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2021 Periodic Review Standing Review Team - Standards Grading

Description:

Start Date: 06/04/2021
End Date: 07/19/2021

Associated Ballots:

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

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Q:

1. For BAL-002-3, do you agree with the scoring and findings of the SRT? If not, please comment on which tool question(s) the comment applies to and provide a supporting explanation.

Hot Answers

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

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EEI supports the BAL-002-3 comments.

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

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Other Answers

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

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

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No comments.

Selected wrong choice. Answer is Yes.  

Carl Pineault, On Behalf of: Hydro-Qu?bec Production, , Segments 1, 5

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Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Questions C2 & Q4: SRP recomends BAL-002-3 R1 be separated into three separate requirements rather than one requirement with 3 sub-parts.

Israel Perez, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/19/2021

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

Alan Kloster, On Behalf of: Great Plains Energy - Kansas City Power and Light Co. - MRO - Segments 1, 3, 5, 6

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Q:

2. For BAL-005-1 , do you agree with the scoring and findings of the SRT? If not, please comment on which tool question(s) the comment applies to and provide a supporting explanation.

Hot Answers

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

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EEI supports the BAL-005-1 comments.

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

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Other Answers

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

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

- 0 - 0

No comments

Selected wrong choice. Answer is Yes.  

Carl Pineault, On Behalf of: Hydro-Qu?bec Production, , Segments 1, 5

- 0 - 0

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Israel Perez, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/19/2021

- 0 - 0

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

Alan Kloster, On Behalf of: Great Plains Energy - Kansas City Power and Light Co. - MRO - Segments 1, 3, 5, 6

- 0 - 0

Q:

3. For EOP-004-4, do you agree with the scoring and findings of the SRT? If not, please comment on which tool question(s) the comment applies to and provide a supporting explanation.

Hot Answers

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

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While EEI supports many of the EOP-004-4 comments, we do not support the need for “additional categories of functional entities (created) to ensure sufficient reporting is done at the distribution level.”  Although there has been rapid growth of DERs in many areas at the distribution level and this trend will likely continue as a result of FERC Order 2222, the actions are not necessary because Distribution Providers (DPs) are already identified in EOP-004-4 as a Responsible Entity, and the DP should be the entity with the greatest awareness of any reportable event that occurs on their distribution system.   Additionally, owners of DERs are unlikely to meet NERC’s registration threshold, but if they did, they would be required to register as a GO/GOP, negating any need for a new category.  

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

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Other Answers

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

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

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No comments

Selected wrong choice. Answer is Yes.  

Carl Pineault, On Behalf of: Hydro-Qu?bec Production, , Segments 1, 5

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Relative to C2, for requirements R1 and R2, we appreciate the comment and understand its foundation, however, the identified functions (Distribution System Operator, etc.) are not currently part of the registered functions set forth in the Rules of Procedure.  The addition of a new functional entity to Rules of Procedure must occur before they can be considered for addition to the applicable sections of EOP-004.  For this reason, the referenced comment is beyond the scope of this project.

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Israel Perez, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/19/2021

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

Alan Kloster, On Behalf of: Great Plains Energy - Kansas City Power and Light Co. - MRO - Segments 1, 3, 5, 6

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Q:

4. For EOP-005-3, do you agree with the scoring and findings of the SRT? If not, please comment on which tool question(s) the comment applies to and provide a supporting explanation.

Hot Answers

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

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EEI offers the following EOP-005-3 comments:

  1. EEI does not support the addition of a new subpart to Requirement R1 that would include the following: “Load enabled with Load Shedd (UFLS) devices and setpoint frequencies”.  While this change could provide some marginal value, we are unaware of a sufficient reliability benefit to the blackstart processes to justify this change.  Entities need flexibility because most restoration situations are fact specific and defining specific UFLS devices could impede restoration efforts.  Moreover, the purpose of UFLS systems is to stave off conditions that might lead to instability or collapse; not contribute to restoration or otherwise impede in the restoration process after a regional or areawide collapse.
  2. EEI does not support adding a dual fuel capability subpart to Requirement R1.  If the TOP needs this information, the information can be obtained through data specification/requests processes already defined in TOP-003.
  3. The existing 90-day reporting timeframe after identifying “any unplanned permanent BES modification” is not too long or otherwise unjustified.  On the contrary, validating, assessing, and developing alternatives to a TOPs restoration plan is not an inconsequential effort and the time allowed should not be shortened.
  4. EEI supports the NERC comment suggesting that R7 should be modified to require the testing of all fuel types of a blackstart resources.
  5. EEI does not support proposed changes to R11, because the term “Blackstart Resource Agreements” is clear.
  6. EEI supports NERC’s suggestion to add “the type of unit and fuel type[s]” to R14, subpart 14.1.

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

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Other Answers

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

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EOP-005-3 R1

RE:         C3: This single Requirement has three requirements:

1.           Develop a Restoration Plan

2.           Implement the Plan following a Disturbance

3.           Have the Plan approved by the RC

Consider splitting into individual Requirements.

Duke Energy Response:

Splitting Requirement R1 into individual Requirements is duplicative or previously addressed in a prior Standard version.  Specifically: (1) EOP-005-2 R7 previously considered and removed the singular Requirement to implement a Restoration Plan following a Disturbance and (2) EOP-005-3 R4 already requires a revised Plan to be approved by the RC.

 

NERC:   C3: R1X Add Identification of Load enabled with Underfrequency Load Shed (UFLS) devices and setpoint frequencies.

Duke Energy Response:

Identification of Load enabled with UFLS devices and setpoint frequencies is duplicative.  Specifically, if a specific Load (or all Loads) are identified, then the loads would fall under R1.8.

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

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No comments

Selected wrong choice. Answer is Yes.  

Carl Pineault, On Behalf of: Hydro-Qu?bec Production, , Segments 1, 5

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Relative to C3, for requirement R1, we believe the requested additions are already addressed in R1.6 and R1.8; and that adding an additional requirement would be an administrative burden.   Additionally, relative to the time period comments set forth for requirement R4, we suggest that 30 days is too short to redraft the applicable plans and finalize them for submission to an RC.  For this reason, we would support retaining the 90 day requirement or discussing reduction to 60 days.

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Israel Perez, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/19/2021

- 0 - 0

Evergy supports and incorporates by reference Edison Electric Institute’s (EEI) response to Question 4.

Alan Kloster, On Behalf of: Great Plains Energy - Kansas City Power and Light Co. - MRO - Segments 1, 3, 5, 6

- 0 - 0

Q:

5. For EOP-006-3‚Äč, do you agree with the scoring and findings of the SRT? If not, please comment on which tool question(s) the comment applies to and provide a supporting explanation.

Hot Answers

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

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EEI offers the following comments:

  1. EEI does not agree that Requirement R1 is unclear or ambiguous.  While we do not disagree that Requirement R1 reads like a statement rather than a requirement, the enforceable requirements are clearly contained in Requirement R1’s subparts.
  2. EEI does not agree that Requirement R6 implies a need for a “hard copy” of the latest restoration plan of each TOP within the RC’s primary and backup control center because the word “copy” can be understood to mean a hard copy or soft copy. 
  3. EEI supports the comment that consideration should be given to modifying Requirement R8 to allow regional drills, not conducted by a single RC, to satisfy the drill requirements contained in Requirement R8.  Such a change would contribute to improved efficiencies for both the RC and those entities participating in those drills.

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

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Other Answers

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

- 0 - 0

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

- 0 - 0

No comments

Selected wrong choice. Answer is Yes.  

Carl Pineault, On Behalf of: Hydro-Qu?bec Production, , Segments 1, 5

- 0 - 0

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

- 0 - 0

Israel Perez, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/19/2021

- 0 - 0

Evergy supports and incorporates by reference Edison Electric Institute’s (EEI) response to Question 5.

Alan Kloster, On Behalf of: Great Plains Energy - Kansas City Power and Light Co. - MRO - Segments 1, 3, 5, 6

- 0 - 0

Q:

6. For EOP-008-2, do you agree with the scoring and findings of the SRT? If not, please comment on which tool question(s) the comment applies to and provide a supporting explanation.

Hot Answers

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

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EEI offers the following comments:

  1. Distribution System Operators should not be added to the applicability section of EOP-008-2.  While EEI recognizes that DERs are growing, and they are having greater impact on BES reliability, additional analysis and justification to substantiate such a change is needed before such a change is considered.
  2. EEI supports the comment that Requirement R8 “does not support reliability,” and the drafting team’s conclusion implies that this requirement may merit consideration for retirement, or as suggested by the RE that the obligations contained in this requirement might be better suited to a Reliability Guideline.   

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

- 0 - 0

Other Answers

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

- 0 - 0

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

- 0 - 0

No comments

Selected wrong choice. Answer is Yes.  

Carl Pineault, On Behalf of: Hydro-Qu?bec Production, , Segments 1, 5

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Relative to C2, for requirements R1 and R2, we appreciate the comment and understand its foundation, however, the identified functions (Distribution System Operator, etc.) are not currently part of the registered functions set forth in the Rules of Procedure.  The addition of a new functional entity to Rules of Procedure must occur before they can be considered for addition to the applicable sections of EOP-004.  For this reason, the referenced comment is beyond the scope of this project.

GSOC disagrees with the comments regarding setting deadlines for recovery after an unplanned outage.  While we understand the concern that not having undefined boundaries on the recovery of functionality after an unplanned outage presents, we would suggest that unplanned outages can occur as a result of abnormal and sometimes catastrophic events. It would be challenging to identify an appropriate apply time limit or deadline within which entities should recover when their unplanned outage occurs as a result of a catastrophic event.  For this reason, we would not support the addition of generic or over-arching deadlines for recovery from unplanned outages.  

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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R1 C3: Requirement 1.4 is a combined requirement.  IT requires an Operating Procedure used in determining when to implement backup functionality and a requirement that specifies decision making authority to implement the backup functionality.  This is confusing and should be separated into two distinct requirements.

R2: Q3 & Q11 : “have a copy” implies a hard copy printed out.  It is possible to have an electronic copy available and can ensure that both “copies” are concistent.  However, it is unclear if this is acceptable for compliance.

R4: Q11 the statement in parenthesis “provided through its own dedicated backup functionality or at another entity’s control center..” is confusing, it basically stats that an entity or anyone else can provide the functionality. Why specify this distinction as it’s not clear who must do what.

R5 Q11: “any changes of any part of the Operating Plan..” is a vague description.  A change in just a phone number for the enteties necessary to contact per 1.6.1 whoudl thus require an approval of the change. That may be a lengthly approval process for a simple phone number update. SRP recomends that an approval only be required for a substatative change or a change in the process itself or even just a change for items in R1.2 items.

Israel Perez, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/19/2021

- 0 - 0

Evergy supports and incorporates by reference Edison Electric Institute’s (EEI) response to Question 6.

Alan Kloster, On Behalf of: Great Plains Energy - Kansas City Power and Light Co. - MRO - Segments 1, 3, 5, 6

- 0 - 0

Hot Answers

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

- 0 - 0

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

- 0 - 0

Other Answers

All of the grades were pretty close, meaning all graders agree the Standards are accomplishing their intent.

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

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No additional comments at this time.

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

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No additional comments

Carl Pineault, On Behalf of: Hydro-Qu?bec Production, , Segments 1, 5

- 0 - 0

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

- 0 - 0

Israel Perez, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/19/2021

- 0 - 0

No additional comments. 

Alan Kloster, On Behalf of: Great Plains Energy - Kansas City Power and Light Co. - MRO - Segments 1, 3, 5, 6

- 0 - 0