loops and their impacts on the BES.  Based on that analysis, it was determined that sub-50kV loops are not considered looped interconnections under the BES definition.  In this figure, based on the sub-50kV loops, there should be three separate radial systems that meet the language in Exclusion E1 for exclusion from the BES.  This added figure should be removed as it is not consistent with the current BES definition. Additional figures subject to these same comments are p. 72, Figure E1-20 and p. 100, Figure E3-7.

p. 77, Net Capacity section – Adding “under all operating conditions” is counter to the language in the next sentence and is not in any way intended by the current BES definition.  We recommend that this language be removed as the current language in this section is clear and unambiguous.

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

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National Grid supports Edison Electric Institute’s (EEI) comments, likely to be submitted by EEI after September 10.  In particular, National Grid does not agree with the interpretation of Note 2 of BES Exclusion E1 (Radial systems) as illustrated in Figures E1.4 and E1.20, Figures E3.6 and E3.7, as well as Figures E3.10 and E3.11.  National Grid strongly suggests Figures E1.4 and E1.20, Figures E3.6 and E3.7, as well as Figures E3.10 and E3.11 to be removed from the Bulk Electric System Definition Document.

National Grid, Segment(s) 1, 3, 10/30/2017

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Douglas Johnson, On Behalf of: Douglas Johnson, , Segments 1

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It seems to ELCON that the “more than 2 connections” rule is inferred from an example used by FERC in their order approving the most recent Definition of the Bulk Electric System.  In ELCON’s view, the Commission used this example for purposes of explanation; not to set a literal expectation of the only acceptable configuration. 

A straight-forward interpretation of E1 Note 2 bears out our position.  It states the “presence of a contiguous loop, operated at a voltage level of 50 kV or less, between configurations being considered as radial systems, does not affect this exclusion.”  There is no mention that “between configurations” is limited to two radial networks.  As such, this interpretation is in conflict with the vetted and approved Definition of the Bulk Electric System.  Furthermore, the limitation serves no reliability purpose. 

ELCON sees the further inclusion of radial systems with connections below 50 kV as a violation of the FPA’s intent in Section 215(a).  This can change only if such a configuration is shown to be the root cause of a BES event or if a comprehensive system vulnerability analysis confirms a reliability threat exists. Since that has not occurred, the interpretation is invalid.

Along the same lines, there is no justification for the interpretation of Note 1 that a normally open switch does not affect the use of Exclusion E1.  It clearly states that a “normally open switching device between radial systems, as depicted on prints or one-line diagrams for example, does not affect this exclusion.” There is no provision for the number of radial networks under evaluation, or the operating voltage of the normally open switch. 

ELCON believes that this means that if three radial networks are connected below 50 kV – and one of the connections is through a normally open switch – only the two always-connected networks would be considered for an E1 exclusion.  The third would be assessed independently.

John Hughes, On Behalf of: John Hughes, , Segments 7

ELCON Comments - Definition of the BES 9-7-18.docx

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The proposed revisions are unsupported by, and indeed conflict with, the BES Definition.  Proposed Figures E1.4 and E1.20 should be revised to indicate that Exclusion E1 applies in both cases, as each diagram depicts three radial systems.  Proposed new Figures E3.6, E3.7, E3.10, and E3.11 should be deleted, as the systems depicted should be evaluated and excluded under E1.  (The exceptions process is of course always available to add any otherwise-excluded facilities to the BES that have a material impact on reliability due to an atypical configuration or other circumstances.)

Note 2 to E1 states: "The presence of a contiguous loop operated at a voltage level of 50 kV or less, between configurations being considered as radial systems, does not affect this exclusion."  Had the SDT intended that only 2 connection points be permitted, they would have instead written "between no more than two configurations."  

If there were a reliability concern with the current, unbounded Note 2, the BES Definition would need to be revised.  But there does not appear to be any reliability gap; the September 2013 White Paper that NERC submitted to FERC as part of its December 2013 filing in support of Note 2, and on which FERC relied in approving Note 2, indicates that the impedance of the "looped" system is primarily determined by the voltage level.  The number of connection points (number of transformers) should not be expected to play a significant role in the relative impedance of the lower-voltage loop.  There is no engineering reason why adding an additional connection point to a system would significantly increase that system’s reliability impact, provided that all connection points remain internally connected at less than 50kV.  The White Paper’s use of 2 points of connection for modeling purposes was a reasonable simplifying assumption, not an implicit limitation on the applicability of Note 2.

Proposed new Figure E1.20 compounds the problems with proposed Figure E1.4 by asserting that a normally open device on the 50kV loop does not change the fact that the system has 3 points of connection and thus will not be considered under E1.  This question should never arise in the first place, since the system in Figure E1.20, like the system in Figure E1.4, would qualify for E1 under Note 2 even without the normally open device.  But it nevertheless bears pointing out that the proposed treatment of the normally open device in Figure E1.20 is inconsistent with the text of the BES definition--pursuant to E1 Note 1, “A normally open switching device between radial systems, as depicted on prints or one-line diagrams for example, does not affect this exclusion.”  A N.O. device is considered open for BES determination purposes, so the configuration in E1.20 is effectively two separate radial systems, one of which includes a sub-50kV loop.  

We also note an unrelated error--according to the Table of Contents, the generator in Figure E1.6 should be non-BES, but instead, in the clean revised version, Figure E1.6 appears to be a repeat of Figure E1.5, with the original version of Figure E1.5 mistakenly deleted.

Rebecca Baldwin, On Behalf of: Transmission Access Policy Study Group, NA - Not Applicable, Segments 4

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

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

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

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APPA does not agree with the proposed revisions to Section III.1 associated with Exclusions, E1 and E3. The revisions are unsupported by, and conflict with, the BES Definition.  Proposed Figures E1-4 and E1-20 should be revised to indicate that Exclusion E1 applies in both cases, as each diagram depict three radial systems. Otherwise removal is recommended. Proposed new Figures E3-6, E3-7, E3-10, and E3-11 should be deleted, as the systems depicted should be evaluated and excluded under E1. 

The changes proposed in figure E1-4 (and other figures identified below) significantly change how sub-50kV loops impact whether certain facilities satisfactorily meet Exclusion E1 for excluding certain radial facilities from the BES. Such a significant change to how Exclusion E1 is used, cannot simply be done through a revised reference document. A change of this magnitude should  be addressed in a Request for Interpretation or through a proposed Standard Authorization Request (SAR) to revise the BES definition. Simply stated, sub-50kV loops between radial systems do not constitute looped interconnections under the BES definition. The BES definition drafting team performed significant analysis regarding loops and their impacts on the BES.  Based on that analysis, it was determined that sub-50kV loops are not considered looped interconnections under the BES definition. In this figure, based on the sub-50 kV loops, there should be three separate radial systems that meet the language in Exclusion E1 for exclusion from the BES.  

FERC supported the BES SDT’s analysis for radial systems and sub-50 kV facilities. In Paragraph 42 of RD14-2-00, the Commission stated: “Accordingly, we conclude that NERC’s technical analysis for including a 50 kV threshold for excluding certain looped facilities is well supported.” The Commission does not state: between two (2) looped facilities.  Further the Commission quotes the NERC petition: “[t]he standard drafting team conducted technical analysis including modeling the physics of loop flows through sub-100 kV systems, in order to determine an appropriate threshold.”  The BEPWG is providing an interpretation beyond what the BES SDT addressed in the standard and should be addressed in a SAR seeking to revise the definition.  

Jack Cashin, On Behalf of: American Public Power Association, , Segments 4

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 A non-BES example would help demonstrate the application of Exclusion 1 in Figures E1.5-E1.7. Please refer to Figure E1-5 from the April 2014 (v2) version.    

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

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Duke Energy disagrees with the revisions made for E3. It is not clear why “more than two (2) connections” is being used when referring to connection points. What was the BEPWG’s logic in picking the number of connection points of 2? Does this mean that connection points of 2 or less should not be included for E3? Is the BEPWG intending to eliminate the 50kV cutoff that was previously understood by industry? Please clarify the use of “more than two (2) connections”.

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

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See attached.

Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

Hydro One - BES reference document revision - Q3.docx

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The introductory caption to Figure E1.4 states that it depicts a configuration “that contains a sub-100kV loop (less than 50kV) with multiple points of connection (more than two(2)), which cannot be evaluated under the criteria established in Exclusion E1 and can only be evaluated under the criteria established in exclusion E3 (See Figure E3.6 and E3.7).” The problem with this description is that it doesn’t clearly point to the “multiple points of connection” to the ≥100kV lines as the disqualifier for E1 analysis, and thus could be misleadingly interpreted as pointing to the two sub-50kV loops connecting the contiguous facilities as the “points of connection” that are disqualifying.  This would be inconsistent with Note 2 of Exclusion E1, which states that “the presence of a contiguous loop operated at a voltage level of 50kV or less, between configurations being considered as radial systems, does not affect this exclusion.”

  

To avoid confusion, Southern would recommend a more specific and clarified description of Figure E1.4 such as the following:

 

“Figure E1.4 depicts a configuration that contains two sub-100 kV loops (i.e., <50kV) connecting contiguous facilities that are also connected to three separate and unconnected ≥100kV transmission lines.  Therefore, the contiguous transmission elements do not emanate from a “single” point of connection of 100kV or higher, and thus cannot be evaluated under the criteria established in Exclusion E1.  Instead, they may only be evaluated under the criteria established in Exclusion E3 (See Figure E3.6 and E3.7).” 

 

This would more clearly emphasize that the disqualifier relates to the multiple ≥100kV line connections to which the contiguous facilities are connected, and that, consistent with Note 2, the presence of the two sub-50kV lines connecting the contiguous facilities do not affect the evaluation.

 

In addition, the orange text box in Figure E1.4 seems to misleadingly state that “the presence of the sub-50kV loops … establishes multiple points of connection”. Instead it should simply state that the presence of multiple points of connection (notwithstanding the sub-50kV loop) to more than two unconnected ≥100kV lines prevents the scenario from being analyzed under Exclusion E1.

 

Similar clarifications should also be made to Figure E1.20.

Southern Company, Segment(s) 1, 3, 5, 6, 10/30/2017

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With the incorporation of the comments provided in Question 6 below, Reclamation supports the revisions to Section III.1 and III.3.

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

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Tri-State agrees with the comments made by the NRECA.

Specifically, Tri-State believes figures E1-4, E1-20, E3-7, and E3-11 are contrary to Note 2 within the approved BES definition, with regards to considerations of sub-50kV loops. Furthermore, diagrams E3-6 and E3-10 should be evaluated under E1 for Radial Systems rather than E3 Local Networks due to Note 2. 

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

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SPP Standards Review Group (SSRG), Segment(s) 2, 1, 3, 5, 6, 9/10/2018

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FMPA agrees with the following comments submitted by APPA:     APPA does not agree with the proposed revisions to Section III.1 associated with Exclusions, E1 and E3. The revisions are unsupported by, and conflict with, the BES Definition.  Proposed Figures E1-4 and E1-20 should be revised to indicate that Exclusion E1 applies in both cases, as each diagram depict three radial systems. Otherwise removal is recommended. Proposed new Figures E3-6, E3-7, E3-10, and E3-11 should be deleted, as the systems depicted should be evaluated and excluded under E1.

 

The changes proposed in figure E1-4 (and other figures identified below) significantly change how sub-50kV loops impact whether certain facilities satisfactorily meet Exclusion E1 for excluding certain radial facilities from the BES. Such a significant change to how Exclusion E1 is used, cannot simply be done through a revised reference document. A change of this magnitude should  be addressed in a Request for Interpretation or through a proposed Standard Authorization Request (SAR) to revise the BES definition. Simply stated, sub-50kV loops between radial systems do not constitute looped interconnections under the BES definition. The BES definition drafting team performed significant analysis regarding loops and their impacts on the BES.  Based on that analysis, it was determined that sub-50kV loops are not considered looped interconnections under the BES definition. In this figure, based on the sub-50 kV loops, there should be three separate radial systems that meet the language in Exclusion E1 for exclusion from the BES. 

 

FERC supported the BES SDT’s analysis for radial systems and sub-50 kV facilities. In Paragraph 42 of RD14-2-00, the Commission stated: “Accordingly, we conclude that NERC’s technical analysis for including a 50 kV threshold for excluding certain looped facilities is well supported.” The Commission does not state: between two (2) looped facilities.  Further the Commission quotes the NERC petition: “[t]he standard drafting team conducted technical analysis including modeling the physics of loop flows through sub-100 kV systems, in order to determine an appropriate threshold.”  The BEPWG is providing an interpretation beyond what the BES SDT addressed in the standard and should be addressed in a SAR seeking to revise the definition

FMPA, Segment(s) , 10/23/2017

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

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It seems to Oxy that the “more than 2 connections” rule is inferred from an example used by FERC in their order approving the most recent Definition of the Bulk Electric System.  In Oxy’s view, the Commission used this example for purposes of explanation; not to set a literal expectation of the only acceptable configuration. 

A straight-forward interpretation of E1 Note 2 bears out our position.  It states the “presence of a contiguous loop, operated at a voltage level of 50 kV or less, between configurations being considered as radial systems, does not affect this exclusion.”  There is no mention that “between configurations” is limited to two radial networks.  As such, this interpretation is in conflict with the vetted and approved Definition of the Bulk Electric System.  Furthermore, the limitation serves no reliability purpose. 

Oxy sees the further inclusion of radial systems with connections below 50 kV as a violation of the FPA’s intent in Section 215(a).  This can change only if such a configuration is shown to be the root cause of a BES event or if a comprehensive system vulnerability analysis confirms a reliability threat exists. Since that has not occurred, the interpretation is invalid.

Along the same lines, there is no justification for the interpretation of Note 1 that a normally open switch does not affect the use of Exclusion E1.  It clearly states that a “normally open switching device between radial systems, as depicted on prints or one-line diagrams for example, does not affect this exclusion.” There is no provision for the number of radial networks under evaluation, or the operating voltage of the normally open switch. 

Oxy believes that this means that if three radial networks are connected below 50 kV – and one of the connections is through a normally open switch – only the two always-connected networks would be considered for an E1 exclusion.  The third would be assessed independently.

Oxy, Segment(s) 7, 5, 9/6/2016

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The revisions to Section III.1 BES Exclusion E1 & Section III.3 Exclusion E3 to include examples and diagrams associated with networked facilities that have multiple (more than two (2)) connections at 100 kV or above do not illustrate how these facilities should be evaluated and are inconsistent with the BES definition as drafted and approved and should be removed for the guidance document.

 

Note 2 of the BES Definition E1 exclusion reads:

“The presence of a contiguous loop operated at a voltage level of 50 kV or less, between configurations being considered as radial systems, does not affect this exclusion.”

The BEPWG revision interprets this language to mean it can only apply if there are 2 connections to the loop configuration and more that 2 connections would prohibit the use of this exclusion. It is unclear where this new interpretation originated from. The language of the exclusion provides no indication of the number of connections the note applies to. Further, the note was subject of a significant amount of scrutiny though the BES definition development process and the BEPWG interpretation disregards this.

 

For historical reference, this note was not included during the Phase 1 development of the BES definition and was only drafted for Phase 2 in response to FERC’s interpretation of the exclusion in order 773, approving the BES definition (Phase 1). In Order 773 FERC disagreed with NERC interpretation.

        

NERC’s Interpretation from Order 773:

152. NERC further explains that the focus of the definition of bulk electric system is on looped or networked connections at or above 100 kV. According to NERC, connections operated below 100 kV, generally do not carry significant parallel flow due to the higher impedance of lower voltage facilities. If such facilities are necessary for the reliable operation of the interconnected transmission network, NERC states that the exception process can be used to include such facilities.

 

FERC’s Response:

155. The Commission finds figure 3, which is identical to figure 5, is a networked configuration through a 69kV loop and does not qualify for exclusion E1. The Commission also finds that, because the load in figure 3 can be served by either 230 kV line, it does not depict a “radial system.”

 

The Phase 2 revision of the BES definition was initiated in part due to this interpretation by FERC and resulted in the addition of the E1 Note 2 related to sub-50kV looped configurations and their impact on the E1 exclusion.  NERC conducted a technical analysis and determined “based on the above analysis, it concluded that a 50kV threshold for sub-100 kV loops does not preclude the application of exclusion E1 (Paragraph 12 of order RD14-2-000).”

 

FERC Accepted this as follows:

42. We find that NERC’s modification to exclusion E1, to add a 50kV threshold for excluding certain radial loops, is reasonable. We find that NERC’s technical justification based on the scenarios and configurations utilized in its analysis supports the selection of a 50kV threshold and represents the vast majority of configurations that will be encountered in the industry. As explained by NERC, “[t]he standard drafting team conducted technical analysis including modeling the physics of loop flows through sub-100 kV systems, in order to determine an appropriate threshold.”45 Further, the NERC White Paper explains that “the Standard Drafting Team conducted extensive simulations of power flows which demonstrated that there is no power reversal into the BES when circuit loop operating voltages are [50 kV or less]. Therefore, the study concludes that low voltage circuit loops operated [at 50 kV or less] should not affect the application of Exclusion E1.”46 Accordingly, we conclude that NERC’s technical analysis for including a 50kV threshold for excluding certain looped facilities is well supported. Moreover, NERC’s approach is also consistent with the bright-line threshold concept in the definition which is designed to eliminate ambiguity (Paragraph 42 of order RD14-2-000).

 

There is no indication in the Order approving the Phase 2 addition of E1 Note 2 that this would only apply in situations where there were only 2 connections. The order describes the technical analysis conducted by NERC and states there is no power reversal into the BES when circuit loop operating voltages are sub-50kV. The BES definition Phase 2 drafting team conducted significant technical analysis to provide the justification for this specific language and the interpretation that multiple connections would not impact the Exclusion E1, regardless of the number of connections.

 

Based on the analysis conducted by NERC and the approval of the Note 2 language by FERC, the number of connections into a sub-50kV system are irrelevant and the revised interpretation by the BEPWG is inappropriate and inconsistent with the definition as approved. These revisions should be removed from the document.

Additionally, when examining diagram E1.20, it is unclear what justification is in use to specify that this is not applicable to the E1 radial system exclusion. The Phase 1 BES standard Drafting team established the following language to address normally open breakers in response to FERC interpretation:

Note 1: A normally open switching device between radial systems, as depicted on prints or one-line diagrams for example, does not affect this exclusion.

 

There is no indication of the voltage class at which this note applies in either the definition of in Order 773, paragraphs 176 and 177 accepting the concept of normally open switching devices. The BEPWG is changing the interpretation of the normally open switching device by only applying it for Facilities operated at 100kV to the detriment of reliability. Distribution systems will have to perform a cost benefit analysis when installing additional connections to other systems (BES or Non-BES). While these connections enhance reliability and improve the ability to serve customer load these systems they may see a significant expansion in compliance obligation, even if these are only used as emergency back-up supply. This diagram should be revised to indicate that all the 100kV connections are E1 applicable Radial systems.

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

FERC Order 773 Figure 3.docx

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Hot Answers

Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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John Pearson, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

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Other Answers

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

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

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

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Figures E2.5 and E2.4 have merit, but Figure E2.3 is questionable since it duplicates Figure E2.5 in part.

Russell Noble, On Behalf of: Cowlitz County PUD, , Segments 3, 5

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

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

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Jack Stamper, On Behalf of: Clark Public Utilities, , Segments 3

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I support the comments of Russell Noble of Cowlitz County PUD.

Steve Alexanderson, On Behalf of: Steve Alexanderson, , Segments 3, 4

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None

PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 9/6/2018

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No comment.

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

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Scott Downey, On Behalf of: Scott Downey, , Segments 1

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

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Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Manitoba Hydro, Segment(s) 5, 3, 6, 1, 8/8/2017

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We agree if clarifications are made to identify that the breaker configuration does matter. If a breaker separates two generators from the BES within the same substation, then they should not be considered the same point of interconnection. A line and substation versus bus bar and breakers does not provide for any addition to reliability.

Cooper Compliance Corp, Segment(s) 3, 5, 1, 9/7/2018

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In Section III.3 BES Exclusion E2, AZPS notes that the proposed revisions added the phrase “under all operating conditions” on p. 77 of the redlined document.  AZPS disagrees with the addition of the phrase “under all operating conditions” and recommends changing the phrase to “under normal operating conditions.”  AZPS is concerned that the revision (as proposed) removes the capability of registered entities to exclude abnormal system events from the net capacity, which could result in facilities fluctuating in and out of the BES definition solely as a result of an abnormal system condition.  Such was not the intention of the development of the definition and criteria of the BES definition, which was intended to capture those facilities that made up or significantly impacted the BES – not ancillary facilities that may have an insignificant impact during a system event.  AZPS recommends that the SDT withdraw the proposed addition of the phrase “under all operating conditions” as it is inserted on p. 77 of the redlined document.

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

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

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National Grid supports Edison Electric Institute’s (EEI) comments.

National Grid, Segment(s) 1, 3, 10/30/2017

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Douglas Johnson, On Behalf of: Douglas Johnson, , Segments 1

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See ELCON's response to Question 2.

John Hughes, On Behalf of: John Hughes, , Segments 7

ELCON Comments - Definition of the BES 9-7-18.docx

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Rebecca Baldwin, On Behalf of: Transmission Access Policy Study Group, NA - Not Applicable, Segments 4

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

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

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Though we agree with the proposed changes, we have the following suggestion.

It would be helpful if the SDT defined net capacity even more explicitly. For example, The Net Capacity determination for exclusion E2 is the maximum hourly value of the most recent 12 month period under all operating conditions of the net aggregated flow (calculated or measured MVA value when MWs flow to the BES) from retail generating unit(s) with a common point(s) of connection at or above 100 kV to the BES as measured by integrated hourly revenue metering.

There has been considerable regulatory review of the E2 exclusion by Québec’s regulator, the Régie de l’énergie, which, like FERC, approves standards but obviously only for application in Québec. The suggested improvements are good. However, it would be helpful if the SDT defined net capacity even more explicitly.

 

 

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

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Jack Cashin, On Behalf of: American Public Power Association, , Segments 4

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

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Duke Energy recommends that the BEPWG consider expanding or clarifying what is meant by use of the term “retail” when referencing “behind the retail meter generators” throughout the Inclusion diagrams as well as Exclusion E2. Does “retail” as referred to in the document pertain to a customer, or a system? Is “retail” supposed to mean the opposite of “wholesale”? Further clarification on the use of the term would be beneficial for the industry.

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

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See response to Question 1.

Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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Southern Company, Segment(s) 1, 3, 5, 6, 10/30/2017

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With the incorporation of the comments provided in Question 6 below, Reclamation supports the revisions to Section III.3.

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

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

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Please see Comment 1 for suggestion to include Figure I2-3 in section E2.

SPP Standards Review Group (SSRG), Segment(s) 2, 1, 3, 5, 6, 9/10/2018

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it should be clarified what "behind-the-meter" means, technically all generation is "behind-the-meter" , for compliance purposes this needs to be defined.  It is assumed an example of behind the meter generation would be retail customer solar generation but this needs to be clarified.

FMPA, Segment(s) , 10/23/2017

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

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Occidental Chemical Corporation (Oxy) appreciates the examples and diagrams added by the BEPWG to clarify the assessment of behind-the-meter generation.  We could find no issue with the processes described that determine whether such generation should initially be considered part of the BES (or not).

However, there was not a clear correspondence between the configurations shown in Inclusion I2 versus those in Exclusion E2.  This is particularly important for those I2 assessments that result in a positive outcome (i.e.; the behind-the-meter generation is part of the BES).  Since those must be subsequently evaluated under the E2 criteria, a one-to-one correlation would help immensely.

As an example, Diagram I2.8 shows two separately metered behind-the-meter generators located at a single plant.  Both have been identified under I2 as part of the BES.  However, the most closely matching diagram under Exclusion E2 is E2.3 – and it shows both generators are served by a single meter.  OXY believes that the total net MVA delivered to a single point of interconnection is the key factor; which is not affected by the number of meters.  However, it may be better if both configurations are illustrated in I2 and E2 to eliminate any confusion on the topic.

Oxy, Segment(s) 7, 5, 9/6/2016

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

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Hot Answers

Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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John Pearson, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

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Other Answers

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

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The NERC Rules of Procedure (ROP) contain a definition for the term “Bulk Power System” in ROP Appendix 2. In the BES Reference Document, the team changed it to the undefined term “bulk power system” – see clean page iii.  Although it’s not a Glossary term, it is used in both FERC orders that define the BES since “Bulk-Power System” is defined in the Federal Power Act. The defined term “Bulk Power System” should be restored with this footnote.

“The term “Bulk Power System,” while not a NERC Glossary term, is defined in Appendix 2 of the NERC Rules of Procedure and in the Federal Power Act. It is used in the FERC proceedings that define BES.

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

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

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Removal of the second paragraph in the Summary appears to be an attempt to buttress arguments for the proposed addition of compliance obligations for Figures E1.4, E1.20, E3.6, E3.7, 3.10, and E3.11.  This paragraph was authored by the BES Standard Drafting Team, and provides insight on their intent concerning “the impact of sub-100 kV looped Facilities regardless of voltage level.”  From this paragraph the statement “it was shown that looped facilities below 50 kV had no impact on the reliability of the BES” does not place a limiting number on the facilities which may be linked together by elements operated below 50 kV.  Should the BEPWG continue in this track, a formal request for SDT interpretation or SAR should be submitted to clarify this matter. 

Notwithstanding the above, the proposed revision concerning ownership has merit.

Russell Noble, On Behalf of: Cowlitz County PUD, , Segments 3, 5

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 Page vi, Summary section, first paragraph, last sentence; capitalize the F in the last word facilities to Facilities.  This clearly shows that the ac and dc electrical Facilities are aligned with the NERC Glossary.

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

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

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Clark believes the proposed deleted paragraph that reads “FERC Order No. 773 directed implementation of the revised BES definition to take into account the impact of sub-100 kV looped Facilities regardless of voltage level. This altered previous guidance on the evaluation of radial systems. The drafting team developed a technical justification setting a threshold of 50 kV as the value where looped facilities had potential impact on the BES, i.e., if a looped Facility was below 50 kV, an entity could still apply Exclusion E1 as it was shown that looped facilities below 50 kV had no impact on the reliability of the BES. Configurations as shown in the diagrams dealing with the radial system and local network exclusions as well as the system diagrams reflect this finding.” should be retained in the Summary. This text provides context to the concept that looped facilities operating below 50 kV do not impact the E1 exclusion.

Jack Stamper, On Behalf of: Clark Public Utilities, , Segments 3

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I support the comments of Russell Noble of Cowlitz County PUD.

Steve Alexanderson, On Behalf of: Steve Alexanderson, , Segments 3, 4

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Figure E1.5 or E1.6: (PDF Pages 39 and 40):

E1.5 and E1.6 appear to be duplicates of one another. Is one supposed to be a generator less than 20 MW and a Non-BES representation?

PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 9/6/2018

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BPA does not approve of the deletion of second paragraph in the Summary which references FERC Order No. 773 containing the language:

“if a looped Facility was below 50 kV, an entity could still apply Exclusion E1 as it was shown that looped facilities below 50 kV had no impact on the reliability of the BES. Configurations as shown in the diagrams dealing with the radial system and local network exclusions as well as the system diagrams reflect this finding.”

The deletion of the description of this defining threshold, combined with the addition of revised figures E1-4, E1-20, E3-6, E3-7, E3-10, and E3-11 appears to be a material change of the BES Definition exclusion criteria. The subsequent necessary analysis and documentation requirements that would go along with needing to evaluate every radial exclusion past the point of being <50 kV and deep into utility customer street level distribution systems to find any <50kV loops and then potentially need to assemble two-years of integrated hourly SCADA flows for every radial leg feeding into a city to demonstrate E3 qualification or even simply to prove that in a tremendous distribution system all the street level distribution lines are indeed radial, so that the supplying <100 kV radial feed can then be excluded under E1 rather than E3  would be absurd. This would have the potential to require reviewing distribution voltage street level onelines for every city, town, and county which would be an extreme overreach and far outside the original spirit of intentions in defining the Bulk Electric System. The sheer amount of time and resources that would be wasted going down to every distribution line is unacceptable.

Proposed revision: Do not delete. Instead, retain the second paragraph in the Summary section as it was previously written:

“FERC Order No. 773 directed implementation of the revised BES definition to take into account the impact of sub-100 kV looped Facilities regardless of voltage level. This altered previous guidance on the evaluation of radial systems. The drafting team developed a technical justification setting a threshold of 50 kV as the value where looped facilities had potential impact on the BES, i.e., if a looped Facility was below 50 kV, an entity could still apply Exclusion E1 as it was shown that looped facilities below 50 kV had no impact on the reliability of the BES. Configurations as shown in the diagrams dealing with the radial system and local network exclusions as well as the system diagrams reflect this finding.”

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

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Scott Downey, On Behalf of: Scott Downey, , Segments 1

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

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Comments: We disagree with the general summary for E1.4 and E1.20.  Per Note 2 in the NERC Glossary for E1, these examples can be evaluated under E1.

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Manitoba Hydro, Segment(s) 5, 3, 6, 1, 8/8/2017

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Cooper Compliance Corp, Segment(s) 3, 5, 1, 9/7/2018

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

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Page iv – In the first paragraph of the Introduction, there should be a footnote indicating what the Bulk Electric System Process Working Group (BEPWG) is, the names of the members and their organization.  The only information that is publicly known is that the working group is comprised of NERC and RE staff – this is not enough information to understand the basis/context of the proposed changes.  Maximum transparency is important for this initiative.  Additionally, the BEPWG must provide support and specific reasoning for all of the proposed changes. 

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

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National Grid supports Edison Electric Institute’s (EEI) comments.

National Grid, Segment(s) 1, 3, 10/30/2017

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Douglas Johnson, On Behalf of: Douglas Johnson, , Segments 1

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John Hughes, On Behalf of: John Hughes, , Segments 7

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The introduction to Chapter I5 includes the sentence “It is important to note that Inclusion I5 identifies only static or dynamic ‘devices’ to be included by meeting the qualifying connection criteria, and does not include any of the associating qualifiers (i.e., associated dedicated transformers).”  The text beginning “the associating qualifiers” is unclear; we suggest instead “the associated equipment (e.g. associated dedicated transformers)."

Rebecca Baldwin, On Behalf of: Transmission Access Policy Study Group, NA - Not Applicable, Segments 4

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We appreciate the work of Bulk Electric System Exception Process Working Group (BEPWG) for the revision of Bulk Electric System (BES) Reference Document. We support the proposed general revisions in the Section Introduction and Summaries; however, there is still confusion regarding the applicability of the definition of BES, including the respective inclusions and exclusions.

According to NERC website[1], Entities should apply the definition of BES, including the respective inclusions and exclusions, to their asset inventory effective July 1, 2014. This applies to assets owned by the Entity but there are no readily available guidelines on who (or which Entity) should apply the definition of BES when we have the following scenarios, which are but not limited to:

o  Jointly Owned Facilities – multiple owners, single operator

Example: A single generating station owned by several different Entities (Owner A: 50%, Owner B: 30% & Owner C: 20%) and operated by Owner A.

o  Jointly Owned Facilities – single owner, interconnection utility as operator

Example: A single dispersed generating station interconnected to Operator’s switching station. Also where, Operator has ownership of the line from Point of Interconnection to Point of Aggregation.

o  Jointly Owned Facilities – Multiple single owner generator interconnections, utility as Operator

Example: A single Entities’ switchyard interconnecting multiple generating stations.

Hence, we would like request BEPWG to provide some guidelines (or industry best practices) in the Introduction section to clarify who is responsible or should be responsible to identify an asset. This guidelines may include, but is not limited to:

o   Interconnection Agreement language, specific to obligations and responsibilities

o   How a dispute or disagreement (among the owners/operator) should be settled

o   How the guidelines will impact already existing facilities vs new and coming ones

To provide the owners and operators of generation resources (and potential future developers) with an expectation of their compliance obligations (including applicability of BES inclusion and exclusion), BEPWG should work to move this effort forward as expeditiously as possible. Thank you for your consideration of these comments.

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

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

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

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APPA believes that there should be full transparency for the Document authors, the BEPWG. The names of the members and their organization should be clear and laid out.  By comparison the members of the BES SDT were apparent and public.  

Removal of the second paragraph in the Summary appears to be an attempt to buttress arguments for the proposed addition of compliance obligations for Figures E1-4, E1-20, E3-6, E3-7, 3-10, and E3-11.  This paragraph was authored by the BES Standard Drafting Team and provides insight on their intent concerning “the impact of sub-100 kV looped Facilities regardless of voltage level.”  From this paragraph the statement “it was shown that looped facilities below 50 kV had no impact on the reliability of the BES” does not place a limiting number on the facilities which may be linked together by elements operated below 50 kV.  Should the BEPWG continue in this track, a formal request for SDT interpretation or SAR should be submitted to clarify this matter.  

Jack Cashin, On Behalf of: American Public Power Association, , Segments 4

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

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

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Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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The Disclaimer section could be improved by clarifying how the document has evolved from being initially drafted by the SDT to being revised by the BEPWG.  Southern would suggest the following clarification in the disclaimer section:

“This document is not an official position of NERC and will not be binding on enforcement decisions of the NERC Compliance Monitoring and Enforcement Program. The original reference document reflects the professional opinion of the DBES SDT, given in good faith for illustrative purposes only.  Subsequent revisions to the document have been made by the BEPWG, also given in good faith for illustrative purposes, and were not reviewed and finalized by the DBES SDT but rather through the process for approving supporting documents found in Chapter 11 of the Standards Process Manual (Appendix 3A of the NERC Rules of Procedure).”

 

Additionally, because attribution of revisions and new illustrations of the BEPWG provide helpful clarity, Southern recommends appending to the document’s Version History a table specifying the disposition of specific illustrations as either new or updated, and indicating that additional edits to text throughout the document were made. The notations of the BEPWG provided at each new or updated illustration can then be removed from the final approved version.

Southern Company, Segment(s) 1, 3, 5, 6, 10/30/2017

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See the response to Question 6.

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

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

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SPP Standards Review Group (SSRG), Segment(s) 2, 1, 3, 5, 6, 9/10/2018

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APPA believes that there should be full transparency for the Document authors, the BEPWG. The names of the members and their organization should be clear and laid out.  By comparison the members of the BES SDT were apparent and public.  

Removal of the second paragraph in the Summary appears to be an attempt to buttress arguments for the proposed addition of compliance obligations for Figures E1-4, E1-20, E3-6, E3-7, 3-10, and E3-11.  This paragraph was authored by the BES Standard Drafting Team and provides insight on their intent concerning “the impact of sub-100 kV looped Facilities regardless of voltage level.”  From this paragraph the statement “it was shown that looped facilities below 50 kV had no impact on the reliability of the BES” does not place a limiting number on the facilities which may be linked together by elements operated below 50 kV.  Should the BEPWG continue in this track, a formal request for SDT interpretation or SAR should be submitted to clarify this matter. 

FMPA, Segment(s) , 10/23/2017

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

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Oxy, Segment(s) 7, 5, 9/6/2016

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

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Hot Answers

None

Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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Small generation facilities that are beginning to make up a more substantial part of the generation mix are typically exempted from the BES and from providing models for the power flow and dynamic performance of their facilities.  It may be necessary to consider other criteria for inclusion instead of simply the interconnection point and generator MVA.

John Pearson, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

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Other Answers

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

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The team should develop an explanation of how the terms “non-retail generation” and “behind-the-meter” generation are related in this version of the document to clarify its use of this terminology. The following may not be how the terms are intendws to be used; it is offered as an example for the team to consider.

“Behind-the-meter” generation is the MVA capacity of customer-owned generation.  That portion of behind-the-meter generation MVA that is used to serve the customer’s own load is “retail generation,” while any excess MVA sold at wholesale is termed “non-retail generation.”

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

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The BES definition would need to be clear as to how it would apply to emerging technologies such as virtual power plants that can span wide areas, behind-the meter energy storage as some of these facilities will inject power back into the grid and not just offset load, and micro-grids.

Another consideration regarding these emerging technologies is how NERC standards would be applied to them if they are included in an update of the BES definition.  For example,

  • If a generator would be required to install a PMU because it is 80 MVA, would 80 PMUs be required if there are 80 1 MVA resources connected to a large distribution system? 

  • One 100 MW generator may need redundant protections to achieve the same level of reliability as one hundred 1 MW generators with no redundancy.

 

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

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Concerning illustrations of multiple generation plants aggregated above 100 KV (more than two (2)), systems are displayed in a manner that at first glance violate good electrical engineering practice, and add confusion rather than clarity.  Using Figure E1.9 as an example, the drawing appears to display a 7-terminal transmission line; it is highly doubtful such a system exists.  A single fault on such a line would shut down all generation. This figure introduces uncertainty in application of the definition if sectionalizing buses are present along with protection systems which would isolate small sections of the radial interconnection from the greater system.  For example, if the horizontal section showing five (5) connections is changed into a bus, then the aggregate of the individual generator plant/facilities at this bus would be 16+14+12+10 = 52 MVA.  Since the bus does not aggregate over 75 MVA of generation, it would be excluded from the BES. Further, if a bus was shown connecting the 52 MVA aggregated generation with the 18 and 15 MVA generators, the BES blue would include this second bus and extend up to the top bus.  The green designations would show below this second bus, including the two lines connecting the 18 and 15 MVA generators.  Modification of illustrations to clarify application of the BES definition in this area would be helpful, and would not require a SAR.

Concerning normal opens, a SAR should be developed to clarify application of Exclusion E3.  This would include the following: defining the three types of normal opens: (1) to separate dissimilar systems, (2) to sectionalize systems operated radial, and (3) to control network flows in an interconnected system; how normal opens should be treated in Exclusion E3; and define the operational voltage at which a reasonable separation can be made between transmission operated below 100 kV and distribution to define a clear demarcation line where the BES definition has no applicability.

Russell Noble, On Behalf of: Cowlitz County PUD, , Segments 3, 5

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With the BEPWG working on this document, the NSRF request that the BEPWG start a project the review the BES Definition itself, as this may simplify emerging technologies.

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

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An additional example needs to be developed and included in the document to accommodate scenarios involving HVDC or similar systems. We suggest a scenario, as shown below in abbreviated form…

BES system è Xfmr with low-side less than 50kV è HVDC element (or similar) è Xfmr with low-side less than 50kV è BES system

 

 

 

 

We believe this scenario is needed to answer the following questions:
1) Are the two transformers excluded or included?
2) Is the “less than 50kV HVDC” a BES element or not?

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

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Jack Stamper, On Behalf of: Clark Public Utilities, , Segments 3

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I support the comments of Russell Noble of Cowlitz County PUD.

Steve Alexanderson, On Behalf of: Steve Alexanderson, , Segments 3, 4

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Additional Comment 1: Core Definition: (PDF Page 3, 5, and 81)

PPL NERC Registered Affiliates suggests removal of the last sentence in the Core Definition statement on PDF page 3 (“This does not include facilities used in the local distribution of electric energy.”) This addition does not seem necessary considering the detailed list of Exclusions within the document.

Additionally, we propose adding the following language to the Core Definition to add clarity to the transformer element assessment: “For the purposes of this primary definition, transformers should be assessed according to the voltage class of their lowest voltage terminal”. If this language were adopted, we believe it would contextualize Inclusion 1 because as it reads currently I1 seems to “exclude” transformers, not include them.

Additional Comment 2: I5 description, first paragraph: (PDF Page 29)

PPL NERC Registered Affiliates recommends revising the I5 statement to: “Static or dynamic devices (excluding generators) dedicated to supplying or absorbing Reactive Power that are connected through a dedicated transformer with a high-side voltage of 100 kV or higher.” Since the Core Definition already captures reactive devices connected at 100 kV or higher and all transformers in Inclusion I1 are connected at 100 kV or higher, the phrases “connected at 100 kV or higher” and “or through a transformer that is designated in Inclusion I1” do not seem to add any value.

Similarly, “Reactive Resource ‘2’” does not seem necessary in Figure I5.1 (PDF Page 30) since such a device would be covered in the Core Definition.

Additional Comment 3: E1 Section and E3 Section (Respective Subsections on Reactive Resources): (PDF Pages 33 and 65 respectively)

Sections E1 and E3 should refer to the Core Definition as well, not just I5. As PPL NERC Registered Affiliates commented in Additional Comment 2 above, we recommend revising the I5 statement since the Core Definition already captures reactive devices connected at 100 kV or higher and all transformers in Inclusion I1 are connected at 100 kV or higher.

Please consider adding an MVAr output threshold below which a reactive resource on an E1 excluded radial or in an E3 excluded local network may be excluded from the BES definition. Another possible alternative is to consider expanding sections E1 and E3 to include reactive resources that do not flow MVArs into the transmission system. This may be determined by reviewing SCADA data for two years for each E1 radial or E3 local network. If the SCADA data shows that MVAr flow is always into the E1 radial or the E3 local network, allow the exclusion of reactive resources from the BES definition.

Please consider adding appropriate drawings to illustrate whatever final guidance is provided in the Reactive Resource subsections in both E1 and E3. For example, if the words remain exactly as they are in this draft, add drawings of a Non-BES radial containing a BES capacitor bank or dynamic reactive device in Section E1 and a Non-BES E3 local network containing a BES capacitor bank or dynamic reactive device in Section E3. Such drawings would better illustrate the point for the reader.

Additional Comment 4: Figures E1.11, E3.1, and E3.2: (PDF Page 45, 66 and 67)

The treatment of retail generation in Figures E1.11, E3.1, and E3.2: (PDF Page 45, 66 and 67) need further clarification.  If retail generation is 100 MVA and only 50 MVA is used by the customer, would the remaining 50 MVA be calculated in the generation of an E1 radial or in an E3 local network?

For example, if an E3 local network has 50 MVA of normal non-retail generation in it and also has a 60 MVA customer generator that uses only 30 MVA to feed the customer’s load, should the remaining 30 MVA be added to the 50 MVA of non-retail generation to determine if the local network under review could be E3 excluded, or does the fact that the retail generator qualifies for an E2 exclusion because it does not export more than 75 MVA mean that the 30 MVA it does export does not need to be included in the E3 generation calculation? Current drawings do not appear to address this subject.

In the E2 Exclusion section under the subsection on “Net Capacity” on PDF Page 58, “threshold value” needs further clarification. After reviewing 12 months of data, it is unclear whether an average net MVA or a maximum net MVA value from the 12 month period should be used in the E2 calculation. 

Additional Comment 5: Hierarchical Summary: (PDF Page 81)

Consider moving this document away from the idea of depending on the hierarchical approach to ensure that the BES status review is done properly, and instead begin to promote that the user digest the concepts that are required to do the assessment such that the user can apply the various inclusions and exclusions in parallel as necessary for each unique scenario under review.

It seems a bit misleading to suggest that the Inclusions/Exclusions can always be applied in a specific order to accomplish the correct outcome. Consider removing the section on sequencing and just let the diagrams that follow stand on their own as representation of an example process.

As an example of how this section can cause confusion, it is clear that E1 assessment can lead to identification of areas that can only be assessed under E3, but this Hierarchical Summary section suggests that E3 should be done before E1. Instead, an engineer should be allowed to take the various Inclusion/Exclusion methodology sections and apply them as appropriate for the variety of situations they face. Prescribing an order of execution promotes blind implementation of process more so than actual absorption of driving concepts behind BES status determination.

PPL NERC Registered Affiliates, Segment(s) 1, 3, 5, 6, 9/6/2018

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As technological advances continue to reduce battery costs and improve efficiencies, we may see more battery facilities interconnecting to the BES. Identifying a MW or MWhr threshold or other criteria for inclusion or exclusion to the BES may be prudent in future revisions.

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

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Scott Downey, On Behalf of: Scott Downey, , Segments 1

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

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Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Figures E1.5 and E1.6 in the revised reference document are the same. It looks like the figure E1-5 in the version-2 (April 2014) document (figure E1-5: Radial System: Single non-BES Generation Resource) is missing in the revised version-3 (clean posted document).

Manitoba Hydro, Segment(s) 5, 3, 6, 1, 8/8/2017

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Cooper Compliance Corp, Segment(s) 3, 5, 1, 9/7/2018

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AZPS proposes a revision to Section III.3 BES Exclusion E3. In the introductory verbiage for BES Exclusion E3, it is stated that any entity that uses E3 to exclude facilities from the BES must be able to show through actual system data (hourly integrated power flow values) over a two year period that power only flows into the network.  The question that naturally arises is where new facilities are built that have the potential to modify a facility previously excluded under E1, is the potential for a BES Exclusion E3 also eliminated? In particular, future changes to facilities will not have two years of actual system data to qualify for BES Exclusion E3.  Nonetheless, where the facility was previously excluded and power flow analysis clearly demonstrates that BES Exclusion E3 is applicable, the language in Section III.3, BES Exclusion E3 appears to prevent application of BES Exclusion E3.  AZPS respectfully asserts that facilities should be able to qualify for BES Exclusion E3 by using powerflow analysis until such time as two years of actual system data demonstrates that the facilities do not meet the criteria for BES Exclusion E3. 

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

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

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National Grid, Segment(s) 1, 3, 10/30/2017

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None. 

Douglas Johnson, On Behalf of: Douglas Johnson, , Segments 1

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John Hughes, On Behalf of: John Hughes, , Segments 7

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Rebecca Baldwin, On Behalf of: Transmission Access Policy Study Group, NA - Not Applicable, Segments 4

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SRP thanks the Standards Drafting Team for their hard work.

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

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BES Definition Reference Document

Comments 8/9/2018

  1. On page 2 of the redline, in Inclusion I2, the team employs the term “generating resource”.  When looking at combined cycle units, such as a two on one (two combustion turbines on one steam turbine), that may have three separate generators, is the team looking at each generator as a separate “generating resource”, or are they one combined unit?  Does it matter if they can be operated independently?  Seminole requests clarification on this because the term “generating unit” is employed in Applicability Section 4.2.7.1 of PRC-005-6, and Seminole requests clarification on the difference of a generating unit and a generating resource, and whether each separate generator in a combined cycle unit such as described, would be separate generating units/resources, or interpreted to be one combined generating unit and one combined generating resource.  The term “generating unit” is also employed in Exclusion E2 of the current BES Definition, which causes Seminole to reason that generating unit may have a different meaning than generating resource.

  2. In Figure I2-10 of the redline, Seminole believes the first statement should state that the total generation connected is greater than 75 MW.  Even though the 25 MVA generator serves lower voltage load, it is still connected to the BES at one common point.  If the 25 MVA generator connects to the BES at a separate point in this figure, then the buswork may be pulled into the BES as it’s potentially greater than 50 kV.  Seminole requests this description to be reworded.

  3. In Figure E1-12 in the redline, there is a greater than 100 kV line to the generator that is highlighted Blue.  Seminole understands the reasoning for this designation, however, there are two radial lines off of this line that are also highlighted blue, both appear to serve load only and have a generator with only a primary winding greater than 100 kV.  Why are these two radial lines not green?  If it’s because these lines are not considered “Transmission systems”, then this is a term that requires additional guidance.

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

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

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The BEPWG asks about application issues associated with emerging technologies.  The question assumes that all BES questions going forward can be answered in the reference document.  As many of the answers in this comment form suggest that the original standard must be consulted before the Reference Document can be a resource. 

 

Jack Cashin, On Behalf of: American Public Power Association, , Segments 4

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

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See administrative comments below:

Section I.  List of figures (pages 7-8) – Page numbers and associated comment changes will need to be incorporated.

-Section II. Figures I2-5, I2-6, I2-7, I2-8, I2-9, I2-10 (pages 16-21) - In these figures, the term “site” was changed to “plant/facility” while in many cases the term “generation” was changed to “generator”. This was not done consistently and is somewhat confusing. Recommendation to use the term “Generation Plant/Facility” in all instances for figures instead of using “Generation site” and/or “Generator Plant/Facility”.

-Section III. Figures E1-20, E3-6, E3-7, E3-10, E3-11 (pages 56, 73, 74, 78, 79) - The title for these figures need to change the words “Sub-100 kV” to “Sub-50 kV”.

Page 60 – Under Net Capacity section change “MWs” to “MVAs” and “Figures E2-1 and E2-5” to “Figures E2-1 through E2-5”.

Page 61 – The figure has not been updated, thus remove: “Note: This is an update, developed by the BEPWG, to the original diagram to provide clarification in the application of the BES definition”.

Page 77 – Change “Figure E3-11” to “Figure E3-13” on 6th line of first paragraph. Rev. 2 of the document previously referred to Figure E3-9 which was renamed to E3-13 in this draft.

 

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

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Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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Southern Company, Segment(s) 1, 3, 5, 6, 10/30/2017

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Reclamation recommends the BES definition be revised where possible to eliminate the need for guidance contained in the Reference Document. For example, if the Exclusions are intended to be applied in a certain order, Reclamation recommends the Exclusions be stated in that order in the BES definition. Specifically, if Exclusion 2 is intended to be applied first, Exclusion 4 applied second, Exclusion 3 applied third, and Exclusion 1 applied last, Reclamation recommends the Exclusions be re-numbered so that Exclusion 2 is now Exclusion 1, Exclusion 4 is now Exclusion 2, Exclusion 3 remains Exclusion 3, and Exclusion 1 is now Exclusion 4.

Reclamation does not agree with the new Table of Contents format. Chapter I, Chapter E, Chapter S, and Chapter 6 are confusing. Reclamation recommends each chapter and section be identified numerically (Chapter 1, Chapter 2, Chapter 3; Section 1, Section 2, Section 3, etc.) and titled with the pertinent subject; for example, Chapter 1 Section 1 – BES Inclusion I1; Chapter 1 Section 2 – BES Inclusion I2.

Reclamation also does not agree with stating the updates to the Reference Document in the body of the document; specifically: all references to “Note: this is a new diagram…” and narrative explanations of new content on page 12 paragraph 1 and page 43 paragraph 1. This information is not substantive to the application of the BES definition and should be stated only in the Version History or an errata document.

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

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Tri-State recommends that the BEPWG split the diagrams for each individual inclusions and exclusions into 2 separate headings. The first heading should be followed by situations where the application of the Inclusion/Exclusion is correct. The second heading should be followed by situations where the application of the Inclusion/Exclusion is not correct.

For instance, diagram E1.19 depicts a situation where Exclusion E1 (Radial Systems) cannot be applied but states it instead may be applicable to Exclusion E3 (Local Network). It is confusing with its placement under the E1 Exclusion since this instance is not applicable to E1. We believe by separating the figures out in the two areas described above, it would reduce any confusion of why a given figure is depicted under a certain Inclusion/Exclusion. 

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

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SPP Standards Review Group (SSRG), Segment(s) 2, 1, 3, 5, 6, 9/10/2018

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The BEPWG asks about application issues associated with emerging technologies.  The question assumes that all BES questions going forward can be answered in the reference document.  As many of the answers in this comment form suggest that the original standard must be consulted before the Reference Document can be a resource.  

FMPA, Segment(s) , 10/23/2017

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We disagree with the guidance offered for Figure E1.4. because under the previous BES definition document the >100 kV supplies to these transformers would be considered as "non-BES".

We disagree with the guidance offered for Figure E1.20.  because under the previous BES definition document, the >100 kV supplies to these transformers would be considered as "non-BES".  In addition, instead of looking strictly at the configuration, a second test should be to look at the protection system on the right-hand subtransmission system to determine if it is designed to operate as a network or a radial system.

We disagree with the guidance offered in Figure E3.13.  If the high side-breaker is closed, then there should not be any significant flow from the >50 kV sub-loop to the transmission system (see Kirchhoff's Current Law) and thus the equipment on the high side of the transformers should not be BES.

We believe that there is something inherently wrong with the NERC definition of BES if it takes more than 100 pages to describe what the BES should or should not contain.

We question why some of the changes to the diagrams were made.  From our perspective, it is not obvious as some of the changes to the diagrams are subtle and hard to detect.  If the purpose of these changes is to provide clarity, we believe that many of the proposed changes fall short of the goal.  It appears to us that some of the changes that are proposed are designed to minimize the number of facilities that would be excluded from the BES, without adequately vetting these changes with the industry.

We believe that the methodology is inconsistent in its handling of BES generators, BES plants, and DERs that provide backfed from the subtransmission and distribution systems.  Backfeed to the transmission system of 1 MW from sub¬-100 kV loops, as a result of DERs and multiple outages to transmission and/or distribution elements, does not constitute support to the BES.  A threshold power flow from sub-100 kV loops needs to be established that is consistent with the threshold for BES generators.

In our opinion requiring 2 years of hourly data to prove that a future facility will not qualify as BES is not possible, and particularly if that facility is designed to supply a sub-100 kV loop.

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

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Oxy, Segment(s) 7, 5, 9/6/2016

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The application of I4.6 seems consistent with the BES definition. However, we are aware of instances of I4 application that are not considered by this reference document and we would like to see included.

As an Example, if multiple owners of dispersed resources interconnected on a common interconnection line at >100kV, but each individual facility is below 75MVA, how would this be treated by the BEPWG?

To be consistent between technology, we would expect the result to be consistent with the result illustrated in example E1.9 on page 43 of the BES definition reference document. That example shows the transmission line as BES eligible (in terms of operating voltage) while each generator and its related GSU for the plants below 75 MVA. The transmission line is potentially eligible for exclusion on the basis of being a radial system.

For clarity, and example that demonstrates this should be added to the Exclusion 1 section.

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

DER E1 Example.docx

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