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2019-06 Cold Weather | EOP-011-2, IRO-010-4, TOP-003-5

Description:

Start Date: 01/27/2021
End Date: 03/12/2021

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2019-06 Cold Weather EOP-011-2 IN 1 ST 2019-06 Cold Weather EOP-011-2 01/27/2021 02/25/2021 03/03/2021 03/12/2021
2019-06 Cold Weather IRO-010-4 IN 1 ST 2019-06 Cold Weather IRO-010-4 01/27/2021 02/25/2021 03/03/2021 03/12/2021
2019-06 Cold Weather TOP-003-5 IN 1 ST 2019-06 Cold Weather TOP-003-5 01/27/2021 02/25/2021 03/03/2021 03/12/2021

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Hot Answers

ERCOT agrees with the placement of cold weather preparedness plan requirements within EOP-011 and supports a requirement that Generator Owners (GO) develop, maintain, and implement cold weather preparedness plans for generating units.  ERCOT supports the proposed requirement to mandate weatherization plans as an important first step in ensuring reliability.  However, an effective Reliability Standard would need to include clear and enforceable metrics, which the plan must be designed to achieve.  ERCOT notes that generators in the ERCOT Region have been required to have weatherization plans for many years.  It is apparent based on the February 2021 extreme cold weather event that having a plan may not be sufficient by itself to ensure reliability.  ERCOT would support a subsequent Reliability Standard project in order to specify these clear and enforceable metrics.

Brandon Gleason, Electric Reliability Council of Texas, Inc., 2, 3/12/2021

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Jun Hua, Austin Energy, 4, 3/12/2021

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Other Answers

Although we are able to locate and understand our entities requirements, we believe the industry may benifit from having all cold weather requirements located in a singled EOP Standard. For entities with multiple types of registered functions, searching for cold weather requirements in multiple different standards may be tedious and confusing.

 

Kristina Marriott, On Behalf of: Kristina Marriott, , Segments 5

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Cold weather operations are heavily weighed into the design phase of the facility and every part of the plant is designed to operate at the lowest ASHRAE temperature expected for the site the facility is constructed at.  This may make sense as an evaluation performed once at the beginning of the project to prove that facilities will operate as expected during cold weather, but no special procedures are required to be performed annually and this should not be an annual requirement. 

Dylan Sontag, On Behalf of: Silicon Ranch Corporation, SERC, Segments 1

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Idaho Power believes this new requirement is quite onerous and will require a large amount of work to complete. Idaho Power has a good handle on how cold weather impacts our facilities and how to respond without adding the additional requirement of a preparedness plan.

The proposed data specifications are extremely work intensive and, in some cases, may not be obtainable. For example, 7.3.2.1. is not something available for some facilities, and obtaining "5 years" of data for 7.3.2.2. is not something readily available for several plants. It could require new systems and additional years of data collection to meet these data requests.

Idaho Power has several questions for NERC to consider going forward:

1) Will entities be provided with a procedure detailing how to create this plan, or are entities expected to develop a procedure from scratch?

2) Will entities be provided a base template for a plan, or are entities expected to start from scratch?

3) How will NERC define the term "cold weather"? The term "cold weather" is too vague without appropriate specificity.

Laura Nelson, 2/10/2021

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For those generators that are located in cold climates and operate regularly in freezing weather, this standard will be a unnecessary administrative series of tasks.  The Cold Weather Preparedness should be limited to those locations where cold weather operations is not frequent.  Despite the recent problems in Texas, Generations in Northern climates continues to be reliable.  Perhaps the standard needs to put the burden on Planning Coordinators to identify generators that are of high risk, and require Cold Weather preparedness from them, excluding others.

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 2/22/2021

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While the proposed change in EOP-011-1 R2.2.9 is acceptable, some of the language in R7 is not. Overall, the requirement language does not state a clear measurable objective and thus does not meet the attributes of a results-based standard as described in Section 2.4 of the Standards Process Manual. Absent a clearly stated objective, the requirement may not achieve its intended outcome or provide a measurable reliability benefit.  Additionally, the requirement to “develop and maintain” along with responsibilities to provide awareness training in R7.4 are administrative in nature adding associated costs without commensurate reliability benefit. By requiring the entity to “implement” the plan, it is implied that the plan is developed and maintained and personnel are aware of their roles and responsibilities.  This can be confirmed via ERO CMEP activities (internal control evaluations). Therefore, the language changes below are provided for consideration by the 2019-06 SDT. The reliability objective was taken from page 86 of The South Central United States Cold Weather Bulk Electronic System Event of January 17, 2018:

R7. Each Generator Owner shall implement one or more cold weather preparedness plan(s) for its generating unit(s) to maximize generator output and availability for BES reliability during these conditions. The cold weather preparedness plan(s) shall include the following, at a minimum

7.1. Generating unit(s) freeze protection measures based on unique factors such as geographical location and plant configuration;

7.2. Annual maintenance and inspection of generating unit(s) freeze protection measures; and

7.3. Generating unit(s) cold weather data, to include:

7.3.1. Generating unit(s) operating limitations in cold weather; and

7.3.2. Generating unit(s):

7.3.2.1. minimum design temperature; or

7.3.2.2. minimum demonstrated historical performance during cold weather in the previous 5 years;

7.4. DELETED

John Allen, City Utilities of Springfield, Missouri, 4, 2/25/2021

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R7 as currently proposed includes training requirements. NERC has worked hard to eliminate duplicate requirements throughout the standards as this can potentially lead to multiple violations for the same single incident. With the exception of EOP-005 and EOP-006, PER-006 covers training requirements. We believe any new training requirements associated with Cold Weather should be included within PER-006 by revising R1.

In addition, the Rationale for R3 within the Guidelines and Technical Basis section provides insight into the reasoning behind the Operating Plan, and the RC’s review of an entity’s Operating Plan. The SDT may want to consider also adding the Generator Operator as well, as instruction from the Transmission entities would likely involve the Generator Operator.

We also believe there needs to be some clarity within the proposed revisions on what actions the receiving entity should, or perhaps should-not, take as a result of receiving this provided information.

AEP has chosen to vote negative on EOP-011, driven by our concerns stated in the first paragraph above related to training requirements.

Thomas Foltz, AEP, 5, 2/26/2021

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Gul Khan, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

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While the proposed change in EOP-011-1 R2.2.9 is acceptable, some of the language in R7 is not. Overall, the requirement language does not state a clear measurable objective and thus does not meet the attributes of a results-based standard as described in Section 2.4 of the Standards Process Manual. Absent a clearly stated objective, the requirement may not achieve its intended outcome or provide a measurable reliability benefit.  Additionally, the requirement to “develop and maintain” along with responsibilities to provide awareness training in R7.4 are administrative in nature adding associated costs without commensurate reliability benefit. By requiring the entity to “implement” the plan, it is implied that the plan is developed and maintained and personnel are aware of their roles and responsibilities.  This can be confirmed via ERO CMEP activities (internal control evaluations). Therefore, the language changes below are provided for consideration by the 2019-06 SDT. The reliability objective was taken from page 86 of The South Central United States Cold Weather Bulk Electronic System Event of January 17, 2018:

R7. Each Generator Owner shall implement one or more cold weather preparedness plan(s) for its generating unit(s) to maximize generator output and availability for BES reliability during these conditions. The cold weather preparedness plan(s) shall include the following, at a minimum

7.1. Generating unit(s) freeze protection measures based on unique factors such as geographical location and plant configuration;

7.2. Annual maintenance and inspection of generating unit(s) freeze protection measures; and

7.3. Generating unit(s) cold weather data, to include:

7.3.1. Generating unit(s) operating limitations in cold weather; and

7.3.2. Generating unit(s):

7.3.2.1. minimum design temperature; or

7.3.2.2. minimum demonstrated historical performance during cold weather in the previous 5 years;

7.4. DELETED

Todd Bennett, Associated Electric Cooperative, Inc., 3, 3/4/2021

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Tyson Archie, Platte River Power Authority, 5, 3/4/2021

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Dan Roethemeyer, Vistra Energy, 5, 3/5/2021

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Why is there a need to specifically identify cold weather events here?  The current standard states that "Reliability impacts of extreme weather conditions." shall be considered when building Emergency Plans.  Will extreme heat, or drought be added in the future as well? Is this being suggested since regions that do not typically experience cold weather events were recently impacted and had not considered them during their plan development?  Would it not be better to leave the statement as is, and provide examples of each type of event?  i.e. 1.2.6. Reliability impacts of extreme weather conditions, such as ice/snowstorms, heat wave, drought, heavy rains, flooding, earthquakes, wind events, landslides, tsunami, etc.?

Bruce Reimer, Manitoba Hydro , 1, 3/5/2021

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EOP-011-1 is applicable to System  Operators (TOP, BA, RC). Adding GO applicability to EOP-011-2 with proposed Requirement 7 does not appear to be a good fit. NIPSCO suggests that creating a new standard may be more appropriate here, similar to what was done with EOP-010-1 GMD Operations. (The SDT discussion above regarding a new standard is noted)  

Joe O'Brien, NiSource - Northern Indiana Public Service Co., 6, 3/5/2021

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Patricia Lynch, NRG - NRG Energy, Inc., 5, 3/5/2021

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We agree with the requirement, however we believe that there should be coordination between Generation Owners, Transmission Planners and Planning Coordinators on the appropriate level of winterization requirements and minimum design temperature requirements. Transmission Planners and Planning Coordinators have the visibility of the entire generation fleet within their area and therefore, should have the ultimate responsibility to set the appropriate minimum design, operating and cold start temperature requirements for the Generator Owners.

 

WECC Cold Weather, Segment(s) 10, 3/5/2021

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Seattle City Light appreciates the efforts of the SDT to balance the requirement for an industry-wide standard while not burdening entities located in routinely cold regions with administrative activities. As part of this balance, Seattle understands that the SDT intends the term “cold weather” and associated activities to apply to conditions that are extremely or abnormally cold for a particular location or region, rather than applying a single measure of “cold weather” (such as “below freezing”) across the continent. What is “cold weather” for a plant in Texas is routine weather for a plant in Minnesota or Canada, for instance. To make this distinction clear, Seattle recommends that wherever the term “cold weather” has been added to a Standard, it should be replaced with the term “abnormally cold weather.”

Matthew Nutsch, On Behalf of: Seattle City Light, WECC, Segments 1, 3, 4, 5, 6

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Talen agrees with placement of the new Generator Owner cold weather preparedness plan(s) requirement in the EOP-011 standard.

Donald Lock, Talen Generation, LLC, 5, 3/9/2021

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BPA supports Reclamation’s comments.

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Overall, Tacoma Power supports the efforts of the SDT to address the recommendations identified in the 2019 FERC and NERC Staff Report, and concurs that additional measures are necessary to prevent the repeat cold weather events experienced over the last decade. However, Tacoma Power believes there’s a more effective and appropriate strategy to fully address the issues underlying these events.

 

First, Tacoma Power recommends maintaining the current focus of EOP-011 on Real-Time Operations performed by NERC-Certified System Operators in response to an emergency. The recommendations prescribed in the 2019 FERC and NERC Staff Report are related to long-term planning or normal operation Time Horizons. Both the FAC Standards (Facilities Design, Connections, and Maintenance) and the MOD Standards (Modeling, Data, and Analysis) are better suited to capture Requirements necessary to ensure facilities are adequately designed, maintained, and to perform analysis to confirm generation capacity/capability. Tacoma Power requests clarification from the SDT as to why maintenance or design changes (e.g. freeze protection measures) are not contained in the FAC or MOD Standards, and how these activities are tied to Real-Time operations performed during an emergency.

 

As an alternative to adding maintenance and design requirements to EOP Standards, Tacoma Power recommends the SDT approach extreme cold weather events similar to how the industry approached GMD events in Project 2013-03. Instead of prescriptive requirements, the SDT should develop requirements to 1) assess vulnerabilities, 2) communicate results of assessments, and 3) evaluate/identify CAPs, which could include maintenance, design changes, and operating plans. This approach would ensure that vulnerabilities are identified, and only facilities with cold weather vulnerabilities need mitigative actions. These Requirements could be added to a modified MOD-025, which already contains Requirements for GOs to perform testing and studies, or a standalone FAC or MOD Standard. These requirements added to MOD-025 might look like the following:

“RX. Generator Owners shall complete a benchmark Cold Weather Vulnerability Assessment at least once every 60 calendar months. [Violation Risk Factor: High] [Time Horizon: Long-term Planning]

RY. Generator Owners shall communicate to their respective Transmission Planner any vulnerabilities identified in RX that could negatively impact applicable generation facility capacity or availability. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]

RZ. Generator Owners that conclude through the Cold Weather Vulnerability Assessment conducted in Requirement RX that their generation facility has vulnerabilities that could impact generator output and availability during these conditions, shall develop a Corrective Action Plan (CAP) addressing how the vulnerabilities are mitigated. The CAP shall: [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]

RZ.1 Be developed within one year of completion of the Cold Weather Vulnerability Assessment.

RZ.2 Include necessary maintenance activities, cold weather preparation plans, and freeze protection methods.”

Project 2013-03 also created EOP-010, which provides for the Real-Time response and actions performed by the NERC-Certified System Operators in response to GMD events. Tacoma Power recommends the SDT evaluate EOP-010 and consider utilizing this structure and Requirement language for any new cold weather related EOP Requirements. For example, a new EOP-011 requirement could be worded as follows:

“…RX. Each Transmission Operator shall develop, maintain, and implement a cold weather Operating Procedure or Operating Process to mitigate the effects of extreme cold weather events on the reliable operation of its respective system. At a minimum, the Operating Procedure or Operating Process shall include: [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning, Operations Planning, Same-day Operations, Real-Time Operations]…”

Lastly, Tacoma Power does not support adding training requirements to EOP Standards. NERC has worked hard to eliminate duplicate requirements throughout the Standards as this can potentially lead to multiple violations for the same single incident. With the exception of EOP-005 and EOP-006, PER-006 covers training requirements for plant personnel. Tacoma Power recommends moving the EOP-011 Part R7.4 training requirements to PER-006. The purpose of PER-006 is “[t]o ensure that personnel are trained on specific topics essential to reliability to perform or support Real-time operations of the Bulk Electric System.” Training of personnel for cold weather preparedness is essential to reliability and supports real-time operations of the BES. Additionally, PER-006 is applicable to GO personnel and is not related to Operator certifications contained in PER-005 (PER-005 personnel are explicitly excluded in the PER-006 applicability). Therefore, PER-006 is a more appropriate location for this new training requirement than EOP-011, which is focused on NERC-certified System Operator actions during or following an emergency.

In order to incorporate this new GO training requirement to PER-006, Tacoma Power recommends adding a second Requirement and modifying the applicability section, similar to the following:

New PER-006 Requirement:

“R2. Each Generator Operator shall provide training to personnel identified in Applicability section 4.1.1.2 on the roles and responsibilities of site personnel contained in the applicable cold weather preparedness plan. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning]

M2. Each Generator Operator shall have available for inspection, evidence that the applicable personnel completed training. This evidence may be documents such as training records showing successful completion of training that includes training materials, the name of the person, and date of training.”

New PER-006 Applicability:

“4.1.1.2 Plant personnel who are responsible for performing actions contained in the applicable entities cold weather preparedness plan. (Applicable only to R2)”

Tacoma Power, Segment(s) 1, 3, 4, 5, 6, 3/9/2021

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N/A.

Leonard Kula, Independent Electricity System Operator, 2, 3/9/2021

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Many generating units exist in tropic/subtropic parts of the US where the proposed cold weather requirements are much more burdensome than necessary.   Of course, the proposed change recognizes this in Part 7.1 when discussing “unique factors such as geographical location”. However, the proposed change continues to require identification of “generating unit operating limitations in cold weather” (Part 7.3.1) regardless of whether the generating unit is located in a geographical location where cold weather requirements are minimal or non-existent.  The section should include specificity as to what geographic areas would require addressing parts 7.2, 7.3, and 7.4.

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 3/10/2021

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Southern Company agrees that EOP-011 is the best fit for this new cold weather preparedness plan requirement.  Southern Company offers the following suggestions for the SDT.

1. Revise the wording of proposed requirement 7.3.2.2

a. The current wording is not specific enough on what data is being asked for (Temperature, operational limitations, etc.).  

b. Additionally, as currently written, the GO could provide the minimum design temperature or the unit’s minimum demonstrated historical performance within the last 5 years.  If the historical performance within the last five years is significantly higher than the design temp, and this number is the one provided to the RC/BA, it could cause the RC/BA to be overly conservative.  For example, a unit provides a demonstrated historical performance in the last 5 years of 25 degrees, however the unit has a design temperature of 15 degrees, but since the RC/BA only has the 25 degree data point, they are overly conversative/cautious in their system setup since they do not know the unit’s full capabilities (designed to 15 degrees).

c. Suggest re-wording to “If design temperature is not available, the minimum historical temperature in cold weather in the previous 5 years in which the unit has demonstrated full output operation”.

2. Discuss moving proposed requirement 7.4 to PER-006

a. Would ensure consistency as PER-006’s Purpose is “to ensure that personnel are trained on specific topics essential to reliability to perform or support Real‐time operations of the Bulk Electric System.”  Comment is intended to capture the GO/GOP training requirements in regards to this cold weather standard only, and not to reflect GO/GOP attendance at other training outlined in PER-006.

b. Would require that the GO be added to the Applicability of PER-006 if moved

c. Would require that the Functional Entity language (specifically existing GOP language) be revisited to ensure alignment and consistency with the new cold weather preparedness training requirement 

3. GOP applicability

a. There are instances where “Company X” owns a facility and “Company Y” operates and maintains the facility. In some of these instances this 3rd party operator is the registered GOP.  

b. There could be compliance conflicts if a GO is held accountable for this new requirement and the associated cold weather preparedness plan that it “develops and maintains”, but one that a separate GOP “implements” on their behalf.  There are also training considerations here as currently written (GO training the GOP). 

Southern Company, Segment(s) 1, 3, 6, 5, 1/14/2021

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  1. Our facilities are located in Northeast Region; they are prepared for extreme weather. This would just cause an Administrative redundancy of cold weather plans that already exist and have historically been in place from their initial design.

    • Instead of blanket requirements to address cold weather, possibly develop requirements to 1) assess vulnerabilities based on generator location, 2) communicate results of assessments, and 3) evaluate/identify CAPs, which could include maintenance, design changes, and operating plans. This approach would ensure that all vulnerabilities are captured, and only facilities with cold weather risks need to take mitigative actions.

  2. Training requirements belong in the PER Standards and not EOP Standards. Recommend moving R7.4 to PER-006-1.

  3. EOP-011 is written for Emergency Operations (recovery and mitigation) and is not written from the perspective of preparing generation facilities for emergencies.

  4. EOP-011 requirements deal with real-time operations. Requirements that deal with design or maintenance are not real-time measurements.

  5. Proposed EOP-011 R7 changes may not address the root cause behind the recent cold weather failures. The cause of these failures is that the generating units were not designed for low frequency high impact weather events.

Erick Barrios, New York Power Authority, 6, 3/10/2021

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This requirements implementation period is one year. We would need more time to implement this. Two years would be requested. GO & GOP doesn’t have a cold weather preparedness plan. In the Northwest we already specify our Units to perform based on local temperatures. We do inspections of equipment and systems but it is not officially filed. We currently do not track training on the roles and responsibilities of site personnel.

Glen Farmer, Avista - Avista Corporation, 5, 3/10/2021

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Although supportive of the intent of the Cold Weather Project, LES believes additional clarity is needed within EOP-011 R7 for Generator Owners. As such, LES supports the comments provided by the MRO NSRF.

Lincoln Electric System, Segment(s) 5, 6, 3, 1, 4/17/2018

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FE Voter, Segment(s) 1, 3, 5, 6, 4, 2/23/2021

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NO. 

NCPA supports TAPS comments.

Marty Hostler, Northern California Power Agency, 4, 3/10/2021

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Duke Energy agrees with the placement of cold weather preparedness plan requirements within EOP-011. However, Duke Energy suggests the following EOP-011 clarifications/modifications:

(1) Delineate the fact that Generator Owners wouldn’t normally communicate with the Balancing Authority or Reliability Coordinator relative to cold weather preparedness plans;

(2) Although EOP-011-1 currently contains proposed Requirements R1.2.6.2 and R2.2.9.2 (“any other extreme weather conditions”) language, suggest deleting proposed Requirements R1.2.6.2 and R2.2.9.2 and allowing proposed R1.2.6.1 and R2.2.9.1 to serve as the exclusive extreme weather language;

(3) Add a provision for the Transmission Operator/Balancing Authority to review the Generator Operator Winter Preparedness Plan;

(4) Remove R7.3.2 and subsections.  These additional administrative requirements do not improve reliability, and nowhere does it describe how this information will be utilized;

(5) The NERC functional entity for “7.4. Awareness training on the roles and responsibilities of site personnel contained in the cold weather preparedness plan” should be changed to reflect a GOP responsibility instead of the GO.

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

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Reclamation does not agree with the changes to EOP-011 Section 4, Applicability. The purpose of EOP-011 is Emergency Preparedness. Cold weather is seasonal and expected, not an emergency. Hydroelectric generators already have local cold weather plans (e.g., seasonal plants, water restrictions due to temperature, etc.). Reclamation recommends Section 4.2.1 be revised to clarify that the standard does not apply to hydroelectric generators or to certain geographic locations.

Recent events in ERCOT were associated with extreme weather across much of the US; however, only one geographic area experienced a disruption in reliability. The same area was associated with an event 10 years ago (September 2011 Southwest Blackout Event). The recurrence in the same area 10 years later supports the position that FERC is seeking to regulate the entire US on an issue that is specific to geography and type of generation. For the other areas of the country and other types of generators that routinely prepare for and experience cold weather, new requirements to document plans and provide training entail new administrative and financial burdens with low potential for increases to reliability.

Reclamation identifies that the placement of the new requirement in EOP-011 will make EOP-011 newly applicable to many Generator Owners across the nation. No other emergency preparedness requirements are attached to Generator Owners in this standard. The addition of a new standard adds a burden that may not be necessary in light of other standards that already apply to Generator Owners which could be leveraged to accomplish the goal. Reclamation recommends the SDT consider other standards for the Generator Owner cold weather requirements, such as PER standards for the training requirements and PRC standards for the maintenance practices and policies.

Richard Jackson, U.S. Bureau of Reclamation, 1, 3/11/2021

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See TAPS comments. 

NCPA, Segment(s) 4, 5, 6, 4/3/2020

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For Florida entities it will be challenging to develop cold weather plans with the “cold” weather we experience. See #4 below.

Training requirements belong in the PER Standards and not EOP Standards. Recommend moving R7.4 to PER-006-1. EOP-011 is written for Emergency Operations not for preparing generation facilities for emergencies.

Ballard Mutters, Orlando Utilities Commission, 3, 3/11/2021

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GRE supports the comments of the NSRF 

Michael Brytowski, Great River Energy, 3, 3/11/2021

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The MRO NSRF understand the intent of this Project and supports the updating of the three applicable Standards.  We are also aware of a reduced timeline to get to a Final Ballot.  Our Standard Development Process is so designed for multiple revision of Standards during a Project’s life cycle.  The MRO NSRF’s current set of comments are to assist the Drafting Team in ensuring that an effective and efficient set of updated continent-wide Standards are Results-Based and support the Reliable Operation and resiliency of our BPS during cold weather.

All additional Requirements need to state a clear measurable objective in order to meet the attributes of a results-based standard as described in Section 2.4 of the Standards Process Manual.  The following recommendations should assist the SDT in fulfilling the writing of a results-based standard.

 The MRO NSRF is pointing out that the Purpose Statemen states, “… that Operating Plans are coordinated within a RC Area”, which includes the proposed GO plan(s).  The currently enforceable EOP-011-1 the TOP (in R1) and the BA (in R2) requires the RC to review and approve those Operating Plans.  The proposed plan(s) per R7 (for the GO) does not state that any GO Cold Weather plan is required to be reviewed and approved by the RC.  The Purpose Statement needs to be updated to reflect the overall object of ALL the contained Requirements.  Recommend that the Purpose Statement simply read as, “To ensure each TOP, BA and GO has developed plan(s) to mitigate operating Emergencies to maintain the adequately level of reliability of the BES”, or words of that effect.  This simplified Purpose Statement then allows each Requirement to specifically address what is needed to be accomplished to support the adequate level of reliability that is required for BES operations.

R7 does not state a clear measurable objective.  Absent a clearly stated objective, the requirement may not achieve its intended outcome or provide a measurable reliability benefit.  Additionally, the requirement to “develop and maintain” along with responsibilities to provide awareness training in R7.4 are administrative in nature adding associated costs without commensurate reliability benefit. By requiring the entity to “implement” the plan, it is implied that its developed and maintained and personnel are aware of their roles and responsibilities.  This can be confirmed via ERO CMEP activities (internal control evaluations). Therefore, the language changes below are provided for consideration by the 2019-06 SDT. The reliability objective was taken from page 86 of The South Central United States Cold Weather Bulk Electronic System Event of January 17, 2018:

R7, The basis of R7 is to have a “preparedness” plan, “preparedness” is defined as “the quality or state of being prepared”.  This is interpreted as the GO is to have a plan to assist in “starting” only, hence a “preparedness plan”.  If this is not the intention, the SDT should clearly state what the intention is.

Part 7.1, Delete “unique factors”.  Which is an ambiguous word, recommend using “specific factors”.  This implies a clearer objective for each BES generator’s specific configuration.

Part 7.3.1, requires obtaining “operating limitations” and if those limitations are unknown, then 7.3.2 gives the GO other avenues to gather generator’s cold weather data.  At the end of 7.3.1 there is an “AND” this should be changed to an “OR”.  A GO may have data specified in 7.3.1 and if don’t then they can use 7.3.2 to obtain the generator’s cold weather data via different methods.

Part 7.3,  Recommend that within 7.3 (or its replacement), there is an additional part that reads; “Based on engineer analysis to determine minimum cold weather performance”.  This wording is currently used in PRC-027-1 supplement material and is a catch all when the GO cannot obtain manufacture cold weather design limitations or temperature(s).

Part 7.3.2.2, Requires a previous (rolling) 5 years of data.  Every year, the GO will need to update their data to cover the previous 5 years if part 7.3.2.2 is used to gather cold weather data.  Recommend that “in the previous 5 years” be deleted.  This will remove the “rolling” data requirement.  The NSRF recommends that a recommended amount of time for past performance be at least five years of cold weather data and this would be published in a Guideline and Technical document.

Part 7.4, Awareness training on the roles and responsibilities of site personnel contained in the cold weather preparedness plan.  The requirement of awareness training is unclear and not sure how it supports reliability.  Since R7 only requires freeze protection measures and annual maintenance and inspection of those freeze protection measures, plus minimum design elements, not sure how awareness training is going to enforce reliability.  Being “aware” of something cannot be measured such as training on a task can be measured.  So, I can be “aware” that when it is cold outside my generator may not start.  Plus, the “awareness” is for the roles and responsibilities of site personnel.  I’m sure plant personnel are aware what the plant electrician does, what the control room operator does, etc. 

Recommend 7.4 be deleted since it is an administrative element of R7.  The use of an ambiguous word like “awareness” will be viewed like “familiar” as in soon to be retired PRC-001-1.1(ii).  You cannot measure awareness.  With any identification of freeze protection measures within the preparedness plan, they become part of the BES generator.  Someone within the applicable entity will be preforming an annual inspection (most likely via a checklist) and thus, the freeze protections will perform as designed. Plus, awareness of the freeze protection measures to the GO is fruitless, since they installed the freeze protection measures.

Based on the previous concerns, the NSRF suggests the following changes to R7: (File attached)

 

 

MRO NSRF, Segment(s) 2, 3, 5, 1, 6, 4, 0, 3/11/2021

Question 1.PNG

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Texas RE appreciates the Standard Drafting Team’s (SDT) initial efforts to enhance the NERC Reliability Standards to ensure that Generator Owners (GOs), Balancing Authorities (BAs) and Transmission Operators (TOPs) take adequate steps to prepare for cold weather conditions.  Texas RE notes that the 2019 FERC and NERC Staff Report on the South Central United States Cold Weather BES Event of January 18, 2018 (“2019 Cold Weather Event Report”) specifically commented that “[a] mandatory Reliability Standard would require [GOs] to properly prepare for extreme cold weather, and would help [Reliability Coordinators (RCs)] and BAs identify units which may not be able to perform during an extreme cold weather event.”  (2019 Cold Weather Report, at 89).  Texas RE supports the SDT’s efforts to implement the mandatory Reliability Standard described in the 2019 Cold Weather Report to require, among other things, GOs to develop, maintain, and implement cold weather preparedness plans as a new Requirement R7 in the existing EOP-011 Standard. 

 

While Texas RE believes the proposed EOP-011-2 Requirement R7 reflects the general cold weather preparedness recommendations set forth in the 2019 Cold Weather Report, Texas RE believes that the SDT should consider incorporating additional specificity from the report in developing more specific, measurable requirements.  In particular, Texas RE recommends incorporating more specific elements identified in the 2019 Cold Weather Report to establish (1) clear timeframes for implementing cold weather preparedness plans, (2) minimum, measurable requirements for GO cold weather preparedness plans, and (3) more specific criteria around minimum maintenance activities and their periodicity.  Texas RE further recommends including provisions for RCs to review GO cold weather preparedness plans, in a manner consistent with the RC reviewing BA and TOP data for cold weather per IRO-010 and TOP-003, to ensure adequate cold weather preparedness measures are in place. 

 

Texas RE will first set forth its comments on these items in Requirement R7, as well as some general suggestions regarding other EOP-011 revisions.  Texas RE will then provide some general comments regarding potential revisions to proposed EOP-011 Requirements R1 and R2 to better implement the new Requirement R7 provisions in connection with TOPs and BAs, as well as additional revisions to the EOP-011 attachments. 

Timeframes for Implementing Cold Weather Preparedness Plans (Requirement R7)

As part of the “Generator Sound Practices” section in the 2019 Cold Weather Report, NERC and FERC staff specifically recommended GOs complete “freeze protection-related maintenance prior to winter weather.”  (Cold Weather Report, at p. 101).  Consistent with this recommendation, Texas RE believes the SDT should specify that GOs should implement one or more cold weather preparedness plans “seasonally prior to the expected onset of winter conditions, and review annually.”  The will clarify that timely preparation and implementation of winter weather protections should occur in advance of potential cold weather events, including actions that could require longer lead-times.

 

Minimal Measurable Requirements (Requirement R7, Part 7.1)

While the requirement is written to be flexible, Texas RE recommends creating measurable requirements for implementing freeze protection measures and technologies so there are clear criteria for the GO, as well as to promote consistent implementation of protective measures. For example, the SDT could consider incorporating the 2019 Cold Weather Report recommendation to specifically require continuous monitoring of heat tracing systems though displays and indicator lights as a measurable, minimal element of a GO cold weather preparedness plan. 

 

With all such requirements, the SDT could also consider preserving generator flexibility by requiring either adoption of the minimal measures or a documented justification for why such measures were not adopted as part of the cold weather preparedness plan.  However, if justifying specific freeze protection measures, generators should consider more than their geographic location and plant configuration.  Rather, Texas RE suggests that generators should also be required to consider local historical weather extremes and critical components that, if affected by cold conditions, would result in startup failure, derate, or tripping of the unit or units as part of the generator’s analysis of the measures necessary to implement an adequate cold weather preparedness plan, including the possible justifications for not taking certain freeze protection measures. 

 

Specific Criteria and Periodicity for Maintenance and Inspection Activities (Requirement 7, Part 7.2)

Texas RE agrees with the SDT there should be a requirement for GOs to perform maintenance and inspection activities regarding freeze protection measures.  The 2019 Cold Weather Report specifically identified “[p]erforming periodic adequate maintenance and inspection of freeze protection elements (e.g., generating units’ heat tracing equipment and thermal insulation)” as a key element to ensure GOs adequately prepare for cold weather conditions.  To that end, Texas RE believes that specifically defining both minimum maintenance and inspection activities, as well as maximum maintenance and inspection intervals (in a similar format to the existing protection system maintenance and testing requirements in PRC-005) is important.  By way of example, the 2019 Cold Weather Report specifically recommends GOs adopt “regular, periodic operational checks of heat tracing circuits.”  (2019 Cold Weather Report, at 101).  Texas RE recommends that the SDT specify minimal activities associated with such operational checks and define a regular, periodic maintenance schedule to ensure consistency across generators.  In a similar vein, the SDT should consider including criteria for maintenance activities, such as performing maintenance on generating units’ heat tracing equipment and thermal insulation to properly test equipment functionality. Texas RE generally recommends that maintenance activities be performed at least on an annual basis. 

 

Additional Recommended Revisions

In proposed EOP-011-2 Requirement 7, Part 7.1, Texas RE suggests replacing the term “unique” with the term “site-specific.”  The term “site-specific” better describes geographical and plant configuration factors specific to a generation unit. 

 

In proposed EOP-011-2 Requirement 7, Part 7.3.1, the propose language could possibly be read to be limited to low temperatures.  Texas RE recommends specifying broader attributes of extreme cold weather events, such as freezing precipitation, which can have independent impacts.  Texas RE suggests revising the language in Part 7.3.1 as follows: “Generating unit(s) operating limitations in cold weather due to temperature, icing, snow loads, or other factors; and”.

 

In proposed EOP-011-2 Requirement 7, Part 7.3.2, Texas RE recommends more specificity to account for other factors such as ice build-up and snow load, which could have significant, detrimental reliability impacts that are independent from freezing temperature, especially for renewables.  Texas RE recommends revising Part 7.3.2 as follows: “Minimum design temperature specifications applicable for winter conditions such as temperature, icing, or snow relevant to the facility.”

 

Texas RE is concerned Part 7.3.3.2 allows the GO to use minimum demonstrated historical performance during cold weather solely from the previous five years of cold weather data. This is a short time-frame for historical performance and is unlikely to capture extreme events that occur much less frequently than every five years. By way of example, such a standard would have excluded 2011 generator performance data from 2021 generator cold weather preparedness plans in the Texas RE footprint, meaning that such information would not have been considered in preparations for the most recent severe cold weather event.  Texas RE recommends GOs be required to obtain more detailed data related to generator performance in order to accurately identify temperatures at which the generator would encounter any operating limitations identified, including use of the most extreme weather event experienced at the facility’s geographic location as an outer bound. 

 

Texas RE also recommends clarifying what the performance is during cold weather.  Texas RE inquires how the TOP and RC will interpret this performance to perform the OPA, Real-time monitoring, and Real-time Assessments.

 

Requirement 7, Part 7.4

Texas RE agrees with the requirement for site personnel to have training.  Texas RE recommends adding a more specific part to document the roles and responsibilities of the personnel.  Additionally, there should be a periodicity for personnel to receive training on the cold weather preparedness plan as well as a provision that training be conducted prior to the winter season.

 

Requirements for TOPs and BAs to take specific actions (Requirements R1 and R2)

Texas RE recommends including specific actions that Transmission Operators (TOPs) in Requirement R1 and Balancing Authorities (BAs) in Requirement R2 should take as part of the implementation of the Operating Plans to mitigate operating Emergencies in their respective areas.  As it is currently written, only inclusions of reliability impact are required, not actions themselves, such as notification, cancellation or recall, reconfiguration, redispatch.

 

Attachments

Attachment 1

In section A. 2, Texas RE recommends stating that RCs will notify GOs of EEAs so as to be consistent with the standard language.  The following language could be added: “For an EEA resulting from cold weather, the Reliability Coordinator shall also notify Generator Owners within its Reliability Coordinator Area.” 

 

In section 3.4, Texas RE recommends revising 0.1 to the following: “The Reliability Coordinator shall notify all other Reliability Coordinators via the RCIS of the termination. The Reliability Coordinator shall also notify the neighboring Generator Owners, Balancing Authorities and Transmission Operators within its Reliability Coordinator Area.” 

 

The SDT could also consider changing the numbering as it does not look correct.

 

Rachel Coyne, Texas Reliability Entity, Inc., 10, 3/11/2021

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Entergy, Segment(s) 1, 5, 12/13/2017

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For Florida entities it will be challenging to develop cold weather plans with the “cold” weather we experience. See #4 below.

Training requirements belong in the PER Standards and not EOP Standards. Recommend moving R7.4 to PER-006-1.

Dania Colon, Orlando Utilities Commission, 5, 3/11/2021

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comments submitted

Don Stahl, Black Hills Corporation, 3, 3/11/2021

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The FERC recommendation on training was limited to operators.  However, requirement 7.4 in EOP-011 has no such limitation.  Please limit the training scope to the FERC recommendation.

“Any other extreme weather conditions” added to sections 1.2.6.2 and 2.2.9.2 in EOP-011 opens up the standard to require addressing any weather condition, e.g. tornados, hurricanes, dust storms, floods, etc.  This is not possible to forecast so how is an entity to do this?  The concern being addressed is Cold Weather.  Please limit the scope to this concern.

In EOP-011, if you have 7.3.1, why do you need to also have 7.3.2?  Need to change the “and” in 7.3.1 to an “or”.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

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{C}o   {C}Although requirements R1 and R2 require TOPs and BAs to submit their plans for RC approval, the proposed requirement R7 does not have a corresponding requirement for GOs to submit their plans to the BA or TOP for approval.  Such coordination at the BA and TOP area level is critical to ensuring that GO plans are properly evaluated for each of the areas within which its plants operate and well-coordinated with all entities responsible for the overall reliability of the grid.  While RCs have ultimate authority and oversight, BAs and TOPs also have obligations to maintain reliability within their areas.  The coordination of GO plans with BAs and TOPs as well as RCs during extreme weather events will allow such GO plans to be considered during the operational planning of all responsible entities, ensuring more cohesive, coordinated operational planning between and amongst all responsible entities.

{C}o   To ensure cohesiveness, the training requirements (requirement R7.4) should be added to PER standards versus being scattered within other standard families.

Scott McGough, Georgia System Operations Corporation, 3, 3/11/2021

2019-06_Cold_Weather_Comments_FINAL_GSOC_SBFCB03-11-21.docx

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Cold weather preparedness plans and generating unit cold weather data does not belong in an EOP Standard.  Nothing in the proposed Standard is related to operational actions during an Emergency.  Currently EOP Standards are applicable to the RC, BA, TOP, and GOPs, introducing the GO changes the nature of the EOP family of Standards.  Preparedness plans are more in the nature of preventive maintenance similar the treatment of batteries in the PRC Standards.  We recommend including these requirements in the FAC or MOD Standards

Regarding part 7.3.2.2, if the GO does not have design data, a previous (rolling) 5 years of data is required.  Every year, the GO will need to update their data to cover the previous 5 years if part 7.3.2.2 is used to gather cold weather data.  Recommend that “in the previous 5 years” be deleted.  This will remove the “rolling” data requirement.  Recommended amount of time for past performance be at least five years of cold weather data and this would be published in a Guideline and Technical document. 

Thomas Breene, WEC Energy Group, Inc., 3, 3/11/2021

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Jennifer Bray, Arizona Electric Power Cooperative, Inc., 1, 3/11/2021

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This requirement implementation period is one year. We would need more time to implement this. Two years would be requested. GO & GOP doesn’t have a cold weather preparedness plan. In the Northwest we already specify our Units to perform based on local temperatures. We do inspections of equipment and systems but it is not officially filed. We currently do not track training on the roles and responsibilities of site personnel.

Mike Magruder, Avista - Avista Corporation, 1, 3/11/2021

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See TAPS comments.

Dennis Sismaet, Northern California Power Agency, 6, 3/11/2021

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Utility Services supports the comments posted by the TAPS group.

Brian Evans-Mongeon, Utility Services, Inc., 4, 3/12/2021

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The NAGF agrees with placement of the new Generator Owner cold weather preparedness plan(s) requirements in the EOP-011 standard. Consolidating the GO cold weather preparedness plan requirements under one standard (EOP-011) provides clarity to industry rather than spreading the requirements over multiple standards (ex. FAC-003).

Wayne Sipperly, On Behalf of: North American Generator Forum, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 5

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

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While we agree to the placement of the requirements as part of R1.2.6, we recommend having cold weather conditions as a subset of extreme weather conditions, see suggested edit below

1.2.6. Reliability impacts of:

1.2.6.1. extreme weather conditions

1.2.6.2. cold weather

1.2.6.3 other extreme weather conditions

 

For R7.4 Awareness Training – two items to consider:

  • Requirement focuses on GO/ cold weather only. Recommend this is expanded to incorporate other or specified extreme weather conditions
  • Requirement does not specify how often the training needs to be provided, however, during the SDT Webinar annual training was noted as the intended periodicity.  If that is indeed the expectation, recommend the SDT clarify the requirement.  From a higher level perspective, we are concerned with the number of GO/GOP training requirements that are being introduced in various standards.  Recommend NERC staff consider consolidation of training requirements.

Justin Welty, NextEra Energy - Florida Power and Light Co., 6, 3/12/2021

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Truong Le, On Behalf of: Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5

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Support comments submitted by Tom Breene of WEC Energy Group. 

Janet OBrien, 3/12/2021

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Black Hills Corporation agrees that Requirement 7 can remain in EOP-011 however;

  • Should Add to the applicability, Transmission Owner (TO) that own synchronous condensers.  i.e. like stated in MOD-025 applicability 4.1.2.
  • Because generators are designed specific to their “location/type/etc.” – this requirement will take “Plans” not just a Plan.  They would need to be unit specific.  This will take time to develop for entities with large numbers of BES applicable Facilities/Plants.
  • 7.2 “Annual” is not acceptable; change to more consistent periodicity as stated in other Reliability Standards.  Example: 12 calendar months not to exceed 15 calendar months.
  • 7.3 Cold Weather Data:  to get usable performance data for the TOP/BA’s – this would involve a lot of time/extra work for both the TOP Real Time individuals as well as the GO generator facility management.   Many older generators do not have the capabilities of prior data, as well as the TOP not having generator data to provide to them in order to direct them to what time frame of performance data is needed. 
  • 7.3.1. operating limitations in cold weather can vary by the conditions of the “extreme” weather.   This is hard to define.
  • Per 7.3.2.1. is the minimum design temperature enough to even help the TOP in Real Time and Emergencies?  Black Hills Corporation TOP does not think so, as they feel this is part of the gap!
  • 7.3.2.2. designated 5 Years – where did that time frame come from?  This does not seem consistent with evidence retention periods of other reliability standards. Taking this to 1.2. Evidence Retention section;  …retains from last audit (page 7 of 21 draft).  This could spread data to be kept 10-12 years based on the GO Regional Entity audit schedule.
  • 7.4 What constitutes “Awareness” and how often?  This needs to be clarified.   Mandatory Training seems ‘over the top’ in that knowing how to operate their generator units by the “site operators” is part of their job.  This is felt to be a waste of site operators valuable time.  Operators react to all conditions as needed.

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

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Robin Hill, On Behalf of: Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5

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Aidan Gallegos, On Behalf of: PNM Resources - Public Service Company of New Mexico, , Segments 1, 3

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Cold weather preparedness plans and generating unit cold weather data does not belong in an EOP Standard.  Nothing in the proposed Standard is related to operational actions during an Emergency.  Currently EOP Standards are applicable to the RC, BA, TOP, and GOPs, introducing the GO changes the nature of the EOP family of Standards.  Preparedness plans are more in the nature of preventive maintenance similar the treatment of batteries in the PRC Standards.  We recommend including these requirements in the FAC or MOD Standards.  

Part 7.3.2.2, If the GO does not have design data it requires, a previous (rolling) 5 years of data.  Every year, the GO will need to update their data to cover the previous 5 years if part 7.3.2.2 is used to gather cold weather data.  Recommend that “in the previous 5 years” be deleted.  This will remove the “rolling” data requirement.  The NSRF recommends that a recommended amount of time for past performance be at least five years of cold weather data and this would be published in a Guideline and Technical document. 

Matthew Beilfuss, WEC Energy Group, Inc., 4, 3/12/2021

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DTEE agrees with the NAGF for placement of the new Generator Owner cold weather preparedness plan(s) requirements in the EOP-011 standard. Consolidating the GO cold weather preparedness plan requirements under one standard (EOP-011) provides clarity to industry rather than spreading the requirements over multiple standards (ex. FAC-003).

 

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

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James Baldwin, Lower Colorado River Authority, 1, 3/12/2021

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TMLP agrees that EOP-011 is the most effective place to insert cold weather requirements, though we disagree with the current proposed redlines. Concerns will be addressed in the later questions. 

Devon Tremont, Taunton Municipal Lighting Plant, 1, 3/12/2021

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AZPS agrees but also recommends adding Generator Operator to the scope of R7 as they are the ones that will be implementing the weather preparedness plans.

“Cold weather” is not defined. “Extreme weather conditions” is not defined. Is it based on temperature or geography? What is the scope of “cold” and “extreme”?

Marcus Bortman, APS - Arizona Public Service Co., 6, 3/12/2021

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Teresa Krabe, Lower Colorado River Authority, 5, 3/12/2021

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Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 3/12/2021

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Anthony Jablonski, ReliabilityFirst , 10, 3/12/2021

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PUD No. 1 of Chelan County , Segment(s) 1, 3, 5, 6, 3/12/2021

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SCE supports EEI's comments.

Neil Shockey, 3/12/2021

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Evergy supports and incorporates by reference Edison Electric Institute’s response to Question 1.

Douglas Webb, 3/12/2021

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Support the intent of this project and the updating of the three applicable Standards.  Support the submitted MRO-NSRF comments.

Wayne Guttormson, SaskPower, 1, 3/12/2021

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OGE agrees with including the GO cold weather preparedness plan requirements within EOP-011; however, we do have concerns with the proposed Requirement 7, as detailed below:

R7.1 – the usage of the word “unique” is ambiguous. We suggest removing “unique”.  Our proposed R7.1 language:

  • 7.1. Generating unit(s) freeze protection measures based on factors such as geographical location and plant configuration; 
  • R7.3.2.2 – It is not clear whether the demonstrated historical performance data is for a rolling 5-years since the proposed requirement language is not clear on whether the GOs will need to review their cold weather preparedness plan annually. We suggest removing the 5 years requirement language and including the amount of time for past performance (at least 5 years of cold weather data) to be published in an Implementation Guidance or Technical Rationale document.  We recommend adding an additional subpart if both R7.3.2.1 and R.7.3.2.2 cannot be met. Our proposed R7.3.2.2 and R7.3.2.3 language:
    • “7.3.2.2. minimum demonstrated historical performance during cold weather ; or”
    • “7.3.2.3. engineering analysis to determine minimum cold weather performance.”

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

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General:

Acciona Energy USA Global, LLC (Acciona) understands the purpose and industry need of Project 2019-06 Cold Weather.  The comments provided by Acciona are to ensure the uniqueness of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition are accounted for by the Standards Drafting Team.  Giving appropriate consideration for this emerging generation segment will ensure that any new requirements related to cold weather preparedness are performance and capability based, unambiguous and all applicable entities will be able to reasonably implement them, ultimately bolstering the reliability of the BPS during cold weather events. 

 §4.2. Facilities & Requirement R7. Terminology

Proposed §4.2 is unnecessary and should be removed.  According to the NERC Glossary of Terms (GoT): Generator Owner is defined as an Entity that owns and maintains generating Facility(ies).  The GoT defines Facility as a set of electrical equipment that operates as a single Bulk Electric System Element (e.g., a line, a generator, a shunt compensator, transformer, etc.).  As such, in the proposed Requirement R7. all occurrences of ‘generating unit(s)’ should be replaced with ‘generating Facility(ies)’, which is commonly known term in the industry and is officially defined in the NERC GoT.  Additionally, using the term ‘generating Facility(ies)’ in Requirement R7. would remove any ambiguity in regards to what equipment the requirement is applicable to, as ‘generating Facility(ies)’ encompasses all BES Elements required to import/export energy to the Transmission system.  Notwithstanding using the term ‘generating Facility(ies)’ would be consistent with terminology in other NERC Standards, such as NERC Reliability Standard FAC-008-3 – Facility Ratings, that may be referenced in association with Requirement R7.

Requirement R7.

Acciona has concerns about the term ‘maintain’.  As currently written the term refers to maintaining the cold weather preparedness plan (CWPP).  As it relates to CWPP what is the periodicity for maintenance and what should the maintenance include?  These are items that need to be defined to ensure consistent implementation and that this is a performance-based requirement. 

Requirement R7.1.

Acciona is unclear what Requirement R7.1. is requiring.  Acciona believes that Standards Drafting Team (SDT) is requesting Generator Owners (GO) to identify the generation Facility freeze protection measures that if not functioning would impede on the generation Facility(ies) ability to operate to either its minimum design operating temperature or minimum operational temperature based on demonstrated historical performance during cold weather.  If this is in fact the case then the GO must first determine the minimum ambient temperature in which the facility can operate at.  As currently written this is not a capability-based requirement. 

Unique is defined as being the only one of its kind; unlike anything else.  Acciona suggests removing the term ‘unique’ as there are probably more ‘common’ factors then ‘unique’ factors as it relates to freeze protection.  Acciona believes the term ‘plant configuration’ as it relates to freeze protection is too ambiguous.  For the purposes of the cold weather preparedness plan (CWPP) only freeze protections that impede on the generation Facility(ies) ability to operate to its minimum design operating temperature or minimum operational temperature demonstrated by historical performance during cold weather should be in scope.  This would ensure that this is a capability-based requirement.

Requirement R7.2.

‘Annual’ is not a defined term, consider using bright line criteria.  This would ensure that this is a performance-based requirement.

As stated by the Project 2014-01 Standards Applicability for Dispersed Generation Resources Standards Drafting Team’s white paper: “In some cases, the aggregated capability of the individual generating units may contribute to the reliability of the BPS; as such, there can be reliability benefit from ensuring that certain BES equipment utilized to aggregate the individual units to a common point of connection are operated and maintained as required in PRC-005. When evaluated individually, however, the generating units themselves do not have the same impact on BPS reliability as the system used to aggregate the units. The unavailability or failure of any one individual generating unit would have a negligible impact on the aggregated capability of the Facility; this would be irrespective to whether the dispersed generation resource became unavailable due to occurrence of a legitimate fault condition or due to a failure of a control system, protective element, dc supply, etc.” (https://www.nerc.com/pa/Stand/Prjct201401StdrdsAppDispGenRes/DGR_White_Paper_v17_clean_01_13_2016_Final_rev1.pdf)

For dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition, such as wind generation Facilities, each individual generating unit, a single wind turbine generator (WTG), can have many applicable freeze protections, that if not operational, could impede on the WTG’s ability to operate to its minimum design temperature.  However, as stated by Project 2014-01 Standards Drafting Team, “The unavailability or failure of any one individual generating unit would have a negligible impact on the aggregated capability of the Facility;”.  Acciona would like to request the Project 2019-06 Cold Weather Standards Drafting Team consider whether Requirement R7. should be applicable to the individual generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition, considering the precedent set by Project 2014-01 Standards Applicability for Dispersed Generation Resources Standards Drafting Team.  If the Project 2019-06 Cold Weather Standards Drafting Team determines that Requirement R7. should be applicable to the individual generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition, then Acciona would like to suggest Project 2019-06 Cold Weather Standards Drafting Team consider a percentage/time-based approach for the applicable freeze protections installed in an individual generating units of dispersed power producing resources. For example, 20% of the applicable freeze protections installed in an individual generating units of dispersed power producing resources must be maintained and inspected on annual basis and 100% applicable freeze protections installed in an individual generating units of dispersed power producing resources must be maintained and inspected on a five year basis.

Requirement R7.3.1.

‘Cold weather’ is not a defined term and is interpreted differently depending on a generation Facility(ies) geographic location’s climate.  Acciona suggests that ‘operating limitations’ in scope should be the ones that impede on the generation Facility(ies) ability to operate to its minimum design operating temperature or minimum operational temperature demonstrated by historical performance during cold weather.  This would ensure that this is a capability-based requirement.

Requirement R7.3.2., 7.3.2.1. & 7.3.2.2.

Acciona suggests using the term ‘minimum design operating temperature’ and  ‘minimum demonstrated operating temperature’ in R7.3.2.1. & R7.3.2.2, respectively.  This would ensure that only the minimum ambient temperature that would impede on the generation Facility(ies) ability to operate are in scope.  Using this also ensures only freeze protections and operating limitations that would impede on the generation Facility(ies) ability to operate to its minimum design operating temperature or minimum operational temperature demonstrated historical performance during cold weather should be in scope.

Requirement R7.4.

Acciona is recommending the removal of this Requirement R7.4. as it does not provide a performance, risk, and competency-based reliability requirement that support an effective defense-in-depth strategy nor does it identify a clear and measurable expected outcome.  As stated in Requirement R7. the cold weather preparedness plan (CWPP) must be ‘implemented’.  It is inherent that to ‘implement’ the CWPP site personnel would already be required, either directly or indirectly, to be aware of the required task.  For example, Requirement R7.2. requires annual maintenance and inspection of freeze protections to be a part of the CWPP.  Therefore, for a Generator Owner (GO) to successfully implement its CWPP qualified site personnel would need to perform the annual maintenance and inspection of freeze protections, which makes them aware of their roles & responsibilities as related to the CWPP.

Acciona suggests the following language based on the aforementioned comments:

R7. Each Generator Owner shall develop, maintain, and implement one or more documented cold weather preparedness plan(s) for its generating Facility(ies) as follows:

7.1. The cold weather preparedness plan(s) shall include the following, at a minimum:

7.1.1. generation Facility(ies) cold weather data including:

7.1.1.1. minimum design operating temperature; or

7.1.1.2. minimum demonstrated operating temperature based on historical performance during the coldest weather periods in the previous 5 years; and

7.1.1.3. generation Facility(ies) operating limitations that would prevent the generation Facility(ies) from operating to the temperatures identified in R7.1.1.1. or 7.1.1.2.;

7.1.2. the generation Facility(ies) freeze protection measures that allow the generation Facility(ies) to operate to the temperatures identified in R7.1.1.1. or 7.1.1.2.;

7.2. At least once per calendar year and with no more than 15 calendar months between, Generator Owners shall review the cold weather preparedness plan(s);

7.3. At least once per calendar year and with no more than 15 calendar months between, Generator Owners shall perform maintenance and inspection of generating Facility(ies) freeze protection measures as identified in Requirement R7.1.2.

7.3.1  Freeze protection measures as identified in Requirement R7.1.2. that are physically located in the individual generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition shall be maintained and inspected as follows:

~ 20% of the individual generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition located at a single generation Facility shall have 100% of each individual generating units freeze protection measures as identified in Requirement R7.1.2. maintained and inspected at least once per calendar year and with no more than 15 calendar months between; and

~ 100% of the individual generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition located at a single generation Facility shall have 100% of each individual generating units freeze protection measures as identified in Requirement R7.1.2. maintained and inspected at least once per rolling 60 calendar month period.

 

(Please note Requirement R7.3.1. is suggested language only if Project 2019-06 Cold Weather Standards Drafting Team determines that Requirement R7. should be applicable to the individual generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition)

George Brown, Acciona Energy North America, 5, 3/12/2021

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Santee Cooper supports the efforts of the SDT to address the recommendations identified in the 2019 FERC and NERC Staff Report, and agrees that additional measures are necessary to prevent the repeat cold weather events.  Santee Cooper requests further clarification around several of the additional requirements as currently drafted.

Santee Cooper recommends that the requirements in EOP-011 remain requirements performed by NERC Certified System Operators in response to an emergency.  The new Requirement 7 is related to long-term planning or normal operations.  The FAC standards and the MOD standards are better suited to capture Requirements necessary to ensure facilities are adequately designed, maintained, and to perform analysis.  Alternatively, a new EOP standard could be created that is solely associated to the GO for these requirements.

Santee Cooper requests further clarification on 7.3:  For example, if the design temperature is not available and a historical performance has to be utilized does that five years start when the standard becomes effective?  There would be a similar concern if a GO doesn’t have the design temperatature or has not been tracking historical performance verus temperature.  This requirement needs to be a phased-in to allow GOs to begin gathering the historical performance of units.

Santee Cooper would also like clarification on what data should be collected and included in the historical performance. 

For R7.4, the PER-006 standard that becomes effective on April 1, 2021 should be revised to include training requirements associated with a GO. 

Santee Cooper also requests clarification around the awareness training.  The implementation plan requires “awareness training on the roles and responsibilities of personnel under Requirement R7 Part 7.4 by the effective date of the Reliability Standard”.  Is this a one time training that has to be completed prior to the effective date of the standard or is there an expectation that training be provided on a routine or periodic basis?  It would be helpful if there were some further clarification on what all should be included in the awareness training.

Santee Cooper, Segment(s) 1, 3, 5, 6, 3/12/2021

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Agree with the addition, however, our Generators are located in North East (Temperate Region), they are prepared for extreme but possible conditions. This would just cause an Administrative redundancy of cold weather plans that already exist and have historically been in place from their initial design.

NPCC Regional Standards Committee no UI, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 3/12/2021

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Shannon Ferdinand, On Behalf of: Capital Power Corporation, MRO, WECC, Texas RE, SERC, Segments 1, 6

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Ameren Agrees with and supports NAGF comments

David Jendras, Ameren - Ameren Services, 3, 3/12/2021

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See Tom Breene's comments. 

David Hathaway, WEC Energy Group, Inc., 6, 3/12/2021

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Romel Aquino, Edison International - Southern California Edison Company, 3, 3/12/2021

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ACES Standard Collaborations, Segment(s) 1, 3, 4, 5, 3/12/2021

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EEI supports the placement cold weather requirements within Requirement R7, in EOP-011.  

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

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ISO New England (ISO-NE) supports the inclusion of these requirements in EOP-011; however, recommends the SDT now consider including provisions for non-BES Generators aggregated at a BES station as being included in the NERC Compliance Enforcement Program.

We also offer additional comments for EOP-011:

EOP-011, 3. Purpose expand to include the Generator Operator function as follows:  

Purpose: To ensure each Transmission Operator, Balancing Authority, Generator Owner and Generator Operator has developed plan(s) to mitigate and prepare for operating Emergencies; and that Transmission Operator and Balancing Authority Operating Plans are coordinated within a Reliability Coordinator Area.

EOP-011, 4. Applicability expand to include the Generator Operator as one of the Functional Entities.

EOP-011-2, R1: addition for clarification

1.2.6. Provisions to determine potential Reliability impacts of:

Requirement 1.2 states the TOP’s Operating Plans(s) should include processes to prepare for and mitigate Emergencies.  Reliability impacts of cold weather conditions and any other extreme weather conditions are not a process, but rather a type of Emergency that the TOP must have a plan(s) to address.  This addition will clarify that that a process should be in place to address cold weather and other extreme conditions.

EOP-011-2, R7:  Just as TOPs and RCs (in R1 and R2) “shall maintain a documented specification for the data necessary for it to perform its Operational Planning Analysis, Real-time monitoring, and Real-time Assessments”, GOs should be required to provide the information that is requested by the TOP and RC.

We also recommend the SDT consider the below modifications to R7 (some of which are from ISOs that have such mitigation/requirements in-place due to previous experience), including a recommendation to provide a clear, measurable objective for Part 7.1. Without a clear, measurable objective, the requirement may not achieve its intended outcome or provide a measurable reliability benefit.

R7. Each Generator Owner shall develop, maintain, and implement one or more cold weather preparedness plan(s) for its solely and jointly owned generator Facility(ies). The extreme weather preparedness plan(s) shall be reviewed, tested, and applicable portions shall be implemented prior to each applicable season, and shall include the following, at a minimum: [Violation Risk Factor: High] [Time Horizon: Operations Planning and Real-Time Operations]

7.1. freeze protection measures based on unique factors such as geographical location and plant configuration are adequate to operate through extreme temperatures and weather that are consistent with the geography and meteorology for the location of the unit(s)

            7.1.1 provisions to include the impact of precipitation (e.g. sleet, snowpack)

7.2 Annual maintenance and inspection of freeze protection measures; and

7.3. minimum design temperature or minimum demonstrated historical performance during cold weather in the previous 5 years or maintain cold weather data that is relevant in the absence of actual data within the last 5 years. For example, if cold weather has not occurred in the last 5 years but data from 7 years ago is available, that 7-year-old data should remain in place.  Such Generating unit(s) cold weather data, to include:

7.3.1. Generating unit(s) operating limitations in extreme cold weather; and

7.3.2. Generating unit(s) operating limitations in extreme hot weather; and

7.3.3. Generating unit(s) operating limitations in extreme precipitation events; and

7.3.4. Generating unit(s):

7.3.4.1. minimum and maximum design temperature; or

7.3.4.2. minimum demonstrated historical performance during extreme weather;

R8. Each Generator Operator shall develop, maintain, and implement one or more cold weather preparedness plan(s) for the generating Facility(ies) it operates. The cold weather preparedness plan(s) shall include the following at a minimum: [Violation Risk Factor: High] [Time Horizon: Operations Planning and Real-Time Operations]

8.1. Awareness training on the detailed roles and responsibilities of site personnel contained in the cold weather preparedness plan, including notifications to BAs/RCs/TOPs regarding generator availability and operating limitations during extreme weather.

ISO-NE recommends the SDT consider adding frequency and timing for the training requirement, such as “Annual” and “within 60 days of the start of the season.”

ISO-NE recommends adding provisions for the reliability impacts of hot weather as a separate numbered item. Cold weather is being addressed in this Standard update, but hot weather considerations as well as impacts of extreme precipitation events are similarly important to monitor and understand. Implementing cold weather requirements now and waiting for a hot weather event to implement hot weather requirements may be a mistake.

ISO New England (ISO-NE) supports the inclusion of these requirements in EOP-011; however, recommends the SDT now consider including provisions for non-BES Generators aggregated at a BES station as being included in the NERC Compliance Enforcement Program.

We also offer additional comments for EOP-011:

EOP-011, 3. Purpose expand to include the Generator Operator function as follows:  

Purpose: To ensure each Transmission Operator, Balancing Authority, Generator Owner and Generator Operator has developed plan(s) to mitigate and prepare for operating Emergencies; and that Transmission Operator and Balancing Authority Operating Plans are coordinated within a Reliability Coordinator Area.

EOP-011, 4. Applicability expand to include the Generator Operator as one of the Functional Entities.

EOP-011-2, R1: addition for clarification

1.2.6. Provisions to determine potential Reliability impacts of:

Requirement 1.2 states the TOP’s Operating Plans(s) should include processes to prepare for and mitigate Emergencies.  Reliability impacts of cold weather conditions and any other extreme weather conditions are not a process, but rather a type of Emergency that the TOP must have a plan(s) to address.  This addition will clarify that that a process should be in place to address cold weather and other extreme conditions.

EOP-011-2, R7:  Just as TOPs and RCs (in R1 and R2) “shall maintain a documented specification for the data necessary for it to perform its Operational Planning Analysis, Real-time monitoring, and Real-time Assessments”, GOs should be required to provide the information that is requested by the TOP and RC.

We also recommend the SDT consider the below modifications to R7 (some of which are from ISOs that have such mitigation/requirements in-place due to previous experience), including a recommendation to provide a clear, measurable objective for Part 7.1. Without a clear, measurable objective, the requirement may not achieve its intended outcome or provide a measurable reliability benefit.

R7. Each Generator Owner shall develop, maintain, and implement one or more cold weather preparedness plan(s) for its solely and jointly owned generator Facility(ies). The extreme weather preparedness plan(s) shall be reviewed, tested, and applicable portions shall be implemented prior to each applicable season, and shall include the following, at a minimum: [Violation Risk Factor: High] [Time Horizon: Operations Planning and Real-Time Operations]

7.1. freeze protection measures based on unique factors such as geographical location and plant configuration are adequate to operate through extreme temperatures and weather that are consistent with the geography and meteorology for the location of the unit(s)

            7.1.1 provisions to include the impact of precipitation (e.g. sleet, snowpack)

7.2 Annual maintenance and inspection of freeze protection measures; and

7.3. minimum design temperature or minimum demonstrated historical performance during cold weather in the previous 5 years or maintain cold weather data that is relevant in the absence of actual data within the last 5 years. For example, if cold weather has not occurred in the last 5 years but data from 7 years ago is available, that 7-year-old data should remain in place.  Such Generating unit(s) cold weather data, to include:

7.3.1. Generating unit(s) operating limitations in extreme cold weather; and

7.3.2. Generating unit(s) operating limitations in extreme hot weather; and

7.3.3. Generating unit(s) operating limitations in extreme precipitation events; and

7.3.4. Generating unit(s):

7.3.4.1. minimum and maximum design temperature; or

7.3.4.2. minimum demonstrated historical performance during extreme weather;

R8. Each Generator Operator shall develop, maintain, and implement one or more cold weather preparedness plan(s) for the generating Facility(ies) it operates. The cold weather preparedness plan(s) shall include the following at a minimum: [Violation Risk Factor: High] [Time Horizon: Operations Planning and Real-Time Operations]

8.1. Awareness training on the detailed roles and responsibilities of site personnel contained in the cold weather preparedness plan, including notifications to BAs/RCs/TOPs regarding generator availability and operating limitations during extreme weather.

ISO-NE recommends the SDT consider adding frequency and timing for the training requirement, such as “Annual” and “within 60 days of the start of the season.”

ISO-NE recommends adding provisions for the reliability impacts of hot weather as a separate numbered item. Cold weather is being addressed in this Standard update, but hot weather considerations as well as impacts of extreme precipitation events are similarly important to monitor and understand. Implementing cold weather requirements now and waiting for a hot weather event to implement hot weather requirements may be a mistake.

Michael Courchesne, On Behalf of: Michael Puscas, ISO New England, Inc., 2; Michael Puscas, ISO New England, Inc., 2

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Xcel Energy agrees with the addition of the proposed new requirement in EOP-011.  In regards to proposed R3, we acknowledge that some older plants may not have documented minimum design temperatures, and aren't sure that a 5 year view of historical performance would be adequate to cover some of the more extreme events. 

Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC - Segments 1, 3, 5, 6

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Carl Pineault, Hydro-Qu?bec Production, 5, 3/12/2021

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NV Energy would like to commend the Cold Weather SDT on the work done for this project, as NV Energy does believe this is a necessary industry requirement, especially given the recent Freeze Event that hit the midwest and Texas. 

NV Energy believe the regional guidelines provided by WECC (and potentially other Regional Entities), WECC Extreme Cold Weather Preparation Guideline, provide more sufficient requirements for for generation assets to ensure reliability of Bulk Electric Systems (BES). NV Energy would recommend the SDT review Regional Entity guidelines, and incorporate language to strengthen the compliance requirements. 

NV Energy also cannot agree to R7.3.2.2 as currently written, as additional clarity on existing language and concerns with the creation of a rolling 5-year requirement being additional burdensome from an evidentiary standpoint.

NV Energy is unclear on what is expected to show "demonstrated historical performance". An assumption can be made that an Entity would need to show "successful" historical performance, but again, what does that mean: "The unit did not take an outage due to cold weather?", "It ran as expected?", "We did take an outage due to cold weather events, and that is part of the historical performance record, too". 

Part 7.3.2.2 as written, creates a rolling timeline for evidence, as it request the previous (rolling) 5 years of data.  Thus, every year, the GO will need to update their data to cover the previous 5 years if part 7.3.2.2 is used to gather cold weather data. NV Energy believes that the majority of the data produced for this requirement would ultimately be unnecessary, as the foundation of this requirement is for extreme cold weather events. NV Energy would recommends that “in the previous 5 years” be deleted.  This will remove the “rolling” data requirement.  And another option would be to request the a finite number of coldest weather days during a finite timeline to review generating unit performance against.

Kevin Salsbury, Berkshire Hathaway - NV Energy, 5, 3/12/2021

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Donna Johnson, Oglethorpe Power Corporation, 5, 3/12/2021

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MEC supports the Cold Weather project, but also agrees with and supports the MRO NSRF comments on needed changes first.  Poorly written standards written in haste result in vague requirements which can lead to misinterpretation and needless violations.

Terry Harbour, Berkshire Hathaway Energy - MidAmerican Energy Co., 1, 3/12/2021

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CenterPoint Energy believes Winter Preparations should be standard operating procedure, which would aid in avoiding Emergency Operations. The cold weather preparedness plan(s) requirement should not be in any of the EOP standards.  EOP standards should remain for emergency events such as blackouts, loss of control center, GMD events, and reporting. ​

The FAC Standards focus on facility design, connections, and maintenance and therefore more applicable for the inclusion of ratings and parameters in which facilities should be operated during hot and cold weather conditions. ​

It is our suggestion to develop a new FAC Standard which covers Generation and TO/TOP Substation Winterization practices and requirements.  The new Standard would focus on the development and implementation of preventative standard operating procedures intended to mitigate cold weather emergency-level situations. The current EOP-011 would continue to focus on TOP/BA procedures to mitigate emergency situations, if they arise, including severe weather conditions.

Larry Rogers, Southern Indiana Gas and Electric Co., 5, 3/12/2021

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See comments submitted by Edison Electric Institute”.

Kenya Streeter, On Behalf of: Edison International - Southern California Edison Company, , Segments 1, 3, 5, 6

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In EOP-011( R 7.3) needs an explanation on what is required on historical performance.

Jeanne Kurzynowski, On Behalf of: CMS Energy - Consumers Energy Company - RF - Segments 3, 4, 5

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Southern Indiana Gas & Electric Company (SIGE) believes Winter Preparations should be standard operating procedure, which would aid in avoiding Emergency Operations. The cold weather preparedness plan(s) requirement should not be in any of the EOP standards.  EOP standards should remain for emergency events such as blackouts, loss of control center, GMD events, and reporting. 

The FAC Standards focus on facility design, connections, and maintenance and therefore more applicable for the inclusion of ratings and parameters in which facilities should be operated during hot and cold weather conditions. 

It is our suggestion to develop a new FAC Standard which covers Generation and TO/TOP Substation Winterization practices and requirements.  The new Standard would focus on the development and implementation of preventative standard operating procedures intended to mitigate cold weather emergency-level situations. The current EOP-011 would continue to focus on TOP/BA procedures to mitigate emergency situations, if they arise, including severe weather conditions.

SIGE Project 2019-06, Segment(s) 6, 5, 3, 3/12/2021

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OGE agrees with including the GO cold weather preparedness plan requirements within EOP-011; however, we do have concerns with the proposed Requirement 7, as detailed below:

{C}·       R7.1 – the usage of the word “unique” is ambiguous. We suggest removing “unique”.  Our proposed R7.1 language:

{C}o   {C}“7.1. Generating unit(s) freeze protection measures based on unique factors such as geographical location and plant configuration;”

{C}·       R7.3.2.2 – It is not clear whether the demonstrated historical performance data is for a rolling 5-years since the proposed requirement language is not clear on whether the GOs will need to review their cold weather preparedness plan annually. We suggest removing the 5 years requirement language and including the amount of time for past performance (at least 5 years of cold weather data) to be published in an Implementation Guidance or Technical Rationale document.  We recommend adding an additional subpart if both R7.3.2.1 and R.7.3.2.2 cannot be met. Our proposed R7.3.2.2 and R7.3.2.3 language:

{C}o   {C}“7.3.2.2. minimum demonstrated historical performance during cold weather in the previous 5 years; or”

{C}o   {C}“7.3.2.3. engineering analysis to determine minimum cold weather performance.”

Patrick Wells, OGE Energy - Oklahoma Gas and Electric Co., 5, 3/12/2021

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The term “cold weather” can have varied interpretation across the continent. The use of “any other” to extreme weather conditions in addition to “cold weather conditions” within the provisions of proposed R1.2.6 and R2.2.9 provisions of the Standard implies that cold weather is an extreme weather condition. BC Hydro operates many months of the year in cold weather conditions, which are not considered abnormal nor they result in operating Emergencies subject to EOP-011. If the “cold weather” term will become part of EOP-011, BC Hydro recommends that a clarification/definition within the context of extreme weather conditions be also developed.

The requirements for Generator Owner cold weather preparedness plans as drafted in Requirement R7 include provisions for freeze protection measures (R7.1), maintenance (R7.2), training (R7.4). BC Hydro’s view is that such provisions are better suited to appropriate Facility maintenance and/or design, and personnel training standards. BC Hydro recommends that EOP-011 do not include GO-applicable preparedness plans and that EOP-011 remain applicable to BA, RC and TOP functional entities.

BC Hydro Generation equipment are mostly physically located inside in climate controlled buildings. The equipment located in the switchyard outside of the building and which are exposed to weather conditions, are managed by Generator Owner and Transmission Owner functional entities. BC Hydro recommends that SDT considers applicability of the proposed cold weather preparedness plan(s) to the Transmission Owner functional entity.

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

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CenterPoint Energy Houston Electric, LLC (CEHE) believes Winter Preparations should be standard operating procedure, which would aid in avoiding Emergency Operations. The cold weather preparedness plan(s) requirement should not be in any of the EOP standards.  EOP standards should remain for emergency events such as blackouts, loss of control center, GMD events, and reporting. ​

The FAC Standards focus on facility design, connections, and maintenance and therefore more applicable for the inclusion of ratings and parameters in which facilities should be operated during hot and cold weather conditions. ​

It is our suggestion to develop a new FAC Standard which covers Generation and TO/TOP Substation Winterization practices and requirements.  The new Standard would focus on the development and implementation of preventative standard operating procedures intended to mitigate cold weather emergency-level situations. The current EOP-011 would continue to focus on TOP/BA procedures to mitigate emergency situations, if they arise, including severe weather conditions.  ​

CEHE Project 2019-06 Cold Weather, Segment(s) 1, 3/12/2021

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Darnez Gresham, Berkshire Hathaway Energy - MidAmerican Energy Co., 3, 3/12/2021

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Exelon supports the placement of cold weather requirements within Requirement R7, in EOP-011. 

 

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

Daniel Gacek, Exelon, 1, 3/12/2021

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CEPM agrees with the inclusion of the GO requirements in EOP-011 R7 with these considerations:

-        While the requirement gives the plant the latitude to come up with its own plan for cold weather preparedness, it also leaves open the possibility that any failure of the unit during cold weather operations could be considered a violation

-        Should there be requirements to update the plan if historical performance indicate the plan was not effective?

o   No obligation to produce an effective/successful plan

-        What is the expectation if weather exceeds the design basis of the plant?

-        Should there be some trigger (i.e. seasonal, calendar quarter, temperature, etc…) to invoke plan?

-        No indication as to how often awareness training should take place.

 

Cogentrix Energy Power Management, Segment(s) 5, 3/12/2021

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MISO is supportive of this project and supports the joint comments filed by the IRC SRC.

In addition, MISO believes weatherization must addressed. We support the inclusion of preparedness requirements in EOP-011; however, we think that the proposed language in Part 7.1 does not go far enough. Without a clear, measurable objective, the requirement may not achieve its intended outcome or provide a measurable reliability benefit. We recommend the SDT establish a national reference with geographic locational emphasis that can be used as a standard for consistency of application across the NERC footprint. As to what reference it should be, we leave  it up to the SDT to produce some factors. As an example, something like the USDA gardening zone map may be sufficient as a temperature reference.

Recommended language:

R7. Each Generator Owner shall develop, maintain, and implement one or more cold weather preparedness plan(s) for its solely and jointly owned generator Facility(ies). The extreme weather preparedness plan(s) shall be reviewed, tested, and applicable portions shall be implemented prior to each applicable season, and shall include the following, at a minimum: [Violation Risk Factor: High] [Time Horizon: Operations Planning and Real-Time Operations]

7.1. freeze protection measures based on factors such as geographical location and plant configuration that are adequate to operate through extreme temperatures and weather. The methodology used to establish extreme temperatures for each solely and joint owned unit shall be one or more industry standards such as the USDA Plant Hardiness Zone Map.

 

Bobbi Welch, Midcontinent ISO, Inc., 2, 3/12/2021

2019-06_Cold_Weather_Unofficial_Comment_Form_MISO_03-12-21.pdf

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Support comments by Western Area Power Administration, Sean Erickson, Segment 1.

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

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Amy Jones, On Behalf of: Public Utility District No. 2 of Grant County, Washington, , Segments 1, 4, 5, 6

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No, PG&E believes Winter Preparations should be standard operating procedure, which would aid in avoiding Emergency Operations just as other utilities have commented. PG&E has a good handle on how cold weather impacts our facilities and how to respond without adding the additional requirement of a separate preparedness plan.  PG&E Facilities have been designed to operate reliably in the conditional environment they exist in, most of which are located in cold mountainous terrain.  Local Maintenance practices and procedures already exist as well as already established cold weather plans of which should be the only guidance necessary to continue reliable operation of PG&E’s facilities.  In the point of recommending a locational fit PG&E would suggests considering the development of a new FAC Standard as the location.

Additionally, neither cold nor extreme weather are defined in this proposed standard nor in NERC’s Glossary of Terms.

PG&E recommends that the Distribution Provider (DP) be included in the Appliable FEs. NERC’s Functional Model v5.1 details the roles and relationships for each FE. Specifically, the DP is tasked to provide and implement load-shed capability. Timely and accurate load shedding is key to responsiveness to any Reliability Coordinator (RC) directives which support reliability of the grid during extreme weather events. This comment is specific to section 1.2.6 and 1.2.6.2 in the proposed draft of EOP-011-2. A corresponding requirement, evidence retention and VSLs should be developed to clarify the expectations for the DP, largely around the ability to support implementation of load shedding in a defined timeframe.

Pamalet Mackey, On Behalf of: Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5

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W. Dwayne Preston, Austin Energy, 3, 3/12/2021

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IRC SRC supports the inclusion of these requirements in EOP-011; however, recommends the SDT now consider including provisions for non-BES Generators aggregated at a BES station as being included in the NERC Compliance Enforcement Program.

We also offer additional comments for EOP-011:

EOP-011, 3. Purpose expand to include the Generator Operator function as follows:  

Purpose: To ensure each Transmission Operator, Balancing Authority, Generator Owner and Generator Operator has developed plan(s) to mitigate and prepare for operating Emergencies; and that Transmission Operator and Balancing Authority Operating Plans are coordinated within a Reliability Coordinator Area.

EOP-011, 4. Applicability expand to include the Generator Operator as one of the Functional Entities.

EOP-011-2, R1: addition for clarification

1.2.6. Provisions to determine potential Reliability impacts of:

Requirement 1.2 states the TOP’s Operating Plans(s) should include processes to prepare for and mitigate Emergencies.  Reliability impacts of cold weather conditions and any other extreme weather conditions are not a process, but rather a type of Emergency that the TOP must have a plan(s) to address.  This addition will clarify that that a process should be in place to address cold weather and other extreme conditions.

EOP-011-2, R7:  Just as TOPs and RCs (in R1 and R2) “shall maintain a documented specification for the data necessary for it to perform its Operational Planning Analysis, Real-time monitoring, and Real-time Assessments”, GOs should be required to provide the information that is requested by the TOP and RC.

We also recommend the SDT consider the below modifications to R7 (some of which are from ISOs that have such mitigation/requirements in-place due to previous experience), including a recommendation to provide a clear, measurable objective for Part 7.1. Without a clear, measurable objective, the requirement may not achieve its intended outcome or provide a measurable reliability benefit.

R7. Each Generator Owner shall develop, maintain, and implement one or more cold weather preparedness plan(s) for its solely and jointly owned generator Facility(ies). The extreme weather preparedness plan(s) shall be reviewed, tested, and applicable portions shall be implemented prior to each applicable season, and shall include the following, at a minimum: [Violation Risk Factor: High] [Time Horizon: Operations Planning and Real-Time Operations]

7.1. freeze protection measures based on unique factors such as geographical location and plant configuration are adequate to operate through extreme temperatures and weather that are consistent with the geography and meteorology for the location of the unit(s)

            7.1.1 provisions to include the impact of precipitation (e.g. sleet, snowpack)

7.2 Annual maintenance and inspection of freeze protection measures; and

7.3. minimum design temperature or minimum demonstrated historical performance during cold weather in the previous 5 years or maintain cold weather data that is relevant in the absence of actual data within the last 5 years. For example, if cold weather has not occurred in the last 5 years but data from 7 years ago is available, that 7-year-old data should remain in place.  Such Generating unit(s) cold weather data, to include:

7.3.1. Generating unit(s) operating limitations in extreme cold weather; and

7.3.2. Generating unit(s) operating limitations in extreme precipitation events; and

7.3.3. Generating unit(s):

7.3.3.1. minimum and maximum design temperature; or

7.3.3.2. minimum demonstrated historical performance during extreme weather;

R8. Each Generator Operator shall develop, maintain, and implement one or more cold weather preparedness plan(s) for the generating Facility(ies) it operates. The cold weather preparedness plan(s) shall include the following at a minimum: [Violation Risk Factor: High] [Time Horizon: Operations Planning and Real-Time Operations]

8.1. Awareness training on the detailed roles and responsibilities of site personnel contained in the cold weather preparedness plan, including notifications to BAs/RCs/TOPs regarding generator availability and operating limitations during extreme weather.

The IRC SRC recommends the SDT consider adding frequency and timing for the training requirement, such as “Annual” and “within 60 days of the start of the season.”

The IRC SRC questions adding provisions for the reliability impacts of hot weather as a separate numbered item. Cold weather is being addressed in this Standard update, but hot weather considerations as well as impacts of extreme precipitation events are similarly important to monitor and understand. Implementing cold weather requirements now and waiting for a hot weather event to implement hot weather requirements may be a mistake.

Standards Review Committee (SRC), Segment(s) 2, 1/25/2016

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CAISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 3/12/2021

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OPG concurs with the NPCC Regional Standards Committee’s comments.

Constantin Chitescu, Ontario Power Generation Inc., 5, 3/12/2021

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In addition to supporting the IRC SRC comments, PJM requests consideration of the following modifications to the proposed requirements:

R7. Each Generation Owner shall develop, maintain, and implement one or more cold weather preparedness plan(s) that are documented with supporting source data for its solely and jointly owned generator Facility(ies).  The extreme weather preparedness plan(s) shall be reviewed, tested, and applicable portions shall be implemented prior to each applicable season, and shall include the following, at a minimum: [Violation Risk Factor: High] [Time Horizon: Operations Planning and Real-Time Operations]

R7.1 freeze protection measures based on unique factors such as geographical location and plant configuration are adequate to operate through extreme temperatures and weather that are consistent with the geography and meteorology for the location of the unit(s) as validated by their host RC.

R7.3 Generating unit(s) cold weather data to include: minimum design temperature for new units or units with limited historical performance during cold weather; and demonstrated historical performance during cold weather for units with historical cold weather performance.  (To replace: Minimum design temperature; or minimum demonstrated historical performance during cold weather in the previous 5 years.) 

Requesting the Standard Drafting Team to add definitions in the standard to define cold weather (recommend using NOAA data) and extreme weather conditions.

 

Elizabeth Davis, On Behalf of: Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2

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Please clarify if EOP-011 R7 is an effort to change the cold weather design of units, for example requring a unit not designed to operate below freezing to now operate below freezing.  Or if its just requring the operator to basiclly clarify the units capabilities and maintain that capability.  

Please remove the five year as a rigid requirement in R7 part 7.3.2.2, simply stating historical performance over cold weather provides for a more compelete response from the Generator Owners on the capability of their equipment.  It could be stated as "for example over the last five years".  Alternately the SDT could allow for other time windows as long as the Generator Owner had a techinical rationale for the different time window.  

Aaron Staley, Orlando Utilities Commission, 1, 3/12/2021

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The EOP-011 should remain for emergency operation events, such as blackouts, and procedures to mitigate emergency situations, if they arise. These procedures would include emergency events following severe weather conditions.  Winterization preparedness and practice requirements should be defined under FAC Standards or a new EOP specific for cold weather events.  Adding 1.2.6 and 2.2.9 just seems like a redundant way to add something specific for the cold weather event issue, where do you stop?. 

Would be supportive of GO cold weather requirements, such as redlined in EOP-011, however concerns with some of the existing redline wording includes:

R7.1 – the word “unique” is ambiguous.  Suggest factual measure based on factual numbers and historical possible temperatures. 

R7.3.2.1 and R7.3.2.2 – the minimum design temp or the 5-years reference is not sufficient to protect against what happened in the Texas 2021 event.  Would need 100+ year worst imaginable wording to even get close to providing protection. 

Glenn Pressler, CPS Energy, 3, 3/12/2021

- 0 - 0

Michael Dillard, Austin Energy, 5, 3/12/2021

- 0 - 0

The EOP-011 should remain for emergency operation events, such as blackouts, and procedures to mitigate emergency situations, if they arise. These procedures would include emergency events following severe weather conditions.  Winterization preparedness and practice requirements should be defined under FAC Standards or a new EOP specific for cold weather events.  Adding 1.2.6 and 2.2.9 just seems like a redundant way to add something specific for the cold weather event issue, where do you stop?. 

Would be supportive of GO cold weather requirements, such as redlined in EOP-011, however concerns with some of the existing redline wording includes:

R7.1 – the word “unique” is ambiguous.  Suggest factual measure based on factual numbers and historical possible temperatures. 

R7.3.2.1 and R7.3.2.2 – the minimum design temp or the 5-years reference is not sufficient to protect against what happened in the Texas 2021 event.  Would need 100+ year worst imaginable wording to even get close to providing protection. 

Gladys DeLaO, CPS Energy, 1, 3/12/2021

- 0 - 0

Hot Answers

ERCOT disagrees that the RC should be required to consider generator design specifications (such as a manufacturer’s minimum ambient operating temperature) or historical cold-weather performance information in developing its OPA or RTA.  Instead, it would be more effective if the GOP were required to provide an accurate indication of its actual or anticipated capability and availability based on expected or real-time weather conditions and known limitations.  As the entity solely responsible for the operation of the generator, the GOP is in a much better position than the RC (or the BA or TOP, for that matter) to understand and predict the impacts of different cold weather scenarios on that generator.  Therefore, if the SDT proceeds with revisions to IRO-010, ERCOT suggests revising Requirement R1.3 to read as follows:

 

1.3                   Provisions for notification of generating unit capability and availability that reflects any operating limitations or unit-specific design specifications during actual and anticipated cold weather conditions.

 

However, ERCOT believes that it may be simpler and clearer to explicitly assign the GOP the responsibility to communicate cold weather impacts on generator capability and availability.  This could be achieved by adding such a requirement in a new R8 to EOP-011 (see response to Question 8 below).  However, if the SDT proceeds with a data specification requirement, that requirement would more appropriately be placed on the BA and TOP, rather than the RC (see same response).

Brandon Gleason, Electric Reliability Council of Texas, Inc., 2, 3/12/2021

- 0 - 0

Jun Hua, Austin Energy, 4, 3/12/2021

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Other Answers

The industry may benifit from having all cold weather requirements located in a singled EOP Standard. For entities with multiple types of registered functions, searching for cold weather requirements in multiple different standards may be tedious and confusing.

Kristina Marriott, On Behalf of: Kristina Marriott, , Segments 5

- 0 - 0

There are no annual cold weather preparations for our solar facilities that need to be performed and our facilities are not limited in any way during cold weather.

Dylan Sontag, On Behalf of: Silicon Ranch Corporation, SERC, Segments 1

- 0 - 0

Laura Nelson, 2/10/2021

- 0 - 0

For those generators that are located in cold climates and operate regularly in freezing weather, this standard will be a unnecessary administrative series of tasks.  The Cold Weather Preparedness should be limited to those locations where cold weather operations is not frequent.  Despite the recent problems in Texas, Generations in Northern climates continues to be reliable.  Perhaps the standard needs to put the burden on Planning Coordinators to identify generators that are of high risk, and require Cold Weather preparedness from them, excluding others.

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 2/22/2021

- 0 - 0

John Allen, City Utilities of Springfield, Missouri, 4, 2/25/2021

- 0 - 0

Thomas Foltz, AEP, 5, 2/26/2021

- 0 - 0

Gul Khan, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

- 0 - 0

Todd Bennett, Associated Electric Cooperative, Inc., 3, 3/4/2021

- 0 - 0

Tyson Archie, Platte River Power Authority, 5, 3/4/2021

- 1 - 0

Dan Roethemeyer, Vistra Energy, 5, 3/5/2021

- 0 - 0

Not applicable.

Bruce Reimer, Manitoba Hydro , 1, 3/5/2021

- 0 - 0

NIPSCO TOP and its RC (MISO) already include GO data in their data specifications for TOP-003 and IRO-010 respectively. It is not clear what additional information is being requested in the proposed R1.3 in both of these proposed standards and this should be clarified.     

Joe O'Brien, NiSource - Northern Indiana Public Service Co., 6, 3/5/2021

- 0 - 0

Patricia Lynch, NRG - NRG Energy, Inc., 5, 3/5/2021

- 0 - 0

R1 of IRO-010 is about creating data specification. An RC creating a data specification and then subsequently receiving the data does not ensure that expected upcoming cold weather conditions will be taken into consideration in an Operational Planning Analysis (OPA). An optimal outcome of a standard requirement would be that expected severe cold weather conditions are known/anticipated in an OPA timeframe and then appropriate Operating Plans are developed to address those upcoming system conditions. A better placement of cold weather preparedness requirement would be in in IRO-008-2 so that expected upcoming cold weather conditions are adequately anticipated in the OPAs and Operating Plans are accordingly developed. Similarly, a requirement for BAs to evaluate their upcoming cold weather conditions could also be placed in TOP-002. Such requirements would in of themselves prompt RCs to request appropriate data (such as generation unit temperature limitations) that are needed for appropriately performing their OPAs. An alternate option could be to add a requirement in the OPA definition to include upcoming cold weather impacts in the OPA as inputs to the OPA.

The second comment is more specific about the data items being requested in 1.3. First of all the requirement says ‘Provisions for notification of BES generating unit-specific specification….’ which is a very broad requirement because a generating unit’s design specification is not a single page item. There are several binders and hundreds of design drawings that are part of a generating unit’s design specification. An RC requesting BES generating unit-specific design specification may be compliant with the requirement but may not receive the actual piece of relevant information needed for cold weather analysis. A more meaningful quantity to request as part of data specification (which can then also be applied in an OPA) is the designed operating temperature range for a unit. For example, if the designed minimum operating temperature limit for a unit is 25o F and if upcoming weather conditions are going to be 20o F, then it could be considered in an OPA that a particular unit may not be able to operate (or even be started to operate) in the upcoming weather conditions and operating entities can plan accordingly.

WECC Cold Weather, Segment(s) 10, 3/5/2021

- 0 - 0

Seattle City Light appreciates the efforts of the SDT to balance the requirement for an industry-wide standard while not burdening entities located in routinely cold regions with administrative activities. As part of this balance, Seattle understands that the SDT intends the term “cold weather” and associated activities to apply to conditions that are extremely or abnormally cold for a particular location or region, rather than applying a single measure of “cold weather” (such as “below freezing”) across the continent. What is “cold weather” for a plant in Texas is routine weather for a plant in Minnesota or Canada, for instance. To make this distinction clear, Seattle recommends that wherever the term “cold weather” has been added to a Standard, it should be replaced with the term “abnormally cold weather.”

Matthew Nutsch, On Behalf of: Seattle City Light, WECC, Segments 1, 3, 4, 5, 6

- 0 - 0

Talen agrees with placement of Reliability Coordinator data specification requirements in the IRO-010 standard.

Donald Lock, Talen Generation, LLC, 5, 3/9/2021

- 0 - 0

BPA supports Reclamation’s comments.

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tacoma Power, Segment(s) 1, 3, 4, 5, 6, 3/9/2021

- 0 - 0

N/A.

Leonard Kula, Independent Electricity System Operator, 2, 3/9/2021

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 3/10/2021

- 0 - 0

Southern Company agrees that IRO-010 is the best fit for this new RC data specification requirement.  Southern Company offers the following suggestions for the SDT.

1. Revise the wording of proposed requirement 1.3

a. Suggest re-wording to “Provisions for notification of BES generating unit-specific minimum design temperature or if design temperature is not available, the minimum historical temperature during cold weather in the previous 5 years in which the unit has demonstrated full output operation, and BES generating unit operating limitations during local forecasted cold weather.”

Southern Company, Segment(s) 1, 3, 6, 5, 1/14/2021

- 0 - 0

Erick Barrios, New York Power Authority, 6, 3/10/2021

- 0 - 0

This requirements implementation period is one year. We would need more time to implement this. Two years would be requested. GO & GOP doesn’t have provisions for evaluating future weather events and acting on them. In the Northwest we already specify our Units to perform based on local temperatures. We do inspections of equipment and systems, but it is not officially filed.

Glen Farmer, Avista - Avista Corporation, 5, 3/10/2021

- 0 - 0

Lincoln Electric System, Segment(s) 5, 6, 3, 1, 4/17/2018

- 0 - 0

FE Voter, Segment(s) 1, 3, 5, 6, 4, 2/23/2021

- 0 - 0

Existing standards are not broken, they either are not being used, or enforced.

The existing IRO-010/TOP-003 Standards already allows RCs and TOPs the opportunity to obtain said data via their data specification requests to GO/GOPS, if they intend on using said data.

 

Forcing a RC or TOP to ask for data they don't need, nor have any accountability to use, is not efficient use of customer's dollars, and does not increase reliability.  As proposed standard modifications are a mere administrative burden, that costs everyone with no measurable reliability benefit.

 

As TAPS mentioned in prior SAR Comments.  The standards are written broadly by design, and thus include data specific to cold weather issues, as well as everything else that each RC, BA, or TOP needs to perform its operational functions.

 

Nor is there any indication in NERC's enforcement data that failure to respond to data specifications is a widespread problem.  If RCs, BAs, and TOPs are, in fact, having trouble getting the information they need, that is a CMEP problem, not a standards problem, since, as noted above, IRO-010-2 and TOP-003-3 already require each RC, BA, and TOP to request, without limitation, "the data necessary for it to perform" its operational functions, and require the entities receiving the data specifications to provide all such data.

 

As NERC said in its petition for approval of (among others) IRO-010-1a, which used the same top-down approach as IRO-010-2 and TOP-003-3, "[t]he requirements in the standard specify a formal request as the method for the Reliability Coordinator to explicitly identify the data and information it needs for reliability; and require the entities with the data to provide it as requested.  This method is sound because the Reliability Coordinator is the only entity that knows what data it needs to properly perform its reliability tasks, and the most efficient format for accepting this data."  Docket No. RM10-15, at 35 (Dec. 31, 2009) (emphasis added).  The alternative approach-listing each type of data that must be provided-will unavoidably be both under- and over-inclusive, since in addition to varying from one entity to another, data needs change over time as new technologies and risks emerge.

Marty Hostler, Northern California Power Agency, 4, 3/10/2021

- 0 - 0

This change is made redundant by the proposed change in TOP-003 and existing coordination required between the RC, BA, and TOP in IRO-008-2 R2.  Since the BAs and TOPs will be required to include cold weather considerations as part of their data specifications and into their Operational Planning Analyses, the RC will have to consider the potential cold weather impacts of the generators that have been accounted for in the Operating Plans of the respective BAs and TOPs.

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

- 0 - 0

Requirement R1.3 states “unit specific design specifications.” It is assumed that this refers to cold weather design, but it is not clear. Hydroelectric generators are secured inside buildings and do not have these specifications. Reclamation recommends excluding hydroelectric generators from this requirement as they rely on water operations, for which cold weather considerations are already accounted by local operations and maintenance procedures.

Richard Jackson, U.S. Bureau of Reclamation, 1, 3/11/2021

- 0 - 0

Existing standards are not broken, they either are not being used, or enforced.

The existing IRO-010/TOP-003 Standards already allows RCs and TOPs the opportunity to obtain said data via their data specification requests to GO/GOPS, if they intend on using said data.

 

Forcing a RC or TOP to ask for data they don't need, nor have any accountability to use, is not efficient use of customer's dollars, and does not increase reliability.  As proposed standard modifications are a mere administrative burden, that costs everyone with no measurable reliability benefit.

 

As TAPS mentioned in prior SAR Comments.  The standards are written broadly by design, and thus include data specific to cold weather issues, as well as everything else that each RC, BA, or TOP needs to perform its operational functions.

 

Nor is there any indication in NERC's enforcement data that failure to respond to data specifications is a widespread problem.  If RCs, BAs, and TOPs are, in fact, having trouble getting the information they need, that is a CMEP problem, not a standards problem, since, as noted above, IRO-010-2 and TOP-003-3 already require each RC, BA, and TOP to request, without limitation, "the data necessary for it to perform" its operational functions, and require the entities receiving the data specifications to provide all such data.

 

As NERC said in its petition for approval of (among others) IRO-010-1a, which used the same top-down approach as IRO-010-2 and TOP-003-3, "[t]he requirements in the standard specify a formal request as the method for the Reliability Coordinator to explicitly identify the data and information it needs for reliability; and require the entities with the data to provide it as requested.  This method is sound because the Reliability Coordinator is the only entity that knows what data it needs to properly perform its reliability tasks, and the most efficient format for accepting this data."  Docket No. RM10-15, at 35 (Dec. 31, 2009) (emphasis added).  The alternative approach-listing each type of data that must be provided-will unavoidably be both under- and over-inclusive, since in addition to varying from one entity to another, data needs change over time as new technologies and risks emerge.

NCPA, Segment(s) 4, 5, 6, 4/3/2020

- 0 - 0

Ballard Mutters, Orlando Utilities Commission, 3, 3/11/2021

- 0 - 0

GRE supports the comments of the NSRF 

Michael Brytowski, Great River Energy, 3, 3/11/2021

- 0 - 0

All data required by the RC should be the same data points as required for the BA and TOP.  This will provide consistency across these three Functional Entities.  Recommend that Part 7.3 and its sub-components be deleted from the proposed EOP-011-2 and be placed in IRO-010 (with modifications, see below) these are data points the RC should want to ask for to ensure they know the capabilities of BES generators in their system during cold weather conditions. 

7.3.1 requires “operating limitations” and if those limitations are unknown, then 7.3.2 gives the GO other avenues to gather generator’s cold weather data.  At the end of 7.3.1 there is an “AND” this should be changed to an “OR”.  A GO may have data specified in 7.3.1 and if don’t then they can use 7.3.2 to obtain the generator’s cold weather data via different methods.

MRO NSRF, Segment(s) 2, 3, 5, 1, 6, 4, 0, 3/11/2021

- 0 - 0

Texas RE agrees with the addition of requirements for Reliability Coordinators (RCs) to develop a documented data specification including the provision for notification of BES generating unit-specific design performance during cold weather, as well as expected BES generating unit operational limitations during local forecasted cold weather.  Texas RE suggests the SDT consider matching the language of the proposed IRO-010-4 Requirement R1, Part 1.3 with the proposed generating unit cold weather data requirements set forth EOP-011-2 Requirement R7, Part 7.3 as modified by Texas RE’s comments concerning that Part.  In a similar vein to GOs, RCs should obtain data beyond minimal design temperatures or minimal historical performance over a five-year period so they can account for other factors such as ice build-up and snow load, which could have significant, detrimental reliability impacts that are independent from freezing temperature, especially for renewables in performing Operational Planning Analyses, Real-time monitoring, and Real-time Assessments.

 

The language, “provisions for notification”, could possibly be read to imply that the data provision is event-driven instead of data that is requested and collected by the RC prior to any forecasted cold weather event.  While it may be helpful for the RC to receive event-driven notification from entities regarding any expected limitations during a specific forecasted cold weather event, the RC should be requesting and collecting data regarding design specifications and operating limitations for cold weather as part of the normal data request and collection processes, with the periodicity specified per IRO-010-4 Requirement R1, Part 1.4. 

Rachel Coyne, Texas Reliability Entity, Inc., 10, 3/11/2021

- 0 - 0

Entergy, Segment(s) 1, 5, 12/13/2017

- 0 - 0

IRO-010 already permits the RC to ask for this data and EOP-011 requires the RC to plan for this event. I don’t believe it’s necessary to add a redundant requirement to the obligation the RC has in EOP-011 within the IRO-010 standard. R1.3 is only required for cold weather conditions. It doesn’t include extreme weather conditions as specified in EOP-011 and should also be included for consistency.

 

Dania Colon, Orlando Utilities Commission, 5, 3/11/2021

- 0 - 0

comments submitted

Don Stahl, Black Hills Corporation, 3, 3/11/2021

- 0 - 0

The proposed requirement 7.3.2.2 in EOP-011 has a 5-year limitation on historical data.  However, the new requirements in IRO-010 do not have this limitation.  As such, will the historical information be required back to the commissioning of the unit?  If not, please add the 5-year limitation.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 1 - 0

Scott McGough, Georgia System Operations Corporation, 3, 3/11/2021

2019-06_Cold_Weather_Comments_FINAL_GSOC_SBFCB03-11-21.docx

- 0 - 0

Thomas Breene, WEC Energy Group, Inc., 3, 3/11/2021

- 0 - 0

All data required by the RC should be the same data points as required for the BA and TOP.  This will provide consistency across these three Functional Entities.  ACES recommends that Part 7.3 and its sub-components be deleted from the proposed EOP-011-2 and be placed in IRO-010.

 

AEPC is signing on to ACES comments as well.

Jennifer Bray, Arizona Electric Power Cooperative, Inc., 1, 3/11/2021

- 0 - 0

This requirement implementation period is one year. We would need more time to implement this. Two years would be requested. GO & GOP doesn’t have a cold weather preparedness plan. In the Northwest we already specify our Units to perform based on local temperatures. We do inspections of equipment and systems but it is not officially filed. We currently do not track training on the roles and responsibilities of site personnel.

Mike Magruder, Avista - Avista Corporation, 1, 3/11/2021

- 0 - 0

Existing standards are not broken, they either are not being used, or enforced.

The existing IRO-010/TOP-003 Standards already allows RCs and TOPs the opportunity to obtain said data via their data specification requests to GO/GOPS, if they intend on using said data.

 

Forcing a RC or TOP to ask for data they don't need, nor have any accountability to use, is not efficient use of customer's dollars, and does not increase reliability.  As proposed standard modifications are a mere administrative burden, that costs everyone with no measurable reliability benefit.

 

As TAPS mentioned in prior SAR Comments.  The standards are written broadly by design, and thus include data specific to cold weather issues, as well as everything else that each RC, BA, or TOP needs to perform its operational functions.

 

Nor is there any indication in NERC's enforcement data that failure to respond to data specifications is a widespread problem.  If RCs, BAs, and TOPs are, in fact, having trouble getting the information they need, that is a CMEP problem, not a standards problem, since, as noted above, IRO-010-2 and TOP-003-3 already require each RC, BA, and TOP to request, without limitation, "the data necessary for it to perform" its operational functions, and require the entities receiving the data specifications to provide all such data.

 

As NERC said in its petition for approval of (among others) IRO-010-1a, which used the same top-down approach as IRO-010-2 and TOP-003-3, "[t]he requirements in the standard specify a formal request as the method for the Reliability Coordinator to explicitly identify the data and information it needs for reliability; and require the entities with the data to provide it as requested.  This method is sound because the Reliability Coordinator is the only entity that knows what data it needs to properly perform its reliability tasks, and the most efficient format for accepting this data."  Docket No. RM10-15, at 35 (Dec. 31, 2009) (emphasis added).  The alternative approach-listing each type of data that must be provided-will unavoidably be both under- and over-inclusive, since in addition to varying from one entity to another, data needs change over time as new technologies and risks emerge.

Dennis Sismaet, Northern California Power Agency, 6, 3/11/2021

- 0 - 0

Utility Services supports the comments posted by the TAPS group.

Brian Evans-Mongeon, Utility Services, Inc., 4, 3/12/2021

- 0 - 0

The NAGF agrees with placement of Reliability Coordinator data specification requirements in the IRO-010 standard.

Wayne Sipperly, On Behalf of: North American Generator Forum, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 5

- 0 - 0

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

- 0 - 0

R1.3 Provisions for notification of BES generating unit-specific design temperature or minimum historical performance during cold weather, and expected BES generating unit operation limitations during local forecasted cold weather. We recommend focusing on minimum historical performance and defining the time period (e.g. 50 yr) to provide a more consistent approach across regions.

Justin Welty, NextEra Energy - Florida Power and Light Co., 6, 3/12/2021

- 0 - 0

Truong Le, On Behalf of: Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5

- 0 - 0

Janet OBrien, 3/12/2021

- 0 - 0

For Black Hills Corporation, it depends on what the RC requires when they rewrite their data specification which will then apply to the entities under their footprint.

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

- 0 - 0

Robin Hill, On Behalf of: Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5

- 0 - 0

Aidan Gallegos, On Behalf of: PNM Resources - Public Service Company of New Mexico, , Segments 1, 3

- 0 - 0

Matthew Beilfuss, WEC Energy Group, Inc., 4, 3/12/2021

- 0 - 0

DTEE agrees with the NAGF that the placement of Reliability Coordinator data specification requirements in the IRO standard is appropriate.

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

- 0 - 0

James Baldwin, Lower Colorado River Authority, 1, 3/12/2021

- 0 - 0

Devon Tremont, Taunton Municipal Lighting Plant, 1, 3/12/2021

- 0 - 0

AZPS would like to know what is the minimum periodicity for data to be provided? For example, seasonal vs annual. What is the requirement timeline for new generation added after the implementation date of this requirement? What is the scope of the data requirement or design criteria?  Is the “minimum historical performance during cold weather” defined as 5 years as specified in EOP-011 R7.3.2.2? What is the implementation plan for new generating units?

Marcus Bortman, APS - Arizona Public Service Co., 6, 3/12/2021

- 0 - 0

Teresa Krabe, Lower Colorado River Authority, 5, 3/12/2021

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 3/12/2021

- 0 - 0

Anthony Jablonski, ReliabilityFirst , 10, 3/12/2021

- 0 - 0

PUD No. 1 of Chelan County , Segment(s) 1, 3, 5, 6, 3/12/2021

- 0 - 0

SCE supports EEI's comments.

Neil Shockey, 3/12/2021

- 0 - 0

Evergy supports and incorporates by reference Edison Electric Institute’s response to Question 2.

Douglas Webb, 3/12/2021

- 0 - 0

Support the intent of this project and the updating of the three applicable Standards.  Support the submitted MRO-NSRF comments.

Wayne Guttormson, SaskPower, 1, 3/12/2021

- 0 - 0

There is no provision in any NERC Standard for the RC to incorporate the unit specific design specifications or minimum historical performance as well as expected BES generating unit operation limitations during cold weather into any of their analysis, which is currently being proposed for an addition to IRO-010. The existing language in IRO-010 R1.1 already provides for the collection of necessary data (“A list of data and information needed by the Reliability Coordinator to support its Operational Planning Analyses, Real-time monitoring, and Realtime Assessment…..”). We believe this data would include any generator cold or extreme weather limitations. In addition, IRO-008 should be revised as well so that the data collected by the RC is utilized in the RC’s Operational Planning Analysis (OPA) and Real-time Assessment (RTA) for anticipated cold weather conditions. By incorporating the GO cold weather parameters into their OPA and RTA, the RC will be able to understand limitations in specific areas of its region and to develop more effective Operating Plans to address those upcoming system conditions. 

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

Acciona Energy USA Global, LLC (Acciona) supports the Midwest Reliability Organization NERC Standards Review Forum’s (MRO NSRF) comments.

George Brown, Acciona Energy North America, 5, 3/12/2021

- 0 - 0

Santee Cooper recommends R1.3 be a phased in implementation in case GOs have problems getting the unit-specific design specification and they have not been collecting historical performance.  Phasing this requirement in allows GOs time to start collecting the minimum historical performance data during cold weather.

Also, what is “cold weather”for this requirement?  This could be a very different interpretation of this term based on where generating resources are located in North America.  Is the expectation that an entity define what constitutes cold weather?  That may cause an issue during an audit.

Santee Cooper, Segment(s) 1, 3, 5, 6, 3/12/2021

- 0 - 0

NPCC Regional Standards Committee no UI, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 3/12/2021

- 0 - 0

Allowing different planning entities the ability to make multiple requests of generators results in inefficiencies and can take focus away from more critical activities. A central, streamlined, and consistent process for submitting this type of data would benefit the grid. For greatest efficiency, NERC should proactively work with TOPs and RCs to identify pertinent information related to cold weather operating characteristics (and other areas of critical concern). NERC should consider if the Align tool, GADS portal, Misoperation Portal, or other similar centralized tools, could be used to streamline how / when these data requests are made. In addition, a centralized portal could include a data submission element such that a GO/GOP only must submit data once for it to be used, as required, by the appropriate planning entities (TOP, BA, RC).

If a centralized tool is not developed, the SDT should add a minimum time requirement to R3/R4/R5 such that the planning entity is required to give ample notice to the entity from which it is requesting data. Currently, each planning entity has a different process and timeline for making data requests; as a GO/GOP registered in multiple regions we must understand and work within each planning entity’s process. In addition, the onus should be on the planning entities to provide a fulsome, publicly available (on Align or NERC Website) list of entities required to submit data vs. requiring entities to rely on negative confirmation.

Shannon Ferdinand, On Behalf of: Capital Power Corporation, MRO, WECC, Texas RE, SERC, Segments 1, 6

- 0 - 0

Ameren Agrees with and supports NAGF comments

David Jendras, Ameren - Ameren Services, 3, 3/12/2021

- 0 - 0

David Hathaway, WEC Energy Group, Inc., 6, 3/12/2021

- 0 - 0

Romel Aquino, Edison International - Southern California Edison Company, 3, 3/12/2021

- 0 - 0

All data required by the RC should be the same data points as required for the BA and TOP. This will provide consistency across these three Functional Entities. ACES recommends that Part 7.3 and its sub-components be deleted from the proposed EOP-011-2 and be placed in IRO-
010.

ACES Standard Collaborations, Segment(s) 1, 3, 4, 5, 3/12/2021

- 0 - 0

EEI supports placing the Reliability Coordinator data specification requirements within IRO-010.

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

- 0 - 0

The ISO-NE supports the inclusion of the data specification requirements in IRO-010; however, recommends the SDT modify the text of the requirement to allow for entity flexibility in specifying the data provided to ensure that the data received is actionable for use in Reliability Coordinator models.

1.3. Provisions for notification of operating limitations, capability and availability for generating Facility(ies) during current and projected cold weather conditions.

Michael Courchesne, On Behalf of: Michael Puscas, ISO New England, Inc., 2; Michael Puscas, ISO New England, Inc., 2

- 0 - 0

Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Carl Pineault, Hydro-Qu?bec Production, 5, 3/12/2021

- 0 - 0

This would align with the current relationship between IRO-010 and TOP-003, and that the RC spec remains in IRO-010, and the TOP and BA specs in TOP-003 would align with the RC spec. 

Kevin Salsbury, Berkshire Hathaway - NV Energy, 5, 3/12/2021

- 0 - 0

Donna Johnson, Oglethorpe Power Corporation, 5, 3/12/2021

- 0 - 0

MEC supports the Cold Weather project, but also agrees with and supports the MRO NSRF comments on needed changes first.  Poorly written standards written in haste result in vague requirements which can lead to misinterpretation and needless violations.

Terry Harbour, Berkshire Hathaway Energy - MidAmerican Energy Co., 1, 3/12/2021

- 0 - 0

Larry Rogers, Southern Indiana Gas and Electric Co., 5, 3/12/2021

- 0 - 0

See comments submitted by Edison Electric Institute”.

Kenya Streeter, On Behalf of: Edison International - Southern California Edison Company, , Segments 1, 3, 5, 6

- 0 - 0

Jeanne Kurzynowski, On Behalf of: CMS Energy - Consumers Energy Company - RF - Segments 3, 4, 5

- 0 - 0

SIGE Project 2019-06, Segment(s) 6, 5, 3, 3/12/2021

- 0 - 0

 There is no provision in any NERC Standard for the Reliability Coordinator to incorporate into any of their analysis the unit specific design specifications or performance during cold weather, being required to be collected by the revision to IRO-010.  The existing language already provides for the collection of "…data and information necessary needed by the Reliability Coordinator to support its Operational Planning Analyses, Real-time monitoring, and Real-time Assessments…"  This would include any generator cold or extreme weather limitations.  Why would you require an entity to request data that they are not required to use?   

Patrick Wells, OGE Energy - Oklahoma Gas and Electric Co., 5, 3/12/2021

- 0 - 0

The proposed Requirement R1.3 references “unit-specific design specification”, which is a very broad term that seems better suited to facility ratings/design. Secondly, there needs to be added context on what constitutes “minimal historical performance”. This can be captured in Facilities ratings/design standards including dependencies on temperature or other weather parameters for specific “emergency” conditions, and how these may affect a generating unit’s operating limitations.

The term “cold weather” can have varied interpretations throughout the continent, so a more concise term and/or definition that would also include which weather elements may be subject to this (e.g. cold weather may imply this is just for ice/snow) would be helpful.

BC Hydro suggest that the IRO-010 language be kept to the specific information, such as the designed operating temperature range of a unit that would be necessary for performing Operations Planning Analyses.

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

- 0 - 0

CEHE Project 2019-06 Cold Weather, Segment(s) 1, 3/12/2021

- 0 - 0

Darnez Gresham, Berkshire Hathaway Energy - MidAmerican Energy Co., 3, 3/12/2021

- 0 - 0

Exelon supports placing the Reliability Coordinator (RC) data specification requirements within IRO-010.

 

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

Daniel Gacek, Exelon, 1, 3/12/2021

- 0 - 0

Cogentrix Energy Power Management, Segment(s) 5, 3/12/2021

- 0 - 0

MISO supports the IRC SRC comments

Bobbi Welch, Midcontinent ISO, Inc., 2, 3/12/2021

- 0 - 0

Support comments by Western Area Power Administration, Sean Erickson, Segment 1.

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

- 0 - 0

Amy Jones, On Behalf of: Public Utility District No. 2 of Grant County, Washington, , Segments 1, 4, 5, 6

- 0 - 0

Yes, PG&E generally agrees with the modifications to IRO-010 as proposed.

 

Pamalet Mackey, On Behalf of: Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5

- 0 - 0

W. Dwayne Preston, Austin Energy, 3, 3/12/2021

- 0 - 0

The IRC SRC supports the inclusion of the data specification requirements in IRO-010; however, recommends the SDT modify the text of the requirement to allow for entity flexibility in specifying the data provided to ensure that the data received is actionable for use in Reliability Coordinator models.

1.3. Provisions for notification of operating limitations, capability and availability for generating Facility(ies) during current and projected cold weather conditions.

Standards Review Committee (SRC), Segment(s) 2, 1/25/2016

- 0 - 0

CAISO supports the inclusion of the data specification requirements in IRO-010; however, recommends the SDT modify the text of the requirement to remove “Provisions for notification of BES generating unit-specific design specification or minimum historical performance during cold weather”.  This does not seem necessary for OPA/RTA/RT monitoring and seems more appropriate for inclusion in TOP-003.

 

Jamie Johnson, California ISO, 2, 3/12/2021

- 0 - 0

Constantin Chitescu, Ontario Power Generation Inc., 5, 3/12/2021

- 0 - 0

In addition to supporting the IRC SRC comments, PJM requests consideration of the following:

For R1.3, requesting clarifying language to allow RC flexibility in data specifications for [Provisions for notification of BES generating unit-specific design specification or minimum historical performance during cold weather, and expected BES generating unit operation limitations during local forecasted cold weather.]

Elizabeth Davis, On Behalf of: Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2

- 0 - 0

I don't believe it is neccessary to include the language in IRO-010.  EOP-011 requires the TOP to plan for cold weather and for the RC to review those plans.  IRO-010 is to ensure the RC can receive the data it needs and IRO-010 R1 allows the RC to ask for data in addition to the exisiting sub-parts of R1.  IRO-010s purpose does not include prescribing to the RC what data they need, but ensuring they have access to the data they determine they need.

Aaron Staley, Orlando Utilities Commission, 1, 3/12/2021

- 0 - 0

The proposed new IRO-010 redline requirement (1.3) is really just a subset of the data required in 1.1; it doesn’t cover improvement or cover the 2021 Texes event due to gas shortages or how a generator would establish cold weather limits for a gas unit, due to un-availability of gas supply, for example. 

Glenn Pressler, CPS Energy, 3, 3/12/2021

- 0 - 0

Michael Dillard, Austin Energy, 5, 3/12/2021

- 0 - 0

The new IRO-010 redline requirement (1.3) is really just a subset of the data required in 1.1; it doesn’t cover improvement cover the 2021 Texes event due to gas shortages or how a generator would establish cold weather limits for a gas unit (due to availability of gas supply). 

Gladys DeLaO, CPS Energy, 1, 3/12/2021

- 0 - 0

Hot Answers

As ERCOT has noted below in response to Question 8, it would be more straightforward to place the communication obligation on the GOP through a new R8 in EOP-011.  However, if the SDT proceeds with a data specification requirement, ERCOT agrees it would be appropriate to place such a requirement on the TOP and BA by inserting new R1.3 and new R2.3 in TOP-003, to read as follows:

 

1.3/2.3             Provisions for notification of generating unit capability and availability that reflects any operating limitations or unit-specific design specifications during actual and anticipated cold weather conditions.

Brandon Gleason, Electric Reliability Council of Texas, Inc., 2, 3/12/2021

- 0 - 0

Jun Hua, Austin Energy, 4, 3/12/2021

- 0 - 0

Other Answers

The industry may benifit from having all cold weather requirements located in a singled EOP Standard. For entities with multiple types of registered functions, searching for cold weather requirements in multiple different standards may be tedious and confusing.

Kristina Marriott, On Behalf of: Kristina Marriott, , Segments 5

- 0 - 0

There are no annual cold weather preparations for our solar facilities that need to be performed and our facilities are not limited in any way during cold weather.

Dylan Sontag, On Behalf of: Silicon Ranch Corporation, SERC, Segments 1

- 0 - 0

Laura Nelson, 2/10/2021

- 0 - 0

For those generators that are located in cold climates and operate regularly in freezing weather, this standard will be a unnecessary administrative series of tasks.  The Cold Weather Preparedness should be limited to those locations where cold weather operations is not frequent.  Despite the recent problems in Texas, Generations in Northern climates continues to be reliable.  Perhaps the standard needs to put the burden on Planning Coordinators to identify generators that are of high risk, and require Cold Weather preparedness from them, excluding others.

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 2/22/2021

- 0 - 0

John Allen, City Utilities of Springfield, Missouri, 4, 2/25/2021

- 0 - 0

While AEP sees the value and benefit of the inclusion of the Transmission Operator data specification requirements as currently proposed, AEP is concerned by exactly how this data would conceivably be used, specifically in regards to the potential impact that the sharing of this information could unintentionally have on the market. For example, an entity could perhaps be running close to a design specification or minimum historical performance and could perhaps be penalized as a result. We are also concerned by the potential subjectivity or inconsistency that might occur in determining compliance.

In addition, we also believe there needs to be some clarity within the proposed revisions on what actions the receiving entity should take, or perhaps should-not take, as a result of receiving this provided information.

Thomas Foltz, AEP, 5, 2/26/2021

- 0 - 0

Gul Khan, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

- 0 - 0

Todd Bennett, Associated Electric Cooperative, Inc., 3, 3/4/2021

- 0 - 0

Tyson Archie, Platte River Power Authority, 5, 3/4/2021

- 1 - 0

Dan Roethemeyer, Vistra Energy, 5, 3/5/2021

- 0 - 0

Bruce Reimer, Manitoba Hydro , 1, 3/5/2021

- 0 - 0

See response to Question 2 above.

Joe O'Brien, NiSource - Northern Indiana Public Service Co., 6, 3/5/2021

- 0 - 0

Patricia Lynch, NRG - NRG Energy, Inc., 5, 3/5/2021

- 0 - 0

Same comments as question 2.

WECC Cold Weather, Segment(s) 10, 3/5/2021

- 0 - 0

Seattle City Light appreciates the efforts of the SDT to balance the requirement for an industry-wide standard while not burdening entities located in routinely cold regions with administrative activities. As part of this balance, Seattle understands that the SDT intends the term “cold weather” and associated activities to apply to conditions that are extremely or abnormally cold for a particular location or region, rather than applying a single measure of “cold weather” (such as “below freezing”) across the continent. What is “cold weather” for a plant in Texas is routine weather for a plant in Minnesota or Canada, for instance. To make this distinction clear, Seattle recommends that wherever the term “cold weather” has been added to Standard, it should be replaced with the term “abnormally cold weather.”

Matthew Nutsch, On Behalf of: Seattle City Light, WECC, Segments 1, 3, 4, 5, 6

- 0 - 0

Talen agrees with placement of Transmission Operator data specification requirements in the TOP-003 standard.

Donald Lock, Talen Generation, LLC, 5, 3/9/2021

- 0 - 0

BPA supports Reclamation’s comments.

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tacoma Power, Segment(s) 1, 3, 4, 5, 6, 3/9/2021

- 0 - 0

N/A.

Leonard Kula, Independent Electricity System Operator, 2, 3/9/2021

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 3/10/2021

- 0 - 0

Southern Company agrees that TOP-003 is the best fit for this new TOP data specification requirement.  Southern Company offers the following suggestions for the SDT.

1. Revise the wording of proposed requirement 1.3

a. Suggest re-wording to “Provisions for notification of BES generating unit-specific minimum design temperature or if design temperature is not available, the minimum historical temperature during cold weather in the previous 5 years in which the unit has demonstrated full output operation, and BES generating unit operating limitations during local forecasted cold weather.”

Southern Company, Segment(s) 1, 3, 6, 5, 1/14/2021

- 0 - 0

Erick Barrios, New York Power Authority, 6, 3/10/2021

- 0 - 0

This requirements implementation period is one year. We would need more time to implement this. Two years would be requested. GO & GOP doesn’t have provisions for evaluating future weather events and acting on them. In the Northwest we already specify our Units to perform based on local temperatures. We do inspections of equipment and systems, but it is not officially filed.

Glen Farmer, Avista - Avista Corporation, 5, 3/10/2021

- 0 - 0

LES contends that it should not be the TOP’s responsibility to determine, or verify, cold weather capabilities of any units connected to their TOP Area. Requirements set forth related to the Generator Owners will be adhered to by them and units should be rated accordingly, just as in the FAC standards. The TOP should then require that capability information be submitted as part of the TOP-003 data specification and leave it at that. Even if multiple de-rates occur at different temperatures, all that should be needed is a rating schedule. Having the TOP require design specifications and performance data is not something they should, or are even equipped, to handle. Additionally, the phrase “operational limitations” is also ambiguous by nature; for a more clear and concise approach, we recommend referring to unit capabilities. To ensure TOPs are not inundated with unnecessary information, and to maintain clear expectations, LES suggests the following change to TOP-003 R1.3:

“R1.3.  Provisions for notification of expected BES generating unit capabilities during local forecasted cold weather.”

Lincoln Electric System, Segment(s) 5, 6, 3, 1, 4/17/2018

- 0 - 0

FE Voter, Segment(s) 1, 3, 5, 6, 4, 2/23/2021

- 0 - 0

NO. See response to Question 3.

Marty Hostler, Northern California Power Agency, 4, 3/10/2021

- 0 - 0

This change is made redundant by the proposed change in due to the existing coordination required between the RC, BA, and TOP in IRO-008-2 R2.  Since the BAs and TOPs will be required to include cold weather considerations as part of their data specifications and into their Operational Planning Analyses, the GOP will have to consider the potential cold weather impacts of its generators to provide information to the respective BAs and TOPs for inclusion in their Operating Plans.  Suggest removal of R1.3 phrase “generating unit-specific design specification or minimum historical performance during cold weather” because this information is only valuable if the facility is maintained to design specifications.

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

- 0 - 0

Requirement R1.3 states “unit specific design specifications.” It is assumed that this refers to cold weather design, but it is not clear. Hydroelectric generators are secured inside buildings and do not have these specifications. Reclamation recommends excluding hydroelectric generators from this requirement as they rely on water operations, for which cold weather considerations are already accounted by local operations and maintenance procedures.

Richard Jackson, U.S. Bureau of Reclamation, 1, 3/11/2021

- 0 - 0

Existing standards are not broken, they either are not being used, or enforced.

The existing IRO-010/TOP-003 Standards already allows RCs and TOPs the opportunity to obtain said data via their data specification requests to GO/GOPS, if they intend on using said data.

 

Forcing a RC or TOP to ask for data they don't need, nor have any accountability to use, is not efficient use of customer's dollars, and does not increase reliability.  As proposed standard modifications are a mere administrative burden, that costs everyone with no measurable reliability benefit.

 

As TAPS mentioned in prior SAR Comments.  The standards are written broadly by design, and thus include data specific to cold weather issues, as well as everything else that each RC, BA, or TOP needs to perform its operational functions.

 

Nor is there any indication in NERC's enforcement data that failure to respond to data specifications is a widespread problem.  If RCs, BAs, and TOPs are, in fact, having trouble getting the information they need, that is a CMEP problem, not a standards problem, since, as noted above, IRO-010-2 and TOP-003-3 already require each RC, BA, and TOP to request, without limitation, "the data necessary for it to perform" its operational functions, and require the entities receiving the data specifications to provide all such data.

 

As NERC said in its petition for approval of (among others) IRO-010-1a, which used the same top-down approach as IRO-010-2 and TOP-003-3, "[t]he requirements in the standard specify a formal request as the method for the Reliability Coordinator to explicitly identify the data and information it needs for reliability; and require the entities with the data to provide it as requested.  This method is sound because the Reliability Coordinator is the only entity that knows what data it needs to properly perform its reliability tasks, and the most efficient format for accepting this data."  Docket No. RM10-15, at 35 (Dec. 31, 2009) (emphasis added).  The alternative approach-listing each type of data that must be provided-will unavoidably be both under- and over-inclusive, since in addition to varying from one entity to another, data needs change over time as new technologies and risks emerge.

NCPA, Segment(s) 4, 5, 6, 4/3/2020

- 0 - 0

Ballard Mutters, Orlando Utilities Commission, 3, 3/11/2021

- 0 - 0

GRE supports the comments of the NSRF 

Michael Brytowski, Great River Energy, 3, 3/11/2021

- 0 - 0

All data required by the TOP should be the same data points as required for the BA and RC.  This will provide consistency across these three Functional Entities.  Recommend that Part 7.3 and its sub-components be deleted from the proposed EOP-011-2 and be placed in TOP-003 (with modifications, see below) these are data points the TOP should want to ask for to ensure they know the capabilities of BES generators in their system during cold weather conditions. 

7.3.1 requires “operating limitations” and if those limitations are unknown, then 7.3.2 gives the GO other avenues to gather generator’s cold weather data.  At the end of 7.3.1 there is an “AND” this should be changed to an “OR”.  A GO may have data specified in 7.3.1 and if don’t then they can use 7.3.2 to obtain the generator’s cold weather data via different methods.

MRO NSRF, Segment(s) 2, 3, 5, 1, 6, 4, 0, 3/11/2021

- 0 - 0

Texas RE agrees with the addition of requirements for Transmission Operators (TOPs) to develop a documented data specification including the provision for notification of BES generating unit-specific design performance during cold weather, as well as expected BES generating unit operational limitations during local forecasted cold weather.  Texas RE suggests the SDT consider matching the language of the proposed TOP-003-5 Requirement R1, Part 1.3 with the proposed generating unit cold weather data requirements set forth EOP-011-2 Requirement R7, Part 7.3 as modified by Texas RE’s comments concerning that Part.  Much like GOs, TOPs should obtain data beyond minimal design temperatures or minimal historical performance over a five-year period so they can account for other factors such as ice build-up and snow load, which could have significant, detrimental reliability impacts that are independent from freezing temperature, especially for renewables in performing Operational Planning Analyses, Real-time monitoring, and Real-time Assessments.

 

The language, “provisions for notification”, could possibly be read to imply that the data provision is event-driven instead of data that is requested and collected by the TOP prior to any forecasted cold weather event.  While it may be helpful for the TOP to receive event-driven notification from entities regarding any expected limitations during a specific forecasted cold weather event, the TOP should be requesting and collecting data regarding design specifications and operating limitations for cold weather as part of the normal data request and collection processes, with the periodicity specified per TOP-003-5 Requirement R1, Part 1.4.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 3/11/2021

- 0 - 0

Entergy, Segment(s) 1, 5, 12/13/2017

- 0 - 0

TOP-003 R1 already permits the TOP to ask for this data and EOP-011 requires the TOP to plan for this event. I don’t believe it’s necessary to add a redundant requirement to the obligation the TOP has in EOP-011 within the TOP-003 standard. R1.3 is only required for cold weather conditions. It doesn’t include extreme weather conditions as specified in EOP-011 and should also be included for consistency.

 

Dania Colon, Orlando Utilities Commission, 5, 3/11/2021

- 0 - 0

comments submitted

Don Stahl, Black Hills Corporation, 3, 3/11/2021

- 0 - 0

The proposed requirement 7.3.2.2 in EOP-011 has a 5-year limitation on historical data.  However, the new requirements in TOP-003 do not have this limitation.  As such, will the historical information be required back to the commissioning of the unit?  If not, please add the 5-year limitation.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 1 - 0

Scott McGough, Georgia System Operations Corporation, 3, 3/11/2021

2019-06_Cold_Weather_Comments_FINAL_GSOC_SBFCB03-11-21.docx

- 0 - 0

Thomas Breene, WEC Energy Group, Inc., 3, 3/11/2021

- 0 - 0

All data required by the TOP should be the same data points as required for the BA and RC.  This will provide consistency across these three Functional Entities. ACES recommends that Part 7.3 and its sub-components be deleted from the proposed EOP-011-2 and be placed in TOP-003.

 

AEPCO  is siging on to ACES comments as well.

Jennifer Bray, Arizona Electric Power Cooperative, Inc., 1, 3/11/2021

- 0 - 0

This requirement implementation period is one year. We would need more time to implement this. Two years would be requested. GO & GOP doesn’t have a cold weather preparedness plan. In the Northwest we already specify our Units to perform based on local temperatures. We do inspections of equipment and systems but it is not officially filed. We currently do not track training on the roles and responsibilities of site personnel.

Mike Magruder, Avista - Avista Corporation, 1, 3/11/2021

- 0 - 0

Existing standards are not broken, they either are not being used, or enforced.

The existing IRO-010/TOP-003 Standards already allows RCs and TOPs the opportunity to obtain said data via their data specification requests to GO/GOPS, if they intend on using said data.

 

Forcing a RC or TOP to ask for data they don't need, nor have any accountability to use, is not efficient use of customer's dollars, and does not increase reliability.  As proposed standard modifications are a mere administrative burden, that costs everyone with no measurable reliability benefit.

 

As TAPS mentioned in prior SAR Comments.  The standards are written broadly by design, and thus include data specific to cold weather issues, as well as everything else that each RC, BA, or TOP needs to perform its operational functions.

 

Nor is there any indication in NERC's enforcement data that failure to respond to data specifications is a widespread problem.  If RCs, BAs, and TOPs are, in fact, having trouble getting the information they need, that is a CMEP problem, not a standards problem, since, as noted above, IRO-010-2 and TOP-003-3 already require each RC, BA, and TOP to request, without limitation, "the data necessary for it to perform" its operational functions, and require the entities receiving the data specifications to provide all such data.

 

As NERC said in its petition for approval of (among others) IRO-010-1a, which used the same top-down approach as IRO-010-2 and TOP-003-3, "[t]he requirements in the standard specify a formal request as the method for the Reliability Coordinator to explicitly identify the data and information it needs for reliability; and require the entities with the data to provide it as requested.  This method is sound because the Reliability Coordinator is the only entity that knows what data it needs to properly perform its reliability tasks, and the most efficient format for accepting this data."  Docket No. RM10-15, at 35 (Dec. 31, 2009) (emphasis added).  The alternative approach-listing each type of data that must be provided-will unavoidably be both under- and over-inclusive, since in addition to varying from one entity to another, data needs change over time as new technologies and risks emerge.

Dennis Sismaet, Northern California Power Agency, 6, 3/11/2021

- 0 - 0

Utility Services supports the comments posted by the TAPS group.

Brian Evans-Mongeon, Utility Services, Inc., 4, 3/12/2021

- 0 - 0

The NAGF agrees with placement of Transmission Operator data specification requirements in the TOP-003 standard.

Wayne Sipperly, On Behalf of: North American Generator Forum, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 5

- 0 - 0

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

- 0 - 0

Similar to IRO-010 modifications, we recommend focusing on minimum historical performance and defining the time period (e.g. 50 year) to provide a more consistent approach across regions.

Justin Welty, NextEra Energy - Florida Power and Light Co., 6, 3/12/2021

- 0 - 0

Truong Le, On Behalf of: Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5

- 0 - 0

Janet OBrien, 3/12/2021

- 0 - 0

For Black Hills Corporation, it depends on what other TOPs require when they rewrite their data specification.  Black Hills Corporation believes the addition of unit-specific information and limitations during local forecasted cold weather will be helpful for our studies. 

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

- 0 - 0

Robin Hill, On Behalf of: Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5

- 0 - 0

Aidan Gallegos, On Behalf of: PNM Resources - Public Service Company of New Mexico, , Segments 1, 3

- 0 - 0

Matthew Beilfuss, WEC Energy Group, Inc., 4, 3/12/2021

- 0 - 0

Consistent with the NAGF, DTEE agrees with placement of Transmission Operator data specification requirements in the TOP-003 standard.

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

- 0 - 0

James Baldwin, Lower Colorado River Authority, 1, 3/12/2021

- 0 - 0

Devon Tremont, Taunton Municipal Lighting Plant, 1, 3/12/2021

- 0 - 0

AZPS agrees that the requirement is in the correct standard, TOP-003. However, AZPS does not see value added for the addition of this requirement and feels it is somewhat redundant to TOP-002 engineering study, resource commitment, etc? Consider BA applicability. 

Marcus Bortman, APS - Arizona Public Service Co., 6, 3/12/2021

- 0 - 0

Teresa Krabe, Lower Colorado River Authority, 5, 3/12/2021

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 3/12/2021

- 0 - 0

Anthony Jablonski, ReliabilityFirst , 10, 3/12/2021

- 0 - 0

PUD No. 1 of Chelan County , Segment(s) 1, 3, 5, 6, 3/12/2021

- 0 - 0

SCE supports EEI's comments.

Neil Shockey, 3/12/2021

- 0 - 0

Evergy supports and incorporates by reference Edison Electric Institute’s response to Question 3.

Douglas Webb, 3/12/2021

- 0 - 0

Support the intent of this project and the updating of the three applicable Standards.  Support the submitted MRO-NSRF comments.

Wayne Guttormson, SaskPower, 1, 3/12/2021

- 0 - 0

The existing language in TOP-003 already provides for the collection of "…data and information necessary needed by the Transmission Operator to support its Operational Planning Analyses, Real-time monitoring, and Real-time Assessments…".  This would include any generator cold or extreme weather limitations; therefore, is unnecessary to specifically address.  Additionally, the NERC Functional Model identifies the Balancing Authority as the entity responsible for "Formulating an operational plan (generation commitment, outage, etc.) for reliability evaluation."  The TOP is responsible for the Real-time operating reliability of the transmission assets under its control. The TOP should not be required to ensure the Balancing Authority is performing their function. This is evidenced in Recommendation 1 of the "Report on the South Central United States Cold Weather Bulk Electric System Event of January 17, 2018”, in which the TOP function was not identified.

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

Acciona Energy USA Global, LLC (Acciona) supports the Midwest Reliability Organization NERC Standards Review Forum’s (MRO NSRF) comments.

George Brown, Acciona Energy North America, 5, 3/12/2021

- 0 - 0

Santee Cooper has concerns with the term cold weather as this could be interpreted differently depending on where generating resources are located.  Should there be some standard definition of cold weather as below a certain temperature?

Santee Cooper, Segment(s) 1, 3, 5, 6, 3/12/2021

- 0 - 0

NPCC Regional Standards Committee no UI, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 3/12/2021

- 0 - 0

Allowing different planning entities the ability to make multiple requests of generators results in inefficiencies and can take focus away from more critical activities. A central, streamlined, and consistent process for submitting this type of data would benefit the grid. For greatest efficiency, NERC should proactively work with TOPs and RCs to identify pertinent information related to cold weather operating characteristics (and other areas of critical concern). NERC should consider if the Align tool, GADS portal, Misoperation Portal, or other similar centralized tools, could be used to streamline how / when these data requests are made. In addition, a centralized portal could include a data submission element such that a GO/GOP only must submit data once for it to be used, as required, by the appropriate planning entities (TOP, BA, RC).

If a centralized tool is not developed, the SDT should add a minimum time requirement to R3/R4/R5 such that the planning entity is required to give ample notice to the entity from which it is requesting data. Currently, each planning entity has a different process and timeline for making data requests; as a GO/GOP registered in multiple regions we must understand and work within each planning entity’s process. In addition, the onus should be on the planning entities to provide a fulsome, publicly available (on Align or NERC Website) list of entities required to submit data vs. requiring entities to rely on negative confirmation.

Shannon Ferdinand, On Behalf of: Capital Power Corporation, MRO, WECC, Texas RE, SERC, Segments 1, 6

- 0 - 0

Ameren Agrees with and supports NAGF comments

David Jendras, Ameren - Ameren Services, 3, 3/12/2021

- 0 - 0

David Hathaway, WEC Energy Group, Inc., 6, 3/12/2021

- 0 - 0

Romel Aquino, Edison International - Southern California Edison Company, 3, 3/12/2021

- 0 - 0

All data required by the TOP should be the same data points as required for the BA and RC. This will provide consistency across these three Functional Entities. ACES recommends that Part 7.3 and its sub-components be deleted from the proposed EOP-011-2 and be placed in
TOP-003.

ACES Standard Collaborations, Segment(s) 1, 3, 4, 5, 3/12/2021

- 0 - 0

EEI supports placing the Transmission Operator data specification requirements within TOP-003.

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

- 0 - 0

Michael Courchesne, On Behalf of: Michael Puscas, ISO New England, Inc., 2; Michael Puscas, ISO New England, Inc., 2

- 0 - 0

Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Carl Pineault, Hydro-Qu?bec Production, 5, 3/12/2021

- 0 - 0

NV Energy cannot agree to the revisions, as it requests additional clarity within the Standard, or in a Technical Guidance document, on the definition of "operation limitations". 

Kevin Salsbury, Berkshire Hathaway - NV Energy, 5, 3/12/2021

- 0 - 0

Donna Johnson, Oglethorpe Power Corporation, 5, 3/12/2021

- 0 - 0

MEC supports the Cold Weather project, but also agrees with and supports the MRO NSRF comments on needed changes first.  Poorly written standards written in haste result in vague requirements which can lead to misinterpretation and needless violations.

Terry Harbour, Berkshire Hathaway Energy - MidAmerican Energy Co., 1, 3/12/2021

- 0 - 0

Larry Rogers, Southern Indiana Gas and Electric Co., 5, 3/12/2021

- 0 - 0

See comments submitted by Edison Electric Institute”.

Kenya Streeter, On Behalf of: Edison International - Southern California Edison Company, , Segments 1, 3, 5, 6

- 0 - 0

Jeanne Kurzynowski, On Behalf of: CMS Energy - Consumers Energy Company - RF - Segments 3, 4, 5

- 0 - 0

SIGE Project 2019-06, Segment(s) 6, 5, 3, 3/12/2021

- 0 - 0

{C} The existing language in TOP-003 already provides for the collection of "…data and information necessary needed by the Transmission Operator to support its Operational Planning Analyses, Real-time monitoring, and Real-time Assessments…"  This would include any generator cold or extreme weather limitations.  There is no need to spell it out individually.  Additionally, the NERC Functional Model identifies the Balancing Authority as the entity responsible for "Formulating an operational plan (generation commitment, outage, etc.) for reliability evaluation."  The TOP is responsible for the Real-time operating reliability of the transmission assets under its purview.  The TOP should not be required to ensure the Balancing Authority is performing their function, which is probably why the TOP function was not mentioned in Recommendation 1 of the "Report on the South Central United States Cold Weather Bulk Electric System Event of January 17, 2018."    {C}{C}{C}[A1]{C} {C}[A2]{C} 

The existing language in TOP-003 already provides for the collection of "…data and information necessary needed by the Transmission Operator to support its Operational Planning Analyses, Real-time monitoring, and Real-time Assessments…".  This would include any generator cold or extreme weather limitations; therefore, is unnecessary to specifically address.  Additionally, the NERC Functional Model identifies the Balancing Authority as the entity responsible for "Formulating an operational plan (generation commitment, outage, etc.) for reliability evaluation."  The TOP is responsible for the Real-time operating reliability of the transmission assets under its control.  [A3] The TOP should not be required to ensure the Balancing Authority is performing their function. This is evidenced in Recommendation 1 of the "Report on the South Central United States Cold Weather Bulk Electric System Event of January 17, 2018”, in which the TOP function was not identified.  

 

 

 

 

Patrick Wells, OGE Energy - Oklahoma Gas and Electric Co., 5, 3/12/2021

- 0 - 0

The proposed Requirement R1.3 references “unit-specific design specification”, which is a very broad term that seems better suited to facility ratings/design. Secondly, there needs to be added context on what constitutes “minimal historical performance”. This can be captured in Facilities ratings/design standards including dependencies on temperature or other weather parameters for specific “emergency” conditions, and how these may affect a generating unit’s operating limitations.

The term “cold weather” can have varied interpretations throughout the continent, so a more concise term and/or definition that would also include which weather elements may be subject to this (e.g. cold weather may imply this is just for ice/snow) would be helpful.

BC Hydro suggest that the IRO-010 language be kept to the specific information, such as the designed operating temperature range of a unit that would be necessary for performing Operations Planning Analyses

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

- 0 - 0

CEHE Project 2019-06 Cold Weather, Segment(s) 1, 3/12/2021

- 0 - 0

Darnez Gresham, Berkshire Hathaway Energy - MidAmerican Energy Co., 3, 3/12/2021

- 0 - 0

Exelon supports placing the Transmission Operator (TOP) data specification requirements within TOP-003.

 

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

Daniel Gacek, Exelon, 1, 3/12/2021

- 0 - 0

Cogentrix Energy Power Management, Segment(s) 5, 3/12/2021

- 0 - 0

MISO supports the IRC SRC comments

Bobbi Welch, Midcontinent ISO, Inc., 2, 3/12/2021

- 0 - 0

Support comments by Western Area Power Administration, Sean Erickson, Segment 1.

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

- 0 - 0

Amy Jones, On Behalf of: Public Utility District No. 2 of Grant County, Washington, , Segments 1, 4, 5, 6

- 0 - 0

Yes, PG&E generally agrees with the proposed modifications proposed in TOP-003-5 as proposed.

Pamalet Mackey, On Behalf of: Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5

- 0 - 0

W. Dwayne Preston, Austin Energy, 3, 3/12/2021

- 0 - 0

Standards Review Committee (SRC), Segment(s) 2, 1/25/2016

- 0 - 0

CAISO supports the inclusion of the data specification requirements within TOP-003 however, recommends the SDT move R1.3 to R2 making this a requirement of the BA rather than the TOP.

Jamie Johnson, California ISO, 2, 3/12/2021

- 0 - 0

Constantin Chitescu, Ontario Power Generation Inc., 5, 3/12/2021

- 0 - 0

PJM supports the IRC SRC comments.

Elizabeth Davis, On Behalf of: Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2

- 0 - 0

I don't believe it is neccessary to include the language in TOP-003.  EOP-011 requires the TOP to plan for cold weather.  TOP-003 is to ensure the TOP can receive the data it needs and TOP-003 R1 allows the TOP to ask for data in addition to the exisiting sub-parts of R1.  TOP-003 purpose does not include prescribing to the TOP what data they need, but ensuring they have access to the data they determine they need.  

Aaron Staley, Orlando Utilities Commission, 1, 3/12/2021

- 0 - 0

Do not agree with adding generation limitations to TOP data specification is benefitial, especially in the ERCOT region, as generation data is communicated directly to ERCOT, not the TOP.  

Glenn Pressler, CPS Energy, 3, 3/12/2021

- 0 - 0

Michael Dillard, Austin Energy, 5, 3/12/2021

- 0 - 0

Do not agree with adding generation limitations to TOP data specification is beneficial, especially in the ERCOT region, as generation data is communicated directly to ERCOT, not the TOP.

Gladys DeLaO, CPS Energy, 1, 3/12/2021

- 0 - 0

Hot Answers

ERCOT does not see a proposed data specification requirement in EOP-011.  If the SDT intends to proceed with a data specification requirement for BAs, ERCOT suggests that this would most appropriately be placed in TOP-003 R2 (see response to Question 3, above).

Brandon Gleason, Electric Reliability Council of Texas, Inc., 2, 3/12/2021

- 0 - 0

Jun Hua, Austin Energy, 4, 3/12/2021

- 0 - 0

Other Answers

The industry may benifit from having all cold weather requirements located in a singled EOP Standard. For entities with multiple types of registered functions, searching for cold weather requirements in multiple different standards may be tedious and confusing.

Kristina Marriott, On Behalf of: Kristina Marriott, , Segments 5

- 0 - 0

There are no annual cold weather preparations for our solar facilities that need to be performed and our facilities are not limited in any way during cold weather.

Dylan Sontag, On Behalf of: Silicon Ranch Corporation, SERC, Segments 1

- 0 - 0

Laura Nelson, 2/10/2021

- 0 - 0

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 2/22/2021

- 0 - 0

John Allen, City Utilities of Springfield, Missouri, 4, 2/25/2021

- 0 - 0

AEP is unsure of the meaning or intent of this question, as we are unable to locate the proposed changes inferred by the question itself.

Thomas Foltz, AEP, 5, 2/26/2021

- 0 - 0

Gul Khan, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

- 0 - 0

In addition to the current EOP-011 draft language, the following language should be added to draft TOP-003-5 R2 to address the BA: “Provisions for notification of BES generating unit-specific design specification or minimum historical performance during cold weather, and expected BES generating unit operation limitations during local forecasted cold weather”

Todd Bennett, Associated Electric Cooperative, Inc., 3, 3/4/2021

- 0 - 0

Tyson Archie, Platte River Power Authority, 5, 3/4/2021

- 1 - 0

Dan Roethemeyer, Vistra Energy, 5, 3/5/2021

- 0 - 0

If the standard is geared towards ensuring generators run during extreme weather events, should not the same performance factors be considered during ALL weather events?  What critical generator auxiliaries are affected by weather events? Should the standard require an evaluation of all systems that are required to run/operate the generator, and have each of those systems evaluated for their limitations during various weather events?  i.e. If a thermal unit requires river water as part of its cooling system, does the unit have any limitations during a drought?  If so, does your plan address those/have a plan for that? 

Bruce Reimer, Manitoba Hydro , 1, 3/5/2021

- 0 - 0

: BA data specification requirements for NIPSCO would likely be covered by MISO via CFR00001.

Joe O'Brien, NiSource - Northern Indiana Public Service Co., 6, 3/5/2021

- 0 - 0

Patricia Lynch, NRG - NRG Energy, Inc., 5, 3/5/2021

- 0 - 0

WECC Cold Weather, Segment(s) 10, 3/5/2021

- 0 - 0

Seattle City Light appreciates the efforts of the SDT to balance the requirement for an industry-wide standard while not burdening entities located in routinely cold regions with administrative activities. As part of this balance, Seattle understands that the SDT intends the term “cold weather” and associated activities to apply to conditions that are extremely or abnormally cold for a particular location or region, rather than applying a single measure of “cold weather” (such as “below freezing”) across the continent. What is “cold weather” for a plant in Texas is routine weather for a plant in Minnesota or Canada, for instance. To make this distinction clear, Seattle recommends that wherever the term “cold weather” has been added to Standard, it should be replaced with the term “abnormally cold weather.”

Matthew Nutsch, On Behalf of: Seattle City Light, WECC, Segments 1, 3, 4, 5, 6

- 0 - 0

Talen agrees with placement of Balancing Authority data specification requirements in the EOP-011 standard.

Donald Lock, Talen Generation, LLC, 5, 3/9/2021

- 0 - 0

BPA supports Reclamation’s comments.

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Instead of adding a new BA requirement in EOP-011, Tacoma Power recommends adding a sub-requirement to TOP-003 R2 for the BA to request data specifications from GO.

Tacoma Power, Segment(s) 1, 3, 4, 5, 6, 3/9/2021

- 2 - 0

N/A.

Leonard Kula, Independent Electricity System Operator, 2, 3/9/2021

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 3/10/2021

- 0 - 0

Southern Company believes that this should be included in TOP-003-5 R2, as noted below in our response to Question 7. 

Southern Company, Segment(s) 1, 3, 6, 5, 1/14/2021

- 0 - 0

Erick Barrios, New York Power Authority, 6, 3/10/2021

- 0 - 0

The addition for R1 (1.2.6.) for TOP would be satisfied by R7 so it would be on the GO to provide information. 

Glen Farmer, Avista - Avista Corporation, 5, 3/10/2021

- 0 - 0

Lincoln Electric System, Segment(s) 5, 6, 3, 1, 4/17/2018

- 0 - 0

FE Voter, Segment(s) 1, 3, 5, 6, 4, 2/23/2021

- 0 - 0

There is no data specification requirement for the BA.  So I am not clear why this question was asked.  Did the SDT post the work files on the NERC website? Or make an error by asking this question?

 

 

Marty Hostler, Northern California Power Agency, 4, 3/10/2021

- 0 - 0

None.

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

- 0 - 0

The posted clean and redline versions of EOP-011 do not appear to identify any Balancing Authority data specification requirements.

As identified for the data specifications for Reliability Coordinators and Transmission Operators, Reclamation recommends excluding hydroelectric generators from this requirement as they rely on water operations, for which cold weather considerations are already accounted by local operations and maintenance procedures.

Richard Jackson, U.S. Bureau of Reclamation, 1, 3/11/2021

- 0 - 0

There is no data specification requirement for the BA.  So I am not clear why this question was asked.  Did the SDT post the work files on the NERC website? Or make an error by asking this question?

NCPA, Segment(s) 4, 5, 6, 4/3/2020

- 0 - 0

The BA data specification requirements should be added to TOP-003, as the SDT is proposing to do for the TOP data specification requirements.  The BA language should mirror the TOP and RC language, as described below; using different language, and putting it in a different location from other BA data specification requirements, will lead to unnecessary confusion.  BAs, RCs, and TOPs need the same data with respect to cold weather limitations, and it will be more efficient for GOs to be able to provide the same data to each entity.

Proposed EOP-011, R7.3 is essentially a data specification requirement; it should thus be moved to IRO-010 and TOP-003 and combined with the new proposed language in those standards.  The wording should also be revised to more accurately reflect the requirement’s goal: that entities that need the information be made aware of the conditions under which the generator will be inoperable.  That goal can be accomplished via the communication of known cold weather operating limitations, the minimum design temperature, the minimum demonstrated historical performance during cold weather, or an engineering analysis.  It would be inappropriate to require entities to provide multiple forms of evidence of the same fact. 

In addition, “in the previous 5 years” should be deleted from R7.3.2.2, because it results in an unnecessary administrative requirement to update the information every year regardless of whether there has been a change.  Referring simply to the “minimum demonstrated historical performance during cold weather” requires an update only if there is a change. 

The data specification requirement for BAs, TOPs, and RCs (renumbered as appropriate) should read:

7.3. Generating unit(s) cold weather data, Provisions for notification of BES generating unit-specific data related to expected performance in cold weather, to include:

7.3.1. Generating unit(s):

7.3.1.1 operating limitations in cold weather; and or

7.3.2. Generating unit(s):

7.3.2.11.2. minimum design temperature; or

7.3.2.21.3. minimum demonstrated historical performance during previous cold weather events; or in the previous 5 years;

Ballard Mutters, Orlando Utilities Commission, 3, 3/11/2021

- 0 - 0

GRE supports the comments of the NSRF 

Michael Brytowski, Great River Energy, 3, 3/11/2021

- 0 - 0

All data required by the BA should be the same data points as required for the RC and TOP.  This will provide consistency across these three Functional Entities. BA data request should not be in EOP-011-2 but rather in TOP-003 R2.  Recommend that Part 7.3 and its sub-components be deleted from the proposed EOP-011-2 and be placed in TOP-003 (with modifications, see below) these are data points the RC should want to ask for to ensure they know the capabilities of BES generators in their system during cold weather conditions. 

7.3.1 requires “operating limitations” and if those limitations are unknown, then 7.3.2 gives the GO other avenues to gather generator’s cold weather data.  At the end of 7.3.1 there is an “AND” this should be changed to an “OR”.  A GO may have data specified in 7.3.1 and if don’t then they can use 7.3.2 to obtain the generator’s cold weather data via different methods.

 

 

MRO NSRF, Segment(s) 2, 3, 5, 1, 6, 4, 0, 3/11/2021

- 0 - 0

Texas RE agrees there should be data specification requirements for the Balancing Authority (BA) as the BA should have this data for its Operating Plan as proposed in the revised EOP-011-2 Requirement R2. 

 

In addition, however, Texas RE recommends that the SDT consider adopting similar unit-specific design specifications, minimum historical performance, and expected BES generating unit operation limitations data specification requirements for BAs in TOP-003-5 Requirement R2 as is currently established for TOPs in the proposed TOP-003-5 Requirement R1 and RCs in the proposed IRO-010-4 R1.  The changes proposed in EOP-011 R2 require the BA to include the reliability impacts of cold weather conditions in its EOP-011 Operating Plan, but there does not to appear to be a requirement for the BA to collect data related to design specifications and operating limitations as part of its data specification or for the GO to provide these parameters to the BA.  

Rachel Coyne, Texas Reliability Entity, Inc., 10, 3/11/2021

- 0 - 0

Entergy, Segment(s) 1, 5, 12/13/2017

- 0 - 0

Proposed EOP-011, R7.3 is essentially a data specification requirement; it should thus be moved to IRO-010 and TOP-003 and combined with the new proposed language in those standards.  The wording should also be revised to more accurately reflect the requirement’s goal: that entities that need the information be made aware of the conditions under which the generator will be inoperable.  That goal can be accomplished via the communication of known cold weather operating limitations, the minimum design temperature, the minimum demonstrated historical performance during cold weather, or an engineering analysis.  It would be inappropriate to require entities to provide multiple forms of evidence of the same fact. 

In addition, “in the previous 5 years” should be deleted from R7.3.2.2, because it results in an unnecessary administrative requirement to update the information every year regardless of whether there has been a change.  Referring simply to the “minimum demonstrated historical performance during cold weather” requires an update only if there is a change. 

The data specification requirement for BAs, TOPs, and RCs (renumbered as appropriate) should read:

7.3. Generating unit(s) cold weather data, Provisions for notification of BES generating unit-specific data related to expected performance in cold weather, to include:

7.3.1. Generating unit(s):

7.3.1.1 operating limitations in cold weather; and or

7.3.2. Generating unit(s):

7.3.2.11.2. minimum design temperature; or

7.3.2.21.3. minimum demonstrated historical performance during previous cold weather events; or in the previous 5 years;

7.3.1.4 engineering analysis of expected operation limitations in cold weather.

Dania Colon, Orlando Utilities Commission, 5, 3/11/2021

- 0 - 0

comments submitted

Don Stahl, Black Hills Corporation, 3, 3/11/2021

- 0 - 0

The posted EOP-011-2 redline does not require the BA to make a change to its data specification.  Balancing Authority data specification requirements should be addressed in TOP-003 Requirement R2.  We do support the addition of language in EOP-011 Requirement R2 to include reliability impacts of cold weather or any other extreme weather conditions in a Balancing Authority’s Operating Plan(s).

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 1 - 0

Scott McGough, Georgia System Operations Corporation, 3, 3/11/2021

2019-06_Cold_Weather_Comments_FINAL_GSOC_SBFCB03-11-21.docx

- 0 - 0

TOP-003 contains the BA Data Specification, these requirements should be included in that Standard

Thomas Breene, WEC Energy Group, Inc., 3, 3/11/2021

- 1 - 0

All data required by the BA should be the same data points as required for the RC and TOP.  This will provide consistency across these three Functional Entities. BA data request should not be in EOP-011-2 but rather in TOP-003 R2.  ACES recommends that Part 7.3 and its sub-components be deleted from the proposed EOP-011-2 and be placed in TOP-003.

AEPCO is signing on to ACES comments as well.

Jennifer Bray, Arizona Electric Power Cooperative, Inc., 1, 3/11/2021

- 0 - 0

The addition for R1 (1.2.6.) for TOP would be satisfied by R7 so it would be on the GO to provide information.

Mike Magruder, Avista - Avista Corporation, 1, 3/11/2021

- 0 - 0

There is no data specification requirement for the BA.  So I am not clear why this question was asked.  Did the SDT post the work files on the NERC website? Or make an error by asking this question?

Dennis Sismaet, Northern California Power Agency, 6, 3/11/2021

- 0 - 0

Utility Services supports the comments posted by the TAPS group.

Brian Evans-Mongeon, Utility Services, Inc., 4, 3/12/2021

- 0 - 0

The NAGF agrees with placement of Balancing Authority data specification requirements in the EOP-011 standard.

Wayne Sipperly, On Behalf of: North American Generator Forum, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 5

- 0 - 0

The BA data specification requirements should be added to TOP-003, as the SDT is proposing to do for the TOP data specification requirements.  The BA language should mirror the TOP and RC language, as described below; using different language, and putting it in a different location from other BA data specification requirements, will lead to unnecessary confusion.  BAs, RCs, and TOPs need the same data with respect to cold weather limitations, and it will be more efficient for GOs to be able to provide the same data to each entity.

Proposed EOP-011, R7.3 is essentially a data specification requirement; it should thus be moved to IRO-010 and TOP-003 and combined with the new proposed language in those standards.  The wording should also be revised to more accurately reflect the requirement’s goal: that entities that need the information be made aware of the conditions under which the generator will be inoperable.  That goal can be accomplished via the communication of known cold weather operating limitations, the minimum design temperature, the minimum demonstrated historical performance during cold weather, or an engineering analysis.  It would be inappropriate to require entities to provide multiple forms of evidence of the same fact. 

In addition, “in the previous 5 years” should be deleted from R7.3.2.2, because it results in an unnecessary administrative requirement to update the information every year regardless of whether there has been a change.  Referring simply to the “minimum demonstrated historical performance during cold weather” requires an update only if there is a change. 

The data specification requirement for BAs, TOPs, and RCs (renumbered as appropriate) should read:

7.3. Provisions for notification of BES generating unit-specific data related to expected performance in cold weather, to include:

7.3.1. Generating unit(s):

7.3.1.1 operating limitations in cold weather; or

7.3.1.2. minimum design temperature; or

7.3.1.3. minimum demonstrated historical performance during previous cold weather events; or 

7.3.1.4 engineering analysis of expected operation limitations in cold weather.

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

- 0 - 0

Justin Welty, NextEra Energy - Florida Power and Light Co., 6, 3/12/2021

- 0 - 0

The BA data specification requirements should be added to TOP-003, as the SDT is proposing to do for the TOP data specification requirements.  The BA language should mirror the TOP and RC language, as described below; using different language, and putting it in a different location from other BA data specification requirements, will lead to unnecessary confusion.  BAs, RCs, and TOPs need the same data with respect to cold weather limitations, and it will be more efficient for GOs to be able to provide the same data to each entity.

Proposed EOP-011, R7.3 is essentially a data specification requirement; it should thus be moved to IRO-010 and TOP-003 and combined with the new proposed language in those standards.  The wording should also be revised to more accurately reflect the requirement’s goal: that entities that need the information be made aware of the conditions under which the generator will be inoperable.  That goal can be accomplished via the communication of known cold weather operating limitations, the minimum design temperature, the minimum demonstrated historical performance during cold weather, or an engineering analysis.  It would be inappropriate to require entities to provide multiple forms of evidence of the same fact. 

In addition, “in the previous 5 years” should be deleted from R7.3.2.2, because it results in an unnecessary administrative requirement to update the information every year regardless of whether there has been a change.  Referring simply to the “minimum demonstrated historical performance during cold weather” requires an update only if there is a change. 

The data specification requirement for BAs, TOPs, and RCs (renumbered as appropriate) should read:

7.3. Provisions for notification of BES generating unit-specific data related to expected performance in cold weather, to include:

7.3.1. Generating unit(s):

7.3.1.1 operating limitations in cold weather; or

7.3.1.2. minimum design temperature; or

7.3.1.3. minimum demonstrated historical performance during previous cold weather events; or

7.3.1.4 engineering analysis of expected operation limitations in cold weather.

Truong Le, On Behalf of: Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5

- 0 - 0

Support comments submitted by Tom Breene of WEC Energy Group. 

Janet OBrien, 3/12/2021

- 0 - 0

While Black Hills Corporation is not a BA, we do not see any reason to further break down EOP-011 R1.2.6 and 2.2.9

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

- 0 - 0

Robin Hill, On Behalf of: Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5

- 0 - 0

Aidan Gallegos, On Behalf of: PNM Resources - Public Service Company of New Mexico, , Segments 1, 3

- 0 - 0

TOP-003 contains the BA Data Specification, these requirements should be included in that Standard.

Matthew Beilfuss, WEC Energy Group, Inc., 4, 3/12/2021

- 0 - 0

Consistent with the NAGF, DTEE agrees with placement of Balancing Authority data specification requirements in the EOP-011 standard.

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

- 0 - 0

James Baldwin, Lower Colorado River Authority, 1, 3/12/2021

- 0 - 0

The BA data specification requirements should be added to TOP-003, as the SDT is proposing to do for the TOP data specification requirements.  The BA language should mirror the TOP and RC language, as described below; using different language, and putting it in a different location from other BA data specification requirements, will lead to unnecessary confusion.  BAs, RCs, and TOPs need the same data with respect to cold weather limitations, and it will be more efficient for GOs to be able to provide the same data to each entity.

Proposed EOP-011, R7.3 is essentially a data specification requirement; it should thus be moved to IRO-010 and TOP-003 and combined with the new proposed language in those standards.  The wording should also be revised to more accurately reflect the requirement’s goal: that entities that need the information be made aware of the conditions under which the generator will be inoperable.  That goal can be accomplished via the communication of known cold weather operating limitations, the minimum design temperature, the minimum demonstrated historical performance during cold weather, or an engineering analysis.  It would be inappropriate to require entities to provide multiple forms of evidence of the same fact. 

In addition, “in the previous 5 years” should be deleted from R7.3.2.2, because it results in an unnecessary administrative requirement to update the information every year regardless of whether there has been a change.  Referring simply to the “minimum demonstrated historical performance during cold weather” requires an update only if there is a change. 

The data specification requirement for BAs, TOPs, and RCs (renumbered as appropriate) should read:

7.3. Provisions for notification of BES generating unit-specific data related to expected performance in cold weather, to include:

7.3.1. Generating unit(s):

7.3.1.1 operating limitations in cold weather; or

7.3.1.2. minimum design temperature; or

7.3.1.3. minimum demonstrated historical performance during previous cold weather events; or

7.3.1.4 engineering analysis of expected operation limitations in cold weather.

Devon Tremont, Taunton Municipal Lighting Plant, 1, 3/12/2021

- 0 - 0

AZPS agrees but would like to add the additional comments. “Cold weather” is not defined. “Extreme weather conditions” not defined. Is it based on temperature or geography? What is the scope of “cold” and “extreme”?

Move 1.2.6 to be a sub-bullet under 1.2.5 and move 2.2.9 to be a sub-bullet under 2.2.8 (example below)

1.2.5. Provisions for operator-controlled manual Load shedding that minimizes the overlap with automatic Load shedding and are capable of being implemented in a timeframe adequate for mitigating the Emergency; and Reliability impacts of:

                 1.2.5.1. cold weather conditions; and

                 1.2.5.2. any other extreme weather conditions

 

2.2.8. Provisions for operator-controlled manual Load shedding that minimizes the overlap with automatic Load shedding and are capable of being implemented in a timeframe adequate for mitigating the Emergency; and Reliability impacts of:

                 2.2.8.1. cold weather conditions; and

                 2.2.8.2. any other extreme weather conditions.

Marcus Bortman, APS - Arizona Public Service Co., 6, 3/12/2021

- 0 - 0

Teresa Krabe, Lower Colorado River Authority, 5, 3/12/2021

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 3/12/2021

- 0 - 0

  • For EOP-011-2 R7. 7.1, consider rewording the sub-requirement to emphasize that geographic location and plant configuration are only some examples of unique factors (other unique factors can and should be considered). See example below.
    • 7.1 Generating unit(s) freeze protection measures based on unique factors that include, but are not limited to, geographical location, plant configuration, and varying operational scenarios.
  • For EOP-011-2 R7. 7.3.2.2, there are two recommendations and suggested rewording below:
    1. The wording, “demonstrated historical performance”, in 7.3.2.2 could be interpreted that historical cold weather information is only applicable when the generator is typically running/operational. Suggest to reword so that 7.3.2.2 is focused on cold weather experienced over a period of time at a plant location.
    2. Extend the timeframe from 5 years to 10 years. This aligns with the language in BAL-502-RF-03 to review resource adequacy based on “one day in ten year” loss of Load expectation. Other Reliability Coordinators/Planning Coordinators also has various assessment test methods that are designed to review risks associated with a “one day in ten year” type of event. This change may better cover geographic areas that do not frequently experience cold weather events.

7.3.2.2. Minimum demonstrated historical  cold weather experienced in the previous 10 years

 

Anthony Jablonski, ReliabilityFirst , 10, 3/12/2021

- 0 - 0

PUD No. 1 of Chelan County , Segment(s) 1, 3, 5, 6, 3/12/2021

- 0 - 0

SCE supports EEI's comments.

Neil Shockey, 3/12/2021

- 0 - 0

Evergy supports and incorporates by reference Edison Electric Institute’s response to Question 4.

Douglas Webb, 3/12/2021

- 0 - 0

Support the intent of this project and the updating of the three applicable Standards.  Support the submitted MRO-NSRF comments.

Wayne Guttormson, SaskPower, 1, 3/12/2021

- 0 - 0

The SDT provided no data specification requirement in EOP-011. Instead, the language in EOP-011 requires the BA to develop, maintain and implement one or more Operating Plan to address cold weather conditions – which is appropriate. However, we also believe that modifications to TOP-003 to address data specifications for the BA are unnecessary given Requirement R2 already includes language to specify “the data necessary for it to perform its analysis functions and Real-time monitoring” and Requirement R5 requires all applicable entities to provide the specified data. 

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

Acciona Energy USA Global, LLC (Acciona) supports the Midwest Reliability Organization NERC Standards Review Forum’s (MRO NSRF) comments.

George Brown, Acciona Energy North America, 5, 3/12/2021

- 0 - 0

Santee Cooper recommends adding a requirement to TOP-003 for the BA to request data specifications from a GO.

Santee Cooper, Segment(s) 1, 3, 5, 6, 3/12/2021

- 0 - 0

NPCC Regional Standards Committee no UI, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 3/12/2021

- 0 - 0

Allowing different planning entities the ability to make multiple requests of generators results in inefficiencies and can take focus away from more critical activities. A central, streamlined, and consistent process for submitting this type of data would benefit the grid. For greatest efficiency, NERC should proactively work with TOPs and RCs to identify pertinent information related to cold weather operating characteristics (and other areas of critical concern). NERC should consider if the Align tool, GADS portal, Misoperation Portal, or other similar centralized tools, could be used to streamline how / when these data requests are made. In addition, a centralized portal could include a data submission element such that a GO/GOP only must submit data once for it to be used, as required, by the appropriate planning entities (TOP, BA, RC).

If a centralized tool is not developed, the SDT should add a minimum time requirement to R3/R4/R5 such that the planning entity is required to give ample notice to the entity from which it is requesting data. Currently, each planning entity has a different process and timeline for making data requests; as a GO/GOP registered in multiple regions we must understand and work within each planning entity’s process. In addition, the onus should be on the planning entities to provide a fulsome, publicly available (on Align or NERC Website) list of entities required to submit data vs. requiring entities to rely on negative confirmation.

Shannon Ferdinand, On Behalf of: Capital Power Corporation, MRO, WECC, Texas RE, SERC, Segments 1, 6

- 0 - 0

Ameren Agrees with and supports NAGF comments

David Jendras, Ameren - Ameren Services, 3, 3/12/2021

- 0 - 0

See Tom Breene's comments.

David Hathaway, WEC Energy Group, Inc., 6, 3/12/2021

- 0 - 0

Romel Aquino, Edison International - Southern California Edison Company, 3, 3/12/2021

- 0 - 0

All data required by the BA should be the same data points as required for the RC and TOP. This will provide consistency across these three Functional Entities. BA data request should not be in EOP-011-2 but rather in TOP-003 R2. ACES recommends that Part 7.3 and its subcomponents be deleted from the proposed EOP-011-2 and be placed in TOP-003.

ACES Standard Collaborations, Segment(s) 1, 3, 4, 5, 3/12/2021

- 0 - 0

EEI agrees with the placement of Balancing Authority (BA) data specifications in EOP-011 Reliability Standard. 

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

- 0 - 0

This is a "No" vote. ISO-NE recommends the Balancing Authority data specification requirements be defined under TOP-003 along with the TOP data specification requirements.

Michael Courchesne, On Behalf of: Michael Puscas, ISO New England, Inc., 2; Michael Puscas, ISO New England, Inc., 2

- 0 - 0

Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Carl Pineault, Hydro-Qu?bec Production, 5, 3/12/2021

- 0 - 0

For consistency, the BA data spec should be handled similarly to the TOP data spec and be included in TOP-003. 

Kevin Salsbury, Berkshire Hathaway - NV Energy, 5, 3/12/2021

- 0 - 0

Donna Johnson, Oglethorpe Power Corporation, 5, 3/12/2021

- 0 - 0

MEC supports the Cold Weather project, but also agrees with and supports the MRO NSRF comments on needed changes first.  Poorly written standards written in haste result in vague requirements which can lead to misinterpretation and needless violations.

Terry Harbour, Berkshire Hathaway Energy - MidAmerican Energy Co., 1, 3/12/2021

- 0 - 0

The SDT revisions applicable to the BA placed in EOP-011 address the inclusion of the reliability impacts of cold weather conditions in the BA's emergency operations plan(s) and do not address the data specification. Any revisions to the BA data specification requirement would better fit in TOP-003 R2.

Larry Rogers, Southern Indiana Gas and Electric Co., 5, 3/12/2021

- 0 - 0

See comments submitted by Edison Electric Institute”.

Kenya Streeter, On Behalf of: Edison International - Southern California Edison Company, , Segments 1, 3, 5, 6

- 0 - 0

Jeanne Kurzynowski, On Behalf of: CMS Energy - Consumers Energy Company - RF - Segments 3, 4, 5

- 0 - 0

The SDT revisions applicable to the BA placed in EOP-011 address the inclusion of the reliability impacts of cold weather conditions in the BA's emergency operations plan(s) and do not address the data specification. Any revisions to the BA data specification requirement would better fit in TOP-003 R2.

SIGE Project 2019-06, Segment(s) 6, 5, 3, 3/12/2021

- 0 - 0

The SDT provided no data specification requirement in EOP-011. Instead, the language in EOP-011 requires the BA to develop, maintain and implement one or more Operating Plan to address cold weather conditions – which is appropriate. However, we also believe that modifications to TOP-003 to address data specifications for the BA are unnecessary given Requirement R2 already includes language to specify “the data necessary for it to perform its analysis functions and Real-time monitoring” and Requirement R5 requires all applicable entities to provide the specified data.

Patrick Wells, OGE Energy - Oklahoma Gas and Electric Co., 5, 3/12/2021

- 0 - 0

The posted EOP-011 draft for comment (EOP-011-2_Redline_01272021) does not appear to include a new or modified EOP-011 Requirement identifying “Balancing Authority data specification requirements” referenced in Question #4 above. Please clarify.

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

- 0 - 0

The SDT revisions applicable to the BA placed in EOP-011 address the inclusion of the reliability impacts of cold weather conditions in the BA's emergency operations plan(s) and do not address the data specification. Any revisions to the BA data specification requirement would better fit in TOP-003 R2.

CEHE Project 2019-06 Cold Weather, Segment(s) 1, 3/12/2021

- 0 - 0

Darnez Gresham, Berkshire Hathaway Energy - MidAmerican Energy Co., 3, 3/12/2021

- 0 - 0

Exelon agrees with the placement of the Balancing Authority (BA) data specifications in the EOP-011 Reliability Standard.  

 

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

Daniel Gacek, Exelon, 1, 3/12/2021

- 0 - 0

CEPM agrees with the inclusion of cold weather conditions in R2, but feel it should be a sub-requirement under extreme weather conditions to allow for other extreme weather sub-requirements at a later date (i.e. hurricane, Tornado, Thunder/Lightning, GMD, etc…)

Cogentrix Energy Power Management, Segment(s) 5, 3/12/2021

- 0 - 0

MISO supports the IRC SRC comments

Bobbi Welch, Midcontinent ISO, Inc., 2, 3/12/2021

- 0 - 0

Support comments by Western Area Power Administration, Sean Erickson, Segment 1.

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

- 0 - 0

Amy Jones, On Behalf of: Public Utility District No. 2 of Grant County, Washington, , Segments 1, 4, 5, 6

- 0 - 0

Yes, PG&E generally agrees with the proposed modifications of EOP-011 with respect to the Balancing Authority.

Pamalet Mackey, On Behalf of: Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5

- 0 - 0

W. Dwayne Preston, Austin Energy, 3, 3/12/2021

- 0 - 0

IRC SRC recommends the Balancing Authority data specification requirements be defined under TOP-003 along with the TOP data specification requirements.

Standards Review Committee (SRC), Segment(s) 2, 1/25/2016

- 0 - 0

CAISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee.

Jamie Johnson, California ISO, 2, 3/12/2021

- 0 - 0

Constantin Chitescu, Ontario Power Generation Inc., 5, 3/12/2021

- 0 - 0

PJM supports the IRC SRC comments.

Elizabeth Davis, On Behalf of: Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2

- 0 - 0

I don't think that the phrase "Data Specification" optimally reflects the changes in EOP-011-2 for the BA.  There is a requirement to plan for cold weather which may require them to request data, and they can request that data under the existing TOP-003 R2 which does not require modification.

Aaron Staley, Orlando Utilities Commission, 1, 3/12/2021

- 0 - 0

Not clear on the “data specification requirement” added for the BA; appears to be adding BA requirement to add “Processes to prepare for and mitigate Emergencies including” for cold weather conditions; this is too vague to offer reliable solution to the 2021 cold weather event.

Glenn Pressler, CPS Energy, 3, 3/12/2021

- 0 - 0

Michael Dillard, Austin Energy, 5, 3/12/2021

- 0 - 0

Not clear on the “data specification requirement” added for the BA; appears to be adding BA requirement to add “Processes to prepare for and mitigate Emergencies including” for cold weather conditions; this is too vague to offer reliable solution to the 2021 cold weather event. 

Gladys DeLaO, CPS Energy, 1, 3/12/2021

- 0 - 0

Hot Answers

ERCOT refers the SDT to its response to No. 1 above.  ERCOT also believes an additional inspection should be conducted immediately prior to any expected extreme cold weather event.

Brandon Gleason, Electric Reliability Council of Texas, Inc., 2, 3/12/2021

- 0 - 0

Jun Hua, Austin Energy, 4, 3/12/2021

- 0 - 0

Other Answers

We would like to better understand the requirements for freeze protection on Peak Resources, such as Wind and Solar generating sources.

Can maintenance and inspection be more defined by minimum requirements? If not, perhaps a FAQ / Supplemenatary Reference could provide additional details and examples.

Kristina Marriott, On Behalf of: Kristina Marriott, , Segments 5

- 0 - 0

If the equipment on-site does not require any specific cold weather maintenance, then this should not be a required.

Dylan Sontag, On Behalf of: Silicon Ranch Corporation, SERC, Segments 1

- 0 - 0

This requirement would be challenging to achieve at all plants on an annual basis. A more realistic alternative would be to tie this new "maintenance and inspections" requirement to regular generator maintenance intervals already in place at the entity.

Laura Nelson, 2/10/2021

- 0 - 0

For those generators that are located in cold climates and operate regularly in freezing weather, this standard will be a unnecessary administrative series of tasks.  The Cold Weather Preparedness should be limited to those locations where cold weather operations is not frequent.  Despite the recent problems in Texas, Generations in Northern climates continues to be reliable.  Perhaps the standard needs to put the burden on Planning Coordinators to identify generators that are of high risk, and require Cold Weather preparedness from them, excluding others.

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 2/22/2021

- 0 - 0

The drafting team should consider adding something like "not to exceed 15 months" similar to what's in other standards.

John Allen, City Utilities of Springfield, Missouri, 4, 2/25/2021

- 0 - 0

Thomas Foltz, AEP, 5, 2/26/2021

- 0 - 0

Gul Khan, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

- 0 - 0

Todd Bennett, Associated Electric Cooperative, Inc., 3, 3/4/2021

- 0 - 0

Platte River Power Authority suggests replacing annual with calendar year for the required maintenance and inspection schedule.  Requiring actions to be performed each calendar year promotes consistency in audit approach across regions.  Per the April 19, 2019 NERC CMEP Practice Guide, “annual” can be interpreted as once per calendar year, or a rolling 12-months.  Calendar year is widely accepted across regions to be interpreted as January 1 to December 31 of each year. The use of calendar year is also consistent with other maintenance and testing standards such as PRC-005.  This also allows registered entities the flexibility to complete maintenance and inspections that better align with generating plant maintenance cycles and rotating outages.  

Tyson Archie, Platte River Power Authority, 5, 3/4/2021

- 1 - 0

Dan Roethemeyer, Vistra Energy, 5, 3/5/2021

- 0 - 0

Annually is fine for entities with a limited number of generators, but this will become an extreme burden for companies like MH who has 100+ generators? Once every 3 calendar years (like blackstart testing) is recommended.

Bruce Reimer, Manitoba Hydro , 1, 3/5/2021

- 0 - 0

R7 as a whole does not provide enough specificity. It is not clear what will be required for inspections, historical performance tracking, and awareness training in addition to the annual maintenance. Also, the term “calendar year” should be considered in lieu of “annual”.

Joe O'Brien, NiSource - Northern Indiana Public Service Co., 6, 3/5/2021

- 0 - 0

Patricia Lynch, NRG - NRG Energy, Inc., 5, 3/5/2021

- 0 - 0

WECC Cold Weather, Segment(s) 10, 3/5/2021

- 0 - 0

Seattle City Light appreciates the effort made by the SDT to balance the requirement for an industry-wide standard while not burdening entities located in routinely cold regions with administrative activities. However, in the case of inspection requirements, Seattle does not feel this balance has been met. The inspection and documentation requirements specifically call out freeze protection for documentation and annual inspection. This specificity goes against the general approach of focusing new requirements and activities on cold weather conditions that are abnormal for a particular location or region. Freezing conditions and freeze protection are normal for the northern half of the continent. As written, these requirements require administrative documentation and activities for entities with facilities in such locations. Seattle recommends that these requirements be revised to focus on the objective of documenting and annually inspecting those specific measures implemented to provide operating protection during abnormally cold conditions, whatever those may be for a particular location.

Matthew Nutsch, On Behalf of: Seattle City Light, WECC, Segments 1, 3, 4, 5, 6

- 0 - 0

Talen supports the annual requirement for maintenance and inspection of generating unit freeze protection measures.

Donald Lock, Talen Generation, LLC, 5, 3/9/2021

- 0 - 0

BPA supports Reclamation’s comments.

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Tacoma Power is supportive of specifying a periodicity of performing maintenance activities, if these activities are required. Instead of “annual,” Tacoma Power recommends specifying either “each calendar year”, “15-month” or “12-month” in accordance with the PER-005 Standards White Paper.

Tacoma Power, Segment(s) 1, 3, 4, 5, 6, 3/9/2021

- 2 - 0

N/A.

Leonard Kula, Independent Electricity System Operator, 2, 3/9/2021

- 0 - 0

Part 7.2 should provide a list (or give examples) of minimum maintenance and inspection requirements for specific forms of freeze protection measures (e.g., what, at a minimum, would be required for maintenance and inspection of insulations, heat trace, etc). 

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 3/10/2021

- 0 - 0

Southern Company believes this requirement could be viewed as somewhat vague, and that further clarification may be required other than just an “annual requirement”.

Southern Company, Segment(s) 1, 3, 6, 5, 1/14/2021

- 0 - 0

See response to Question 1.

Erick Barrios, New York Power Authority, 6, 3/10/2021

- 0 - 0

Annual Maintenance and Inspections should not be made mandatory.

Glen Farmer, Avista - Avista Corporation, 5, 3/10/2021

- 0 - 0

Lincoln Electric System, Segment(s) 5, 6, 3, 1, 4/17/2018

- 0 - 0

FE Voter, Segment(s) 1, 3, 5, 6, 4, 2/23/2021

- 0 - 0

NO. There are no reliability improvements or cost estimates posted.  Please provide the SDT's proposed cost versus reliability improvement benefit analysis, for each region, and for annual versus bi-annual inspection/maintenance.

Marty Hostler, Northern California Power Agency, 4, 3/10/2021

- 0 - 0

Duke Energy agrees with Part 7.2 Annual Inspection of generating unit(s) freeze protection measures but suggests Part 7.2. clarify that Annual Maintenance is to be performed on an as-needed basis.

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

- 0 - 0

Annual maintenance for generator types and geographic areas that have never had a problem with cold weather represents an added regulatory burden for a problem that these generators and geographic areas do not have. Given the history of Facilities in northern, colder climates, annual maintenance and inspection requirements may be excessive. Reclamation recommends Generator Owners follow guidance derived from manufacturer specifications and entity evaluations of policy, procedure, and maintenance.

The terms “maintenance and inspection” are too vague. What type of inspections are intended to be required? Does this involve extensive inspections of internal equipment or is it a general life of material inspection? For an example of a clear, yet non-prescriptive presentation of inspection requirements, Reclamation recommends the SDT review FAC-501-WECC-3 Attachment A.

Due to the variety of interpretations of the term “annual,” Reclamation recommends any instances of an annual requirement specify that the required activity take place “at least every 12 months, not to exceed 15 months.”

Richard Jackson, U.S. Bureau of Reclamation, 1, 3/11/2021

- 0 - 0

There are no reliability improvements or cost estimates posted.  Please provide the SDT's proposed cost versus reliability improvement benefit analysis, for each region, and for annual versus bi-annual inspection/maintenance.

NCPA, Segment(s) 4, 5, 6, 4/3/2020

- 0 - 0

Some of these equipment’s maintenance could have a significantly shorter maintenance intervals per manufacturer’s recommendation.

Ballard Mutters, Orlando Utilities Commission, 3, 3/11/2021

- 0 - 0

GRE supports the comments of the NSRF 

Michael Brytowski, Great River Energy, 3, 3/11/2021

- 0 - 0

Suggest adding “not to exceed 15 calendar months” similar to what’s in other standards.

MRO NSRF, Segment(s) 2, 3, 5, 1, 6, 4, 0, 3/11/2021

- 0 - 0

As noted in its response to Question 1, Texas RE recommends additional specificity around maintenance and inspection activities and periodicity in a manner similar to the minimum maintenance activities and maximum maintenance intervals established under PRC-005-6.  As noted in its previous response, the 2019 Cold Weather Report specifically identified “[p]erforming periodic adequate maintenance and inspection of freeze protection elements (e.g., generating units’ heat tracing equipment and thermal insulation)” as a key element to ensure GOs adequately prepare for cold weather conditions.  To that end, Texas RE believes that specifically defining both minimum maintenance and inspection activities, as well as maximum maintenance and inspection intervals is important.  By way of example, the 2019 Cold Weather Report specifically recommends GOs adopt “regular, periodic operational checks of heat tracing circuits.”  (2019 Cold Weather Report, at 101 (emphasis added)).  Texas RE recommends that the SDT specify minimal activities associated with such operational checks and define a regular, periodic maintenance schedule to ensure consistency across generators.  For these types of “inspection-oriented” activities, performing such steps on an annual basis may not be sufficient. 

 

GOs may be able to perform maintenance activities designed to ensure equipment functionality on an annual basis.  Texas RE notes, however, that the 2019 Cold Weather Report recommended that GOs complete “freeze protection-related maintenance prior to winter weather.”  (2019 Cold Weather Report, at 101).  Accordingly, an annual requirement may not be sufficient to ensure that such freeze protection-related maintenance occurs in a timely fashion prior to a cold weather event.  To address this, Texas RE recommends providing certain temporal parameters so that those activities are performed prior to winter, such as requiring annual maintenance occur between the months of April and October.  

Rachel Coyne, Texas Reliability Entity, Inc., 10, 3/11/2021

- 0 - 0

Entergy, Segment(s) 1, 5, 12/13/2017

- 0 - 0

Annual maintenance and inspection needs to be defined: will it be required annually, Jan.-Dec. or annually from the last maintenance? Our units are not taken off line annually. Maintenance is staggered so we don't have all units out the same year.

Dania Colon, Orlando Utilities Commission, 5, 3/11/2021

- 0 - 0

comments submitted

Don Stahl, Black Hills Corporation, 3, 3/11/2021

- 0 - 0

Maybe add verbiage to state inspection be, at a minimum, an annual requirement and not to exceed 15 calendar months.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 1 - 0

Scott McGough, Georgia System Operations Corporation, 3, 3/11/2021

- 0 - 0

Thomas Breene, WEC Energy Group, Inc., 3, 3/11/2021

- 0 - 0

What constitutes maintenance and inspection for this requirement is not explicitly clear.  Additionally, requirement 7.1 requires measures based on “unique factors” which could potentially be interpreted and implemented as each and every unit possessing different “unique” measures, maintenance, and inspection parameters.  This could create a major burden on both compliance and enforcement.  ACES suggests more clearly defining what is being required by defining the terms used in the SAR so that the standard can be measured, implemented, and enforced uniformly across the industry.

AEPCO is signing on to ACES comments as well.

Jennifer Bray, Arizona Electric Power Cooperative, Inc., 1, 3/11/2021

- 0 - 0

Annual Maintenance and Inspections should not be made mandatory.

Mike Magruder, Avista - Avista Corporation, 1, 3/11/2021

- 0 - 0

There are no reliability improvements or cost estimates posted.  Please provide the SDT's proposed cost versus reliability improvement benefit analysis, for each region, and for annual versus bi-annual inspection/maintenance.

Dennis Sismaet, Northern California Power Agency, 6, 3/11/2021

- 0 - 0

Utility Services supports the comments posted by the TAPS group.

Brian Evans-Mongeon, Utility Services, Inc., 4, 3/12/2021

- 0 - 0

The NAGF supports the annual requirement for maintenance and inspection of generating unit freeze protection measures.

Wayne Sipperly, On Behalf of: North American Generator Forum, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 5

- 0 - 0

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

- 0 - 0

While annual inspection is reasonable for preparedness purposes, a required annual maintenance may not be appropriate to all technologies.  For example, combined cycle unit outages may be every 2 years or more based on operational hours.  Recommend some clarification as to what the SDT may be expecting this “annual maintenance” to address.

Justin Welty, NextEra Energy - Florida Power and Light Co., 6, 3/12/2021

- 0 - 0

Truong Le, On Behalf of: Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5

- 0 - 0

Janet OBrien, 3/12/2021

- 0 - 0

As noted in Question1:  Annual is too broad of a term – define annual as each calendar year not to exceed fifteen months between occurrence.  

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

- 0 - 0

Robin Hill, On Behalf of: Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5

- 0 - 0

Aidan Gallegos, On Behalf of: PNM Resources - Public Service Company of New Mexico, , Segments 1, 3

- 0 - 0

Matthew Beilfuss, WEC Energy Group, Inc., 4, 3/12/2021

- 0 - 0

Consistent with the NAGF, DTEE supports the annual requirement for maintenance and inspection of generating unit freeze protection measures.

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

- 0 - 0

James Baldwin, Lower Colorado River Authority, 1, 3/12/2021

- 0 - 0

TMLP believes that an annual requirement is sufficient, but the specific timing of the maintenance and inspections should be further specified and/or additional guidance should be offered (such as prior to entering the winter season). 

Devon Tremont, Taunton Municipal Lighting Plant, 1, 3/12/2021

- 0 - 0

AZPS is in agreement with an annual seasonal preparedness requirement, however that is contingent upon what is the scope of that requirement. The “generating unit freeze protection” term is not defined. Does the freeze protection term mean the defined unit design criteria? AZPS recommends verbiage that clearly defines freeze protection or allows the utility to define the scope of the seasonal preparedness requirements in their own procedures.

Marcus Bortman, APS - Arizona Public Service Co., 6, 3/12/2021

- 0 - 0

Teresa Krabe, Lower Colorado River Authority, 5, 3/12/2021

- 0 - 0

Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 3/12/2021

- 0 - 0

Anthony Jablonski, ReliabilityFirst , 10, 3/12/2021

- 0 - 0

PUD No. 1 of Chelan County , Segment(s) 1, 3, 5, 6, 3/12/2021

- 0 - 0

SCE supports EEI's comments.

Neil Shockey, 3/12/2021

- 0 - 0

Evergy supports and incorporates by reference Edison Electric Institute’s response to Question 5.

Douglas Webb, 3/12/2021

- 0 - 0

Support the intent of this project and the updating of the three applicable Standards.  Support the submitted MRO-NSRF comments.

Wayne Guttormson, SaskPower, 1, 3/12/2021

- 0 - 0

OGE suggests replacing “annual” with “calendar” year for the required maintenance and inspection schedule. Per the April 19, 2019 NERC CMEP Practice Guide, “annual” can be interpreted as once per calendar year, or a rolling 12-months.  Calendar year is widely accepted across regions to be interpreted as January 1 to December 31 of each year. The use of calendar year is also consistent with other maintenance and testing standards such as PRC-005.  This also allows registered entities the flexibility to complete maintenance and inspections that better align with generating plant maintenance cycles and rotating outages. 

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

‘Annual’ is not a defined term, consider using bright line criteria.  This would ensure that this is a performance-based requirement.

As stated by the Project 2014-01 Standards Applicability for Dispersed Generation Resources Standards Drafting Team’s white paper: “In some cases, the aggregated capability of the individual generating units may contribute to the reliability of the BPS; as such, there can be reliability benefit from ensuring that certain BES equipment utilized to aggregate the individual units to a common point of connection are operated and maintained as required in PRC-005. When evaluated individually, however, the generating units themselves do not have the same impact on BPS reliability as the system used to aggregate the units. The unavailability or failure of any one individual generating unit would have a negligible impact on the aggregated capability of the Facility; this would be irrespective to whether the dispersed generation resource became unavailable due to occurrence of a legitimate fault condition or due to a failure of a control system, protective element, dc supply, etc.” (https://www.nerc.com/pa/Stand/Prjct201401StdrdsAppDispGenRes/DGR_White_Paper_v17_clean_01_13_2016_Final_rev1.pdf)

For dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition, such as wind generation Facilities, each individual generating unit, a single wind turbine generator (WTG), can have many applicable freeze protections, that if not operational, could impede on the WTG’s ability to operate to its minimum design temperature.  However, as stated by Project 2014-01 Standards Drafting Team, “The unavailability or failure of any one individual generating unit would have a negligible impact on the aggregated capability of the Facility;”.  Acciona would like to request the Project 2019-06 Cold Weather Standards Drafting Team consider whether Requirement R7. should be applicable to the individual generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition, considering the precedent set by Project 2014-01 Standards Applicability for Dispersed Generation Resources Standards Drafting Team.  If the Project 2019-06 Cold Weather Standards Drafting Team determines that Requirement R7. should be applicable to the individual generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition, then Acciona would like to suggest Project 2019-06 Cold Weather Standards Drafting Team consider a percentage/time-based approach for the applicable freeze protections installed in an individual generating units of dispersed power producing resources. For example, 20% of the applicable freeze protections installed in an individual generating units of dispersed power producing resources must be maintained and inspected on annual basis and 100% applicable freeze protections installed in an individual generating units of dispersed power producing resources must be maintained and inspected on a five year basis.

George Brown, Acciona Energy North America, 5, 3/12/2021

- 0 - 0

 Santee Cooper is in agreement of specifying a periodicity of performing maintenance activities but recommends these be required each calendar year instead of on an annual basis. 

Santee Cooper, Segment(s) 1, 3, 5, 6, 3/12/2021

- 0 - 0

This does not capture the freeze protection measures that are put in place on an as-needed basis such as heaters, blankets, etc. 

NPCC Regional Standards Committee no UI, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 3/12/2021

- 0 - 0

This requirement should be applicable to generators based on risk (i.e. not applicable to generators where operating in freezing conditions is standard operating procedure and does not equate an ‘operating emergency’). Where this requirement is applicable, the SDT should consider allowing the entity to make a risk-based maintenance plan with timelines (frequencies and scope of work can be offered via tables as in PRC-005). This would reduce inefficiencies related to doing unnecessary maintenance work annually just to satisfy a compliance standard. If the SDT is opposed to offering different timelines for different equipment, a 15-month to 24-month timeline should be incorporated, rather than annual. This would allow sites to better align their maintenance- and inspection-related work with their regular maintenance outages.

Shannon Ferdinand, On Behalf of: Capital Power Corporation, MRO, WECC, Texas RE, SERC, Segments 1, 6

- 0 - 0

Ameren Agrees with and supports NAGF comments

David Jendras, Ameren - Ameren Services, 3, 3/12/2021

- 0 - 0

David Hathaway, WEC Energy Group, Inc., 6, 3/12/2021

- 0 - 0

Romel Aquino, Edison International - Southern California Edison Company, 3, 3/12/2021

- 0 - 0

What constitutes maintenance and inspection for this requirement is not explicitly clear. Additionally, requirement 7.1 requires measures based on “unique factors” which could potentially be interpreted and implemented as each and every unit possessing different “unique” measures, maintenance, and inspection parameters. This could create a major burden on both compliance and enforcement. ACES suggests more clearly defining what is being required by defining the terms used in the SAR so that the standard can be measured, implemented, and enforced uniformly across the industry.

ACES Standard Collaborations, Segment(s) 1, 3, 4, 5, 3/12/2021

- 0 - 0

The language within Requirement R7, subpart 7.2 is clear to ensure GOs conduct annual maintenance and inspection of their generating unit freeze protection.

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

- 0 - 0

Michael Courchesne, On Behalf of: Michael Puscas, ISO New England, Inc., 2; Michael Puscas, ISO New England, Inc., 2

- 0 - 0

An annual requirement is reasonable, but we recommend using terminology consistent with other standards i.e. every "calendar year" or "not to exceed 15 months."

Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC - Segments 1, 3, 5, 6

- 0 - 0

Carl Pineault, Hydro-Qu?bec Production, 5, 3/12/2021

- 0 - 0

Kevin Salsbury, Berkshire Hathaway - NV Energy, 5, 3/12/2021

- 0 - 0

Donna Johnson, Oglethorpe Power Corporation, 5, 3/12/2021

- 0 - 0

Terry Harbour, Berkshire Hathaway Energy - MidAmerican Energy Co., 1, 3/12/2021

- 0 - 0

Larry Rogers, Southern Indiana Gas and Electric Co., 5, 3/12/2021

- 0 - 0

See comments submitted by Edison Electric Institute”.

Kenya Streeter, On Behalf of: Edison International - Southern California Edison Company, , Segments 1, 3, 5, 6

- 0 - 0

Jeanne Kurzynowski, On Behalf of: CMS Energy - Consumers Energy Company - RF - Segments 3, 4, 5

- 0 - 0

SIGE Project 2019-06, Segment(s) 6, 5, 3, 3/12/2021

- 0 - 0

OKGE suggests replacing “annual” with “calendar” year for the required maintenance and inspection schedule. Per the April 19, 2019 NERC CMEP Practice Guide, “annual” can be interpreted as once per calendar year, or a rolling 12-months.  Calendar year is widely accepted across regions to be interpreted as January 1 to December 31 of each year. The use of calendar year is also consistent with other maintenance and testing standards such as PRC-005.  This also allows registered entities the flexibility to complete maintenance and inspections that better align with generating plant maintenance cycles and rotating outages

Patrick Wells, OGE Energy - Oklahoma Gas and Electric Co., 5, 3/12/2021

- 0 - 0

 BC Hydro recommends that the language in R7.2 clarifies that "freeze protection measures" in R2 are those identified under R7.1.

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

- 0 - 0

CEHE Project 2019-06 Cold Weather, Segment(s) 1, 3/12/2021

- 0 - 0

Darnez Gresham, Berkshire Hathaway Energy - MidAmerican Energy Co., 3, 3/12/2021

- 0 - 0

The language within Requirement R7, subpart 7.2 is clear to ensure GOs conduct annual maintenance and inspection of their generating unit freeze protection.

 

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

Daniel Gacek, Exelon, 1, 3/12/2021

- 0 - 0

  • Needs to be prior to the cold weather season for inspections and any necessary system repairs.
  • Critical Paths should be identified:
    • Fuel resources
    • Instrument Air
    • Potable water
  • Critical Paths need to be specified for:
    • Idenfied for heat trace
    • identified for heat blanket
    • Identified for barriers

Cogentrix Energy Power Management, Segment(s) 5, 3/12/2021

- 0 - 0

MISO supports the IRC SRC comments

Bobbi Welch, Midcontinent ISO, Inc., 2, 3/12/2021

- 0 - 0

Support comments by Western Area Power Administration, Sean Erickson, Segment 1.

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

- 0 - 0

Amy Jones, On Behalf of: Public Utility District No. 2 of Grant County, Washington, , Segments 1, 4, 5, 6

- 0 - 0

No, PG&E believes Winter Preparations should be standard operating procedure, which would aid in avoiding Emergency Operations just as other utilities have commented. PG&E has a good handle on how cold weather impacts our facilities and how to respond without adding the additional requirement of a separate preparedness plan.  PG&E Facilities have been designed to operate reliably in the conditional environment they exist in, most of which are located in cold mountainous terrain.  Local Maintenance practices and procedures already exist as well as already established cold weather plans of which should be the only guidance necessary to continue reliable operation of PG&E’s facilities.  In the point of recommending a locational fit PG&E would suggests considering the development of a new FAC Standard as the location.

Pamalet Mackey, On Behalf of: Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Ed Hanson, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5; Sandra Ellis, Pacific Gas and Electric Company, 1,3,5

- 0 - 0

W. Dwayne Preston, Austin Energy, 3, 3/12/2021

- 0 - 0

Standards Review Committee (SRC), Segment(s) 2, 1/25/2016

- 0 - 0

Jamie Johnson, California ISO, 2, 3/12/2021

- 0 - 0

OPG concurs with the NPCC Regional Standards Committee’s comments.

Constantin Chitescu, Ontario Power Generation Inc., 5, 3/12/2021

- 0 - 0

PJM supports the IRC SRC comments.

Elizabeth Davis, On Behalf of: Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2; Tom Foster, PJM Interconnection, L.L.C., 2

- 0 - 0

Aaron Staley, Orlando Utilities Commission, 1, 3/12/2021

- 0 - 0

Not clear on the “data specification requirement” added for the BA; appears to be adding BA requirement to add “Processes to prepare for and mitigate Emergencies including” for cold weather conditions; this is too vague to offer reliable solution to the 2021 cold weather event.

Glenn Pressler, CPS Energy, 3, 3/12/2021

- 0 - 0

Michael Dillard, Austin Energy, 5, 3/12/2021

- 0 - 0

Adding an “Annual maintenance and inspection of generating unit(s) freeze protection measures” requirement could appear beneficial from the outside, but such a requirement would not have helped prevent the Texas 2021 winter event.  Such requirement would only be an administrative check box.  Terms such as “Annual” is also too vague for example, in “7.2. Annual maintenance and inspection of generating unit(s) freeze protection measures” should be tightened to be more specific, like quarter before winter season each calendar year.

Gladys DeLaO, CPS Energy, 1, 3/12/2021

- 0 - 0

Hot Answers

If the RC, TOP, and/or BA are required to include generator design specifications (such as a manufacturer’s minimum ambient operating temperature) and/or historical cold-weather performance information in its OPA or RTA or Real-time monitoring as currently proposed, ERCOT would need to develop system changes in order to use such data for all generators because ERCOT presently utilizes minimum design data for only wind and solar resources, some of which are designed to automatically shut down at certain temperatures.  These system changes could take several years.   If the alternative language ERCOT has proposed in response to Questions 2, 3, or 8 is approved, ERCOT would have no objection to a 12-month (or perhaps shorter) implementation timeline.

Brandon Gleason, Electric Reliability Council of Texas, Inc., 2, 3/12/2021

- 0 - 0

Jun Hua, Austin Energy, 4, 3/12/2021

- 0 - 0

Other Answers

Kristina Marriott, On Behalf of: Kristina Marriott, , Segments 5

- 0 - 0

The implementation plan could be replaced by a cold weather operations report due 12 months following the effective date which would detail any unique cold weather operations.

Dylan Sontag, On Behalf of: Silicon Ranch Corporation, SERC, Segments 1

- 0 - 0

A 12-month implementation does not allow enough time for adequate compliance. A minium of 36 months would be more adequate and would fall in line with other new requirements implemented in the past. It would take a minimum of 3 years to get this type of new program off the ground effectively.

Laura Nelson, 2/10/2021

- 0 - 0

For those generators that are located in cold climates and operate regularly in freezing weather, this standard will be a unnecessary administrative series of tasks.  The Cold Weather Preparedness should be limited to those locations where cold weather operations is not frequent.  Despite the recent problems in Texas, Generations in Northern climates continues to be reliable.  Perhaps the standard needs to put the burden on Planning Coordinators to identify generators that are of high risk, and require Cold Weather preparedness from them, excluding others.

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 2/22/2021

- 0 - 0

John Allen, City Utilities of Springfield, Missouri, 4, 2/25/2021

- 0 - 0

While 12 months may be sufficient for some of the proposed obligations regarding preparedness itself, we do not believe it would be sufficient to accommodate all the various impacts related to operations. We believe 24 months would be more appropriate, and would allow entities the time necessary to develop the required documentation, including those related to communications.

Thomas Foltz, AEP, 5, 2/26/2021

- 0 - 0

Gul Khan, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

- 0 - 1

Todd Bennett, Associated Electric Cooperative, Inc., 3, 3/4/2021

- 0 - 0

Platte River Power Authority suggests an eighteen (18) month implementation plan to provide enough specificity for an industry wide standard.  An 18-month implementation plan allows registered entities the appropriate amount of time to develop the associated cold-weather preparedness plans, develop training materials, and train affected personnel, as well as allows for cold-weather training to potentially be aligned with other required training at generation sites.

Tyson Archie, Platte River Power Authority, 5, 3/4/2021

- 1 - 0

Dan Roethemeyer, Vistra Energy, 5, 3/5/2021

- 0 - 0

Not applicable

Bruce Reimer, Manitoba Hydro , 1, 3/5/2021

- 0 - 0

Considering the scope of this project which covers 3 standards the Implementation Plan should be extended to 24 months.

Joe O'Brien, NiSource - Northern Indiana Public Service Co., 6, 3/5/2021

- 0 - 0

Patricia Lynch, NRG - NRG Energy, Inc., 5, 3/5/2021

- 0 - 0

WECC Cold Weather, Segment(s) 10, 3/5/2021

- 0 - 0

Matthew Nutsch, On Behalf of: Seattle City Light, WECC, Segments 1, 3, 4, 5, 6

- 0 - 0

Talen recommends that the proposed Implementation Plan be modified to allow for 18-24 months following the effective date to become compliant with EOP-011. This timeframe will allow for development of cold weather plans, procurement/implementation of freeze protection measures, and training of site personnel.

Donald Lock, Talen Generation, LLC, 5, 3/9/2021

- 0 - 0

BPA supports Reclamation’s comments.

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

As noted in Tacoma Power’s comments to Question 1, instead of specifying a Standard Implementation Plan timeline, each GO should perform a vulnerability assessment and then develop CAPs with appropriate implementation timelines.

Tacoma Power, Segment(s) 1, 3, 4, 5, 6, 3/9/2021

- 2 - 0

N/A.

Leonard Kula, Independent Electricity System Operator, 2, 3/9/2021

- 0 - 0

Scott Langston, Tallahassee Electric (City of Tallahassee, FL), 1, 3/10/2021

- 0 - 0

Yes, Southern Company believes that 12 months is sufficient time to ensure compliance with the new requirements.

Southern Company, Segment(s) 1, 3, 6, 5, 1/14/2021

- 0 - 0

Instead of 12 months implement an 18 month or 24-month plan

Erick Barrios, New York Power Authority, 6, 3/10/2021

- 0 - 0

This is not enough time to implement. Two or three years would be achievable.

Glen Farmer, Avista - Avista Corporation, 5, 3/10/2021

- 0 - 0

Lincoln Electric System, Segment(s) 5, 6, 3, 1, 4/17/2018

- 0 - 0

FE Voter, Segment(s) 1, 3, 5, 6, 4, 2/23/2021

- 0 - 0

NO. A more appropriate implementation plan timeline might be two-three years depending on cost and potential work load GO/GOPs project for this new FERC/NERC mandated project and other regulatory agency existing/proposed obligations.  In addition, time is needed to budget and obtain approvals for new capital investment dollars (labor/material) and new positions to meet new requirements.

Marty Hostler, Northern California Power Agency, 4, 3/10/2021

- 0 - 0

Alternative - Duke Energy recommends a 24-month implementation period to allow for drafting of the plans, training, and development of the required maintenance work orders.

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

- 0 - 0

An implementation period of 12 months may be restrictive to Facilities that have large footprints with long procurement processes, such as federal entities. Reclamation recommends a 24-month implementation period for EOP-011, IRO-010, and TOP-003 to account for necessary research, development, and procurement needs. At a minimum, the implementation period should be 24 months for EOP-011 because Generator Owners have never had to comply with this standard before.

Richard Jackson, U.S. Bureau of Reclamation, 1, 3/11/2021

- 0 - 0

A more appropriate implementation plan timeline might be two-three years depending on cost and potential work load GO/GOPs project for this new FERC/NERC mandated project and other regulatory agency existing/proposed obligations.  In addition, time is needed to budget and obtain approvals for new capital investment dollars (labor/material) and new positions to meet new requirements.

NCPA, Segment(s) 4, 5, 6, 4/3/2020

- 0 - 0

Winterization may be a capital-intensive undertaking for some generators, and twelve months may not be enough time for some entities to finance and perform the necessary work.  Reliability would be better served by allowing registered entities a bit more time to truly winterize, than by imposing an unrealistic deadline that may lead some entities to water down their plans to avoid being noncompliant.

A 36-month implementation schedule would be more reasonable.

Ballard Mutters, Orlando Utilities Commission, 3, 3/11/2021

- 0 - 0

GRE supports the comments of the NSRF 

Michael Brytowski, Great River Energy, 3, 3/11/2021

- 0 - 0

Recommend this be pushed to 24 months.  Each GO with a BES generator is going to need to review their freeze protection measures (or purchase and install them), develop an Annual maintenance and inspection process for those freeze protection measures (this is noted since there must be GOs who do not have freeze protection measures in place per the past failure to start during cold weather).  Budget cycles for most Entities (including GOs) are forecasted one year and purchased the following year.  If this remains at the 12-month implementation plan, there may be small GOs with BES generators who may be non-compliant by not having enough time to implement their freeze protection measures or they may “boil down” their freeze protection measures due to “unique factors”.

MRO NSRF, Segment(s) 2, 3, 5, 1, 6, 4, 0, 3/11/2021

- 0 - 0

Texas RE appreciates the SDT developing the language for initial performance not only for the reliability benefits but also for oversight clarification that often gets overlooked.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 3/11/2021

- 0 - 0

Entergy, Segment(s) 1, 5, 12/13/2017

- 0 - 0

Please clarify the purpose of EOP-011 R7.  If it is to require the generator owner to add new equipment to their plants to increase the cold weather preparedness then at least 36 Months would be a more appropriate time duration. If the requirement is just about formally determining the units existing capability and maintaining that capability thn 12 months is a sufficient time frame.

Winterization may be a capital-intensive undertaking for some generators, and twelve months may not be enough time for some entities to finance and perform the necessary work.  Reliability would be better served by allowing registered entities a bit more time to truly winterize, than by imposing an unrealistic deadline that may lead some entities to water down their plans to avoid being noncompliant.

Dania Colon, Orlando Utilities Commission, 5, 3/11/2021

- 0 - 0

comments submitted

Don Stahl, Black Hills Corporation, 3, 3/11/2021

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 1 - 0

Scott McGough, Georgia System Operations Corporation, 3, 3/11/2021

- 0 - 0

Recommend this be 24 months, this allows the GO time to adopt the preparedness plans, perform activities and train in a managed fashion.  Each GO with a BES generator is going to need to review their freeze protection measures (or purchase and install them), develop an Annual maintenance and inspection process for those freeze protection measures (this is noted since there must be GOs who do not have freeze protection measures in place per the past failure to start during cold weather).  Budget cycles for most Entities (including GOs) is forecasted one year and purchased the following year.  If this remains at the 12 month implementation plan, there may be small GOs with BES generators who may be non-compliant by not having enough time to implement their freeze protection measures or they may “boil down” there freeze protection measures due to “unique factors”.   

Thomas Breene, WEC Energy Group, Inc., 3, 3/11/2021

- 1 - 0

ACES recommends this be pushed to 24 months.  Each GO with a BES generator is going to need to review their freeze protection measures (or purchase and install them), develop an annual maintenance and inspection process for those freeze protection measures. Company budget cycles are requested to be measured as a consideration in the time-extension decisions.

 

AEPCO is sigining on to ACES comments as well.

Jennifer Bray, Arizona Electric Power Cooperative, Inc., 1, 3/11/2021

- 0 - 0

This is not enough time to implement. Two or three years would be achievable.

Mike Magruder, Avista - Avista Corporation, 1, 3/11/2021

- 0 - 0

A more appropriate implementation plan timeline might be two-three years depending on cost and potential work load GO/GOPs project for this new FERC/NERC mandated project and other regulatory agency existing/proposed obligations.  In addition, time is needed to budget and obtain approvals for new capital investment dollars (labor/material) and new positions to meet new requirements.

Dennis Sismaet, Northern California Power Agency, 6, 3/11/2021

- 0 - 0

Utility Services supports the comments posted by the TAPS group.

Brian Evans-Mongeon, Utility Services, Inc., 4, 3/12/2021

- 0 - 0

The NAGF recommends that the proposed Implementation Plan be modified to allow for 18-24 months following the effective date to become compliant with EOP-011. This timeframe will allow for development of cold weather plans, procurement/implementation of freeze protection measures, and training of site personnel.

Wayne Sipperly, On Behalf of: North American Generator Forum, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 5

- 0 - 0

The implementation period for EOP-011 should be at least 18 months.  Winterization may be a capital-intensive undertaking for some generators, and twelve months may not be enough time for some entities to finance and perform the necessary work.  Reliability would be better served by allowing registered entities a bit more time to truly winterize, than by imposing an unrealistic deadline that may lead some entities to water down their plans to avoid being noncompliant.

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

- 0 - 0

A 12-month implementation seems reasonable. However, given the current concerns, it may be prudent to have a staggered implementation plan with high priority items be completed within the proposed 12-month implementation period.  Considering “weather plans” should already exist having a staggered timeframe may be feasible. 

Justin Welty, NextEra Energy - Florida Power and Light Co., 6, 3/12/2021

- 0 - 0

The implementation period for EOP-011 should be at least 18 months.  Winterization will be a capital-intensive undertaking for our generators in Florida, and twelve months may not be enough time for our agency to finance and perform the necessary work.  Reliability would be better served by allowing registered entities a bit more time to truly winterize, than by imposing an unrealistic deadline that may lead some entities to water down their plans to avoid being non-compliant.

Truong Le, On Behalf of: Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; Neville Bowen, Ocala Utility Services, 3; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5; David Owens, Gainesville Regional Utilities, 1,3,5

- 0 - 0

Support comments submitted by Tom Breene of WEC Energy Group. 

Janet OBrien, 3/12/2021

- 0 - 0

Black Hills Corporation Power Delivery department feels that more time would be needed than just 12 months for implementation.  Suggest at least 24 months to account for unplanned outages, development of plans, and required training.

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

- 0 - 0

Robin Hill, On Behalf of: Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5; Heather Morgan, EDP Renewables North America LLC, 5

- 0 - 0

Aidan Gallegos, On Behalf of: PNM Resources - Public Service Company of New Mexico, , Segments 1, 3

- 0 - 0

Recommend this be pushed to 24 months, this allows the GO time to adopt the preparedness plans, perform activities and train in a managed fashion.  Each GO with a BES generator is going to need to review their freeze protection measures (or purchase and install them), develop an Annual maintenance and inspection process for those freeze protection measures (this is noted since there must be GOs who do not have freeze protection measures in place per the past failure to start during cold weather).  Budget cycles for most Entities (including GOs) is forecasted one year and purchased the following year.  If this remains at the 12 month implementation plan, there may be small GOs with BES generators who may be non-compliant by not having enough time to implement their freeze protection measures or they may “boil down” there freeze protection measures due to “unique factors”.    

Matthew Beilfuss, WEC Energy Group, Inc., 4, 3/12/2021

- 0 - 0

Consistent with the NAGF, DTEE recommends that the proposed Implementation Plan be modified to allow for 18-24 months following the effective date to become compliant with EOP-011. This timeframe will allow for development of cold weather plans, procurement/implementation of freeze protection measures, and training of site personnel.

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

- 0 - 0

James Baldwin, Lower Colorado River Authority, 1, 3/12/2021

- 0 - 0

The implementation period for EOP-011 should be at least 18 months.  Winterization may be a capital-intensive undertaking for some generators, and twelve months may not be enough time for some entities to finance and perform the necessary work.  Reliability would be better served by allowing registered entities a bit more time to truly winterize, than by imposing an unrealistic deadline that may lead some entities to water down their plans to avoid being noncompliant.

Devon Tremont, Taunton Municipal Lighting Plant, 1, 3/12/2021

- 0 - 0

Marcus Bortman, APS - Arizona Public Service Co., 6, 3/12/2021

- 0 - 0

Teresa Krabe, Lower Colorado River Authority, 5, 3/12/2021

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 3/12/2021

- 0 - 0

Anthony Jablonski, ReliabilityFirst , 10, 3/12/2021

- 0 - 0

PUD No. 1 of Chelan County , Segment(s) 1, 3, 5, 6, 3/12/2021

- 0 - 0

SCE supports EEI's comments.

Neil Shockey, 3/12/2021

- 0 - 0

Evergy supports and incorporates by reference Edison Electric Institute’s response to Question 6.

Douglas Webb, 3/12/2021

- 0 - 0

Support the intent of this project and the updating of the three applicable Standards.  Support the submitted MRO-NSRF comments.

Wayne Guttormson, SaskPower, 1, 3/12/2021

- 0 - 0

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

- 0 - 0

Acciona Energy USA Global, LLC (Acciona) supports the Midwest Reliability Organization NERC Standards Review Forum’s (MRO NSRF) comments.

George Brown, Acciona Energy North America, 5, 3/12/2021

- 0 - 0

Santee Cooper recommends an eighteen (18) month implementation plan allow registered entities the appropriate amount of time to develop the associated cold-weather preparedness plans, develop training materials, and train affected personnel.

Santee Cooper, Segment(s) 1, 3, 5, 6, 3/12/2021

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Instead of 12 months 18 months – It takes time to install winterization equipment.

NPCC Regional Standards Committee no UI, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 3/12/2021

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Twelve months to create a plan in compliance with EOP-011 R7 is sufficient, but the SDT should consider an additional 12-24 months for implementation and training. 

Shannon Ferdinand, On Behalf of: Capital Power Corporation, MRO, WECC, Texas RE, SERC, Segments 1, 6

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Ameren Agrees with and supports NAGF comments

David Jendras, Ameren - Ameren Services, 3, 3/12/2021

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See Tom Breene's comments.  

David Hathaway, WEC Energy Group, Inc., 6, 3/12/2021

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Romel Aquino, Edison International - Southern California Edison Company, 3, 3/12/2021

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ACES recommends this be pushed to 24 months. Each GO with a BES generator is going to need to review their freeze protection measures (or purchase and install them), develop an annual maintenance and inspection process for those freeze protection measures. Company budget cycles are requested to be measured as a consideration in the time-extension decisions.

ACES Standard Collaborations, Segment(s) 1, 3, 4, 5, 3/12/2021

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EEI supports the proposed 12-month Implementation Plan.

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

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The SDT should consider ways to expedite the implementation and effective date of the data specification requirements so that they can be in place prior to the next winter season following FERC approval.  The Implementation Plan can be structured such that there are longer lead times for asset owners to meet the freeze protection measure requirements and preparedness plans; however, the ERO Enterprise should seek ways to inform the industry to begin preparations immediately after the Ballot Body approves the requirements

Michael Courchesne, On Behalf of: Michael Puscas, ISO New England, Inc., 2; Michael Puscas, ISO New England, Inc., 2

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC - Segments 1, 3, 5, 6

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Carl Pineault, Hydro-Qu?bec Production, 5, 3/12/2021

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NV Energy believes that initial planning and maintenance requirements can be initiated following twelve months from the effective date. However, NV Energy believes the implementation plan timeline should take into account required time for corrective actions found during the implementation period, and thus be extended to 18 months. 

Kevin Salsbury, Berkshire Hathaway - NV Energy, 5, 3/12/2021

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OPC agrees with the NAGF recommendation that the proposed Implementation Plan be modified to allow for 18-24 months following the effective date to become compliant with EOP-011. This timeframe will allow for development of cold weather plans, procurement/implementation of freeze protection measures, and training of site personnel.