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2021-06 Modifications to IRO-010 and TOP-003 | Standard Authorization Request

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Start Date: 07/08/2021
End Date: 08/06/2021

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Hot Answers

ERCOT does not agree with the proposed scope of the SAR, but does generally agree that it is appropriate to review Reliability Standards in order to reduce administrative burdens and eliminate redundancies, as long as revisions do not adversely impact reliability.  For this SAR, ERCOT agrees that it is appropriate to review the zero-defect expectation, but with caution.  Specifically, ERCOT believes bright line criteria should still set a high standard, but be focused on reliability needs. For example, telemetry availability may be percentage based (e.g., 98 to 99% on a rolling average considering forced or other unplanned outages). A strong performance metric incents the selection of more reliable technologies.  ERCOT also agrees that it is appropriate to evaluate the potential removal of other data exchange requirements that are redundant. Finally, ERCOT agrees that the Reliability Standards should ensure Responsible Entities (RC, BA, TOP) have the ability to request and receive any information necessary to perform their responsibilities.

ERCOT disagrees that IRO-010 and TOP-003 should restrict the content and scope of the data specification. As stated in the standards, the data specification should include any data that the entity finds necessary to perform its analyses, which is done in these standards through the data specification. Changing the scope of the data specification does not solve the zero-defect concern.  In addition, ERCOT does not believe it is appropriate to revise definitions in order to correspond to a particular requirement. Revising definitions, including those for “real-time monitoring” and “Balancing Authority analysis functions” as highlighted in the SAR, could result in unintended consequences beyond IRO-010 and TOP-003. ERCOT also disagrees that the drafting team should consider a requirement(s) to ensure entities use the data in the specification because of the administrative burden associated with doing so.  Accordingly, ERCOT suggests removing the proposed revision of definitions from the SAR and deleting the second and third bullet points identified as questions to evaluate redundant requirements.  Specifically, ERCOT suggests the following language be deleted from the SAR:

“If minor modifications were made to IRO-010-2, TOP-003-3 and/or associated definitions (especially Real-time monitoring and Balancing Authority analysis functions), then would the activity be within the scope of those standards? If so, then revise and remove as redundant.”

”Does the receiving Registered Entity have an obligation to use the information? If so, then identify the existing requirement or create a new requirement for them to use it. If not, then retire outright as unnecessary for reliability of the BES.”

Brandon Gleason, On Behalf of: Brandon Gleason, , Segments 2

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MISO supports comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC).

In addition, MISO recommends the project scope be expanded to include a dispute resolution process. This would allow entities to address the zero-defect concern and provide a way for entities to come to a mutually agreeable solution prior to escalating it to the regulator for resolution.

MISO also supports constricting the scope of IRO-010 and TOP-003 to data required for reliability needs as a reasonable approach; however, we do not support a narrowing of scope that would limit the applicability of IRO-010 and TOP-003 to include SCADA data sent via ICCP only, as we use the data specification to collect modeling and outage data as well.

Finally, MISO would prefer to tie the scope to reliability needs as opposed to specific standards as there may be data we require for reliability purposes that are not specifically tied to one of the standards listed in the SAR.

Bobbi Welch, On Behalf of: Midcontinent ISO, Inc., , Segments 2

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Other Answers

Amber Parker, On Behalf of: Unisource - Tucson Electric Power Co., WECC, Segments NA - Not Applicable

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Lenise Kimes, On Behalf of: City and County of San Francisco - WECC - Segments 1

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

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AZPS does not have any comments or suggestions for the project scope currently

Marcus Bortman, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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N/A.

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

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AEP agrees with the purpose and perceived need as expressed in the proposed SAR, and sees value in pursuing it. The clarity that the SAR seeks is definitely needed and would be very beneficial. Having said that, the means by which that clarity is obtained, as well as the content of that clarity, are both important issues that industry will need to work on effectively in order to achieve a successful outcome and meaningful change to these standards. In addition, AEP encourages the members of the future Standards Drafting Team to ensure that their eventual revisions are not written in such a way that they are unduly burdensome, especially for larger entities having voluminous data points.

In order for the TOP to perform the necessary real time assessments for the entire BES, they may require data points at lower voltages which are not needed by the RC and thus not provided. The RTO, serving as the RC, should continue to define what data points they need for their own obligations (as per IRO-010), however AEP recommends that changes be made to TOP-003 to allow the TOP to define what data they need from the RC, including data that might not be required or needed by the RC for their own purposes.  Examples of such data include DER data, detailed renewable energy models, and neighboring TOP sub-transmission data that the RTO may not include in their models.  TOPs may identify these data needs through studies conducted to determine the impact of external data on the TOP’s footprint for RTA/OPA purposes. All of this type of external DP/GOP/TOP data should be provided by the RTO. As currently written, the RC has no existing obligations within TOP-003 to do so. As such, obligations for the RC to provide this data would need to be developed and incorporated into TOP-003. With the RTO providing the TOP the necessary data to meet TOP-003 data specifications for Real-time monitoring and RTA/OPA, the revised standards should provide clarity to each applicable entity (RTO/TOP) on which entities need to receive a data specification document from the applicable entity.

Data specification documents are shared between TOPs/GOPs/DPs/etc., even though a majority, if not all, of the data is received via the RTO. To reduce the administrative burden, the data specification documents should only be communicated to the RTOs and any entities serving as the RC who are directly supplying the TOP data.  AEP believes direct data connections (i.e. not through the RTO) should be avoided if at all possible, as managing these types of special links are extremely difficult and complicate data sharing between entities. In addition, such bi-lateral data links to individual companies may be more susceptible to data reliability issues and could have potential compliance ramifications, with TOP-001 as just one example. Additional clarity also needs to be addressed in the standards regarding the details required in the specification documents.  Some entities keep the data specification documents at a very high level (which is preferred) while other entities specify individual data point names and detailed requirements in their data specification documents (not preferred).

AEP recommends the SDT also consider the development of a NERC Glossary Term for real-time monitoring, as we believe the clarity it would bring would be very beneficial if referenced within TOP-003 and IRO-010.

AEP believes the suggestions above would be beneficial and prevent divergence in Real-time Assessment analysis from inconsistency in the models themselves, clarifying exactly where the data is coming from, and by reducing administrative burden.

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5, 6

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

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Texas RE agrees there could be efficiencies gained by clarifying certain actions in the standards.  Texas RE is concerned, however, that the SAR drafting team’s approach is simply assuming these requirements will be handled by the data specification requirements.  There are no obligations for what exactly needs to be in the data specification requirements.  The Project 2014-03 drafting team stated several times that FERC has made it clear that the assumption cannot be made on something based on other requirements that dictate certain actions.  This SAR appears to be assuming that actions will be taken on data based on a data specification in which there are no requirements.  Texas RE has several additional concerns, including the statement regarding a zero-defect expectation, proposing risk-based data specification requirements, the four reliability-related tasks, and the requirements proposed for possible retirement.

 

Zero-defect Expectation

The statement in the Purpose or Goal section “As written the standards create a zero-defect expectation for each Registered Entity receiving a data specification to demonstrate perfect performance on every item in the data specification for an entire audit period. These issues result in a significant amount of unnecessary administrative burden for the Registered Entity to demonstrate compliance, including excessive data retention” is not accurate. The entity receiving the data specification is only required to satisfy the obligations of the data specification, and not achieve “perfect performance.” 

 

The entity drafting the data specification can build in thresholds for imperfect performance within the data specification itself.  By way of example, the telemetry data specifications for the RC in Texas RE’s footprint permits entities to have 92% of telemetry deemed important by the RC achieve a quarterly reliability of 90%.  For all telemetry, the availability threshold drops to 80%.  In addition, the IRO-010 Standard specifically contemplates the creation of data conflict and reconciliation processes within the data specification itself.  Again, in Texas RE’s footprint, the applicable data specification provides entities does not establish a “zero-defect expectation,” but requires that if an entity cannot resolve a telemetry data issue within two business days, it must provide an estimated time of resolution. 

 

Risk-based data specification

Texas RE is unclear on how a risk-based approach would achieve the purpose of the standards in an effective and efficient manner.  Texas RE is concerned that problems may not be identified if performance oversight is only triggered by significant events or unresolved data conflicts.  In order for the system to be operated in a reliable manner, constant and consistent data must be provided.  While Texas RE generally supports risk-based compliance approaches, Texas RE believes that such approaches are best determined within the framework of the specific data specification itself rather than prescribed through the IRO-010 data specification standard itself. 

 

Reliability-related Tasks

Texas RE does not agree that there are only the four reliability-related tasks specified in the SAR.  “Core BES reliability-related tasks” are defined in the SAR by only four tasks, all of them operational, and contained only in the eight Standards specified.  Other reliability-related tasks do exist but do not fit in the four categories described in the SAR.

 

For example, modeling data dictates OPA, RTA, and Real-time monitoring results but is not listed.  Based on the language provided, the SAR drafting team envisions that OPA, RTA, or Real-time monitoring will be performed and therefore the entity is “compliant” without ever having any obligation to ensure it receives quality inputs to provide quality output, which would help ensure reliability.  This could lead to inconsistencies and diminished accountability for inadequate data specifications, especially for those that lack information necessary to support reliable operations.

 

The core reliability-related tasks do not include data provisions (EOP-005, IRO-017) because they would not be associated with the OPA or RTA within the IRO-010 and TOP-003 data specifications. As this data would impact reliability studies that occur after the Long-term Planning Horizon, but significantly before the next-day studies, it appears there is a gap in the Standards.

 

Texas RE does not agree that RTA and OPA need further clarification.  Industry should be aware of what is needed regarding these tasks since there are NERC defined terms and ERO endorsed Implementation Guidance on RTA. A definition for Real-time monitoring could help in providing clarity on expectations.

 

Texas RE requests the SAR drafting team provide examples of data specifications that are not part of the core reliability-related tasks.

 

Requirements proposed for possible retirement:

Texas RE is concerned that the requirements being proposed for retirement have to do with conditions that are not part of the OPA and RTA as the data specifications requirements are intended.

 

For example, notification of changes to the capabilities of a Blackstart Resource affecting the ability to meet the Transmission Operator’s restoration plan may require a TOP to modify its restoration plan. This evaluation and modification would not be within the scope of the OPA or RTA, unless the SDT plans to include these tasks as part of its clarification the core BES reliability-related tasks.

 

Additionally, IRO-017-1 R3 requires provision of the Planning Assessment to the RC so the TP and PC can jointly develop solutions with its respective RC for identified issues or conflicts with planned outages in its Planning Assessment. As outages are scheduled and coordinated months if not years in advance, relying on entities to identify and resolve these issues or conflicts through the OPA and RTA is not practical.

 

Another example is that voltage control is not part of one of the core reliability-related tasks, which could lead to voltage collapse if it is not consider in the data specification.

 

Lastly, Texas RE is concerned that entities may not include specific data points that are being proposed for removal in its data specification.  This will lead to inconsistencies in implementation and could lower the bar for reliability if entities do not consider certain data points.  The SAR drafting team should not assume that all entities will have the same reliability tasks and all entities will consider the same data specifications.  Making the requirements general in nature lowers the compliance requirements and increases the risk that data management will not be done in an effective manner to support reliable operations.

 

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

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1. RF believes the SAR does not clearly establish problems with the existing standards.

2. RF feels an effective SAR would need to more clearly identify specific requested changes to the standards.

3. RF does not agree there is a need to revise the standard; rather, RF believes collaboration between entities provides an effective means of addressing concerns with data specifications.

4. See additional general comments from RF in response to Question 2.

Anthony Jablonski, On Behalf of: Anthony Jablonski - - Segments 10

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

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

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GSOC appreciates the effort to develop a definition for Real-time monitoring.

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

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.

Jamie Monette, On Behalf of: Allete - Minnesota Power, Inc., , Segments 1

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The NSRF supports the SAR’s risk-based approach for data collections.  The NSRF also supports the second purpose of pulling in other exchange requirements within different Standards.  This will give all applicable Entities a single place to review (and provide) required data.

MRO NSRF, Segment(s) 2, 4, 1, 6, 3, 5, 7/1/2021

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See attached comments to subtentiate our support on the proposed scope.

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

HQP comments TOP-IRO.docx

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

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Southern Company fully  supports the secondary purpose described in the SAR to identify and remove redundant requirements and if necessary, retire requirements that are not needed for reliability.

The first purpose of the SAR, as written, is not clear.  Both IRO-010-3 and TOP-003-4 currently indicate that their purpose is to allow the parties seeking data (the RC, BA, and TOP) to create the data specs they need to fulfill their responsibilities.  It is not clear, through the words in the SAR, that the revision purpose, as stated, is needed.

“The revisions should allow each Registered Entity with operational responsibilities to perform the tasks identified in IRO-010-2 and TOP-003-3 the ability to request and receive any information it needs to perform those tasks, while protecting public disclosure of commercially sensitive information.”

It is not clear what is new.   If standard revision changes are needed, the reason for a change needs to be more clearly stated, because the parties who can issue data specifications already have the flexibility to ask for exactly what they need to fulfill their responsibilities.

Southern Company, Segment(s) 1, 3, 6, 5, 3/30/2021

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CAISO agrees with the comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee (SRC). In addition, CAISO requests the SAR drafting team consider the following:

  • RCs have no direct interrelationships with DPs, PCs, TOs, TPs, TSPs, GOs/GOPs per the current NERC Reliability Functional Model.  Therefore, any changes to the standards related to data exchange should follow the Functional Model obligations. Currently RCs have direct relationship with BAs and TOPs.

  • Adding the following standards to this project related to data exchange: CIP-002, CIP-012, EOP-006, EOP-010, EOP-011, FAC-008, IRO-002, MOD-001, PRC-002, PRC-012, PRC-023, and TPL-001

Jamie Johnson, On Behalf of: Jamie Johnson, , Segments 2

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Exelon agrees with the proposed scope of this SAR and concurs with the comments submitted by the EEI.  

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

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Standards Review Committee (SRC), Segment(s) 2, 8/6/2021

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Evergy agrees with the proposed scope of this SAR.  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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The American Public Power Association (APPA), the Large Public Power Council (LPPC), and Transmission Access Policy Study Group (TAPS) strongly support the scope and purpose of this SAR and the development of a risk-based approach to entity compliance. The Associations believe the SAR meets two of the (Board approved 11/20) 2021 ERO Work Plan Priorities of, “Expand Risk-Based Focus in Standards, Compliance Monitoring, and Enforcement; and, Capture Effectiveness, Efficiency, and Continuous Improvement Opportunities.” The SAR scope seeks to make the standards more risk-based and in turn minimize administrative burden.  Moreover, the scope seeks to make the standards more effective and efficient, while ensuring that other existing standards with operational data exchange either improve reporting, or eliminate duplication.

 

APPA, LPPC and TAPS acknowledge that the ERO has discretion to take a risk-based approach to compliance monitoring, registered entities must comply with all applicable standard requirements. Public power utilities are typically on the receiving end of data specifications and currently experience uncertainty on the effort needed to demonstrate compliance with the current zero-defect requirements. Under the effective data specification standards, entities that receive data specifications could be expected to demonstrate perfect performance with respect to every item in each data specification.  Such an expectation is counter to a risk-based approach. Therefore, under the current standards complying entities expend excessive resources on data requirements rather than on reliability improvements. The scope of the proposed SAR seeks to simplify the administrative burden in the Project standards.  By refining definitions associated with the standards and coordinating with existing data standards the SAR scope should serve to make the body of standards more efficient and effective.

Jack Cashin, On Behalf of: Jack Cashin, , Segments 4

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

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Ameren agrees with and supports EEI comments.

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

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ACES Standard Collaborations, Segment(s) 1, 5, 3, 4, 8/6/2021

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EEI supports the efforts of the SER Phase 2 Team and this SAR, which addresses consolidating and simplifying information and data exchange requirements.  EEI also agrees with APPA, TAPS and LPPC that this project aligns with two of the five ERO Work Plan Priorities (i.e., 1. Expand Risk-Based Focus in Standards and 2. Capture Effectiveness, Efficiency and Continuous Improvement Opportunities). (Ref. 2021 ERO Work Plan, dated 11/5/2020/NERC Board Approved). EEI is also supportive of expanding this project as identified in this SAR to remove potentially redundant operational data exchange requirements included in other standards identified within the detailed SAR Scope.

Additionally, EEI recommends updating the SAR to reflect the current version of both IRO-010 and TOP-003 Reliability Standards.

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

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SPP supports the comments submitted by the NSRF. In addition, SPP suggests that the SAR drafting team consider including the following issues which are aligned with the SAR's purpose:

  • Mutually-agreeable timing requirements associated with responding to data specifications;
  • A methodology to negotiate data exchanges where one entity questions whether the requested data is necessary for reliability (e.g., dispute resolution);
  • Provisions to address confidentiality concerns; and
  • Data requirements should be pertinent to reliability analysis.

Matthew Harward, On Behalf of: Southwest Power Pool, Inc. (RTO), MRO, WECC, Segments 2

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We would like to expand the scope to include a requirement that the appropriate functional entity who is reponsible for delivering the data is specified.  For example, the entity should identify if they are expecting the data to be provided by the GO or TO versus the GOP or TOP.

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

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OPG concurs with NPCC's RSC comments.

David Kwan, On Behalf of: Ontario Power Generation Inc. - NPCC - Segments 5

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Hot Answers

ERCOT notes that the Reliability Standards resulting from Projects 2015-09 and 2019-06 have been approved by the NERC Board of Trustees and should therefore not be identified as projects to coordinate with. ERCOT suggests removal of the references to these projects.

ERCOT suggests the drafting team consider whether the data specification required by IRO-010 and TOP-003 should also include data necessary for outage coordination (IRO-017).  In addition, ERCOT suggests the standard drafting team be mindful that compliance obligations should not interfere with entities providing telemetry that enhances real time monitoring capabilities (e.g. PMU, adding additional SCADA measurements), given more challenging technologies are being integrated on the electric system, even if a requesting entity has State Estimation capabilities (every 1 to 5 min).   

Brandon Gleason, On Behalf of: Brandon Gleason, , Segments 2

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Bobbi Welch, On Behalf of: Midcontinent ISO, Inc., , Segments 2

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Other Answers

Amber Parker, On Behalf of: Unisource - Tucson Electric Power Co., WECC, Segments NA - Not Applicable

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No additional comments.

Lenise Kimes, On Behalf of: City and County of San Francisco - WECC - Segments 1

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No additional comments at this time.

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

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AZPS does not have any additional comments for the drafting team to consider currently.

Marcus Bortman, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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N/A.

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

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While not explicitly within the scope of this SAR, AEP believes there are reliability benefits in pursuing a data sharing network. This will benefit all entities, including smaller entities, in performing real time assessments as the grid continues to evolve and mature. In addition, having such a data sharing network would also significantly reduce the administrative burden associated with the sharing and obtaining of data.

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5, 6

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

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

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1)      RF does not agree with language, “As written the standards create a zero-defect expectation for each Registered Entity receiving a data specification to demonstrate perfect performance on every item in the data specification for an entire audit period. Additionally, it is not clear what should be included in a data specification.”  RF believes the SDT did not want to prescribe a data specification and wisely left it up to the RC, BA and TOP to decide on what information was needed to perform the various operational assessments. 

2)      RF believes that if an entity that has an issue with the data specification or it is not clear to them should work with that respective entity to fully understand their obligation(s). 

{3)      RF believes it is not a burden for an entity to show compliance as they can provide logs or show the compliance monitoring team through a walkthrough or have an attestation from the RC, BA or TOP stating they have received everything they requested.

Anthony Jablonski, On Behalf of: Anthony Jablonski - - Segments 10

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

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N/A

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

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

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Minnesota Power supports the purpose of this project, especially the secondary purpose of consolidating data requirements from other standards into these two. Minnesota Power also agrees with the NSRF comment regarding establishing a common method for the collection and distribution of data specifications

Jamie Monette, On Behalf of: Allete - Minnesota Power, Inc., , Segments 1

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The NSRF recommends that the SAR drafting team expand the scope to capture the following data specification issues (if not already in the proposed scope). 

1.  The NSRF (and all Entities) know that some data requests are predicated on electronic data (ICCP) submittals that may be required to be sent every couple seconds.  This can lead to an auditing nightmare to prove continuous compliance for the Entity and the Auditor.  TOP-001-5, R9 gives a 30 minute or more window for the BA and TOP to inform the RC when telemetering has been affected between Entities.  This does not remove the burden of proving all ICCP scans were delivered and received by two Entities.

2.  There should be a common way to request and provide data specifications.  An Entity providing data has no way of knowing who to send the data to at the receiving Entity.  And will not have proof that the data was submitted as prescribed by the Standard.  The NSRF does not know if this belongs in a Standard or a Data Submittal Guideline, which would be for the Standard Drafting Team to investigate.  One way this could be alleviated is for all data specifications to be sent to the Primary Compliance Contact, Alternate Compliance Contact or Authorizing Officer.

MRO NSRF, Segment(s) 2, 4, 1, 6, 3, 5, 7/1/2021

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

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None

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

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IRO-010-2 is inactive, Version -3 is the active version.  The SAR names version -2 as the one to be modified.

TOP-003-3 is inactive, Version -4 is the active version.   The SAR names version -3 as the one to be modified.

Southern Company, Segment(s) 1, 3, 6, 5, 3/30/2021

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Jamie Johnson, On Behalf of: Jamie Johnson, , Segments 2

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

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Standards Review Committee (SRC), Segment(s) 2, 8/6/2021

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

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APPA, LPPC and TAPS strongly support the proposed “top-down” approach to clarify the tasks in the standards.  Public Power believes the current IRO-010 and TOP-003 standards provide a one-stop source for entities to get the data they need for Operational Planning Analysis, Real-time Assessments, Real-time Monitoring, and Balancing Authority Analysis—the BES reliability-related tasks that drive IRO-010 and TOP-003 data specifications.

The approach has been supported by NERC. As NERC said in its petition for approval for 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).”  Much more recently, NERC stated in its April 6, 2020 comments on FERC’s NOPR regarding the Phase 1 SER retirements (RM19-16 and RM19-17, at 9 (emphasis added)):  Reliability Standards MOD-032-1, IRO-010-2, and TOP-003-3 provide the entities responsible for the reliable modeling, planning, and operation of the BPS with the authority to obtain the information they need from Generator Owners and Transmission Owners to complete their reliability tasks, which may include next most limiting equipment information.  Now that these broader data specification standards are in place, NERC has identified no reliability need to maintain additional requirements expressly requiring the provision of this data in the FAC-008 standard. APPA, LPPC and TAPS agree with NERC that the standards it cites give RCs, TOPs, and BAs the authority to get the information they need to carry out their reliability tasks.  That is equally the case whether the information at issue is identification of next most limiting equipment, weather-related operational constraints, or real-time operating data. The associations are concerned that much of the history behind the data specification concept is being forgotten; and as a result, drafting teams are reverting to specifying the information that must be provided on a continent-wide basis.  This overly-prescriptive approach would result in reliability standards being revised constantly to chase moving targets with every new technology or risk that emerges. These standards can be precise with respect to the information to be requested, or they can be accurate; they cannot be both, and accuracy has to be the priority. The data specification should be flexible enough to evolve with risks and technologies, as well as being flexible enough to apply in the varying operational environments across the continent. Consequently, the associations believe that clarification of the scope of the four BES reliability-related tasks identified in the SAR would allow the data specification to simply reflect what each RC, BA or TOP needs to perform those tasks based on its particular operational environment, and that doing so should alleviate the concerns behind recent attempts to add a detrimental amount of specificity to the standards.  Based on confusion among stakeholders, it appears that clarification of acceptable types of data (i.e., whatever the requesting entity needs) and formats/methods of transfer (i.e., anything—SCADA/ICCP, telephone, email, etc.—so long as it is mutually agreeable) is also necessary.

Jack Cashin, On Behalf of: Jack Cashin, , Segments 4

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Please consider updating the SAR with the current standard version numbers.

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

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

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

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Thank you for the opportunity to provide comments.

ACES Standard Collaborations, Segment(s) 1, 5, 3, 4, 8/6/2021

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

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Matthew Harward, On Behalf of: Southwest Power Pool, Inc. (RTO), MRO, WECC, Segments 2

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

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OPG concurs with NPCC's RSC comments.

David Kwan, On Behalf of: Ontario Power Generation Inc. - NPCC - Segments 5

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