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2018-03 Standards Efficiency Review Retirements | FAC-008-5

Description:

Start Date: 11/30/2020
End Date: 01/13/2021

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2018-03 Standards Efficiency Review Retirements FAC-008-5 IN 1 ST 2018-03 Standards Efficiency Review Retirements FAC-008-5 11/30/2020 12/29/2020 01/04/2021 01/13/2021

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Hot Answers

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Paul Mehlhaff, Sunflower Electric Power Corporation, 1, 1/13/2021

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Other Answers

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 12/2/2020

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Thomas Foltz, AEP, 5, 12/16/2020

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Kjersti Drott, 12/21/2020

- 0 - 0

Daniela Atanasovski, APS - Arizona Public Service Co., 1, 12/21/2020

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

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The NSRF agrees with the SER Retirements.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

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Yes, R7 should be retired.  R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.

Consequently,   I am balloting to retire what we can agree to retire.  

 

 

Marty Hostler, On Behalf of: Northern California Power Agency, , Segments 3, 4, 5, 6

- 0 - 0

Yes, R7 should be retired.  R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter. Consequently,   I am balloting to retire what we can agree to retire.  

Michael Whitney, On Behalf of: Northern California Power Agency, , Segments 3, 4, 5, 6

- 0 - 0

Yes, R7 should be retired.  R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.

Consequently,   I am balloting to retire what we can agree to retire

Dennis Sismaet, Northern California Power Agency, 6, 1/6/2021

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Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

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Bruce Reimer, Manitoba Hydro , 1, 1/7/2021

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Texas RE recommends removing “subject to Requirement R2” in Requirement R8.  It should be clear that all Generator Owners (GO) shall provide Facility Ratings data when the Reliability Coordinators (RC), Planning Coordinators (PC), Transmission Planners (TP), Transmission Owners (TO), and Transmission Operators (TOP) identify a need for the data. Since Requirement R2 is already applicable to a large majority of GOs, removing the verbiage in Requirement R8, would eliminate the need for GOs to evaluate how a request for Facility Ratings data fits into the applicability specified within Requirement R8.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 1/8/2021

- 0 - 0

Jeremy Lorigan, Seminole Electric Cooperative, Inc., 3, 1/8/2021

- 0 - 0

FE Voter, Segment(s) 1, 3, 5, 6, 4, 7/31/2020

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Tammy Porter, On Behalf of: Lee Maurer, Oncor Electric Delivery, 1

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Yes, R7 should be retired.  R8 should also be retired. However, FERC did not agree to Retire R8 in their last ruling on this matter.

 

Truong Le, On Behalf of: Chris Gowder, Florida Municipal Power Agency, 3,4,5,6; Carol Chinn, Florida Municipal Power Agency, 3,4,5,6; Richard Montgomery, Florida Municipal Power Agency, 3,4,5,6; Dale Ray, Florida Municipal Power Agency, 3,4,5,6

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Anton Vu, Los Angeles Department of Water and Power, 6, 1/11/2021

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Richard Jackson, U.S. Bureau of Reclamation, 1, 1/11/2021

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N/A.

Leonard Kula, Independent Electricity System Operator, 2, 1/11/2021

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None.

Brandon Gleason, Electric Reliability Council of Texas, Inc., 2, 1/12/2021

- 0 - 0

Tyson Archie, Platte River Power Authority, 5, 1/12/2021

- 2 - 0

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

- 0 - 0

Joe Tarantino, On Behalf of: Nicole Goi, Sacramento Municipal Utility District, 1,3,4,5,6; Charles Norton, Sacramento Municipal Utility District, 1,3,4,5,6; Foung Mua, Sacramento Municipal Utility District, 1,3,4,5,6; Kevin Smith, Balancing Authority of Northern California, 1

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Jenjira Knernschield, On Behalf of: Old Dominion Electric Coop., , Segments 3

- 0 - 0

David Jendras, Ameren - Ameren Services, 3, 1/13/2021

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EEI supports the retirement of Requirement R7 and retention of Requirement R8.  

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

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Andrea Barclay, On Behalf of: Andrea Barclay, , Segments 3, 4

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Douglas Webb, 1/13/2021

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Laura Nelson, 1/13/2021

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Maurice Paulk, Cleco Corporation, 3, 1/13/2021

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NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 1/13/2021

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Dania Colon, Orlando Utilities Commission, 5, 1/13/2021

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Exelon concurs with the EEI comment, supporting the retirement of Requirement R7 and the retention of Requirement R8. 

Submitted on behalf of Exelon, Segments 1, 3, 5, 6

Daniel Gacek, Exelon, 1, 1/13/2021

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Austin Energy agrees with the comments submitted by Platter River Power.  
However, Austin Energy would like the SDT to consider providing clarification to the sub-requirement R8.2 where, when requested for the owner to provide within 30-days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to request "cart blanc" the next most limiting element for all facilities.  Auditors are requesting the "next most limiting element" expanding the scope of the standard.

 

W. Dwayne Preston, Austin Energy, 3, 1/13/2021

- 1 - 0

Austin Energy agrees with the comments submitted by Platter River Power.  

However, Austin Energy would like the SDT to consider providing clarification to the sub-requirement R8.2 where, when requested for the owner to provide within 30-days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to request "cart blanc" the next most limiting element for all facilities.  Auditors are requesting the "next most limiting element" expanding the scope of the standard.

Jun Hua, Austin Energy, 4, 1/13/2021

- 1 - 0

Austin Energy agrees with the comments submitted by Platter River Power.  

However, Austin Energy would like the SDT to consider providing clarification to the sub-requirement R8.2 where, when requested for the owner to provide within 30-days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to request "cart blanc" the next most limiting element for all facilities.  Auditors are requesting the "next most limiting element" expanding the scope of the standard.

Michael Dillard, Austin Energy, 5, 1/13/2021

- 1 - 0

No comments

Carl Pineault, Hydro-Qu?bec Production, 5, 1/13/2021

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No additional comments.

Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 1/13/2021

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Erin Green, On Behalf of: Western Area Power Administration, , Segments 1, 6

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Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

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Jennifer Bray, Arizona Electric Power Cooperative, Inc., 1, 1/13/2021

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MISO supports the retirement of Requirement R7 and the retention of Requirement R8.

Bobbi Welch, Midcontinent ISO, Inc., 2, 1/13/2021

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Austin Energy agrees with the comments submitted by Platter River Power.  

Austin Energy would like the SDT to consider providing clarification to the sub-requirement R8.2 where, when requested for the owner to provide within 30-days, or other agreed upon timeframe, be clarified so it is not an opening for expansion by auditors to request "carte blanche" the next most limiting element for all facilities.  Auditors are requesting the "next most limiting element" expanding the scope of the standard.

Andrew Gallo, 1/13/2021

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Hot Answers

As in its previous NOPR response, BPA agrees with FERC’s assertion that Requirement R8’s direction to communicate with Transmission Owners is not found in MOD-032, TOP-001, and/or IRO-010, therefore is a provision to be retained in FAC-008. BPA does, however, agree with the comments submitted by Platte River Power Authority and recommends that Requirement R8 be revised to add clarity and reduce undue burden on reporting entities.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Paul Mehlhaff, Sunflower Electric Power Corporation, 1, 1/13/2021

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Other Answers

Colleen Campbell, AES - Indianapolis Power and Light Co., 3, 12/2/2020

- 0 - 0

Thomas Foltz, AEP, 5, 12/16/2020

- 0 - 0

Kjersti Drott, 12/21/2020

- 0 - 0

None

Daniela Atanasovski, APS - Arizona Public Service Co., 1, 12/21/2020

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

- 0 - 0

None

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

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In the future the SDT or NERC should develop a formal definition of jointly owned facilities, since there appears to be conflicting interruptions being enforced that may not have been vetted  in accordance with the NERC Standards Processes Manual Standards Interruption process. 

Additionally, the SAR was to modify V3 not V4.  Thus the proposed Version should be V4.  To my knowledge FERC did not approve the prior proposed V4.

Marty Hostler, On Behalf of: Northern California Power Agency, , Segments 3, 4, 5, 6

- 0 - 0

In the future the SDT or NERC should develop a formal definition of jointly owned facilities, since there appears to be conflicting interruptions being enforced that may not have been vetted  in accordance with the NERC Standards Processes Manual Standards Interruption process. 

Additionally, the SAR was to modify V3 not V4.  Thus the proposed Version should be Version 4 not Version 5.  To my knowledge FERC did not approve the prior proposed V4.  See item section 39 at link Federal Register :: Electric Reliability Organization Proposal To Retire Requirements in Reliability Standards Under the NERC Standards Efficiency Review

Michael Whitney, On Behalf of: Northern California Power Agency, , Segments 3, 4, 5, 6

- 0 - 0

In the future the SDT or NERC should develop a formal definition of jointly owned facilities, since there appears to be conflicting interruptions being enforced that may not have been vetted  in accordance with the NERC Standards Processes Manual Standards Interruption process. 

Additionally, the SAR was to modify V3 not V4.  Thus the proposed Version should be Version 4 not Version 5.  To my knowledge FERC did not approve the prior proposed V4.  See item section 39 at link Federal Register :: Electric Reliability Organization Proposal To Retire Requirements in Reliability Standards Under the NERC Standards Efficiency Review

Dennis Sismaet, Northern California Power Agency, 6, 1/6/2021

- 0 - 0

None.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

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Bruce Reimer, Manitoba Hydro , 1, 1/7/2021

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Texas RE noticed an apparent redundancy in the Severe VSL language.  The proposed Severe VSL language indicates that entities providing less than 85% of the information required under FAC-008-5, R8 Part 8.1 commit a “Severe” level violation.  Correspondingly, the final proposed Severe VSL category indicates that an entity’s complete failure to provide rating information required pursuant to FAC-008-5, R8 Part 8.1 also constitutes a “Severe” level violation.  From Texas RE’s perspective, because an entity has already committed a “Severe” violation when it submits less than 85% of the information required under FAC-008-5, R8 Part 8.1, the additional language in the final section addressing a complete failure is wholly subsumed within the 85% or less provision.  As such, Texas RE recommends its removal. 

 

Texas RE also noticed a space between 85 and % in the second to last sentence in the Severe VSL section.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 1/8/2021

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R8 limits the provision of information from the TO (and applicable GO) to ONLY “its associated RC, PC, TP, TO, and TOP” and does not have any provision for adjacent RCs, PCs, TPs, TOs, or TOPs to request similar information.  I would be inclined to include language that adjacent entities can request this information which would be in-line with what FERC has issues in its NOPR on 11/19/2020 on “Managing Transmission Line Ratings.” 

Also, I do disagree in part with the VSL’s for R8 in that there is no quantitative way to measure whether an entity only provide “85%” of the information associated with a facility rating vs. “90%” and vs. “87%”.  I agree with the quantitative measure on whether the entity provided it within the 30 calendar days or within the agreed to time-frame. 

 

Jeremy Lorigan, Seminole Electric Cooperative, Inc., 3, 1/8/2021

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N/A

FE Voter, Segment(s) 1, 3, 5, 6, 4, 7/31/2020

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N/A

Tammy Porter, On Behalf of: Lee Maurer, Oncor Electric Delivery, 1

- 0 - 0

Truong Le, On Behalf of: Chris Gowder, Florida Municipal Power Agency, 3,4,5,6; Carol Chinn, Florida Municipal Power Agency, 3,4,5,6; Richard Montgomery, Florida Municipal Power Agency, 3,4,5,6; Dale Ray, Florida Municipal Power Agency, 3,4,5,6

- 0 - 0

Anton Vu, Los Angeles Department of Water and Power, 6, 1/11/2021

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Since R8 will not be retired despite industry support, Reclamation recommends the drafting team seek to simplify R8 as a means of addressing industry opinion on its lack of value. Revising R8 could eliminate the difficulties of interpreting this requirement by narrowing the focus to address only the portions described in FERC’s rationale for rejecting its retirement. Reclamation recommends the language of R8 be simplified to require TOs and GOs subject to R2 to identify the most limiting Element and second most limiting Element for each solely or jointly owned Facility.

 

Richard Jackson, U.S. Bureau of Reclamation, 1, 1/11/2021

- 0 - 0

N/A.

Leonard Kula, Independent Electricity System Operator, 2, 1/11/2021

- 0 - 0

None.

Brandon Gleason, Electric Reliability Council of Texas, Inc., 2, 1/12/2021

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Platte River agrees with the SDT’s recommendation to retire Requirement R7 from FAC-008-3 in response to FERC Oder No. 873. Platte River would like R8 to be retired in its entirety as we believe sufficient technical justification was provided for its retirement by NERC in their June 7, 2019 petition.  If R8 cannot be retired in its entirety, we recommend revising R8 as detailed below.   

Platte River recommends removing item 2) Total Transfer Capability (TTC) from Requirement 8.2, as TTC is primarily used for commercial operations not reliability.  As stated in NERC’s June 7, 2019 petition: “Real-time system operators are ambivalent of these commercial arrangements, as they must maintain reliability of the BES according to SOLs and IROLs.  If a scheduled interchange would violate SOLs or IROLs, the real-time operators must disregard the scheduled interchange and operate the system to its actual reliability limits.”  This observation is reinforced by NERC’s statement in the 2015 filing related to risk-based reliability proposing removal of the Interchange Authority from the compliance registry.  

Additionally, Platte River agrees with NERC’s justification for the proposed retirement of the 56 MOD A Reliability Standards and their associated requirements which includes the rationale that these standards are commercial in nature.  If/when the MOD A reliability standards are retired, determining TTC will no longer be required by any NERC reliability standard.  Removing TTC at this time would be forward looking and beneficial as to not have FAC-008-5 referencing an out of date term.

Platte River recommends removing or, at a minimum, defining 3) an impediment to generator deliverability.  This term is not defined in the NERC Glossary of Terms, and to date, ERO-endorsed guidance is not available for entities to reference for defining generator deliverability.  Due to the differences in size and complexity of registered entities and individual generating units, generator deliverability can vary widely.  This creates inconsistency and confusion for reporting entities as well as regional entity staff.

Platte River recommends removing item 4) An impediment to service to a major load center from Requirement 8.2.  Major load center is not defined in the NERC Glossary of Terms, and to date, ERO-endorsed guidance is not available for entities to reference for defining a major-load center.  Due to the differences in size and complexity of registered entities, a major load center can vary widely.  This creates inconsistency and confusion for reporting entities as well as regional entity staff.

Therefore, Platte River would like the SDT to consider the following proposed changes to Requirement R8, sub requirement 8.2.

Proposed changes to Requirement R8 of FAC-008-5:

R8: Each Transmission Owner (and each Generator Owner subject to Requirement R2) shall provide requested information as specified below (for its solely and jointly owned Facilities that are existing Facilities, new Facilities, modifications to existing Facilities and re-ratings of existing Facilities) to its associated Reliability Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission Owner(s) and Transmission Operator(s): [Violation Risk Factor: Medium] [Time Horizon: Operations Planning]

8.1. As scheduled by the requesting entities:

8.1.1. Facility Ratings

8.1.2. Identity of the most limiting equipment of the Facilities

 

8.2. Within 30 calendar days (or a later date if specified by the requester), for any requested Facility with a Thermal Rating that limits the use of Facilities under the requester’s authority by causing an Interconnection Reliability Operating Limit (IROL).

8.2.1. Identity of the existing next most limiting equipment of the Facility

8.2.2. The Thermal Rating for the next most limiting equipment identified in Requirement R8, Part 8.2.1.

 

In conclusion, Platte River believes the operation of the Bulk Electric System (BES) is rooted in determining and operating within SOL’s and IROL’s.  Requirement 8.1 addresses the sharing of SOL’s, and Platte River’s recommendation for Requirement 8.2 addresses the critical nature of IROL’s.  Requirement 8.2, as currently written, strays from these two well-known and widely used terms.

Tyson Archie, Platte River Power Authority, 5, 1/12/2021

- 5 - 0

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

- 0 - 0

SMUD agrees with the comments submitted by Platter River Power.  

However, SMUD would like the SDT to consider providing clarificaiton to the sub-requirement R8.2 where, when requested for the owner to provide within 30-days, or other agreed upon timeframe, be clarified so that it is not an opening for expansion by auditors to request "cart blanc" the next most limiting element for all facilities.  Auditors are requesting the "next most limiting element" expanding the scope of the standard.

 

Joe Tarantino, On Behalf of: Nicole Goi, Sacramento Municipal Utility District, 1,3,4,5,6; Charles Norton, Sacramento Municipal Utility District, 1,3,4,5,6; Foung Mua, Sacramento Municipal Utility District, 1,3,4,5,6; Kevin Smith, Balancing Authority of Northern California, 1

- 2 - 0

Jenjira Knernschield, On Behalf of: Old Dominion Electric Coop., , Segments 3

- 0 - 0

David Jendras, Ameren - Ameren Services, 3, 1/13/2021

- 0 - 0

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

Andrea Barclay, On Behalf of: Andrea Barclay, , Segments 3, 4

- 0 - 0

None.

Douglas Webb, 1/13/2021

- 0 - 0

Laura Nelson, 1/13/2021

- 0 - 0

Maurice Paulk, Cleco Corporation, 3, 1/13/2021

- 0 - 0

We recommend that FAC-008 be prioritized for another revision (new project) to act on the potential revisions/corrections that were identified in Project 2017-03 FAC-008-3 Periodic Review.

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 1/13/2021

- 0 - 0

Dania Colon, Orlando Utilities Commission, 5, 1/13/2021

- 0 - 0

Daniel Gacek, Exelon, 1, 1/13/2021

- 0 - 0

W. Dwayne Preston, Austin Energy, 3, 1/13/2021

- 0 - 0

Jun Hua, Austin Energy, 4, 1/13/2021

- 0 - 0

Michael Dillard, Austin Energy, 5, 1/13/2021

- 0 - 0

Carl Pineault, Hydro-Qu?bec Production, 5, 1/13/2021

- 0 - 0

No additional comments.

Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 1/13/2021

- 0 - 0

Erin Green, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

Tacoma Power supports the comments submitted by Platte River Power Authority with respect to modifying the language in FAC-008 R8 if retirement of the Requirement is not feasible.

Jennie Wike, On Behalf of: John Merrell, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Marc Donaldson, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Terry Gifford, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6; Hien Ho, Tacoma Public Utilities (Tacoma, WA), 1,3,4,5,6

- 0 - 0

Jennifer Bray, Arizona Electric Power Cooperative, Inc., 1, 1/13/2021

- 0 - 0

None

Bobbi Welch, Midcontinent ISO, Inc., 2, 1/13/2021

- 0 - 0

Andrew Gallo, 1/13/2021

- 0 - 0