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

2021-07 Extreme Cold Weather Grid Operations, Preparedness, and Coordination | SAR

Description:

Start Date: 11/22/2021
End Date: 12/21/2021

Associated Ballots:

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

Filter:

Hot Answers

EOP-011-2 (effective 4/1/2023) includes a new Requirement R7 that is applicable to the Generator Owner.  R7, part 7.1 states that a Generator Owner’s cold weather preparedness plan(s) shall include “Generating unit(s) freeze protection measures based on geographical location and plant configuration”.  R7, part 7.2 states that a Generator Owner’s cold weather preparedness plan(s) shall include “Annual inspection and maintenance of generating unit(s) freeze protection measures”.  If these sub-parts of R7 do not sufficiently address this FERC/NERC Joint Inquiry report recommendation, EOP-011-2 could be revised to address it.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Tim Kelley, On Behalf of: Sacramento Municipal Utility District - WECC - Segments 1, 3, 4, 5, 6

- 0 - 0

Other Answers

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

- 0 - 0

New Requirements in EOP-011-2 R7 requires that each Generator Owner shall implement and maintain one or more cold weather preparedness plan(s) for its generating units. The requirement is at unit level. Adding component listing for cold-weather components is not necessary.

DTE Energy - DTE Electric, Segment(s) 3, 5, 4, 12/8/2021

- 0 - 0

It is our suggestion that this Requirement be added to Reliability Standard EOP-011 (Emergency Preparedness and Operations) since this Standard (most recent draft) already includes R7, requiring the Generator Owners to implement and maintain cold weather preparedness plans for its generating units.  As part of this Plan, these components/systems could be identified.

Susan Sosbe, On Behalf of: Wabash Valley Power Association, , Segments 1, 3

- 0 - 0

Patti Metro, On Behalf of: National Rural Electric Cooperative Association, , Segments 3, 4

- 0 - 0

None – suggest a new NERC GO/GOP Standard to implement recommendations.  It is also suggested that recently modified TOP-003-5, EOP-011-2 and IRO-010-4 standards not be modified further and consideration be given for moving Cold Weather Requirements in these Standards to the new Standard.

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

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

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

- 0 - 0

The MRO NERC Standards Review Forum (NSRF) believes this recommendation would best be addressed in a Facilities Design, Connections and Maintenance (FAC) standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR).

If this proposal is adopted, MRO NSRF recommends the Standard Drafting Team (SDT) begin work using the corresponding language currently in EOP-011-2, Requirements R7 and R8 and then retire R7 and R8 from EOP-011-2.

In addition, MRO NSRF recommends a change to the scope of the SAR to recognize there may be components that Generator Owners will be unable to protect, such that these cold-weather-critical components could render the unit unavailable. Likewise, this unavailability should be reflected in the generating capacity that can be relied (see our response to question 1e below).

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

- 1 - 0

No Comment.

Michael Krum, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Reclamation identifies that cold weather maintenance does not fit well into any existing reliability standards. Annual maintenance for generator types and geographic areas that have never had a problem with cold weather represent an added regulatory burden for a problem that these generators and geographic areas do not have. Given the performance history of facilities in northern, colder climates, annual maintenance and inspection requirements would be excessive. Reclamation recommends Generator Owners follow guidance derived from manufacturer specifications and entity evaluations of policies, procedures, and maintenance.

Many types of generation equipment are already housed indoors or otherwise have no realistic chance of freezing because these conditions were considered during the design/build phase or, in the case of hydro, the units are not affected by cold weather in any way that can be controlled. For example, efforts to prevent a river from freezing, such as with the use of chemical additives or by any device that would generate enough heat over a large enough area to thaw a freezing river, would be prohibited by environmental regulations. Small hydro facilities may have difficulties with ice buildup on screens intended to prevent large debris from entering the turbines; however, there is no equipment that can be added or removed. Instead, these small facilities already have measures in place to remove ice buildup.

Any new standard must either include exemptions for facilities that are already freeze-resistant, accept working practices already in place that correct ice-related problems, or base its applicability on the historical temperature records of the applicable facilities.

Reclamation recommends a new standard be created in the FAC family to identify “cold weather critical components” and to describe the required maintenance and minimum required maintenance frequency for each component. The new standard should provide an exemption for entities with no cold weather vulnerabilities. Reclamation recommends the format of this new standard be similar to PRC-005-6 or FAC-501-WECC-3 and offers the following example:

Example:

FAC-006-1 – Maintenance for Cold Weather Critical Components.

R1. Each Generator Owner shall establish a maintenance program for its cold weather critical components.

R1.1. The maintenance program shall identify cold-weather-critical components and systems based on:

1.      Historical cold weather experiences of outages, failure to start, deratings, or supply chain impacts.

2.      Minimum ambient temperature and weather conditions from NOAA hourly historical database for minimum occurrence.

3.      Critical fuel supplies, essential systems for energy production, critical supply chain products, or other products critical to maintain energy production.

R1.2. The maintenance program shall identify controls to minimize inherent risks and address:

1.      The maintenance to be performed.

2.      The periodicity to perform the maintenance.

3.      Spare parts, backup systems, or redundant systems.

4.      Procedure to implement preparations for extreme weather events prior to the events occurring.

R2. Each Generator Owner shall follow its maintenance program for cold weather critical components.

R3. Each Generator Owner shall design new generating units to operate to the ambient temperature and weather conditions specified in its cold weather maintenance program.

R4. Each Generator Owner that experiences an outage, failure to start, or derate due to cold weather shall review the generating unit’s outage, failure to start, or derate and develop a corrective action plan for the identified equipment.

R4.1. In cases where the outage cannot be avoided and corrective action would not prevent a similar future outage (e.g., canal freezing), notify the TOP and BA of the potential loss of generation.

R5. Each Generator Owner that develops a corrective action plan pursuant to FAC-006-1 R4 shall implement its corrective action plan.

R6. Each Generator Owner that develops a corrective action plan pursuant to FAC-006-1 R4 shall evaluate whether the plan applies to similar equipment for its other generating units.

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

- 1 - 0

EOP and FAC standards.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

EOP-011-2, Requirement R7 as part of Cold Weather plan

Kenisha Webber, On Behalf of: Entergy - Entergy Services, Inc., SERC, Segments NA - Not Applicable

- 0 - 0

Acciona Energy believes this recommendation would be best addressed in Facilities Design, Connections and Maintenance (FAC) suite of NERC Standards.  Perhaps, the most appropriate place for this recommendation would be NERC Reliability Standard FAC-008 – Facility Ratings (NERC FAC-008).  NERC FAC-008 already includes the majority, if not all equipment, cold-weather-critical components and systems that would be affected by extreme cold weather, which the loss of would ultimately affect the Facility Rating.

Acciona Energy recommends that the Standards Drafting Team adopt and then retire the applicable language from NERC Reliability Standard EOP-011-2 Emergency Preparedness and Operations, Requirement R7 and R8.

George Brown, On Behalf of: Acciona Energy North America, , Segments 5

- 1 - 0

Xcel Energy supports the comments submitted by EEI.

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

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

WECC Cold Weather SAR, Segment(s) 10, 12/17/2021

- 1 - 0

Recommend revising EOP-011 and IRO-010 and create a new defined term(s)

  • Add new requirement to EOP-011:
    • Each Generator Owner shall identify and protect cold-weather-critical components and systems for each generating unit.
  • Create new defined term: Cold-weather-critical components and systems are those which are susceptible to freezing or otherwise failing due to cold weather and which could cause the generating unit to trip, derate, or fail to start.
  • Revise IRO-010, R1.3 as shown below (revisions in red):
    • 1.3 Provisions for notification of BES generating unit(s) operating limitations during local forecasted cold and extreme weather conditions to include:
      • 1.3.x Cold-weather-critical components and systems 

Keith Jonassen, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

- 0 - 0

Dominion Energy suppports the comments submitted by EEI.

Dominion, Segment(s) 3, 5, 1, 9/19/2019

- 0 - 0

No comments

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

- 0 - 0

Michael DePalma, On Behalf of: Onward Energy, MRO, WECC, Texas RE, NPCC, Segments NA - Not Applicable

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 12/20/2021

- 0 - 0

Eversource Group, Segment(s) 1, 3, 9/1/2021

- 0 - 0

FirstEnergy supports comments posted by EEI

 

 

FE Voter, Segment(s) 1, 3, 5, 6, 4, 12/20/2021

- 0 - 0

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

- 0 - 0

NRG Energy Inc. believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

Patricia Lynch, On Behalf of: NRG - NRG Energy, Inc., , Segments 5, 6

- 0 - 0

Texas RE recommends adding this Key Recommendation to EOP-011, since EOP-011-2 Requirement R7 includes implementing and maintaining cold weather preparedness plans.  This recommendation would add additional parts of what is needed in the plan.

 

Alternatively, a new Emergency Preparedness and Operations standard could be created to include the following Key Recommendations from the FERC-NERC-Regional Entity Staff Report: The February 2021 Cold Weather Outages in Texas and South Central United States (Joint Inquiry): 1a, 1c,1d, 1e, and 1f.  Language from future enforceable EOP-011-2 Requirements R7 and R8 could also be included in this new Emergency Preparedness and Operations standard.

 

Texas RE notes that in order to fully implement the Joint Inquiry recommendations, the SDT should consider the impact of extreme weather preparation requirements on the full suite of NERC Reliability Standards.  Based on this principle, Texas RE also recommends the SDT consider the following additional changes:

  • Revising TOP-003 and IRO-010, as in Project 2019-06, to include provisions for notifying the TOP and RC of data necessary to perform the Operational Planning Analyses, Real-time monitoring, and Real-time Assessments;
  • Consider revising the EOP-004 attachment 1 to include a new event type of Critical loss due to cold weather;
  • Consider revising Table 1 in TPL-001 to include cold weather;
  • Consider whether cold weather should be included in the RC’s SOL Methodology in accordance with proposed Reliability Standard FAC-011-4;
  • Consider adding weather as a “steady-state” to Attachment 1 of MOD-032;
  • Consider whether identifying critical elements should be included as part of CIP-002 for identifying high, medium, and low impact BES Cyber Systems; and
  • Consider adding the term “critical elements” to the NERC Glossary as defined in the FERC Report in its execution of recommendations 1a-1g in order to provide consistency and clarity.

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

- 0 - 0

Reliability Standard EOP-011-2

Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

- 0 - 0

PG&E has participated in the preparation and supports the comments provided by the Edison Electric Institute (EEI) for Q1a.

PG&E All Segments, Segment(s) 1, 3, 5, 2/10/2020

- 0 - 0

This recommendation aligns with Requirements R7 and R8 of EOP-011-2. 

BC Hydro recommends that a new EOP Standard(s) focusing on cold weather preparedness be developed to address this recommendation and the Requirements R7 and R8 be moved from EOP-011-2 to the new Standard in the EOP family.

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

- 0 - 0

Tacoma Power does not support adding facility design, analysis or maintenance requirements to EOP Standards. This recommendation should be incorporated into FAC-008 R2.2. FAC-008 R2.2.3 currently captures evaluating Equipment Ratings for ambient conditions and could be expanded to include extreme cold weather events. An example of how this could be addressed in FAC-008 R2.2:

R2.2. The underlying assumptions, design criteria, and methods used to determine the Equipment Ratings identified in Requirement R2, Part 2.1 including identification of how each of the following were considered:

R2.2.1. Equipment Rating standard(s) used in development of this methodology.

R2.2.2. Ratings provided by equipment manufacturers or obtained from equipment manufacturer specifications.

R2.2.3. Ambient conditions (for particular or average conditions or as they vary in real-time).

R2.2.4. Operating limitations.

R2.2.5 Protection against extreme cold weather events

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

- 0 - 0

The FERC, NERC and Regional Entity Staff Report on recent cold weather outages includes numerous recommendations for ensuring the reliability of the Bulk Electric System through potential revisions to NERC Reliability Standards and by other means. Southern Company looks forward to engaging these topics within NERC’s stakeholder process. In this regard, we would like to express our general support of EEI’s comments in response to the proposed Standards Authorization Request for Project 2021-07, Extreme Cold Weather Grid Operations, Preparedness, and Coordination. Southern Company offers the following remarks for consideration by the project’s Standard Authorization Request Drafting Team once established.

Southern Company believes the best location for all cold weather-related standards and requirements would be in a new standard dedicated solely to cold weather requirements.  The existing related requirements of reliability standards EOP-011-2 (R7 & R8), TOP-003-5 (R1.3 & R2.3), and IRO-010-4 (R1.3) can be included in the new standard at a future revision date.  This would ensure all requirements remain in effect continuously.

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

- 0 - 0

EOP-011

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

- 0 - 0

MPC supports comments submitted by the MRO NERC Standards Review Forum (NSRF).

Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1, 5

- 0 - 0

TAPS does not take a position regarding which standard is the appropriate home for the proposed new GO/GOP requirements, but we urge the SDT to consolidate the proposed GO/GOP requirements in a single standard to the extent possible, for ease of reference.

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

- 1 - 0

Santee Cooper, Segment(s) 1, 3, 5, 6, 12/21/2021

- 0 - 0

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

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

- 0 - 0

We recommend this be added to EOP-011.

Donna Wood, On Behalf of: Tri-State G and T Association, Inc., , Segments 1, 3, 5

- 0 - 0

GENERAL COMMENTS: EEI appreciates the efforts by FERC, NERC, and Regional Entity Staff in the development of the February 2021 Cold Weather Outages in Texas and the South-Central US report dated November 2021.  EEI member companies share the desire to better address and respond to extreme cold weather.  The manner and process required to achieve these goals is complex, requiring multiple tools if this effort is to be fully effective.  In our comments to the SAR, we have focused on what can be addressed through NERC Reliability Standards.  We also offer the following observations that should be addressed to avoid unintended and possibly harmful consequences to grid reliability.

  • Generating resources are designed for operation within certain design specifications to meet and achieve certain defined grid applications.  For example, generating resources designed to provide peak output during hot weather conditions will likely be limited when operating during extreme cold weather conditions.  It is also likely that modifications to these resources to meet extreme cold weather conditions may create the need to derate the resource during hot weather conditions, creating different reliability issues. In short, whether a generating resource was designed for optimal use during hot or cold conditions has a bearing on whether additional reliability requirements might be beneficial or detrimental to the resource’s overall performance.
  • This SAR also proposes to require Generator Owners (GOs) to make modifications to their resources that would result in potentially extending their operating specification beyond their original design.  This type of change also needs careful consideration vis-à-vis a NERC Reliability Standard and could impose requirements that are impractical and may go beyond what is allowed by law under the Federal Power Act. 
  • Responsible entities support protecting critical natural gas facilities from inadvertent load shedding.  However, the information needed to identify whether a gas facility is critical understandably resides with the gas facility owners and not with the entities NERC regulates, thus modifications to NERC Reliability Standards for this purpose could be ineffectual if the gas facility owners do not provide this information. 

EEI COMMENT to Question 1a:

While EOP-011-2 could be modified to include the expanded emergency preparedness recommendations contained in this recommendation, the consolidation of the GO/GOP specific extreme cold weather requirements into a single new Reliability Standard, including those developed under NERC Project 2019-06, would provide considerable efficiencies for industry and this project.  

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

- 1 - 0

MidAmerican Energy Company supports EEI and MRO NSRF comments

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

The NAGF believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

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

- 0 - 0

FMPA  supports TAPS (Transmission Access Policy Study Group) comments

LaKenya VanNorman, On Behalf of: Florida Municipal Power Agency - SERC - Segments 3, 4, 5, 6

- 0 - 0

Dana Showalter, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

- 0 - 0

Joe McClung, On Behalf of: JEA, , Segments 1, 3, 5

- 0 - 0

The American Clean Power Association (ACP), the national trade association uniting developers/owners/operators of utility scale wind, solar, storage, and transmission facilities along with allied manufacturers, construction firms, service providers, legal/financial/consulting firms and others, recommends that the most appropriate NERC Standard to address the recommendation to identify and protect cold-weather critical components would be in the Facilities Design, Connections, and Maintenance (FAC) suite. Critical components can be best addressed in this type of standard with a static design number approach.

ACP is also concerned about the use of the term ‘protect’ in this recommendation.  Some of the examples provided (footnote 261) in the Joint Inquiry report for cold-weather-critical components cannot be “protected” against certain cold weather ambient conditions.  Therefore, ACP suggests a language change to the SAR from “protect” to “protect or if unable to protect, if near-term conditions are predicted to be met that would render this cold-weather-critical component unavailable, such unavailability of this cold-weather-critical component shall be reflected in the generating capacity that can be relied on.”  Exceptions should be made for components that are not able to be protected.

Michele Mihelic, On Behalf of: American Clean Power Association, NA - Not Applicable, Segments NA - Not Applicable

- 2 - 0

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

- 0 - 0

Diana Torres, On Behalf of: Imperial Irrigation District, , Segments 1, 3, 5, 6

- 0 - 0

Minnesota Power agrees with MRO’s NERC Standards Review Forum (NSRF) comments.

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

- 0 - 0

BPA supports the comments made by the US Bureau of Reclamation.

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

- 0 - 0

As Generator Owners identify and develop a plan to protect cold-weather-critical components and systems, we recommend they estimate the cost of any proposed protection (or of several protection options). NERC and FERC should understand the cost of protections before the protection activities become mandatory.

Travis Fisher, On Behalf of: Electricity Consumers Resource Council (ELCON), , Segments 7

- 0 - 0

The ISO/RTO Council (IRC) Standards Review Committee (SRC) believes this recommendation would best be addressed in a Facilities Design, Connections and Maintenance (FAC) standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR).

If this proposal is adopted, IRC SRC recommends the Standard Drafting Team (SDT) begin work using the corresponding language currently in EOP-011-2, Requirements R7 and R8 and then retire R7 and R8 from EOP-011-2.

In addition, IRC SRC recommends a change to the scope of the SAR to recognize there may be components that Generator Owners will be unable to protect, such that these cold-weather-critical components could render the unit unavailable. This unavailability should be reflected in the generating capacity provided to the BA as that can be relied upon (see our response to question 1e below).

 

 

ISO/RTO Standards Review Committee, Segment(s) 2, 12/21/2021

- 0 - 0

Enel North America, Inc. believes that the recommendation to identify and protect cold-weather-critical components is best addressed in the FAC-008 (Facilities Ratings) standard.  Enel North America, Inc. believes that the scope of NERC FAC-008 – Facility Ratings (NERC FAC-008) addresses equipment limitations for both normal and emergency operation in winter and summer, and this is suitable to address cold-weather-critical components and systems that would be affected by extreme cold weather.  

The protection of these critical components can be included in EOP-011 or are implied with the limitations listed in FAC-008.   Alternatively, this can be addressed in the Facilities Design and Maintenance suite of standards. However, the most important thing for Enel North America, Inc. is that these requirements are not dispersed across a few different standards.   This may therefore necessitate a separate standard within the Facilities Design and Maintenance suite.  Regarding the recommendation to protect cold-weather-critical components, Enel North America, Inc. agrees with MRO that the scope of the SAR must recognize that there may be some components that are unable to be protected in all scenarios. 

Critical components can be best addressed in this type of standard that involves static design numbers.

Natalie Johnson, On Behalf of: Enel Green Power, , Segments 5

- 0 - 0

Exelon concurs with the comments submitted by the EEI for this question. Additionally, should this drafting team decide to create new standard(s) specific to extreme cold weather, the SAR should allow the drafting team to move the FERC-approved requirements created by Project 2019-06 Cold Weather into the new comprehensive standard(s).    

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

- 0 - 0

AZPS agrees with the comments provided by EEI; EOP-011-2 could be modified to include this recommendation or may be added as a stand alone standard. 

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

- 0 - 0

Hot Answers

EOP-011-2 (effective 4/1/2023) includes a new Requirement R7 that is applicable to the Generator Owner.  R7 requires Generator Owners to “implement and maintain one or more cold weather preparedness plan(s) for its generating units”, and lists the topics that must be addressed in the plan(s) at a minimum.  This FERC/NERC Joint Inquiry report recommendation could possibly be addressed by revising EOP-011-2 to add another Generator Owner requirement.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Tim Kelley, On Behalf of: Sacramento Municipal Utility District - WECC - Segments 1, 3, 4, 5, 6

- 0 - 0

Other Answers

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

- 0 - 0

FAC-008 Facility Ratings. R2. 2.2.3.

2.2.2. Ratings provided by equipment manufacturers or obtained from equipment manufacturer specifications.

2.2.3. Ambient conditions (for particular or average conditions or as they vary in real-time). 2.2.4. Operating limitations.

Update to specify extreme cold weather conditions.

However, a single standard combining all the cold weather requirements that can evolve over time is preferable.

DTE Energy - DTE Electric, Segment(s) 3, 5, 4, 12/8/2021

- 0 - 0

EOP-011, same as above.

Susan Sosbe, On Behalf of: Wabash Valley Power Association, , Segments 1, 3

- 0 - 0

Patti Metro, On Behalf of: National Rural Electric Cooperative Association, , Segments 3, 4

- 0 - 0

None – suggest a new NERC GO/GOP Standard to implement recommendation.  It is also suggested that recently modified TOP-003-5, EOP-011-2 and IRO-010-4 standards not be modified further and consideration be given for moving Cold Weather Requirements in these Standards to the new Standard.

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

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

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

- 0 - 0

MRO NSRF does not believe this recommendation, as written, falls within the scope of what NERC Reliability Standard(s) are authorized to address.

As this recommendation may require Generator Owners to make a significant capital investment, resulting in increased cost to end use ratepayers, the MRO NSRF believes that Section 1201 of the Federal Powers Act (page 349) Section 215, part (3) applies, which in part states, “…the term does not include to enlarge such facilities or to construct new transmission capacity or generation capacity.” MRO NSRF is also concerned that state regulators may not approve the cost associated with “design and retro fit.”

If this recommendation was to be contained in a Reliability Standard, it would mandate that all current and new generation capacity would need to meet some unknown, specific ambient temperature.  If the specific ambient temperature is dependant on the GO to determine, this will not meet the recommendation’s intent.  This would prevent entities to build needed capacity for the vast amount other seasonal times, when capacity is needed, notwithstanding during extreme (specified) ambient temperatures. As this recommendation requires investment, this recommendation may be more appropriately addressed as part of the FERC tariff as part of Generator Interconnection Agreements (GIA).

Alternatively, this may be inherently covered by the recommendation in 1d (below), where CAPs are used to address generating unit’s outage, failure to start, or derates due to freezing.  The intent is for generators to perform during freezing (extreme cold) temperatures.  It should not matter how Generator Owners achieve this, such as in recommendation d.

If this item remains to be within a Reliability Standard, it is recommended that the GO determine what the specific ambient temperature is for BES generators.

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

- 1 - 0

No Comment.

Michael Krum, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Reclamation does not support a requirement to retrofit existing generator units to meet existing potential extreme weather conditions. This may not be cost effective and may create unfair market advantages if implemented. Reclamation acknowledges that when a Generator Owner builds a new generating plant, those units should be designed with the applicable potential extreme weather conditions in mind.

If this recommendation goes forward, Reclamation recommends that prescriptive cold weather design considerations apply only to new generation facilities. Refer to VAR-501-WECC-3.1 Requirement R5 for an example of an acceptable method to implement this recommendation.

Reclamation recommends a requirement for Generator Owners to design new generating units to operate to a specified ambient temperature and weather conditions be contained in the same new standard in the FAC family as that created to identify cold weather critical components and their required maintenance. Please see the example provided in the response to Question 1.a.

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

- 1 - 0

FAC-008-5, and possibly other FAC standards.  Modify or create new.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

EOP-011-2, Requirement R7 as part of Cold Weather plan

Kenisha Webber, On Behalf of: Entergy - Entergy Services, Inc., SERC, Segments NA - Not Applicable

- 0 - 0

Acciona Energy does not believe this recommendation, as written, can or should be addressed in a NERC Reliability Standard(s) at this time.  Specific information, data and details needs to be studied and provided to allow industry to either make proposals on appropriate areas to address this recommendation or develop requirements that meet reliability principles, market principles and are results-based for this recommendation.

George Brown, On Behalf of: Acciona Energy North America, , Segments 5

- 0 - 0

Xcel Energy supports the comments submitted by EEI.

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

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

WECC Cold Weather SAR, Segment(s) 10, 12/17/2021

- 1 - 0

Recommend revising EOP-011 and create a new defined term

  • Add new requirement to EOP-011:
    • Each Generator Owner shall design new or ensure existing generating units operate to a specified ambient temperature and weather conditions which should be based on available extreme temperature and weather data for the generating unit’s location and should account for the effects of precipitation and cooling effect of wind.
  • Create new defined term: Extreme Weather is temperatures at or exceeding the lowest (or highest) recorded temperature at the generator’s physical location (or nearest location where temperature was recorded for which data exists) for a sustained period greater than or equal to one day.

Keith Jonassen, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

- 0 - 0

Dominion Energy supports the comments submitted by EEI and is firmly ofthe opinion that equipment design specificaions are not appropriate for a results based reliability standard and are not support by both the Federal Power Act and FERC Order 672, paragraph 260.

Dominion, Segment(s) 3, 5, 1, 9/19/2019

- 0 - 0

No comments

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

- 0 - 0

There is a question on how “ specified ambient temperature and weather conditions” is determined?  Sites are designed to specific weather conditions already.  For Generator Owners to design new or retrofit existing generating units to operate in anything other than what they were originally designed could cost millions of dollars per site.  This would make more sense for a revised Standard to read “Sites' freeze protection shall be kept functional with original design criteria for winter operations”.

Michael DePalma, On Behalf of: Onward Energy, MRO, WECC, Texas RE, NPCC, Segments NA - Not Applicable

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 12/20/2021

- 0 - 0

Eversource Group, Segment(s) 1, 3, 9/1/2021

- 0 - 0

FirstEnergy supports comments posted by EEI

FE Voter, Segment(s) 1, 3, 5, 6, 4, 12/20/2021

- 0 - 0

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

- 0 - 0

NRG Energy Inc.  believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

Patricia Lynch, On Behalf of: NRG - NRG Energy, Inc., , Segments 5, 6

- 0 - 0

Texas RE suggests this Key Recommendation could work in EOP-011, as EOP-011-2 Requirement Part 7.3.2 already indicates generating units’ cold weather data should include a minimum design temperature.  Requirement R7 could be revised to be more specific as recommended in the Key Recommendations from the FERC Report.

 

Alternatively, a new Emergency Preparedness and Operations standard could be created to include the following Key Recommendations from the Joint Inquiry: 1a, 1c,1d, 1e, and 1f.  Language from future enforceable EOP-011-2 Requirements R7 and R8 could also be included in this new Emergency Preparedness and Operations standard.

 

Additionally, Texas RE recommends the drafting team consider defining thresholds for ambient temperature and weather conditions, specifically for temperature, precipitation, and wind conditions.  Texas RE further recommends that when that threshold of ambient temperature and weather conditions for extreme weather, specifically including precipitation and wind, are forecasted, GOPs with unstaffed units should have the unit staffed 24/7 until the freezing temperatures and precipitation end. This would ensure that the BA and TOP are notified of actual site conditions that could affect unit capacity prior to any actual derate, which would allow BA emergency operations to commence quicker. 

Texas RE also recommends the following:

  • Revising TOP-003 and IRO-010, as in Project 2019-06, to include provisions for notifying the TOP and RC of data necessary to perform the Operational Planning Analyses, Real-time monitoring, and Real-time Assessments;
  • Consider revising the EOP-004 attachment 1 to include a new event type of Critical loss due to cold weather;
  • Consider revising Table 1 in TPL-001 to include cold weather;
  • Consider whether cold weather should be included in the RC’s SOL Methodology in accordance with proposed Reliability Standard FAC-011-4;
  • Consider adding weather as a “steady-state” to Attachment 1 of MOD-032;
  • Consider whether identifying critical elements should be included as part of CIP-002 for identifying high, medium, and low impact BES Cyber Systems; and
  • Consider adding the term “critical elements” to the NERC Glossary as defined in the FERC Report in its execution of recommendations 1a-1g in order to provide consistency and clarity.

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

- 0 - 0

Reliability Standard EOP-011-2

Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

- 0 - 0

PG&E has participated in the preparation and supports the comments provided by the Edison Electric Institute (EEI) for Q1b. 

PG&E is also providing the additional input related to Q1b - PG&E is fully committed to the reliable operation of generating resources during cold weather events.  PG&E would like to take this opportunity to reiterate the EEI comment requiring Generator Owners to design new or retrofit existing generating units to operate at a specified ambient temperature and weather conditions.  Obligating generator owners to implement design changes to new resources and to retrofit existing generators should be closely evaluated to ensure that this action complies with the bounds of the Federal Power Act section 215.

PG&E All Segments, Segment(s) 1, 3, 5, 2/10/2020

- 0 - 0

This recommendation aligns with Requirements R7 and R8 of EOP-011-2. 

BC Hydro recommends that a new EOP Standard(s) focusing on cold weather preparedness be developed to address this recommendation and the Requirements R7 and R8 be moved from EOP-011-2 to the new Standard(s).

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

- 0 - 0

Instead of prescribing specific retrofits or upgrades, Tacoma Power recommends performing a three tier risk-based approach: perform a vulnerability assessment to identify risks, develop actions to mitigate these risks, and then implement the actions. This approach would be similar to how the industry addressed GMD events in Project 2013-03.

FAC-008 and MOD-025 currently ensure that the GO and GOP know the capability and availability of their BES resources under diverse ambient conditions. Either of these Standards could be modified to include a tiered risk-based approach that would ensure facilities are rated or designed for extreme cold weather. For example, these Requirements could 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 Generator Operators and Transmission Planner any vulnerabilities identified in RX that could negatively impact applicable generation facility ratings, 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.”

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

- 0 - 0

The appropriate standard for such a requirement should be in a new standard dedicated solely to cold weather requirements as previously mentioned in Southern Company's response to Question 1a.

Southern Company agrees that generating facilities should have the capability to operate at reasonable expected weather conditions for their location and communicate their capability to the Balancing Authority in a timely manner. However, Southern Company is concerned that the requirement for retrofitting "existing generating units to operate to a specified ambient temperature and weather conditions (e.g., wind, freezing precipitation)" has the potential to unduly burden the economics for some existing generating facilities and could cause the retirement of those facilities that would be impacted by the requirement. Additionally, retrofitting some existing generating facilities in excess of their original design criteria could be technically challenging and cost prohibitive.  

 

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

- 0 - 0

EOP-011

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

- 0 - 0

MPC supports comments submitted by the MRO NERC Standards Review Forum (NSRF).

Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1, 5

- 0 - 0

TAPS does not take a position regarding which standard is the appropriate home for the proposed new GO/GOP requirements, but we urge the SDT to consolidate the proposed GO/GOP requirements in a single standard to the extent possible, for ease of reference.

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

- 0 - 0

Santee Cooper, Segment(s) 1, 3, 5, 6, 12/21/2021

- 0 - 0

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

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

- 0 - 0

We do not think this requirement would fit into any existing standards. However, we do not agree that a new standard is appropriate for this recommendation, as it appears to go beyond FERC’s authority and would instead be the GOs business decision. A possible alternative would be to require GOs to consider XX years of historical data when creating the design for a new BES generating plant.

Donna Wood, On Behalf of: Tri-State G and T Association, Inc., , Segments 1, 3, 5

- 0 - 0

EEI members are fully committed to ensuring that they are able to reliably operate during extreme cold weather conditions.  Changes to a NERC Reliability Standards must be done within the bounds of FPA Section 215, and therefore, it is a question of law whether a NERC Reliability Standard can require GOs to retrofit existing generating resources to operate beyond their original plant design specifications.  Additionally, it is a question of law whether the Federal Power Act prohibits the ERO or FERC from compelling the design of new generation.  That said, GOs are already required to identify the known operating capabilities of their resources during cold weather conditions (see EOP-011-2) and provide that information during forecasted cold weather to responsible Reliability Coordinator (see IRO-010-4) and the Transmission Operator and Balancing Authority (see TOP-003-5) so that an adequate level of reliability can be maintained.  

EEI suggests modifying the SAR as follows: 
 
Generator Owners are required to identify and operate their generating units to the capabilities of their resources and provide that information to responsible Reliability Coordinators, Balancing Authorities, and Transmission Operators so that an adequate level of reliability can be maintained. This projected capability shall be based on the facility’s design, past performance under similar weather conditions and accounting for the effects of precipitation and accelerated cooling effect of wind.

Obligating resource owners to make certain modifications to their resources that were not conveyed, anticipated, or agreed to prior to the design, construction, or commissioning of the resource could have unintended consequences that could impact BES reliability.  As an example, wind turbines that were installed without de-icing technology, when originally built, may not be practically retrofitted in all cases.    Relative to traditional synchronous resources built for operation in warmer climates,  these resources are often designed for peak capacity during very hot weather conditions.  To achieve this capability, these resources are often built in a manner that intentionally exposes operating components to provide greater capacity during extreme hot weather conditions.  Obligating those resource owners to enclose those units/components in favor of operating conditions they were not intended to reliably operate could have negative consequences for grid reliability.

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

- 1 - 0

MidAmerican Energy Company supports EEI and MRO NSRF comments

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

The NAGF believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

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

- 0 - 0

FMPA  supports TAPS (Transmission Access Policy Study Group) comments

LaKenya VanNorman, On Behalf of: Florida Municipal Power Agency - SERC - Segments 3, 4, 5, 6

- 0 - 0

Dana Showalter, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

- 0 - 0

Joe McClung, On Behalf of: JEA, , Segments 1, 3, 5

- 0 - 0

ACP echoes comments filed by the Midwest Reliability Organization NERC Standards Review Forum (MRO NSRF) and others raising concerns about this recommendation.  ACP does not believe this recommendation should be pursued at this time and it should be removed from the standard authorization request (SAR).  There is insufficient information and data to inform how to address and effectively implement this recommendation.  And, there are implications beyond NERC reliability standards, including with respect to the ability of states to achieve their clean energy goals and regarding compensation for retrofits, which necessitates engagement with a broader universe of stakeholders than those involved in NERC reliability standards.  As an interim step, ACP recommends that more detailed information, analysis, and data be developed to better define this approach, along with analysis on the feasibility of retrofits, commercial availability of retrofit options, cost, timeline to implement, potential for generator downtime to install, implications on design parameters for existing facilities etc. so at some point in the future, stakeholders can make a more informed decision on whether and how to approach this recommendation.  For example, what are the specific temperatures and weather conditions that need to be considered?  How frequently do they occur?  How consistent is the data quality across regions?  How do they differ by region and by area within a region?  Are there any technologically feasible, proven, and commercially available retrofit options?  If so, what is the availability of materials, staff etc. to carry out the work?  To the extent there are not, what are the barriers?  What would be the generator downtime to retrofit?  Would generators be at risk of retirement if retrofitting is not economic and, if so, what are the impacts to reliability?

In addition, consideration needs to be given to the operating and design parameters of generators.  For example, in some cases and in certain environments a wind turbine that is optimized to operate at extremely high temperatures, may not be able to also be optimized to operate at extremely low temperatures.  In such situations, it makes sense to keep the focus on higher temperatures as the generators provide more reliability value than they might in designing them to respond to infrequent and/or historically low temperatures and icing conditions.   

With respect to new builds, given that each power plant, geographic location, and transmission system is different, ACP recommends that the needed generator attributes can be best addressed through the Interconnection Agreement and Studies Process where all involved parties can take into consideration systems needs and generator capabilities on a case-by-case basis.

To the extent this recommendation remains in the SAR despite ACP and others recommendation to remove it, ACP requests that exceptions, or at a minimum sufficient grandfathering provisions, be provided from the requirement to retrofit in situations in which a retrofit:

1. Is not technically feasible, proven and commercially available.

2. Would require operating equipment outside its design parameters, which raises potential conflicts with warranties, safety, and regulatory requirements.

Michele Mihelic, On Behalf of: American Clean Power Association, NA - Not Applicable, Segments NA - Not Applicable

- 2 - 0

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

- 0 - 0

Diana Torres, On Behalf of: Imperial Irrigation District, , Segments 1, 3, 5, 6

- 0 - 0

Minnesota Power agrees with MRO’s NERC Standards Review Forum (NSRF) comments.

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

- 0 - 0

BPA supports the comments made by the US Bureau of Reclamation.

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

- 0 - 0

Applying mandatory standards to new builds would be less invasive than asking all existing generators to retrofit to specified weather conditions. ELCON suggests a tiered approach in which NERC could develop new designs for generators that can operate to a specified ambient temperature and weather conditions while exploring the feasibility and cost of applying those new operating requirements to existing generators. Disparate treatment of new and existing assets is common in federal regulation. For example, the Environmental Protection Agency treats existing generation units differently from new units under the Clean Air Act, and the National Highway Traffic Safety Administration treats newer model vehicles differently from existing vehicles when considering fuel economy standards. The same approach makes sense here given the enormous challenge of retrofitting the entire existing generation fleet of a large portion of the United States.

Travis Fisher, On Behalf of: Electricity Consumers Resource Council (ELCON), , Segments 7

- 0 - 0

The IRC SRC strongly supports the spirit and intent of this requirement and believes that this aspect must be addressed in order to achieve the reliability improvements necessary to avoid the bad outcomes experienced as a result of Winter Storm Uri.

That said, it is our understanding the industry has concerns with the “design and retrofit” aspects of this recommendation, as written, and that these aspects may fall outside the scope of what NERC Reliability Standard(s) are authorized to address and may be more appropriately addressed at FERC as terms under Generator Interconnection Agreements (GIA).

If that is the case, the IRC SRC asks that NERC do the following:

1. Work with FERC to ensure that action is taken to address this recommendation in the appropriate forum .

2. Determine how NERC Reliability Standard(s) would address the balance of this requirement; i.e. to account for the effects of precipitation and accelerated cooling effect of wind on generator unit operation as these aspects are not currently included in EOP-011-2, Requirements R7 and R8.

ISO/RTO Standards Review Committee, Segment(s) 2, 12/21/2021

- 0 - 0

Enel North America, Inc. does not believe that this recommendation should be addressed within the NERC Reliability Standards. Each plant, geographic location, and transmission system is different and an attempt to try and develop one Reliability Standard for generating unit design is not the most efficient approach to increasing system reliability during extreme temperature and cold weather events. For example, for some wind generators there is not an infinite operable temperature band, meaning that if they are designed to operate at very high temperatures, they may not be able to operate at very, very low temperatures, and vice versa. Depending on the geographic location of the wind generator, the ambient weather conditions on peak load days, and whether it is located on a summer or winter peaking system, the ability to operate in extreme high temperatures may bring more reliability benefit to the system than the ability to operate under very, very low and infrequent temperatures. Further, the accuracy and availability of historic extreme weather data varies drastically across the country and a standard tied to this type of data would result in dramatically different impacts and outcomes even for generators in the same region. 

Should this recommendation remain in the SAR, Enel North America, Inc. is concerned that the current language does not contain sufficient technical details, thus further research (by NERC Technical Committee(s) or other technical groups is necessary) for the industry to properly implement this recommendation across different regions, generation types, and transmission systems.  It is difficult to make an assessment on operating to a certain ambient temperature and weather conditions without sufficient detail on what those temperature and weather thresholds might be.  Additional definition and criteria on how these operating benchmarks will be derived still needs to be provided.  Weather conditions take into account a wide range of circumstances, even within a limited geographic location; therefore, these specifications need to be clearly defined so that the industry has clear guidance.  Enel North America, Inc. recommends, as a possible solution, to use a probability-based approach that takes into consideration the frequency that the lowest or highest recorded temperature occurs. 

In addition, for existing sites, Enel North America, Inc. believes that in some circumstances grandfathering or exception clauses should be considered (including, but not limited to):    

  • Wind turbines that are built with structural steel or major components that are not rated for lower ambient temperatures. Compliance for these types of wind units would require a complete rebuild of the wind generator from scratch. In some cases (as is discussed further below), without guaranteed compensation to cover the retrofit of existing assets, the assets may exit the market altogether. This would have the opposite effect of ensuring robust supply of generation for reliability during extreme events.
  • Updates to wind turbines that would trigger a complete re-study of the Balance of Plant to accommodate different operating temperatures or design limits. The design of a facility is based on certain turbine fundamentals, and any changes could cause misalignment within the facility design.  These types of changes could impact generator performance, real and reactive capabilities, system modelling, and equipment functionality thereby requiring a variety of studies to be redone. 
  • Updates that would void original equipment manufacturer warranties. Due to the fact that the bulk of the existing wind fleet is relatively new, most units are still under warranty, and warranties are an important part of the way units are operated and maintained. 

For the aforementioned reasons, Enel North America, Inc. is concerned with a one-size-fits-all approach and believes that a mechanism to consider special circumstances and exceptions should be further address and clarified.      

Lastly, Enel North America, Inc. reiterates that this recommendation is not appropriate for NERC Reliability Standards due to the potentially significant and unpredictable costs of retrofits and the broader impact this could have both on electricity markets and grid reliability, given that generators potentially would be taken offline for months to re-build wind sites. FERC, States, ISO/RTOs, and other utility regulators are better positioned to evaluate the costs and benefits of retrofits for their regions and customers.  Enel North America, Inc. recommends that regulators be required to provide compensation for Generator Owner investments for any retrofits.  Generator Owners cannot commit to the significant capital investment that is likely to be involved without certainty that Generator Owners will be compensated and a clear mechanism on how this will be achieved.  

Natalie Johnson, On Behalf of: Enel Green Power, , Segments 5

- 0 - 0

Exelon concurs with the comments submitted by the EEI for this question. 

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

- 0 - 0

AZPS agrees with the comments provided by EEI; recommending that the words “design” and “retrofit” be deleted and replaced with “specify”.

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

- 0 - 0

Hot Answers

EOP-011-2 (effective 4/1/2023) includes a new Requirement R8 that is applicable to the Generator Owner (GO) in conjunction with its Generator Operator (GOP).  R8 states that the GO and GOP “shall identify the entity responsible for providing the generating unit-specific training, and that identified entity shall provide the training to its maintenance or operations personnel responsible for implementing cold weather preparedness plan(s) developed pursuant to Requirement R7”.  If R8 does not sufficiently address this FERC/NERC Joint Inquiry report recommendation, EOP-011-2 could be revised to address it.  Alternatively, the PER-006-1 standard addresses Generator Operator training for Protection Systems and Remedial Action Schemes (RAS) and could be revised to address the recommendation.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

PER-006 includes training requirements for the GOP and respective plant personnel. SMUD recommends locating this new training requirement in the PER-006 Standard with appropriate modifications to the applicability section to include both GO and GOP functions. SMUD also supports expanding the scope of this SAR to include moving the GO/GOP training in EOP-011 R8 to PER-006-1, as was put forward by the LPPC and APPA during the Project 2019-06 commenting period.

SMUD is concerned with locating training requirements in a Standard other than the PER suite of standards. Adding training requirements to other non-training standards creates a condition that makes training requirements hard to find and easy to lose; a condition that is not conducive to a quality standard. Locating training requirements outside of PER Standards is also not following industry precedent, such as the Standards Efficiency Review recommendations and the recent Project 2007-06.2 that moved training requirements from PRC Standards to the new PER-006-1 Standard.

Tim Kelley, On Behalf of: Sacramento Municipal Utility District - WECC - Segments 1, 3, 4, 5, 6

- 0 - 0

Other Answers

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

- 0 - 0

PER-006-1 – Specific Training for Personnel

The purpose clearly states this 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

Extreme Cold Weather Grid Operations, Preparedness, and Coordination is a specific topic for reliability.

DTE Energy - DTE Electric, Segment(s) 3, 5, 4, 12/8/2021

- 0 - 0

EOP-011-2 – R8 already calls for the generator specific training.

Susan Sosbe, On Behalf of: Wabash Valley Power Association, , Segments 1, 3

- 0 - 0

Patti Metro, On Behalf of: National Rural Electric Cooperative Association, , Segments 3, 4

- 0 - 0

Suggest modifying PER-006-1 to implement recommendation.  It is also suggested that recently modified EOP-011-2 training requirements be moved to the new NERC GO/GOP Standard.

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

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

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

- 0 - 0

The MRO NERC Standards Review Forum (NSRF) recommends addressing this recommendation as  two (2) requirements to more accurately address the aspects required of each function:

  • Generator Owner maintenance aspects in an FAC standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR).
  • Generator Operator operations aspects in PER-006.
  • If adopted, MRO NSRF recommends the SDT begin work using the corresponding language currently in EOP-011-2, Requirements R7 and R8 and then retire R7 and R8 from EOP-011-2.

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

- 0 - 0

No Comment.

Michael Krum, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Reclamation disagrees with the requirement for annual training on routine physical maintenance. No other annual maintenance activities require annual training before doing the work. For example, switching the direction of the cooling fans on unit transformers, turning on the reservoir bubblers, etc., are not activities that warrant annual training. This type of training content is not appropriate for a NERC requirement.

For geographical areas and generation types that typically experience cold weather, an annual training requirement is excessive. Generator Owners and Generator Operators in these areas should only be required to provide initial training on their cold weather preparedness plan and provide recurring training only when the plan is updated. Reclamation recommends placing a requirement for conducting training on unit-specific cold weather preparedness in PER-006. Reclamation also recommends moving EOP-011-2 Requirement R8 to PER-006. The requirement to conduct the cold weather preparedness plan training annually should be added only for geographical areas that do not typically experience cold weather.

Example:

PER-006-X

R2. Each Generator Owner, in conjunction with its Generator Operator shall provide generating unit-specific training to its maintenance and operations personnel responsible for implementing the Generator Owner’s cold weather preparedness plan(s) developed pursuant to EOP-011-2 Requirement R7.

R2.1 The generating unit-specific training shall be provided initially and when the cold weather preparedness plan is updated.

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

- 0 - 0

Since it is training, a modified or new PER standard.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

EOP-011-2

Kenisha Webber, On Behalf of: Entergy - Entergy Services, Inc., SERC, Segments NA - Not Applicable

- 0 - 0

Acciona Energy believes this recommendation would be best addressed in Facilities Design, Connections and Maintenance (FAC) suite of NERC Standards in a new standard.

Acciona Energy recommends that the Standards Drafting Team adopt and then retire the applicable language from NERC Reliability Standard EOP-011-2 Emergency Preparedness and Operations, Requirement R7 and R8.

George Brown, On Behalf of: Acciona Energy North America, , Segments 5

- 0 - 0

Xcel Energy supports the comments submitted by EEI.

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

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

WECC Cold Weather SAR, Segment(s) 10, 12/17/2021

- 0 - 0

Recommend revising EOP-011

  • Revise EOP-011, R8 (revision in bold):
    • Each Generator Owner in conjunction with its Generator Operator shall identify the entity responsible for providing the generating unit-specific training, and that identified entity shall annually, prior to the start of the winter season, provide the training to its maintenance or operations personnel responsible for implementing cold weather preparedness plan(s) developed pursuant to Requirement R7.

Keith Jonassen, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

- 0 - 0

Dominion Energy suppports the comments submitted by EEI.

Dominion, Segment(s) 3, 5, 1, 9/19/2019

- 0 - 0

No comments

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

- 0 - 0

Michael DePalma, On Behalf of: Onward Energy, MRO, WECC, Texas RE, NPCC, Segments NA - Not Applicable

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 12/20/2021

- 0 - 0

Eversource Group, Segment(s) 1, 3, 9/1/2021

- 0 - 0

FirstEnergy supports comments posted by EEI

FE Voter, Segment(s) 1, 3, 5, 6, 4, 12/20/2021

- 0 - 0

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

- 0 - 0

NRG Energy Inc.  believes that the recommendation should be included as part of a new standard dedicated to Cold Weather or included in the existing PER-006 standard.

Patricia Lynch, On Behalf of: NRG - NRG Energy, Inc., , Segments 5, 6

- 0 - 0

Texas RE suggests that an annual requirement could be added to EOP-011 R8, which requires training of the maintenance or operations personnel for implementing the cold weather preparedness plan.

 

Alternatively, a new Emergency Preparedness and Operations standard could be created to include the following Key Recommendations from the Joint Inquiry: 1a, 1c,1d, 1e, and 1f.  Language from future enforceable EOP-011-2 Requirements R7 and R8 could also be included in this new Emergency Preparedness and Operations standard.

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

- 0 - 0

Reliability Standard EOP-011-2

Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

- 0 - 0

PG&E has participated in the preparation and supports the comments provided by the Edison Electric Institute (EEI) for Q1c.

PG&E All Segments, Segment(s) 1, 3, 5, 2/10/2020

- 0 - 0

This recommendation aligns with Requirements R7 and R8 of EOP-011-2. 

BC Hydro recommends that a new EOP Standard(s) focusing on cold weather preparedness be developed to address this recommendation and the Requirements R7 and R8 be moved from EOP-011-2 to the new Standard(s).

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

- 0 - 0

Tacoma Power recommends that all O&P standard training requirements should be in the Personnel Performance, Training and Qualifications (PER) family of standards. The existing Standard PER-006 includes training requirements for the GOP and respective plant personnel. We recommend locating this new training requirement in the PER-006 Standard with appropriate modifications to the applicability section to include both GO and GOP functions. Similarly, we also support expanding the scope of this SAR to include moving the GO/GOP training in EOP-011 R8 to PER-006-1, as was put forward by the LPPC and APPA during the Project 2019-06 commenting period.

We are concerned with locating training requirements in a Standard other than the PER suite of standards. Adding training requirements to other non-training standards creates a condition that makes training requirements hard to locate. Moreover, the technical compliance personnel and training personnel often don’t overlap, potentilally creating a compliance gap. Locating training requirements outside of PER Standards is also not following identified industry best practices, such as the Standards Efficiency Review recommendations and the recent Project 2007-06.2 that moved training requirements from PRC Standards to the new PER-006-1 Standard.

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

- 1 - 0

Southern Company recommends that this requirement be included at a future revision date in a new cold weather standard as previously mentioned in Southern Company's response to Question 1a. 

However, for initial inclusion, Southern Company recommends that EOP-011-2 R8 be revised to include the “annual unit-specific cold weather preparedness plan training” requirement.  

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

- 0 - 0

EOP-011

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

- 0 - 0

MPC supports comments submitted by the MRO NERC Standards Review Forum (NSRF).

Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1, 5

- 0 - 0

TAPS does not take a position regarding which standard is the appropriate home for the proposed new GO/GOP requirements, but we urge the SDT to consolidate the proposed GO/GOP requirements in a single standard to the extent possible, for ease of reference.

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

- 0 - 0

Santee Cooper, Segment(s) 1, 3, 5, 6, 12/21/2021

- 0 - 0

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

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

- 0 - 0

We believe this is addressed by EOP-011-2 R8, with the exception of an annual periodicity. So, EOP-011-2 could be modified to add that periodicity. We also recommend consideration be given to moving it to PER-006 to keep all training together.

Donna Wood, On Behalf of: Tri-State G and T Association, Inc., , Segments 1, 3, 5

- 0 - 0

EOP-011-2, Requirement R8 could be modified to address this recommendation.  Also, see EEI comments to 1a.

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

- 0 - 0

MidAmerican Energy Company supports EEI and MRO NSRF comments

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

The NAGF believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

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

- 0 - 0

PER-006 includes training requirements for the GOP and respective plant personnel. We recommend locating this new training requirement in the PER-006 Standard with appropriate modifications to the applicability section to include both GO and GOP functions. We also support expanding the scope of this SAR to include moving the GO/GOP training in EOP-011 R8 to PER-006-1, as was put forward by the LPPC and APPA during the Project 2019-06 commenting period.

We are concerned with locating training requirements in a Standard other than the PER suite of standards. Adding training requirements to other non-training standards creates a condition that makes training requirements hard to find and easy to lose; a condition that is not conducive to a quality standard. Locating training requirements outside of PER Standards is also not following industry precedent, such as the Standards Efficiency Review recommendations and the recent Project 2007-06.2 that moved training requirements from PRC Standards to the new PER-006-1 Standard.

LaKenya VanNorman, On Behalf of: Florida Municipal Power Agency - SERC - Segments 3, 4, 5, 6

- 0 - 0

Dana Showalter, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

- 0 - 0

These comments are being submitted on behalf of APPA and LPPC:

Public power believes that all standard training requirements should be in the Personnel Performance, Training and Qualifications (PER) family of standards. The standard PER-006 includes training requirements for the GOP and respective plant personnel. We recommend locating this new training requirement in the PER-006 Standard with appropriate modifications to the applicability section to include both GO and GOP functions. Similarly, we also support expanding the scope of this SAR to include moving the GO/GOP training in EOP-011 R8 to PER-006-1, as was put forward by the LPPC and APPA during the Project 2019-06 commenting period.

We are concerned with locating training requirements in a Standard other than the PER suite of standards. Adding training requirements to other non-training standards creates a condition that makes training requirements hard to locate. Moreover, the technical compliance personnel and training personnel often don’t overlap, potentially creating a compliance gap; a condition that is not conducive to appropriate compliance. Locating training requirements outside of PER Standards is also not following identified efficient industry best practices, such as the Standards Efficiency Review recommendations and the recent Project 2007-06.2 that moved training requirements from PRC Standards to the new PER-006-1 Standard.

Joe McClung, On Behalf of: JEA, , Segments 1, 3, 5

- 0 - 0

ACP believes this can be addressed in the Facilities Design, Connections and Maintenance suite of NERC standards.

Alternatively, it could be addressed in the EOP-011 Emergency Preparedness and Operations Standard as part of the requirement to have and maintain Cold Weather Preparedness Plans (R7 for Generators).

Regardless, ACP recommends requirements for cold weather preparedness plans and training should be in the same standard rather than dispersed across multiple standards.  

Michele Mihelic, On Behalf of: American Clean Power Association, NA - Not Applicable, Segments NA - Not Applicable

- 2 - 0

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

- 0 - 0

PER-006 includes training requirements for the GOP and respective plant personnel. Imperial Irrigation District recommends locating this new training requirement in the PER-006 Standard with appropriate modifications to the applicability section to include both GO and GOP functions. Imperial Irrigation District also supports expanding the scope of this SAR to include moving the GO/GOP training in EOP-011 R8 to PER-006-1, as was put forward by the LPPC and APPA during the Project 2019-06 commenting period.

Imperial Irrigation District is concerned with locating training requirements in a Standard other than the PER suite of standards. Adding training requirements to other non-training standards creates a condition that makes training requirements easier to overlook. Locating training requirements outside of PER Standards is also not following industry precedent, such as the Standards Efficiency Review recommendations and the recent Project 2007-06.2 that moved training requirements from PRC Standards to the new PER-006-1 Standard.

Diana Torres, On Behalf of: Imperial Irrigation District, , Segments 1, 3, 5, 6

- 0 - 0

Minnesota Power agrees with MRO’s NERC Standards Review Forum (NSRF) comments.

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

- 0 - 0

BPA supports the comments made by the US Bureau of Reclamation.

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

- 0 - 0

Travis Fisher, On Behalf of: Electricity Consumers Resource Council (ELCON), , Segments 7

- 0 - 0

The IRC SRC recommends addressing this recommendation as two (2) requirements to more accurately address the aspects required of each function:

·       Generator Owner maintenance aspects in an FAC standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR).

·       Generator Operator operations aspects in PER-006.

o   Expand the applicable Functional Entities to include Generator Owners and Generator Operators

·       If adopted, IRC SRC recommends the SDT begin work using the corresponding language currently in EOP-011-2, Requirements R7 and R8 and then retire R7 and R8 from EOP-011-2.

ISO/RTO Standards Review Committee, Segment(s) 2, 12/21/2021

- 0 - 0

Enel North America, Inc. believes that the recommendation to conduct unit-specific cold weather preparedness plan training is best addressed in the EOP-011 Emergency Preparedness and Operations Standard as part of the requirement to have and maintain Cold Weather Preparedness Plans (R7 for Generators). The Cold Weather Preparedness Plan is the best area to address this recommendation because the recommendation relates to item a) above for both identifying and protecting cold-weather-critical components. The addition of this recommendation to the Cold Weather Preparedness Plans enables a comprehensive approach to all aspects of cold weather preparedness, including training in the required plans. In addition, the Cold Weather Preparedness Plans enable Generators to make changes, improve and enhance training more frequently than a standard such as FAC-008 Facility Ratings would facilitate. Enel North America, Inc. therefore believes that this recommendation is best addressed by requiring that it is part of the overall Cold Weather Preparedness Plans in the EOP-011 Standard. This recommendation is best addressed with a planning-based approach.

Alternatively, this can be addressed in the Facilities Design and Maintenance suite of standards. However, the most important thing for Enel North America, Inc. is that these requirements are not dispersed across a few different standards.  This may therefore necessitate a separate standard within the Facilities Design and Maintenance suite.

Natalie Johnson, On Behalf of: Enel Green Power, , Segments 5

- 0 - 0

Exelon concurs with the comments submitted by the EEI for this question. 

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

- 0 - 0

EOP-011-2, Requirement R8 could be modified to address this recommendation or could be in a stand alone standard. 

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

- 0 - 0

Hot Answers

EOP-011-2 (effective 4/1/2023) includes a new Requirement R7 that is applicable to the Generator Owner.  R7 requires Generator Owners to “implement and maintain one or more cold weather preparedness plan(s) for its generating units”, and lists the topics that must be addressed in the plan(s) at a minimum.  This FERC/NERC Joint Inquiry report recommendation could possibly be addressed by revising EOP-011-2 to add another Generator Owner requirement to address it.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Tim Kelley, On Behalf of: Sacramento Municipal Utility District - WECC - Segments 1, 3, 4, 5, 6

- 0 - 0

Other Answers

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

- 0 - 0

Similar to FAC-003 R5, PRC-002 R12 which require Corrective Action Plans, include Corrective Action Plan requirement in EOP-11.

DTE Energy - DTE Electric, Segment(s) 3, 5, 4, 12/8/2021

- 0 - 0

We suggest TOP-003-5, Operational Reliability Data:  Both the TOP and the BA must maintain a documented specification for data necessary for it to perform its analysis functions and Real-Time Monitoring.  Under 2.3.2, this includes generating unit data.  Under R5.2, there must be a mutually agreed upon process for resolving data conflicts, so couldn’t the CAP requirement be added here?

Susan Sosbe, On Behalf of: Wabash Valley Power Association, , Segments 1, 3

- 0 - 0

Patti Metro, On Behalf of: National Rural Electric Cooperative Association, , Segments 3, 4

- 0 - 0

None – suggest a new NERC GO/GOP Standard to implement recommendation.  It is also suggested that recently modified TOP-003-5, EOP-011-2 and IRO-010-4 standards not be modified further and consideration be given for moving Cold Weather Requirements in these Standards to the new Standard.

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

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

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

- 0 - 0

The MRO NERC Standards Review Forum (NSRF) believes this recommendation would best be addressed in an FAC standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR).

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

- 0 - 0

No Comment.

Michael Krum, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Please see the response to question 1.a. The proposed example is R4.

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

- 0 - 0

EOP and FAC standards; possibly a new PRC standard.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

EOP-011-2, Requirement R7 as part of Cold Weather plan

Kenisha Webber, On Behalf of: Entergy - Entergy Services, Inc., SERC, Segments NA - Not Applicable

- 0 - 0

Acciona Energy believes this recommendation would be best addressed in Facilities Design, Connections and Maintenance (FAC) suite of NERC Standards in a new standard.

George Brown, On Behalf of: Acciona Energy North America, , Segments 5

- 0 - 0

Xcel Energy supports the comments submitted by EEI.

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

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

WECC Cold Weather SAR, Segment(s) 10, 12/17/2021

- 0 - 0

Recommend adding a new requirement to EOP-011

  • Add new requirement to EOP-011:
    • “Generator Owners that experience outages, failures to start, or derates due to freezing (or other impacts of Extreme Weather) are to review the generating unit’s outage, failure to start, or derate and develop and implement a corrective action plan for the identified equipment, and evaluate whether the plan applies similar equipment for its other generating units.
  • Alternatively, this could also be included in the sub-requirements for R7 as “Corrective Action Plan for reviewing outages, failures to start, or derates due to cold weather or freezing.  

Keith Jonassen, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

- 0 - 0

Dominion Energy suppports the comments submitted by EEI.

Dominion, Segment(s) 3, 5, 1, 9/19/2019

- 0 - 0

No comments

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

- 0 - 0

Michael DePalma, On Behalf of: Onward Energy, MRO, WECC, Texas RE, NPCC, Segments NA - Not Applicable

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 12/20/2021

- 0 - 0

Eversource Group, Segment(s) 1, 3, 9/1/2021

- 0 - 0

FirstEnergy supports comments posted by EEI

FE Voter, Segment(s) 1, 3, 5, 6, 4, 12/20/2021

- 0 - 0

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

- 0 - 0

NRG Energy Inc.  believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

Patricia Lynch, On Behalf of: NRG - NRG Energy, Inc., , Segments 5, 6

- 0 - 0

Texas RE suggests this Key Recommendation could be added as an additional requirement to EOP-011.  Texas RE recommends including a timeline requirement for the corrective action plan (CAP) in order to be effective. 

 

Alternatively, a new Emergency Preparedness and Operations standard could be created to include the following Key Recommendations from the Joint Inquiry: 1a, 1c,1d, 1e, and 1f.  Language from future enforceable EOP-011-2 Requirements R7 and R8 could also be included in this new Emergency Preparedness and Operations standard.

Texas RE also recommends the following:

  • Revising the EOP-004 attachment 1 to include a new event type of critical loss due to cold weather.

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

- 0 - 0

Reliability Standard EOP-011-2

Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

- 0 - 0

PG&E has participated in the preparation and supports the comments provided by the Edison Electric Institute (EEI) for Q1d.

PG&E All Segments, Segment(s) 1, 3, 5, 2/10/2020

- 0 - 0

BC Hydro recommends that a new Standard(s) focusing on cold weather preparedness be developed to address this recommendation.

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

- 0 - 0

Instead of prescribing specific retrofits or upgrades, Tacoma Power recommends performing a three tier approach: perform a vulnerability assessment to identify risks, develop actions to mitigate these risks, and then implement the actions. This risk-based approach would also require entities to re-evaluate their vulnerability assessment if failures occur that weren’t identified in the assessment. This approach would be similar to how the industry addressed GMD events in Project 2013-03.

Tacoma Power also suggests modifying FAC-008 R2.2 to include a subpart to evaluate facility ratings for extreme cold weather failures, as noted in comment 1a.

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

- 0 - 0

The appropriate standard for such a requirement should be in a new standard dedicated solely to cold weather requirements as previously mentioned in Southern Company's response to Question 1a. 

Of concern to Southern Company is the timeline to develop and implement corrective actions, e.g., a large number of wind turbines may need new equipment and the subsequent lead time for equipment and contract labor could be problematic.

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

- 0 - 0

EOP-011, Ameren does this currently.

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

- 0 - 0

MPC supports comments submitted by the MRO NERC Standards Review Forum (NSRF).

Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1, 5

- 0 - 0

TAPS does not take a position regarding which standard is the appropriate home for the proposed new GO/GOP requirements, but we urge the SDT to consolidate the proposed GO/GOP requirements in a single standard to the extent possible, for ease of reference.

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

- 0 - 0

Santee Cooper, Segment(s) 1, 3, 5, 6, 12/21/2021

- 0 - 0

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

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

- 0 - 0

This appears to fit in EOP-011. However, it should be clear that if the unit operated as designed, no corrective action plan would be necessary.

Donna Wood, On Behalf of: Tri-State G and T Association, Inc., , Segments 1, 3, 5

- 0 - 0

EOP-011-02 could be used for this recommendation, however, a more efficient approach would be to develop a new Extreme Cold Weather Reliability Standard.  Also, see EEI comments to 1a.

There are standards that require corrective action plans (e.g., TPL-007-4, PRC-004-3), and it would be a natural starting point to look at those standards when addressing this recommendation. Corrective action plans for resources that experience outages, failure to start, or derates due to equipment failures resulting from temperatures or weather conditions under which the resource was designed to operate under is important, provided that generating unit design limits are accounted for.

To address these concerns and comments, EEI suggests the following modifications to the SAR:

Generator resources operating within their design specifications that experience outages, failures to start, or derates due to extreme cold weather conditions shall be evaluated by the resource owner and develop and implement a corrective action plan to maintain or restore resource capability. 

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

- 0 - 0

MidAmerican Energy Company supports EEI and MRO NSRF comments

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

The NAGF believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

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

- 0 - 0

FMPA  supports TAPS (Transmission Access Policy Study Group) comments

LaKenya VanNorman, On Behalf of: Florida Municipal Power Agency - SERC - Segments 3, 4, 5, 6

- 0 - 0

Dana Showalter, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

- 0 - 0

Joe McClung, On Behalf of: JEA, , Segments 1, 3, 5

- 0 - 0

Please refer to ACP’s response for question 1c - same recommendation as above.

In addition, ACP recommends modifying the recommendation language so that Corrective Action Plans are only developed and implemented when a generating unit experiences an outage, failure to start or derate when the conditions identified in NERC Reliability Standard EOP-011-2 Emergency Preparedness and Operations, Requirement R7.3. et al. are not met.

Michele Mihelic, On Behalf of: American Clean Power Association, NA - Not Applicable, Segments NA - Not Applicable

- 1 - 0

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

- 0 - 0

Diana Torres, On Behalf of: Imperial Irrigation District, , Segments 1, 3, 5, 6

- 0 - 0

Minnesota Power agrees with MRO’s NERC Standards Review Forum (NSRF) comments.

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

- 0 - 0

BPA supports the comments made by the US Bureau of Reclamation.

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

- 0 - 0

Travis Fisher, On Behalf of: Electricity Consumers Resource Council (ELCON), , Segments 7

- 0 - 0

The IRC SRC believes this recommendation would best be addressed in an FAC standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR).

ISO/RTO Standards Review Committee, Segment(s) 2, 12/21/2021

- 0 - 0

Enel North America, Inc. believes that the recommendation to develop Corrective Action Plans (CAPS) is best addressed in the EOP-011 Emergency Preparedness and Operations Standard as part of the requirement to have and maintain Cold Weather Preparedness Plans (R7 for Generators). The Cold Weather Preparedness Plan is the best area to address this recommendation because the recommendation relates to item a) & c) above. The addition of this recommendation to the Cold Weather Preparedness Plans enables a comprehensive approach to all aspects of cold weather preparedness including following up with CAPs.  Enel North America, Inc. recommends that a CAP only be applied in situations where temperature failures occur outside of the operating design conditions for the facility.  Otherwise, the outage, failure to start, or derate would be reported through the existing TOP-003 process (see section e and f below).  The Cold Weather Preparedness Plans enable Generators to make changes, update, and follow-up on CAPS more frequently than a standard such as FAC-008 Facility Ratings would facilitate. Enel North America, Inc. therefore believes that this recommendation is best addressed by requiring that it is part of the overall Cold Weather Preparedness Plans in the EOP-011 Standard. This recommendation is best addressed with a planning-based approach.  

Alternatively, this can be addressed in the Facilities Design and Maintenance suite of standards. However, the most important thing for Enel North America, Inc. is that these requirements are not dispersed across a few different standards.  This may therefore necessitate a separate standard within the Facilities Design and Maintenance suite. 

Natalie Johnson, On Behalf of: Enel Green Power, , Segments 5

- 0 - 0

Exelon generally concurs with the comments submitted by the EEI for this question. Exelon suggests that permissible actions taken pursuant to a corrective action plan may include revising the generating unit’s declared capability to start and operate in extreme weather conditions.

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

- 0 - 0

There are no Reliability Standards currently in effect that could easily be modified to address this recommendation. 

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

- 0 - 0

Q:

e. Which Reliability Standard(s) should be revised to address the recommendation: “The Reliability Standards should be revised to provide greater specificity about the relative roles of the Generator Owners, Generator Operators and Balancing Authorities in determining the generating unit capacity that can be relied upon during “local forecasted cold weather,” which is language from the revised Reliability Standard TOP-003-5, R2.3. -Each Generator Owner/Generator Operator should be required to provide the Balancing Authority with the percentage of the total generating unit capacity that the Generator Owner/Generator Operator reasonably believes the Balancing Authority can rely upon during the “local forecasted cold weather,” including reliability risks related to natural gas fuel contracts. -Each Balancing Authority should be required to use the data provided by the Generator Owner/Generator Operator, combined with its evaluation, based on experience, to calculate the percentage of each individual generating unit’s total capacity that it can rely upon during the “local forecasted cold weather,” and share its calculation with the Reliability Coordinator. Each Balancing Authority should be required to use that calculation of the percentage of total generating capacity that it can rely upon to “prepare its analysis functions and Realtime monitoring,” and to “manag[e] generating resources in its Balancing Authority Area to address . . . fuel supply and inventory concerns” as part of its Capacity and Energy Emergency Operating Plans.”

Hot Answers

TOP-003-5 (effective 4/1/2023) addresses the operational reliability data needs of the Balancing Authorities in Requirements R2 (BA) and R5 (GO, GOP).  We suggest this standard be revised to address the part of the recommendation regarding the GO/GOP’s consideration of “local forecasted cold weather” impacts when providing their generating unit capability data to the BA (with corresponding change to EOP-011-2, R7).  The part of the recommendation that indicates the BA “should be required to use the data provided by the Generator Owner/Generator Operator, combined with its evaluation,….to calculate the percentage of each individual generating unit’s total capacity that it can rely upon during the “local forecasted cold weather”, could be addressed in a revision to TOP-002-4 (R4).  The part of the recommendation that the BA “share its calculation with the Reliability Coordinator” could also be addressed in a revision to TOP-002-4 (R7).  The part of the recommendation that the BA “use that calculation of the percentage of total generating capacity that it can rely upon to “prepare its analysis functions and Realtime monitoring,” and to “manag[e] generating resources in its Balancing Authority Area to address . . . fuel supply and inventory concerns” as part of its Capacity and Energy Emergency Operating Plans” could be addressed in a revision to TOP-010-1(i) and EOP-011-2, respectively.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Tim Kelley, On Behalf of: Sacramento Municipal Utility District - WECC - Segments 1, 3, 4, 5, 6

- 0 - 0

Other Answers

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

- 0 - 0

TOP-003-5 and EOP-011-3

DTE Energy - DTE Electric, Segment(s) 3, 5, 4, 12/8/2021

- 0 - 0

We suggest TOP-003-5:  Since the language is already in this Standard, shouldn’t the specificity be outlined in this Standard as well? Also see “d” above.

Susan Sosbe, On Behalf of: Wabash Valley Power Association, , Segments 1, 3

- 0 - 0

Patti Metro, On Behalf of: National Rural Electric Cooperative Association, , Segments 3, 4

- 0 - 0

None – suggest a new NERC GO/GOP Standard to implement recommendation.  It is also suggested that recently modified TOP-003-5, EOP-011-2 and IRO-010-4 standards not be modified further and consideration be given for moving Cold Weather Requirements in these Standards to the new Standard.

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

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

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

- 0 - 0

Requested by 2022/2023

 

MRO NSRF’s response has been categorized based on the applicable functional entity and task:

  •  Generator Owner and capacity that can be relied upon during ‘local forecasted cold weather:’

MRO NSRF seeks clarification. As both the Generator Owner (GO) and Generator Operator (GOP) are both cited in this recommendation, what is the proposed action for each function; i.e. for the GO portion of this proposed requirement, is the intent to provide a "static" design number for planning purposes?  If so, the MRO NERF believes this recommendation would best be performed by Generator Owners and addressed in a new FAC standard.

If this aspect is retained in the scope of the SAR, MRO NSRF recommends the SDT address this recommendation in an FAC standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR) and begin work using the corresponding language currently in EOP-011-2, Requirements R7 and R8 and then retire R7 and R8 from EOP-011-2.

In addition, the scope of the SAR should be updated to require that the capacity number provided to the Balancing Authority should reflect the inoperability of any cold-weather-critical components that can not be protected, and therefore cannot be relied upon (see our response to question 1a above).

  • Generator Operator and capacity that can be relied upon during ‘local forecasted cold weather:’

MRO NSRF seeks clarification. As both the GO and GOP are both cited in this recommendation, what is the proposed action for each function; i.e. for the GOP portion of this proposed requirement, is the intent to provide a "dynamic" real-time number for operating purposes?  If so, MRO NSRF recommends this be retained in TOP-003-5.

In addition, the scope of the SAR should be updated to require that the capacity number provided to the Balancing Authority should reflect the inoperability of any cold-weather-critical components that can not be protected, and therefore cannot be relied upon (see our response to question 1a above).

  •    Balancing Authority and calculation of capacity that it can rely upon during ‘local forecasted cold weather:

MRO NSRF believes TOP-002-4, R4, Part 4.4 would be a best fit location.  Justification.  R4. Each BA shall have an Operating Plan for the next-day that addresses: 4.4 Capacity and energy reserve requirements, including deliverability capability.

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

- 0 - 0

No Comment.

Michael Krum, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Reclamation recommends any additional information required in a Balancing Authority’s data specification should be contained in TOP-003 Requirement R2.

Reclamation recommends additional requirements for what Balancing Authorities should do with the information they receive pursuant to their data specifications should be contained in TOP-002.

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

- 0 - 0

We believe this is a MISO Generator Verification Capacity Testing issue.  If new/revised standard(s) is developed, it really needs to be in the same standard that will address question 1.a.b. and d.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

Kenisha Webber, On Behalf of: Entergy - Entergy Services, Inc., SERC, Segments NA - Not Applicable

- 0 - 0

The response has been categorized by task:

  • Generator Owner/Operator determining the generating units reliable capacity

Acciona Energy believes this recommendation would be best addressed in Facilities Design, Connections and Maintenance (FAC) suite of NERC Standards.  Perhaps, the most appropriate place for this recommendation would be NERC Reliability Standard FAC-008 – Facility Ratings (NERC FAC-008).  NERC FAC-008 already includes the majority, if not all equipment, cold-weather-critical components and systems that would be affected by extreme cold weather, which the loss of would ultimately affect the Facility Rating.

  • Communicating the generating unit’s reliable capacity to the Balancing Authority and Reliability Coordinator:

Acciona Energy believes this recommendation would be best addressed in NERC Reliability Standard TOP-003 – Operational Reliability Data.

  • Balancing Authority determining the generating units reliable capacity and managing resources:

Acciona Energy supports Midwest Reliability Organization’s (MRO) NERC Standards Review Forum’s (NSRF) comments on this question as it relates to Balancing Authorities.

George Brown, On Behalf of: Acciona Energy North America, , Segments 5

- 0 - 0

Xcel Energy supports the comments submitted by EEI.

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

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

WECC Cold Weather SAR, Segment(s) 10, 12/17/2021

- 0 - 0

Recommend revising TOP-003-5, TOP-002-4, and EOP-011-2

  • Add new requirement to TOP-003-5 which would be applicable to GO/GOPs:
    • Each Generator Owner/Generator Operator should be required to provide the Balancing Authority with the percentage of the total generating unit capacity that the Generator Owner/Generator Operator reasonably believes the Balancing Authority can rely upon during the “local forecasted cold weather,” including reliability risks related to natural gas fuel contracts
  • Add new requirement to which would be applicable to BAs:
    • Each Balancing Authority should be required to use the data provided by the Generator Owner/Generator Operator, combined with its evaluation, based on experience, to calculate the percentage of each individual generating unit’s total capacity that it can rely upon during the “local forecasted cold weather,” and share its calculation with the Reliability Coordinator
  • Add new requirement to TOP-002-4 which would be applicable to BAs:
    • Each Balancing Authority should be required to use a calculation of the percentage of total generating capacity that it can rely upon to prepare its analysis functions and Realtime monitoring, and to “manage generating resources in its Balancing Authority Area to address . . . fuel supply and inventory concerns” as part of its Capacity and Energy Emergency Operating Plans
  • Add new requirement to EOP-011-2 which would be applicable to BAs:
    • Each Balancing Authority should be required to use a calculation of the percentage of total generating capacity that it can rely upon to manag[e] generating resources in its Balancing Authority Area to address fuel supply and inventory concerns as part of its Capacity and Energy Emergency Operating Plans

Keith Jonassen, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

- 0 - 0

Dominion Energy suppports the comments submitted by EEI.

Dominion, Segment(s) 3, 5, 1, 9/19/2019

- 0 - 0

No comments

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

- 0 - 0

We believe the section: Each Generator Owner/Generator Operator should be required to provide the Balancing Authority with the percentage of the total generating unit capacity that the Generator Owner/Generator Operator reasonably believes the Balancing Authority can rely upon during the “local forecasted cold weather,” including reliability risks related to natural gas fuel contracts  is already covered in existing TOP standards.  Our generation assets report available capacity accurately.  We request this section be removed from future Standard changes.  

Michael DePalma, On Behalf of: Onward Energy, MRO, WECC, Texas RE, NPCC, Segments NA - Not Applicable

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 12/20/2021

- 0 - 0

Eversource Group, Segment(s) 1, 3, 9/1/2021

- 0 - 0

FirstEnergy supports comments posted by EEI

FE Voter, Segment(s) 1, 3, 5, 6, 4, 12/20/2021

- 0 - 0

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

- 0 - 0

NRG Energy Inc.  believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

Patricia Lynch, On Behalf of: NRG - NRG Energy, Inc., , Segments 5, 6

- 0 - 0

Texas RE suggests TOP-003 would be an appropriate standard for this Key Recommendation as noted in the Joint Inquiry.  Additionally, the drafting team should consider revising IRO-010 as well, since it would be helpful for the RC to have this information. Texas RE also recommends considering a revision to Table 1 in TPL-001 to include cold weather so the PA/PC have the most accurate information in planning studies.

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

- 0 - 0

N/A

Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

- 0 - 0

PG&E has participated in the preparation and supports the comments provided by the Edison Electric Institute (EEI) for Q1e.

PG&E All Segments, Segment(s) 1, 3, 5, 2/10/2020

- 0 - 0

BC Hydro suggests that this recommendation will impact TOP-002 R4 (BA) and IRO-014 R1 (RC) as it will impact Energy and Capacity Operating Plans; also due to data required to develop these Plans, TOP-003 and IRO-010 could be impacted.

BC Hydro also suggests that considerations be given to FAC-008, FAC-011 and FAC-014 as the operating limits or inputs to operating limits may be impacted by this recommendation.

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

- 0 - 0

Tacoma Power suggests housing these recommendations either in TOP-003 or IRO-010. Specifically, any information that must be provided to the RC should be housed in IRO-010.

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

- 1 - 0

The appropriate standard for such a requirement should be in a new standard dedicated solely to cold weather requirements as previously mentioned in Southern Company's response to Question 1a.

The intent of the requirement should be focused on timely and accurate communications as risks to generation availability are identified by the GO/GOP.  We see this proposed enhanced requirement as an event-based, real-time communication of changes in the capability data provided in TOP-005-5, R2.3.

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

- 0 - 0

Since the referenced language is from TOP-003-5, we believe it should be put in this standard.

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

- 0 - 0

MPC supports comments submitted by the MRO NERC Standards Review Forum (NSRF).

Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1, 5

- 0 - 0

TAPS does not take a position regarding which standard is the appropriate home for the proposed new GO/GOP requirements, but we urge the SDT to consolidate the proposed GO/GOP requirements in a single standard to the extent possible, for ease of reference.

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

- 0 - 0

Santee Cooper, Segment(s) 1, 3, 5, 6, 12/21/2021

- 0 - 0

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

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

- 0 - 0

For the Balancing Authority (BA) role, we think either TOP-002-4, R4, Part 4.4, or TOP-003-5 R2 would be an appropriate place to describe the BA role.

For the Generator Owner (GO) role, we think EOP-011-2, R7, Part 7.3 would be the best fit.

Donna Wood, On Behalf of: Tri-State G and T Association, Inc., , Segments 1, 3, 5

- 0 - 0

The SDT should evaluate whether TOP-003 is the best solution for this recommendation.  Also, see EEI’s comments for question 1a. EEI also offers the following revised language to the SAR:

The Reliability Standards should be revised to provide greater specificity about the relative roles of the Generator Owners, Generator Operators and Balancing Authorities in determining the generating unit capacity that can be relied upon during “local forecasted cold weather,” which is language from the revised Reliability Standard TOP-003-5, R2.3. Each Generator Owner/Generator Operator should be required to provide the Balancing Authority with the percentage of the total generating unit capacity that the Generator Owner/Generator Operator reasonably believes the Balancing Authority can rely upon during the “local forecasted cold weather,” including reliability risks related to natural gas fuel contracts. -Each Balancing Authority should be required to use the data provided by the Generator Owner/Generator Operator, combined with its evaluation, based on experience, to calculate the percentage of each individual generating unit’s total capacity that it can rely upon during the “local forecasted cold weather,” and share its calculation with the Reliability Coordinator. Each Balancing Authority is to consider that resource capacity projections provided by the GO cannot be provided with precision. Entity estimates are based on the historical performance of the resource under similar operating condition and the variability of weather conditions can result in errors in these projections.  Armed with this knowledge, the BA should be required to use those projections in their calculations of the percentage of total generating capacity that it can rely upon to “prepare its analysis functions and Realtime monitoring,” and to “manag[e] generating resources in its Balancing Authority Area to address . . . fuel supply and inventory concerns” as part of its Capacity and Energy Emergency Operating Plans.

 

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

- 0 - 0

MidAmerican Energy Company supports EEI and MRO NSRF comments

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

The NAGF believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

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

- 0 - 0

FMPA  supports TAPS (Transmission Access Policy Study Group) comments

LaKenya VanNorman, On Behalf of: Florida Municipal Power Agency - SERC - Segments 3, 4, 5, 6

- 0 - 0

Dana Showalter, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

- 0 - 0

Joe McClung, On Behalf of: JEA, , Segments 1, 3, 5

- 0 - 0

ACP members believe that the determination of Generation Unit capacity during local forecasted cold weather is best addressed in the Facility Ratings standard (FAC-008). This requirement already addresses equipment capabilities and limitations. NERC FAC-008 already includes the majority, if not all equipment, cold-weather-critical components and systems that would be affected by extreme cold weather, which the loss of would ultimately affect the Facility Rating. This is a static design number that would not require frequent enhancements and improvements such as the Cold Weather Preparedness Plans might. ACP recommends the equipment listing approach, as it is more suitable for this type of activity.

ACP recommends the communication of the generating unit’s reliable capability to the Balancing Authority and Reliability Coordinator would be best addressed in NERC Reliability Standard TOP-003 – Operational Reliability Data, where this additional information can be added to the outage and derate process, which already exists.

ACP does not have a recommendation on this question as it relates to the BA.

Michele Mihelic, On Behalf of: American Clean Power Association, NA - Not Applicable, Segments NA - Not Applicable

- 2 - 0

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

- 0 - 0

Diana Torres, On Behalf of: Imperial Irrigation District, , Segments 1, 3, 5, 6

- 0 - 0

Minnesota Power agrees with MRO’s NERC Standards Review Forum (NSRF) comments.

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

- 0 - 0

BPA supports the comments made by the US Bureau of Reclamation.

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

- 0 - 0

ELCON disagrees that Generator Owners are in the best position to judge the reliability risks related to natural gas fuel contracts. The onus should be on natural gas suppliers to estimate the probability of a failure to deliver fuel, or on FERC to prevent natural gas pipelines from withholding available gas from generators with firm contracts (the “price majeure” phenomenon).

Travis Fisher, On Behalf of: Electricity Consumers Resource Council (ELCON), , Segments 7

- 0 - 0

IRC SRC has categorized its response based on the applicable functional entity and task:

·       Generator Owner - capacity that can be relied upon during ‘local forecasted cold weather’

IRC SRC seeks clarification. As both the Generator Owner (GO) and Generator Operator (GOP) are both cited in this recommendation, what is the proposed action for each function; i.e. for the GO portion of this proposed requirement, is the intent to provide a "static" design number for planning purposes?  If so, the IRC SRC believes this recommendation would best be performed by Generator Owners and addressed in a new FAC standard.

If this aspect is retained in the scope of the SAR, IRC SRC recommends the SDT address this recommendation in an FAC standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR) and begin work using the corresponding language currently in EOP-011-2, Requirements R7 and R8 and then retire R7 and R8 from EOP-011-2.

In addition, the scope of the SAR should be updated to require that the capacity number provided to the Balancing Authority should reflect the inoperability of any cold-weather-critical components that can not be protected, and therefore cannot be relied upon (see our response to question 1a above).

·       Generator Operator - capacity that can be relied upon during ‘local forecasted cold weather’

IRC SRC seeks clarification. As both the GO and GOP are both cited in this recommendation, what is the proposed action for each function; i.e. for the GOP portion of this proposed requirement, is the intent to provide a "dynamic" real-time number for operating purposes?  If so, IRC SRC recommends this be retained in TOP-003-5. 

In addition, the scope of the SAR should be updated to require that the capacity number provided to the Balancing Authority should reflect the inoperability of any cold-weather-critical components that can not be protected, and therefore cannot be relied upon (see our response to question 1a above).

·       Balancing Authority - calculation of capacity that can be relied upon during ‘local forecasted cold weather’

IRC SRC believes  TOP-003-5  would be a best fit location.

              R4. Each BA shall have an Operating Plan for the next-day that addresses:

              4.4 Capacity and energy reserve requirements, including deliverability capability.

 

ISO/RTO Standards Review Committee, Segment(s) 2, 12/21/2021

- 0 - 0

The determination of Generation Unit capacity during local forecasted cold weather is best addressed in the Facility Ratings standard (FAC-008), as this requirement already addresses equipment capabilities and limitations and is a static design number that would not require frequent enhancements and improvements such as the Cold Weather Preparedness Plans might. An equipment listing approach is more suitable for this type of activity involving static design numbers and how they are impacted by cold weather.

Communication of the generating unit’s reliable capability to the Balancing Authority and Reliability Coordinator is best addressed in the TOP-003 for reliability data. This additional information can be added to the outage and derate process that already exists. 

Natalie Johnson, On Behalf of: Enel Green Power, , Segments 5

- 0 - 0

Exelon concurs with the comments submitted by the EEI for this question.

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

- 0 - 0

AZPS agrees with the comments provided by EEI; EEI does not agree that TOP-005 as it would not be a good solution for this recommendation.  The SDT should consider this recommendation to be included as a stand alone standard in which the Generator Operator is able to provide the data on exceptions.

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

- 0 - 0

Hot Answers

EOP-011-2 (effective 4/1/2023) and the corresponding data specification requirements in IRO-010-4 (R1 part 1.3.2) and TOP-003-5 (R1 part 1.3.2; R2 part 2.3.2).

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Tim Kelley, On Behalf of: Sacramento Municipal Utility District - WECC - Segments 1, 3, 4, 5, 6

- 0 - 0

Other Answers

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

- 0 - 0

Include in EOP-011-3 in R7.3.2

DTE Energy - DTE Electric, Segment(s) 3, 5, 4, 12/8/2021

- 0 - 0

Rather than updating another Standard, shouldn’t the language stay in EOP-011-2 and perhaps be revised for clarity?

Susan Sosbe, On Behalf of: Wabash Valley Power Association, , Segments 1, 3

- 0 - 0

Patti Metro, On Behalf of: National Rural Electric Cooperative Association, , Segments 3, 4

- 0 - 0

None – suggest a new NERC GO/GOP Standard to implement recommendation.  It is also suggested that recently modified TOP-003-5, EOP-011-2 and IRO-010-4 standards not be modified further and consideration be given for moving those Cold Weather Requirements in these Standards to the new Standard.

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

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

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

- 0 - 0

Similar to MRO NSRF’s response to question 1e above, our response has been categorized based on the applicable functional entity and task:

  • Accounting for effects of precipitation and accelerated cooling effect of wind:

MRO NSRF believes this recommendation would best be performed by Generator Owners and addressed in a new FAC standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR).

If this proposal is adopted, MRO NSRF recommends the Standard Drafting Team (SDT) begin work using the corresponding language currently in EOP-011-2, Requirements R7 and R8 and then retire R7 and R8 from EOP-011-2.

  • Providing temperature data:

MRO NSRF believes this recommendation would best be performed by Generator Operators and addressed in TOP-003.

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

- 0 - 0

No Comment.

Michael Krum, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Reclamation recommends EOP-011 Requirement R7.3.2 could be revised to clarify this information. 

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

- 0 - 0

FAC or MOD standards.  This needs to be modeled ahead of time as part of facility ratings.  Waiting until you are in Emergency conditions is too late.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

EOP-011-2

Kenisha Webber, On Behalf of: Entergy - Entergy Services, Inc., SERC, Segments NA - Not Applicable

- 0 - 0

The response has been categorized by task:

  • Accounting for effects of precipitation and accelerated cooling effect of wind:

Acciona Energy believes this recommendation would be best addressed in Facilities Design, Connections and Maintenance (FAC) suite of NERC Standards.  Perhaps, the most appropriate place for this recommendation would be NERC Reliability Standard FAC-008 – Facility Ratings (NERC FAC-008).  NERC FAC-008 already includes the majority, if not all equipment, cold-weather-critical components and systems that would be affected by extreme cold weather, which the loss of would ultimately effect the Facility Rating.

Acciona Energy recommends that the Standards Drafting Team adopt and then retire the applicable language from NERC Reliability Standard EOP-011-2 Emergency Preparedness and Operations, Requirement R7 and R8.

  • Providing temperature data:

Acciona Energy believes this recommendation would be best addressed in NERC Reliability Standard TOP-003 – Operational Reliability Data.

George Brown, On Behalf of: Acciona Energy North America, , Segments 5

- 0 - 0

Xcel Energy supports the comments submitted by EEI.

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

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

WECC Cold Weather SAR, Segment(s) 10, 12/17/2021

- 0 - 0

Recommend revising EOP-011-2 R7 

Revise EOP-011-2, R7.3.2 to state:

  • 7.3.2 In a manner which accounts for the effects of precipitation (i.e. icing and snowpack) and the accelerated cooling effect of wind, generating unit(s) minimum:
    • 7.3.2.1. design temperature; or
    • 7.3.2.2. historical operating temperature; or
    • 7.3.2.3  current cold weather performance temperature determined by an engineering analysis.

Keith Jonassen, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

- 0 - 0

Dominion Energy suppports the comments submitted by EEI.

Dominion, Segment(s) 3, 5, 1, 9/19/2019

- 0 - 0

No comments

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

- 0 - 0

There is ambiquitity as to how a Generator Owner would account for thie described weather/atmospheric effects.  Would NERC or other Regiona Entities also measure thiese effects for comparison?  Are engineering studies to be required by Generator Owners,  or would an attestation or other statement assuring the Generator Owner has accoutned for these effects be acceptable?  Who is expected to provide the raw “Temperature Data”?

Michael DePalma, On Behalf of: Onward Energy, MRO, WECC, Texas RE, NPCC, Segments NA - Not Applicable

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 12/20/2021

- 0 - 0

Eversource Group, Segment(s) 1, 3, 9/1/2021

- 0 - 0

FirstEnergy supports comments posted by EEI

FE Voter, Segment(s) 1, 3, 5, 6, 4, 12/20/2021

- 0 - 0

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

- 0 - 0

NRG Energy Inc.  believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

Patricia Lynch, On Behalf of: NRG - NRG Energy, Inc., , Segments 5, 6

- 0 - 0

Texas RE suggests this Key Recommendation could be included in EOP-011.  Alternatively, a new Emergency Preparedness and Operations standard could be created to include the following Key Recommendations from the Joint Inquiry: 1a, 1c,1d, 1e, and 1f.  Language from future enforceable EOP-011-2 Requirements R7 and R8 could also be included in this new Emergency Preparedness and Operations standard.

 

Texas RE also recommends the drafting team consider whether cold weather should be included in the RC’s SOL Methodology in accordance with proposed Reliability Standard FAC-011-4.

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

- 0 - 0

Reliability Standard EOP-011-2

Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

- 0 - 0

PG&E has participated in the preparation and supports the comments provided by the Edison Electric Institute (EEI) for Q1f.

PG&E All Segments, Segment(s) 1, 3, 5, 2/10/2020

- 0 - 0

This recommendation aligns with Requirements R7 and R8 of EOP-011-2. 

BC Hydro recommends that a new EOP Standard(s) focusing on cold weather preparedness be developed to address this recommendation and the Requirements R7 and R8 be moved from EOP-011-2 to the new Standard(s).

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

- 0 - 0

See comments for item 1b with respect to modifying FAC-008 R2.2. Also, Tacoma Power suggests the SDT consider how this recommendation (as currently written) applies to all generation types, such as hydrogeneration.

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

- 0 - 0

Southern Company recommends that this requirement along with all cold weather standards be included at a future revision date in a new cold weather standard as previously mentioned in Southern Company's response to Question 1a.  

However, for initial inclusion, Southern Company recommends that EOP-011-2 R7 be revised and consider revising IRO-010-4, R1 and TOP-003-4, R1 to include the additional weather parameters.  

 

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

- 0 - 0

Since the referenced language is from EOP-011-2, it should be put in this standard.

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

- 0 - 0

MPC supports comments submitted by the MRO NERC Standards Review Forum (NSRF).

Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1, 5

- 0 - 0

TAPS does not take a position regarding which standard is the appropriate home for the proposed new GO/GOP requirements, but we urge the SDT to consolidate the proposed GO/GOP requirements in a single standard to the extent possible, for ease of reference.

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

- 0 - 0

Santee Cooper, Segment(s) 1, 3, 5, 6, 12/21/2021

- 0 - 0

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

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

- 0 - 0

We recommend this be added to EOP-011-2, R2

Donna Wood, On Behalf of: Tri-State G and T Association, Inc., , Segments 1, 3, 5

- 0 - 0

While EEI supports the recommendation to require GOs to account for the effects of precipitation and accelerated cooling effects when providing capacity projections, this information is based on original design specifications and historical unit performance during similar operating conditions and therefore cannot be precisely established.  EOP-011-2, Requirement R7, subpart 7.3 could be modified to address this recommendation.  Also, see EEI’s comments to question 1a.  

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

- 0 - 0

MidAmerican Energy supports EEI and MRO NSRF comments

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

The NAGF believes that the recommendation should be included as part of a new standard dedicated to Cold Weather.

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

- 0 - 0

FMPA  supports TAPS (Transmission Access Policy Study Group) comments

LaKenya VanNorman, On Behalf of: Florida Municipal Power Agency - SERC - Segments 3, 4, 5, 6

- 0 - 0

Dana Showalter, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

- 0 - 0

Joe McClung, On Behalf of: JEA, , Segments 1, 3, 5

- 0 - 0

With respect to accounting for the effect of precipitation and the cooling effect of wind, ACP recommends this recommendation be incorporated in NERC Reliability Standard FAC-008 – Facility Ratings. NERC FAC-008 already includes the majority, if not all equipment, cold-weather-critical components and systems that would be affected by extreme cold weather, which the loss of would ultimately affect the Facility Rating.

ACP recommends that the Standards Drafting Team adopt and then remove the applicable language from NERC Reliability Standard EOP-011-2 Emergency Preparedness and Operations, Requirement R7 and R8.

With respect to reporting temperature data, ACP believe this is best addressed in the TOP-003 Operational Reliability Data.

Michele Mihelic, On Behalf of: American Clean Power Association, NA - Not Applicable, Segments NA - Not Applicable

- 2 - 0

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

- 0 - 0

Diana Torres, On Behalf of: Imperial Irrigation District, , Segments 1, 3, 5, 6

- 0 - 0

Minnesota Power agrees with MRO’s NERC Standards Review Forum (NSRF) comments.

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

- 0 - 0

BPA supports the comments made by the US Bureau of Reclamation.

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

- 0 - 0

ELCON believes question 1(a) takes care of this question—Generator Owners already must identify and protect cold-weather-critical components and systems for each generating unit, which should include accounting for the effects of precipitation and accelerated cooling effect of wind.

Travis Fisher, On Behalf of: Electricity Consumers Resource Council (ELCON), , Segments 7

- 0 - 0

Similar to IRC SRC’s response to question 1e above, our response has been categorized based on the applicable functional entity and task:

·        Accounting for effects of precipitation and accelerated cooling effect of wind:

IRC SRC believes this recommendation would best be performed by Generator Owners and addressed in a new FAC standard along with items 1, 3, 4, 5 and 6 (see pages 3-4 of the SAR).

If this proposal is adopted, IRC SRC recommends the Standard Drafting Team (SDT) begin work using the corresponding language currently in EOP-011-2, Requirements R7 and R8 and then retire R7 and R8 from EOP-011-2.

·        Providing temperature data:

IRC SRC believes this recommendation would best be performed by Generator Operators and addressed in TOP-003.

 

ISO/RTO Standards Review Committee, Segment(s) 2, 12/21/2021

- 0 - 0

With respect to accounting for the effect of precipitation and the cooling effect of wind, Enel North America, Inc. recommends this be incorporated in NERC Reliability Standard FAC-008 – Facility Ratings, as this requirement already addresses equipment capabilities and limitations and is a static design number that would not require frequent enhancements and improvements such as the Cold Weather Preparedness Plans might.  

Communication of the generating unit’s reliable capability to the Balancing Authority and Reliability Coordinator is best addressed in the TOP-003 for reliability data. This additional information can be added to the outage and derate process that already exists. Better forecasting tools to predict the effects of precipitation and accelerated cooling effect of wind (such as NOAA) would help Generators better manage, plan, and incorporate this into their temperature data.

Natalie Johnson, On Behalf of: Enel Green Power, , Segments 5

- 0 - 0

Exelon concurs with the comments submitted by the EEI for this question.  Additionlly, accounting for the effects of precipitation and the accelerated cooling effect of wind will result in a range of possible minimum operating temperatures for each generating unit.  Exelon suggests the drafting team allow generator owners to assign tolerances to declared design temperature data.  

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

- 0 - 0

AZPS agrees with the comments provided by EEI; EOP-011-2, Requirement 7, subpart 7.3 could be modified to address the recommentations. 

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

- 0 - 0

Hot Answers

EOP-011-2 (effective 4/1/2023).  For the Transmission Operator (TOP), Requirement 1, part 1.2.5 requires the TOP’s Operating Plan(s) to mitigate operating Emergencies in its Transmission Operator Area to include “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”.  For the Balancing Authority (BA), Requirement 2, part 2.2.8 requires the BA’s Operating Plan(s) to mitigate Capacity Emergencies and Energy Emergencies within its Balancing Authority Area to include “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”.  A revision of these requirements could address this recommendation.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Tim Kelley, On Behalf of: Sacramento Municipal Utility District - WECC - Segments 1, 3, 4, 5, 6

- 0 - 0

Other Answers

EOP-011-1

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

- 0 - 0

PRC-006-5 could possibly be modified to address the cold weather recommendations by clarifying or adding design requirements for the Planning Coordinators to consider when developing the criteria for UFLS.

DTE Energy - DTE Electric, Segment(s) 3, 5, 4, 12/8/2021

- 0 - 0

We would suggest EOP-011-2.

Susan Sosbe, On Behalf of: Wabash Valley Power Association, , Segments 1, 3

- 0 - 0

Patti Metro, On Behalf of: National Rural Electric Cooperative Association, , Segments 3, 4

- 0 - 0

Suggest revising approved NERC Standard EOP-011-2 R1.2.5 to implement recommendation.

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

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

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

- 0 - 0

The following is broke down by Applicable Entity and either Manual or Automatic load shedding.

Manual load shedding.

TOP.  Expand EOP-011-2, R1, Part 1.2.5 (or within a new Standard).  Justification, 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;

BA.  Expand EOP-011-2, R2, Part 2.2.8 (or within a new Standard).  Justification, 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;

Automatic load shedding.

TO.  Expand PRC-006-5 and any other relevant regional UFLS standards.

DP.  Expand PRC-006-5 and any other relevant regional UFLS standards

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

- 0 - 0

No Comment.

Michael Krum, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Reclamation identifies this recommendation does not fit well into any existing reliability standards. Reclamation suggests a new standard in the EOP family to compliment EOP-005 (generator blackstart) might appropriately address this recommendation. Facilities that might be subjected to load shedding should be required to have an alternate, independent power source.

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

- 0 - 0

We believe this is a MISO/gas issue.  Who is going to be responsible for coordination? RC/ISO, BA, TOP? The answer determines what standard(s) will require modification.  Could be IRO or TOP standards.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

Kenisha Webber, On Behalf of: Entergy - Entergy Services, Inc., SERC, Segments NA - Not Applicable

- 0 - 0

Acciona Energy supports Midwest Reliability Organization’s (MRO) NERC Standards Review Forum’s (NSRF) comments on this question.

George Brown, On Behalf of: Acciona Energy North America, , Segments 5

- 0 - 0

Xcel Energy supports the comments submitted by EEI.

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

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

WECC Cold Weather SAR, Segment(s) 10, 12/17/2021

- 0 - 0

Recommend revising EOP-011-2

  • Revise EOP-011-2, R2 with new sub-requirement that states:
    • Balancing Authorities’ provisions for operator-controlled manual load shedding are to include processes for identifying and protecting critical natural gas infrastructure loads in their respective areas from firm load shed.
  • Revise EOP-011-2, R1 with new sub-requirement that states:
    • Transmission Operators’ (TOPs) provisions for operator-controlled manual load shedding are to include processes for identifying and protecting critical natural gas infrastructure loads in their respective areas from firm load shed.
  • Create new defined term: Critical natural gas infrastructure loads are natural gas production, processing and intrastate and interstate pipeline facility loads which, if de-energized, could adversely affect the provision of natural gas to bulk-power system natural gas-fired generation.

Keith Jonassen, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

- 0 - 0

Dominion Energy suppports the comments submitted by EEI. In addition, Dominion Energy does not support BAs or TOPs attempting to identify critical natural gas infrastructure. The gas pipeline owners have that responsibility and any requirements regarding identification should be in a tarriff and not a reliability standard.

Dominion, Segment(s) 3, 5, 1, 9/19/2019

- 0 - 0

No comments

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

- 0 - 0

Michael DePalma, On Behalf of: Onward Energy, MRO, WECC, Texas RE, NPCC, Segments NA - Not Applicable

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 12/20/2021

- 0 - 0

EOP-011 is the Reliability Standard that should be revised to address the recommendation.

Note: GO/GOPs not TOPs should be required to provide the gas infrastructure that is necessary to run their plants to their associated DPs. DPs then can be required to pass the identified circuits to the TOPs.

Eversource Group, Segment(s) 1, 3, 9/1/2021

- 0 - 0

FirstEnergy supports comments posted by EEI

FE Voter, Segment(s) 1, 3, 5, 6, 4, 12/20/2021

- 0 - 0

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

- 0 - 0

NRG Energy Inc.  has no comment regarding this recommendation as it is not related to GO/GOPs.

Patricia Lynch, On Behalf of: NRG - NRG Energy, Inc., , Segments 5, 6

- 0 - 0

Texas RE recommends the drafting team consider addressing Key Recommendations 1i, 1h, and 1j from the Joint Inquiry in a similar manner as they are all related to one another. The drafting team could consider the following standard categories:

  • Emergency Preparedness and Operations (EOP), since manual load shed is an emergency measure;
  • Protection and Control (PRC), since the PRC standards already include undervoltage load shed and under frequency load shed;
  • Transmission Operations (TOP), since the TOP would be the responsible entity for identifying and protecting critical natural gas infrastructure loads in their respective areas from firm load shed; 
  • Transmission Planning (TPL), since it would be helpful for the Transmission Planners to understand which natural gas infrastructure loads are deemed critical for planning; and
  • Any combination of EOP, PRC, TOP, and TPL standards the drafting team sees fit. 

 

Additionally, Texas RE recommends including a requirement for corrective action during System restoration so it does not affect natural gas loads that are to be protected from firm load shed.  This could be included in the TOPs’ system restoration plans, as required in EOP-005.

 

In addition to having a process for identifying and protecting critical natural gas infrastructure loads from firm load, Texas RE recommends including other critical loads such as law enforcement, hospitals, and 24-Hour emergency services facilities such as fire and rescue garages.

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

- 0 - 0

N/A

Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

- 0 - 0

PG&E has participated in the preparation and supports the comments provided by the Edison Electric Institute (EEI) for Q1g.

PG&E All Segments, Segment(s) 1, 3, 5, 2/10/2020

- 0 - 0

BC Hydro suggest that EOP-011 and possibly PRC-006 could be modified to address this recommendation.

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

- 0 - 0

Tacoma Power suggests adding this recommendation to EOP-011, where there are existing load shedding Requirements. Tacoma Power also recommends that when drafting this Requirement, the SDT should create a separate standalone Requirement, rather than adding a sub-part to an existing Requirement. This makes it easier for TOPs and BAs that don’t have natural gas infrastructure in their footprint to classify the entire Requirement as “Do Not Own” and avoid complicated RSAW narratives describing what sub-parts do and do not apply. 

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

- 1 - 0

Southern Company recommends dividing this requirement amongst the following two standards as load shedding and the need to protect critical gas infrastructure could occur during other seasons; therefore, including it in existing non-cold weather standards is appropriate.  

  • EOP-011-2:  Add manual load shedding requirements to R1 for the Transmission Operator and R2 for the Balancing Authority.
  • PRC-006-5:  Revise automatic load shedding requirements to include provisions for the Transmission Operator and Distribution Provider.

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

- 0 - 0

EOP-011, PRC-006, and regional PRC-006 where applicable.

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

- 0 - 0

MPC supports comments submitted by the MRO NERC Standards Review Forum (NSRF).

Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1, 5

- 0 - 0

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

- 0 - 0

Santee Cooper, Segment(s) 1, 3, 5, 6, 12/21/2021

- 0 - 0

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

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

- 0 - 0

We do not agree that this recommendation should fall entirely on NERC registered entities. Instead, we believe that natural gas providers should be required to provide a list of their critical facilities to the utilities and maintain it as facilities change in the future. The companion NERC requirements, to incorporate such lists into our load shedding plans, could be treated as modifications to the following requirements:

For Manual Load Shedding:
Transmission Operators (TOP) – expand EOP-011-2, R1
Balancing Authorities (BA) – expand EOP-011-2, R2

For Automatic load shedding:
Transmission Owners (TO) that own UFLS – expand PRC-006-5 and any other relevant regional UFLS standards to include a new requirement(s) to address this recommendation.

 

Donna Wood, On Behalf of: Tri-State G and T Association, Inc., , Segments 1, 3, 5

- 0 - 0

EOP-011-2 could be a suitable Reliability Standard to ensure necessary oversight of manual and automatic load shedding programs are designed and implemented by responsible entities to ensure the protection of critical natural gas infrastructure from inadvertent manual or automatic load shedding in order to avoid adversely affecting bulk-power system reliability.  However, without some mechanism for natural gas infrastructure owners to identify and report which of their facilities are critical,  a NERC Reliability Standard may not be effective.  (See our General Comments above) Moreover, it is possible that individual state regulations and retail tariffs may already define what load is considered critical and what can and cannot be shed during emergency operating conditions.  NERC should also recognize that separating identified critical natural gas infrastructure for this purpose is a consequential task that could be difficult or impractical to accomplish.  For example, the facility may be served by the only available distribution feeder in that area and separating that one facility might require the installation of a new distribution line or rerouting another feeder for the sole purpose of supplying what otherwise might be considered a small load. 

Alternatively, EOP-011-2 could address the oversight and planning issues, while PRC-006-5 (UFLS) and PRC-010-2-5 (UVLS) could be used for the implementation part avoiding adding the TOs and DPs to EOP-011-2.   Regardless of the approach, information from the natural gas infrastructure owners is needed.  Additionally, Transmission Service Providers may be a potential source for information regarding which natural gas facilities might be critical since they are responsible for administering transmission tariffs and providing transmission service to transmission customers.

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

- 0 - 0

MidAmerican Energy Company supports EEI and MRO NSRF comments

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

The NAGF has no comment regarding this recommendation.

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

- 0 - 0

LaKenya VanNorman, On Behalf of: Florida Municipal Power Agency - SERC - Segments 3, 4, 5, 6

- 0 - 0

Dana Showalter, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

- 0 - 0

Joe McClung, On Behalf of: JEA, , Segments 1, 3, 5

- 0 - 0

ACP does not have a recommendation on this question.

Michele Mihelic, On Behalf of: American Clean Power Association, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

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

- 0 - 0

Diana Torres, On Behalf of: Imperial Irrigation District, , Segments 1, 3, 5, 6

- 0 - 0

Minnesota Power agrees with MRO’s NERC Standards Review Forum (NSRF) comments.

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

- 0 - 0

BPA agrees with the comments submitted by the US Bureau of Reclamation with additional comments. BPA believes there is an opportunity to alleviate future issues by requiring Critical natural gas facility design to include on-site back-up generator(s) and Auto-Restoration plan(s).

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

- 0 - 0

Travis Fisher, On Behalf of: Electricity Consumers Resource Council (ELCON), , Segments 7

- 0 - 0

IRC SRC has categorized its response by Applicable Entity and Manual or Automatic load shedding.

Manual load shed

Transmission Operator (TOP): Expand EOP-011-2, R1, Part 1.2.5

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;

Balancing Authority (BA): Expand EOP-011-2, R2, Part 2.2.8

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;

Automatic load shed

Transmission Owners (TO) that own UFLS: Expand PRC-006-5 and any other relevant regional UFLS standards.

Distribution Providers (DP) that own UFLS: Expand PRC-006-5 and any other relevant regional UFLS standards

ISO/RTO Standards Review Committee, Segment(s) 2, 12/21/2021

- 0 - 0

Enel North America, Inc. supports Midwest Reliability Organization’s (MRO) NERC Standards Review Forum’s (NSRF) comments on this question.

Natalie Johnson, On Behalf of: Enel Green Power, , Segments 5

- 0 - 0

Exelon concurs with the comments submitted by the EEI for this question.

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

- 0 - 0

AZPS agrees with the comments provided by EEI such that PRC-006 may be the solution to incorporate the recommendation. However, AZPS does not agree with the recommendation as written as it is may not be feasible or economically advisable on how this would be implemented, more specifically “to protect critical natural gas infrastructure loads in our respective areas from firm load shed.” 

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

- 0 - 0

Hot Answers

EOP-011-2 (effective 4/1/2023).  Requirement 2, part 2.2.7 requires the BA’s Operating Plan(s) to mitigate Capacity Emergencies and Energy Emergencies within its Balancing Authority Area to include “use of Interruptible Load, curtailable Load and demand response”.  A revision of this requirement could address this recommendation.  However, it should be considered that the Balancing Authority may not be the entity that “designs” demand response programs with the end-use customers.  Are all BA’s positioned to prohibit use of critical natural gas infrastructure loads for demand response?

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

- 0 - 0

Tim Kelley, On Behalf of: Sacramento Municipal Utility District - WECC - Segments 1, 3, 4, 5, 6

- 0 - 0

Other Answers

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

- 0 - 0

EOP-011-3

DTE Energy - DTE Electric, Segment(s) 3, 5, 4, 12/8/2021

- 0 - 0

We would suggest EOP-011-2. 

Susan Sosbe, On Behalf of: Wabash Valley Power Association, , Segments 1, 3

- 0 - 0

Patti Metro, On Behalf of: National Rural Electric Cooperative Association, , Segments 3, 4

- 0 - 0

Suggest revising approved NERC Standard EOP-011-2 R2.2.1 and R2.2.8 to implement recommendation.

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

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

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

- 0 - 0

MRO NSRF recommends this recommendation be addressed in TOP-002-4, R4, Part 4.4.  Justification, R4. Each BA shall have an Operating Plan for the next-day that addresses: 4.4 Capacity and energy reserve requirements, including deliverability capability.

 

MRO NSRF notes that to ensure this recommendation is effective in producing the results anticipated, a corresponding requirement on those entities providing the Balancing Authority with demand response data; e.g. Distribution Providers, would also be necessary.

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

- 0 - 0

No Comment.

Michael Krum, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Reclamation recommends BAL-502-RF-03 be leveraged as the basis for a continent-wide standard to address this recommendation.

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

- 0 - 0

BAL-502 possibly.  Better to include in a new extreme weather standard that addresses all the above questions.

Consumers Energy Company, Segment(s) 1, 3, 4, 5, 11/29/2017

- 0 - 0

Kenisha Webber, On Behalf of: Entergy - Entergy Services, Inc., SERC, Segments NA - Not Applicable

- 0 - 0

Acciona Energy supports Midwest Reliability Organization’s (MRO) NERC Standards Review Forum’s (NSRF) comments on this question.

George Brown, On Behalf of: Acciona Energy North America, , Segments 5

- 0 - 0

Xcel Energy supports the comments submitted by EEI.

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

- 0 - 0

Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

- 0 - 0

-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

WECC Cold Weather SAR, Segment(s) 10, 12/17/2021

- 0 - 0

Recommend revising EOP-011-2

  • Revise EOP-011-2, R2 with new sub-requirement that states:
    • Balancing Authorities’ operating plans (for contingency reserves and to mitigate capacity and energy emergencies) are to prohibit use of critical natural gas infrastructure loads for demand response.”

Keith Jonassen, On Behalf of: ISO New England, Inc. - NPCC - Segments 2

- 0 - 0

Dominion Energy suppports the comments submitted by EEI. In addition, the prohibition on demand response is a market issue and shoudl be defined in a tarriff or market rules, not a reliability standard governing plans.

Dominion, Segment(s) 3, 5, 1, 9/19/2019

- 0 - 0

No comments

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

- 0 - 0

Michael DePalma, On Behalf of: Onward Energy, MRO, WECC, Texas RE, NPCC, Segments NA - Not Applicable

- 0 - 0

NPCC Regional Standards Committee no NGrid, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 12/20/2021

- 0 - 0

Eversource Group, Segment(s) 1, 3, 9/1/2021

- 0 - 0

FirstEnergy supports comments posted by EEI

FE Voter, Segment(s) 1, 3, 5, 6, 4, 12/20/2021

- 0 - 0

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

- 0 - 0

NRG Energy Inc.  has no comment regarding this recommendation as it is not related to GO/GOPs.

Patricia Lynch, On Behalf of: NRG - NRG Energy, Inc., , Segments 5, 6

- 0 - 0

Texas RE recommends the drafting team consider addressing Key Recommendations 1i, 1h, and 1j from the Joint Inquiry in a similar manner as they are all related to one another. The drafting team could consider the following standard categories:

  • Protection and Control (PRC), since the PRC standards already include undervoltage load shed and under frequency load shed;
  • Transmission Operations (TOP), since the TOP would be the responsible entity for be identifying and protecting critical natural gas infrastructure loads in their respective areas from firm load shed; 
  • Transmission Operations (TOP), since the BA would be the responsible entity for specifying the identification (and maintaining protection for) critical natural gas infrastructure loads in their respective areas to perform its analysis functions and Real-time monitoring; 
  • Transmission Planning (TPL), since it would be helpful for the Transmission Planners to understand which natural gas infrastructure loads are deemed critical for planning;
  • Emergency Preparedness and Operations (EOP), since this activity is most likely to occur during an emergency; and
  • Any combination of PRC, TOP, TPL, and EOP standards the drafting team sees fit. 

 

Additionally, Texas RE recommends including a requirement for corrective action during System restoration so it does not affect natural gas loads that are to be protected from firm load shed.  This could be included in the TOPs’ system restoration plans, as required in EOP-005.

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

- 0 - 0

N/A

Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

- 0 - 0

PG&E has participated in the preparation and supports the comments provided by the Edison Electric Institute (EEI) for Q1h.

PG&E All Segments, Segment(s) 1, 3, 5, 2/10/2020

- 0 - 0

BC Hydro suggest that TOP-002 and EOP-011 could be modified to address this recommendation.

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

- 0 - 0

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

- 0 - 0

Southern Company recommends that EOP-011-2 be revised to address the recommendation pertaining to the Balancing Authority operating plans related to the use of critical natural gas infrastructure loads for demand response.

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

- 0 - 0

This could possibly go under an IRO standard.

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

- 0 - 0

MPC supports comments submitted by the MRO NERC Standards Review Forum (NSRF).

Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1, 5

- 0 - 0

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

- 0 - 0

Santee Cooper, Segment(s) 1, 3, 5, 6, 12/21/2021

- 0 - 0

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

Alan Kloster, On Behalf of: Evergy - MRO - Segments 1, 3, 5, 6

- 0 - 0

We recommend incorporating into TOP-002-4, R4.

Donna Wood, On Behalf of: Tri-State G and T Association, Inc., , Segments 1, 3, 5

- 0 - 0

Given that demand response programs are voluntary, demand-side programs developed to incent customers to voluntarily reduce energy consumption during periods of peak demand, during high energy prices, and during extreme weather conditions, we are unaware of any Reliability Standard that could address this recommendation.  This recommendation may be more suitable to be addressed by state retail electric tariffs.  

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

- 0 - 0

MidAmerican Energy supports EEI and MRO NSRF comments

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

The NAGF has no comment regarding this recommendation.

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

- 0 - 0

LaKenya VanNorman, On Behalf of: Florida Municipal Power Agency - SERC - Segments 3, 4, 5, 6

- 0 - 0

Dana Showalter, On Behalf of: Electric Reliability Council of Texas, Inc., , Segments 2

- 0 - 0

Joe McClung, On Behalf of: JEA, , Segments 1, 3, 5

- 0 - 0

ACP does not have a recommendation on this question.

Michele Mihelic, On Behalf of: American Clean Power Association, NA - Not Applicable, Segments NA - Not Applicable

- 0 - 0

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

- 0 - 0

Diana Torres,