This comment form is no longer interactive because the comment period is closed.

Project 2019-01 Modifications to TPL-007-3

Description:

Start Date: 02/25/2019
End Date: 03/26/2019

Associated Ballots:

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

Filter:

Hot Answers

BC Hydro, Segment(s) 3, 5, 1, 12/18/2018

- 0 - 0

ISO/RTO Standards Review Committee ("SRC") members CAISO, ERCOT, IESO, MISO, NYISO, and SPP agree that the scope of the SAR aligns with the directives of FERC in Order No. 851.

ISO/RTO Standards Review Committee 2019-01 Modifications to TPL-007-3, Segment(s) 2, 3/26/2019

- 0 - 0

Other Answers

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

- 0 - 0

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

- 0 - 0

Given that FERC order No. 851 extends the corrective action plan to the supplemental GMD event vulnerabilities, the scope should include adding a variance similar to D.A. 7.3. for the new requirement to cover the CAP timelines/milestones associated with regulatory approvals in Canada, where applicable.

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

- 0 - 0

It is our view that the original purpose of the supplemental event is to investigate the impact of local enhancement of the generated electric field from a GMD event on the transmission grid.  This requires industry to take a study approach in which the GICs are calculated with the higher, enhanced electric field magnitude of 12 V/km (adjusted for location and ground properties) applied to some smaller defined area while outside of this area the benchmark electric field magnitude of 8 V/km (also adjusted for location and ground properties) is applied. This smaller area is then systematically moved across the system and the calculations are repeated. This is necessary as the phenomenon could occur anywhere on the system.  Using this Version 2 methodology, every part of the system is ultimately evaluated with the higher electric field magnitude.

In our view, the supplemental event represents a more extreme scenario. As such, adding a corrective action plan requirement to the supplemental event obviates the need for studying the benchmark event. Rather than pursuing a Corrective Action Plan for the existing Supplemental GMD Vulnerability Assessment, we believe the SDT should instead pursue only one single GMD Vulnerability Assessment using a reference peak geoelectric field amplitude not determined soley by non-spatially averaged data. This would be preferable to requiring two GMD Vulnerability Assessments, both having Corrective Action Plans and each having their own unique reference peak geoelectric field amplitude. When the Supplemental GMD Vulnerability Assessment was originally developed and proposed, there was no CAP envisioned for it. Because of this, one could argue the merits of having two unique assessments, as each were different not only in reference peak amplitude, but in obligations as well. What is being suggested in this SAR however, is essentially having two GMD Vulnerability Assessments requiring Corrective Action Plans but with different reference peak geoelectric field amplitudes (one presumably higher than the other). It would be unnecessarily burdensome, as well as illogical, to have essentially the same obligations for both a baseline and supplemental vulnerability assessment. One again, we believe a more prudent path would be for the SDT to determine an agreeable reference peak geoelectric field amplitude for a single GMD Vulnerability Assessment that potentially requires a Corrective Action Plan.

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

- 0 - 0

Karie Barczak, On Behalf of: DTE Energy - Detroit Edison Company, , Segments 3, 4, 5

- 0 - 0

The proposed scope of the SAR is appropriate to address FERC order 851. However, we suggest expanding the scope of the SAR to provide the Standard Drafting Team with the ability to consider making a revision to “Table 1: Steady State Planning GMD Event”. The recommendation is to add an item “d.” to the “Steady State:” criteria: “d. System steady state voltage performance shall be within the criteria established in Requirement R3.”

Eversource Group, Segment(s) 3, 1, 9/14/2018

- 0 - 0

The NSRF agrees with the proposed scope as described in the Standard. The proposed scope is appropriate to address FERC directives in Order 851.

The NSRF would like to suggest that the SDT consider modifying the standard to include only one Corrective Action Plan for Requirement R7 that will mitigate performance issues identified in the benchmark GMD Vulnerability Assessment (R4) and/or the supplemental GMD Vulnerability Assessment (R8). If an entity identifies vulnerabilities for the benchmark and the supplemental assessment, the NSRF believes that the CAP for the more severe supplemental assessment will mitigate the vulnerabilities identified in the benchmark assessment.

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

- 0 - 0

City Utilities supports comments from the MRO NSRF.

John Allen, On Behalf of: City Utilities of Springfield, Missouri, , Segments 1, 3, 4

- 0 - 0

Eric Shaw, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

- 0 - 0

Constantin Chitescu, On Behalf of: Ontario Power Generation Inc., , Segments 5

- 0 - 0

CHPD does not agree with requiring the development and implementation of corrective action plans to mitigate assessed supplemental GMD event vulnerabilities. Entities have only just begun the process of evaluating the benchmark GMD event and developing mitigation measures. The industry is in the preliminary stages of assessing and developing mitigation measures for GMD events and has not had much time to develop engineering-judgement, experience, or expertise in this field. Revising the standard to include CAPs for the supplementary GMD event is not appropriate at this time as the industry is still building a foundation for this type of system event analysis and exploring mitigation measures. Without a sound foundation developed, requiring CAPs for the supplemental GMD event could lead to unnecessary mitigation measures and an immense amount of industry resources spent on a still developing science. CHPD suggests that the benchmark GMD event be fully vetted before moving onto additional scenarios such as the supplemental event.

CHPD does not agree with replacing the corrective action plan time-extension provision in Requirement R7.4 with a process through which extensions of time are considered on a case-by-case basis. Since R7.4 is for “situations beyond the control of the entity,” it does not matter if the extensions are considered on a case-by-case basis as the entity will not be able to comply with the CAP timeline as the situation was beyond their control. Adding the case-by-case basis would increase the administrative burden to entities while adding very little benefit to the reliability of the BPS.

Joyce Gundry, On Behalf of: Public Utility District No. 1 of Chelan County, , Segments 1, 3, 5, 6

- 0 - 0

PJM agrees with simulating and studying the impacts of localized peak geoelectric fields covered under the supplemental GMD event in the GMD Vulnerability Assessment. These efforts help to improve the overall understanding of the impacts to the BES as well as gauge system performance under more severe conditions. However, the supplemental GMD event should be considered as an extreme event and although useful to create situational awareness, it should not mandate design requirements.  The situation is analogous to TPL-001-4 extreme (low probability) events where only an evaluation is performed of the possible actions designed to reduce the likelihood or mitigate the consequences of those events.  PJM recommends that the Drafting Team not require Corrective Action Plan(s) for the supplemental GMD event.

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

- 0 - 0

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

- 0 - 0

NERC TPL-001-4 sets forth requirements for TPs to establish a Corrective Action Plan when the analysis indicates an inability of the System to meet the performance requirements for planning events shown in Table 1.  The analysis of an extreme event in Table 1 that results in Cascading caused by the occurrence of extreme events, an evaluation of possible actions designed to reduce the likelihood or mitigate the consequences and adverse impacts of the event(s) shall be conducted, but no Corrective Action Plan is required under an extreme event.  Since the supplimental analysis may be considered an extreme event to the benchment assessment, then the CAP would not be required for the supplemental analysis to be consistant with TPL-001-4.

Matthew Lewis, On Behalf of: Matthew Lewis, , Segments 1, 5

- 0 - 0

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

- 0 - 0

BPA fully supports efforts already in flight to refine the earth resistance modeling and modification to software study tools to produce results that more closely represent real-life GIC conditions.  These refinements are expected to obtain computation of locally varying electric field magnitude and direction for use in computing GIC flow in a modeled transmission network, such that, calculated GIC flow more closely represents actual flows during a GMD event.  BPA is aware of work being done by vendors of commercially available study software, and geophysics researchers, to refine GIC modeling in alignment with the present level of understanding of the physics involved.   The path they are on is clearly heading towards obtaining more refined computation capabilities, within the study tools we use for GIC analysis work, where small area localized conditions are included. 

BPA’s concern is that this capability does not presently exist within the study tools, and as such, study work would be using widely varying assumptions.  BPA believes this variability will increase the likelihood of results that are not representative of actual GIC flow and increase the risk of developing corrective actions that are not beneficial or make matters worse.  Worse in that, an action may actually put the system in a less stable state after the action when compared to riding through the event without taking an action that is actually unnecessary. BPA believes that this Reliability Standard (TPL-007) should not request study work beyond the capacities of the study tools until those tools are made capable of producing refined studies requested by the FERC order No. 851.

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

- 0 - 0

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

Richard Vine, On Behalf of: Richard Vine, , Segments 2

- 0 - 0

To replace the Corrective Action Plan time-extension provision in Requirement R7.4 with a process through, which extensions of time are considered on a case-by-case basis please consider the following:

(1)   A clear criteria for approval and disapproval of the extension of time.

(2)   An appeal process for revisiting timetables that are not agreed upon by the Responsible Entity and the Regional Entity.

(3)   Clearly identifying what supporting documentation is acceptable in the new process.

Another item for consideration is to attach a guideline to the standard that addresses the following questions:

(1)   How will the reviews be scheduled and address who are the participants and their role in the new process?

(2)   What means will this review be conducted (conference call or in-person)

(3)   Does the review team have time parameters they will enforce?

(4)   Will there be circumstances that would be able to by-pass the review and provide a standard extention time that if there are circumstances outside of those, then the case review be concluded?

 

ACES Standard Collaborations, Segment(s) 1, 3, 6, 4, 5, 3/26/2019

- 0 - 0

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

- 0 - 0

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

- 0 - 0

The SPP Standards Review Group (SSRG) supports the proposed scope as described in the SAR.

The SSRG recommends the Standards Drafting Team (SDT) consider the potential of redundancy in the development of two Correction Action Plans (CAPs).

The SSRG reviewed Paragraph 2, from Attachment 1, Calculating Geoelectric Fields for the Benchmark and Supplemental GMD Events. The SSRG recommends that the SDT consider that one CAP could cover both studies. 

The supplemental GMD event is composed of similar elements as described above (Benchmark), except (1) the reference peak geoelectric field amplitude is 12 V/km over a localized area; and (2) the geomagnetic field time series or waveform includes a local enhancement in the waveform2.

SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 3/26/2019

- 0 - 0

The proposed scope of the SAR is appropriate to address FERC order 851. However, we suggest expanding the scope of the SAR to provide the Standard Drafting Team with the ability to consider making a revision to “Table 1: Steady State Planning GMD Event.” The recommendation is to add an item “d.” to the “Steady State:” criteria: “d. System steady state voltage performance shall be within the criteria established in Requirement R3.”

PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

- 0 - 0

Hot Answers

BC Hydro, Segment(s) 3, 5, 1, 12/18/2018

- 0 - 0

None.

ISO/RTO Standards Review Committee 2019-01 Modifications to TPL-007-3, Segment(s) 2, 3/26/2019

- 0 - 0

Other Answers

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

- 0 - 0

it would be beneficial to develop a guideline with as much as details as possible for entities to follow.

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

- 0 - 0

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

- 0 - 0

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

- 0 - 0

Nothing further

Karie Barczak, On Behalf of: DTE Energy - Detroit Edison Company, , Segments 3, 4, 5

- 0 - 0

Eversource Group, Segment(s) 3, 1, 9/14/2018

- 0 - 0

The NSRF suggest expanding the scope of the SAR to provide the SDT with the ability to consider removing or revising requirement R11 and R12. The requirements to have a process to collect GMD data is not necessary in TPL-007 because that data will not be used in the Planning Analysis. Furthermore, the GMD data is not needed to complete the benchmark or supplemental vulnerability assessments.

As an example, see the MISO TPL-007-2 flowchart below. The monitoring requirements are outside the requirement flowchart for Planning Analysis and vulnerability assessment. If this data is needed for GMD research, I believed these requirements are covered by the Section 1600 data request.

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

- 0 - 0

City Utilities supports comments from the MRO NSRF.

John Allen, On Behalf of: City Utilities of Springfield, Missouri, , Segments 1, 3, 4

- 0 - 0

Eric Shaw, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

- 0 - 0

Constantin Chitescu, On Behalf of: Ontario Power Generation Inc., , Segments 5

- 0 - 0

Joyce Gundry, On Behalf of: Public Utility District No. 1 of Chelan County, , Segments 1, 3, 5, 6

- 0 - 0

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

- 0 - 0

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

- 0 - 0

Matthew Lewis, On Behalf of: Matthew Lewis, , Segments 1, 5

- 0 - 0

Reclamation recommends the standards authorization request process include input from FERC so as to thoroughly scope each standard to ensure it includes all of FERC’s desired content prior to it being submitted for FERC approval. This would help eliminate the potential for changes to new standards being ordered simultaneously with the approval of the same standard. Reclamation also recommends FERC provide ample time for NERC to develop standards to avoid the problem of improperly scoped standards being quickly thrown together simply to meet short deadlines.

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

- 0 - 0

None

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

- 0 - 0

Richard Vine, On Behalf of: Richard Vine, , Segments 2

- 0 - 0

It is stated in the SAR that “The potential cost impacts associated with adding corrective action plan requirements for supplemental GMD event vulnerabilities are unknown at this time.”  

Cost Impacts are an important aspect to be studied.  Considerations of estimated time-extensions cost impacts and company budget cycles is requested to be measured in the time-extension decisions. 

Thank you for the opportunity to comment. 

ACES Standard Collaborations, Segment(s) 1, 3, 6, 4, 5, 3/26/2019

- 0 - 0

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

- 0 - 0

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

- 0 - 0

The SSRG recommends the SDT consider developing a non-exclusive list of extension examples.

SPP Standards Review Group, Segment(s) 2, 1, 3, 5, 6, 3/26/2019

- 0 - 0

PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

- 0 - 0