2020-05 Modifications to FAC-001 and FAC-002 | Draft 1

Description:

Start Date: 12/07/2021
End Date: 01/31/2022

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2020-05 Modifications to FAC-001 and FAC-002 FAC-001-4 and FAC-002-4 IN 1 ST 2020-05 Modifications to FAC-001 and FAC-002 FAC-001-4 and FAC-002-4 12/07/2021 01/10/2022 01/21/2022 01/31/2022
2020-05 Modifications to FAC-001 and FAC-002 Implementation Plan IN 1 OT 2020-05 Modifications to FAC-001 and FAC-002 Implementation Plan 12/07/2021 01/10/2022 01/21/2022 01/31/2022

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Hot Answers

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 9/1/2021

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While the proposed strategy itself may be sound overall, we are concerned by what the exact definition of “qualified change” might be after being developed by each Planning Coordinator. Transmission Planners may or may-not agree with a PC’s definition, and those entities would need to be provided an opportunity for the PC to hear their concerns, and be provided an opportunity to help shape the Planning Coordinator’s definition. In addition, the TP should have the ability to perform a determination as to whether they believe a system impact has occurred via a reliability impact study within FAC-002.

AEP appreciates the efforts of the Standard Drafting Team. We would like them to know that AEP‘s Negative votes on the proposed revisions for FAC-001 and FAC-002 are soley driven by the concerns expressed in our response to Question 1 (above). We hope these concerns might be addressed in a way that allows us to support this effort with our Affirmative votes.

Thomas Foltz, AEP, 5, 1/19/2022

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Other Answers

Use of the word “change” in the new definition is potentially misleading. For any “modification” of an interconnection, there is both a change in the physical system (topology, technology, etc.) as well as a change in system performance. The new term “qualified change” could be interpreted to include performance criteria as opposed to changes in topology or technology.  In other words, the intent of the new definition isn’t to require the PC to define system performance criteria for which to evaluate modified/changed interconnections, but rather to define what modifications/changes will require (trigger) system studies prior to placing them in service. An alternate term could be “Qualified System Modification (QSM)” to help cue the reader that this deals with the modification of the system (as was the term originally), not the subsequent change in impact to the system (i.e. not the performance criteria to evaluate against). 

 

CHPD, Segment(s) 5, 3, 6, 1/5/2022

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No, this will continue to add confusion and result in inconsistent results based on a Planning Coordinator's definition.  Entities that have multiple Planning Coordinators may have significant trouble in managing consistency, especially when these are in different Regions.  This will also be problematic during compliance audits where the burden will be on the entity to show it met each PC definition, no matter how badly the definition is written and how ambiguous it may be.

Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1, 3, 5, 6

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BHC agrees that “material modification” should be replaced. However, additional clarification to the term “qualified change” would be helpful for consistent application across ERO enterprise. A guideline providing additional specification and examples would be value-add. 

Jennifer Malon, On Behalf of: Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6

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Carl Pineault, Hydro-Qu?bec Production, 5, 1/17/2022

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Hot Answers

DTEE agrees that the Planning Coordinator (PC) is the appropriate entity to define a ”qualified change.” Consitent with the NAGF recommendations, DTEE requests a consistent “qualified change” definition be developed.

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 9/1/2021

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AEP has no objections to the PC being tasked with defining what a qualified change is, however please see our concerns regarding a) the Transmission Planner being given opportunity to help shape a definition as provided above in Response #1 and b) the importance of pursuing a phased implementation plan as provided below in Response #5.

Thomas Foltz, AEP, 5, 1/19/2022

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Other Answers

The Planning Coordinator may be the appropriate entity for this definition, however more clarification is needed to ensure the definition is being applied correctly. It is easy to see how in areas where there are multiple TO’s under a common PC that FAC-002-4 R6 would be useful, but what about circumstances where PC to PC coordination is required? There are many vertically integrated entities whereby the PC is the Tranmission Planner as well as the Tranmission Owner and adjacent systems (i.e. “affected systems”) are in another PC (see comments for #6 below regarding use of the term “affected systems”). For an interconnection request in one PC’s area, would that PC apply their own definition of a “qualified change” when evaluating impacts on a neighboring PC’s systems? It would be onerous to attempt to apply neighboring criteria when performing system studies. If the intent to apply internal criteria to external systems, it should be clearly stated.

CHPD, Segment(s) 5, 3, 6, 1/5/2022

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Entities may use multiple Planning Coordinators, some may be in different Regions.  For consistency, there should be one definition, not a patchwork of poorly written and ambiguous definitions.  This will put added burden and risk on the entities from the compliance staff who may disagree with the interpretations of the PC definitions.

Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1, 3, 5, 6

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Yes, the PC is the appropriate entity. A guideline providing additional specification and examples would be value-add. 

Jennifer Malon, On Behalf of: Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6

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Carl Pineault, Hydro-Qu?bec Production, 5, 1/17/2022

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Hot Answers

DTEE disgrees that a Lower Violation Risk Factor is aligned with a Severe Vioaltion Severity Level.

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 9/1/2021

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Thomas Foltz, AEP, 5, 1/19/2022

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Other Answers

CHPD, Segment(s) 5, 3, 6, 1/5/2022

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If you are asking the Planning Coordinators to make the definitions, then the PCs should determine how severe the violation should be.  The Drafting team is asking for us to approve a standard with a definition that is yet to be determined.  This puts the entities in a high risk situation with no recourse to debate the definition or the severity of the penalty.

Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1, 3, 5, 6

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BHC does not agree with the singular Severe VSL rating. The ratings should be provided in a tiered structure, similar to the suggestion below.

  • Severe – PC did not have a definition and did no not maintain a publicily available definition…
  • High – PC had a definition, but did not make the public
  • Moderate – PC had a definition, but was not public for an extended duration
  • Lower – PC had a definition, but not public for a small duration

Jennifer Malon, On Behalf of: Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6

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Carl Pineault, Hydro-Qu?bec Production, 5, 1/17/2022

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Hot Answers

A position on cost effectiveness of the proposed approach cannot be conducted until futher information is provided.

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 9/1/2021

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The proposed modifications appear to be cost effective, as they would continue to utilize the existing stakeholder planning and processes that are valued and have proven beneficial.

Thomas Foltz, AEP, 5, 1/19/2022

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Other Answers

CHPD, Segment(s) 5, 3, 6, 1/5/2022

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I do not see a cost/benefit analysis of this standard, how was cost effectiveness established?  What metrics were used?  How much did the problem cost, and how much will the solution cost?

Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1, 3, 5, 6

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BHC believes it would be cost effective with a guideline providing additional specification and examples. 

Jennifer Malon, On Behalf of: Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6

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Carl Pineault, Hydro-Qu?bec Production, 5, 1/17/2022

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Hot Answers

Consistent with the NAGF’s comments, DTEE is concerned with a 12 month implementation plan.  It may not provide enough time or clarity to ensure that entities within a Planning Coordinator area will have enough time to respond to the Planning Coordinator’s definition of a “qualiied change.”  We recommend a longer implementation plan for Generator Owners, perhaps eighteen (18) to twenty-four (24) months.

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 9/1/2021

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While the proposed implementation period for the revised FAC-002 may be sufficient, 12 months would *not* be sufficient for what has been proposed for the revised FAC-001. The PC’s will first require time of their own to develop their definitions through their list of stakeholders. Following that, the Transmission Planners would then need ample opportunity to update their appropriate procedures based on those new definitions. As a result, we believe a phased implementation approach for FAC-001 would be appropriate, one that allows the PC’s 12 months to both develop their definitions and potentially collaborate with their stakeholders on them, and a subsequent (i.e. not “concurrent”) 12 months for the Transmission Planners to update their procedures as needed.

Thomas Foltz, AEP, 5, 1/19/2022

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Other Answers

CHPD, Segment(s) 5, 3, 6, 1/5/2022

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A 12 month implementation is not sufficient, since we don't know how long it will take a PC to negotiate a definition for qualified change, when that will hit our planning process, and how it may impact our facilities.

Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1, 3, 5, 6

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BHC agrees with the 12-month implementation plan, but would recommend providing a guideline with additional specification and examples.

Jennifer Malon, On Behalf of: Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6

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12 months is OK

Carl Pineault, Hydro-Qu?bec Production, 5, 1/17/2022

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Hot Answers

Nothing futher, thank you.

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 9/1/2021

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Thomas Foltz, AEP, 5, 1/19/2022

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Other Answers

The term “affected systems” is also a FERC defined term which refers to “an electric system other than the Transmission Provider’s Transmission System that may be affected by the proposed interconnection.” Use of the term “affected systems” is confusing in a similar way as the term “materially modified” is confusing. Is it the intent of both FAC-001-4 and FAC-002-4 that wherever the term “affected system” is used it is in reference specifically to systems outside of the system to which the interconnection request is made? Because of industry familiarity with the FERC definition, it is inferred that NERC’s meaning of the term affected system is not in reference to a utility’s own system but rather to any impacted neighboring system. However, it appears that the use of the term “affected systems” in FAC-002-4 is meant to cover both the system being interconnected to as well as other surrounding systems, although it’s not clear. For example, is the intention of FAC-002-4 R1.1 to only evaluate “the reliability impact… on affected systems,” meaning those systems outside of the the interconnection request, or is the intent to evaluate the reliability impact to all systems that may be impacted, both the interconnecting system as well as surrounding systems? Use of the term in FAC-001-4 R3 and R4 appears to be more consistent with the FERC definition, but clarification of the intent of the term “affected system” would help ensure consistent interpretation.

CHPD, Segment(s) 5, 3, 6, 1/5/2022

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These changes seem to punt the problem to the Planning Coordinators, do not promote consistency throughout the industry, and will add risk to the facility owners who may have to show compliance to multiple definitions of multiple PCs.

Kevin Conway, On Behalf of: Public Utility District No. 1 of Pend Oreille County, , Segments 1, 3, 5, 6

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BHC would recommend eliminating the “make publicly available” verbiage as it has not been utilized within other Reliability Standards. Recommendations for replacement may include “make available the current definition” as identified in MOD-001-1a R5.

Jennifer Malon, On Behalf of: Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Seth Nelson, Black Hills Corporation, 1,3,5,6; Derek Silbaugh, Black Hills Corporation, 1,3,5,6; Don Stahl, Black Hills Corporation, 1,3,5,6

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Carl Pineault, Hydro-Qu?bec Production, 5, 1/17/2022

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