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2007-17.4 PRC-005 FERC Order No. 803 Directive | PRC-005-6

Description:

Start Date: 07/30/2015
End Date: 09/16/2015

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2007-17.4 PRC-005 FERC Order No. 803 Directive PRC-005-6 IN 1 ST 2007-17.4 PRC-005 FERC Order No. 803 Directive PRC-005-6 07/30/2015 08/28/2015 09/04/2015 09/16/2015
2007-17.4 PRC-005 FERC Order No. 803 Directive PRC-005-6 Non-binding Poll IN 1 NB 2007-17.4 PRC-005 FERC Order No. 803 Directive PRC-005-6 Non-binding Poll 07/30/2015 08/28/2015 09/04/2015 09/16/2015

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Hot Answers

With respect to requirements 4.2.7.1 and 4.2.7.2, automatic reclosing relays addressed are subject to an exemption if the owner of the equipment could demonstrate that a close-in three-phase fault present for twice the normal clearing time (capturing a minimum trip-close-trip time delay) does not result in a total loss of gross generation in the Interconnection exceeding the gross capacity of the largest relevant BES generating unit where the Automatic Reclosing is applied.  However, Hydro One Networks Inc. would like to suggest that the SDT consider indicating the timelines for demonstrating the above applicability.  For example, additional detail on what would trigger a system review, or intervals in which the system review should be performed, could be explicitly stated within the body of the standard.   

Oshani Pathirane, 9/16/2015

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The definition change is consistent with the FERC directive in Order 803.

ACES Standards Collaborators - PRC-005 Project, Segment(s) 1, 3, 5, 6, 4, 9/16/2015

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Other Answers

John Fontenot, 8/10/2015

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Meghan Ferguson, On Behalf of: International Transmission Company Holdings Corporation, MRO, SPP RE, RF, Segments 1

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The SDT needs to add to the definition of automatic reclosing to differentiate it from manual reclosing.  This could be a possible area of confusion with compliance auditors. 

Barbara Kedrowski, On Behalf of: WEC Energy Group, Inc., RF, Segments 3, 4, 5

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Andrew Pusztai, 9/4/2015

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Thomas Foltz, AEP, 5, 9/8/2015

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Jamison Dye, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Leonard Kula, Independent Electricity System Operator, 2, 9/9/2015

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 9/9/2015

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Gul Khan, 9/10/2015

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

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Adam Padgett, On Behalf of: TECO - Tampa Electric Co., FRCC, Segments 1, 3, 4, 5

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Southern Company, Segment(s) 1, 3, 5, 6, 3/27/2015

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John Fontenot, 9/14/2015

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John Fontenot, 9/14/2015

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 Dominion suggest that Version history 6 should be updated to be inclusive of the directive and read as; "Revised to add supervisory relays, the voltage sensing devices, and the associated control circuitry to Automatic Reclosing in accordance with the directives in FERC Order 803.   

Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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John Coggins, 9/15/2015

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Molly Devine, 9/15/2015

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The definition of Automatic Reclosing is not definitive on the functional aspect (Sudden Pressure Relaying provides functional aspect) and just delineates what Components are included.  Is that the standard drafting team’s intent?  Does the use of the term “Automatic Reclosing” in Table 4-1 Maintenance Activities make sense without a functional aspect being defined?

Rachel Coyne, Texas Reliability Entity, Inc., 10, 9/15/2015

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We do not believe this standard is needed.

PSEG, Segment(s) 1, 3, 5, 6, 7/21/2015

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Mike Smith, Manitoba Hydro , 3, 9/15/2015

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David Jendras, Ameren - Ameren Services, 3, 9/16/2015

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Duke Energy requests further clarification from the drafting team on the proposed definition of Automatic Reclosing. Is it the drafting team’s intent that the definition should incorporate all closings that happen automatically, or just Automatic Reclosing relays? There are some scenarios where there is an automatic closing, but no relay is present. There are also some instances where a Supervisory relay is not supervising a reclosing relay, and just providing a close command itself. Would these Supervisory relays that do not supervise an Automatic Reclosing relay be in scope? We ask the drafting team to clarify the intent of the definition, chiefly whether all automatic closing, even in the event that a relay is not present, falls under the scope of this standard, as well as our concern regarding the scope of Supervisory relays.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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Tacoma Power generally agrees with the revised definition of “Automatic Reclosing”; however, Tacoma Power recommends consistently using “supervisory relay(s)” or “supervisory relay(s) or function(s)” among the bulleted Component Types.

Chris Mattson, 9/16/2015

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NPCC--Project 2007-17.4 PRC-005 FERC Order No. 803 Directive - PRC-005-6, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 9/16/2015

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Jennifer Losacco, On Behalf of: NextEra Energy - Florida Power and Light Co., FRCC, Segments 1

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Thank you for the clarification which addresses the SRC’s comments on the SAR.

IRC Standards Review Committee, Segment(s) 2, 5/15/2015

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SPP Standards Review Group, Segment(s) 1, 3, 5, 9/16/2015

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Hot Answers

Hydro One Networks Inc. would like to suggest that, the wording of the title bar’s note be changed to read, “In cases where Automatic Reclosing Components are common to Components listed in Tables 1-3 and 1-5, the Components only need to be tested once during a distinct maintenance interval.”

Hydro One Networks Inc. would also like to suggest that Tables 4-2(a) and 4-2(b) title bars’ notes also be revised to read, “Automatic Reclosing Components”, instead of “Sudden Pressure Relaying”

Oshani Pathirane, 9/16/2015

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We identified a minor grammatical error in Table 1-1.  There is inconsistent capitalization of the acronym “AC” in the first bullet, which lists both “Ac” and “AC”.

We ask the drafting team to clarify in Table 4-1 the phrase “with preceding row attributes,” as the format of the table is unclear whether the reference is to all of the monitored microprocessor reclosing relays and supervisory relays, including Table 2, or just the supervisory relays with waveform sampling three or more times per power cycle.  The format of each table carrying over the header from the previous page makes the phrase “with preceding row attributes” unclear.

We appreciate the drafting team providing clarity in the note of Table 4-3 for cases where Components of Sudden Pressure Relaying are common to Components listed in Table 1‐5, the Components only need to be tested once during a distinct maintenance interval.

ACES Standards Collaborators - PRC-005 Project, Segment(s) 1, 3, 5, 6, 4, 9/16/2015

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Other Answers

John Fontenot, 8/10/2015

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The note on Table 4-3 needs to be updated with the correct information and table reference.

 

Currently, the Note on Table 4-3 reads: “Note: In cases where Components of Sudden Pressure Relaying are common to Components listed in Table 1‐5, the Components only need to be tested once during a distinct maintenance interval.”

 

The Note on Table 4-3 should be re-worded as: “Note: In cases where Automatic Reclosing Components are common to Components listed in Table 1‐3, the Components only need to be tested once during a distinct maintenance interval.”

Meghan Ferguson, On Behalf of: International Transmission Company Holdings Corporation, MRO, SPP RE, RF, Segments 1

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Barbara Kedrowski, On Behalf of: WEC Energy Group, Inc., RF, Segments 3, 4, 5

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Andrew Pusztai, 9/4/2015

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Thomas Foltz, AEP, 5, 9/8/2015

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Jamison Dye, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Leonard Kula, Independent Electricity System Operator, 2, 9/9/2015

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 9/9/2015

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Gul Khan, 9/10/2015

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

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Adam Padgett, On Behalf of: TECO - Tampa Electric Co., FRCC, Segments 1, 3, 4, 5

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Southern Company, Segment(s) 1, 3, 5, 6, 3/27/2015

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John Fontenot, 9/14/2015

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John Fontenot, 9/14/2015

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Dominion also suggests Table 1-1 (redline version page 18 of 41), 1st bullet be revised from “Ac measurements” to read as AC measurements..

Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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John Coggins, 9/15/2015

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Molly Devine, 9/15/2015

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Texas RE inquires as to why the standard drafting team choose 12 years for this Component Type.  In general, in most, not all, of the previous Tables provided for maintenance activities of any unmonitored relay had a 6 Calendar Year Minimum Maintenance Interval.   

 

Texas RE noticed Maintenance Activities of Table 4-1 are not consistent (e.g.- Row 1 states “Verify that settings are as specified” but Row 2 states “Verify: Settings are as specified” (in bullets)  but the format is backwards for the “Operation of the relay inputs…” statement in both rows.

 

Additional clarity may be needed between the Table 4-1 additions and Table 4-3.  In Table 4-1 there is a Component Attribute for supervisory relays that essentially states a 12 Calendar Year Maximum Maintenance Interval  for supervisory relays that have “AC measurements are continuously verified by comparison to an independent AC measurement source, with alarming for excessive error (See Table 2).”  In Table 4-3 “Voltage sensing devices that are connected to microprocessor supervisory relays with AC measurements that are continuously verified by comparison of sensing input value, as measured by the microprocessor relay, to an independent AC measurement source, with alarming for unacceptable error or failure. (See Table 2)” has no periodic maintenance specified.  Texas RE is concerned it appears an entity is required to do the “Maintenance Activity” described in Table 4-1 (“Verify acceptable measurement of power system input values.”) within 12 Calendar Years on the relays but is not required to do any Maintenance Activity on the voltage sensing devices.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 9/15/2015

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We do not believe this standard is needed.

PSEG, Segment(s) 1, 3, 5, 6, 7/21/2015

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Mike Smith, Manitoba Hydro , 3, 9/15/2015

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David Jendras, Ameren - Ameren Services, 3, 9/16/2015

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Duke Energy is unsure of the necessity of inserting the note: “Note: In cases where Components of Sudden Pressure Relaying are common to Components listed in Table 1-5, the Components only need to be tested once during a distinct maintenance interval” to Table 4-3. It doesn’t appear that the note is applicable to this Table. We recommend that the drafting team consider only including the Note on tables where it is best applicable.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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In Tables 4-2(a), 4-2(b), and 4-3, “Sudden Pressure Relaying” should be changed to “Automatic Reclosing.”

Chris Mattson, 9/16/2015

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NPCC--Project 2007-17.4 PRC-005 FERC Order No. 803 Directive - PRC-005-6, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 9/16/2015

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Jennifer Losacco, On Behalf of: NextEra Energy - Florida Power and Light Co., FRCC, Segments 1

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IRC Standards Review Committee, Segment(s) 2, 5/15/2015

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SPP Standards Review Group, Segment(s) 1, 3, 5, 9/16/2015

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Hot Answers

Oshani Pathirane, 9/16/2015

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We generally agree with the document, but question the need for listing PRC-005, PRC-008, PRC-011, and PRC-017 in the introduction.  This only creates confusion and will need to be revised when these standards are retired.  The implementation plan already covers these changes.  The introduction should explain the various FERC orders and the rationale for adding additional equipment to the scope of this standard.  While we understand that the supplementary reference is not mandatory nor enforceable, it should be drafted in a way that does not require constant updates or maintenance for each new version of the standard.

On page 98, the newly added FAQ regarding the parts of the control circuitry that need to be verified should clarify that the numbers listed in the bullets are IEEE device numbers.  Also, the format of this question makes it appear that all of the bullets are applicable and need to be verified.  The reader must get to the final sentence before they find that three of the six bullets do not need verification.  We ask the SDT to reword this question by removing the bullets and clarifying that IEEE device numbers 79, 25, and 27 or 59 would need to be verified while IEEE device numbers 79/ON, 52, and 86 do not.

We identified inconsistent capitalization for “AC,” “DC,” and “VAR”.  The standard capitalizes these words while the technical reference does not.  We recommend that the supplemental reference matches the same usage and capitalization as the standard.

ACES Standards Collaborators - PRC-005 Project, Segment(s) 1, 3, 5, 6, 4, 9/16/2015

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Other Answers

John Fontenot, 8/10/2015

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Meghan Ferguson, On Behalf of: International Transmission Company Holdings Corporation, MRO, SPP RE, RF, Segments 1

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Barbara Kedrowski, On Behalf of: WEC Energy Group, Inc., RF, Segments 3, 4, 5

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However, in the draft standard, the terms, “AC” and “DC” are capitalized.  However, in the FAQ Document, “ac” and “dc” are lower case.  ATC recommends using capitalization (or lack thereof) related to “AC” and “DC” consistently in both the standard and the FAQ Document.

Andrew Pusztai, 9/4/2015

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Thomas Foltz, AEP, 5, 9/8/2015

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Jamison Dye, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Leonard Kula, Independent Electricity System Operator, 2, 9/9/2015

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 9/9/2015

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Gul Khan, 9/10/2015

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

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Adam Padgett, On Behalf of: TECO - Tampa Electric Co., FRCC, Segments 1, 3, 4, 5

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Southern Company, Segment(s) 1, 3, 5, 6, 3/27/2015

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John Fontenot, 9/14/2015

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John Fontenot, 9/14/2015

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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John Coggins, 9/15/2015

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Molly Devine, 9/15/2015

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Texas RE noticed some references to version four of PRC-005, which could cause confusion:

  • Page four in the first paragraph, “PRC-005-4 would apply to this equipment”; and

  • Page Five in the FAQ section regarding Distribution Provider.

On page 20 of the Supplementary document there is a reference to CBM that appears incorrect (“if the condition of the device is continuously monitored (CBM).”)

Rachel Coyne, Texas Reliability Entity, Inc., 10, 9/15/2015

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We do not believe this standard is needed.

PSEG, Segment(s) 1, 3, 5, 6, 7/21/2015

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Mike Smith, Manitoba Hydro , 3, 9/15/2015

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David Jendras, Ameren - Ameren Services, 3, 9/16/2015

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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On page 24 of the redlined version of the Supplementary Reference and FAQ, the bottom box in the flowchart should show R5, not R3.

Chris Mattson, 9/16/2015

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Suggest a clarification in the definition of a synchronizing or synchronism check relay (Sync-Check - 25) as shown below:

“A synchronizing device that produces an output that supervises closure of a circuit breaker between two circuits whose voltages are within prescribed limits of magnitude and within the prescribed phase angle for the prescribed time.  It may or may not include voltage or speed control. A sync-check relay permits the paralleling of two circuits that are within prescribed (usually wider) limits of voltage magnitude and phase angle for the prescribed time.

NPCC--Project 2007-17.4 PRC-005 FERC Order No. 803 Directive - PRC-005-6, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 9/16/2015

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Jennifer Losacco, On Behalf of: NextEra Energy - Florida Power and Light Co., FRCC, Segments 1

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IRC Standards Review Committee, Segment(s) 2, 5/15/2015

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SPP Standards Review Group, Segment(s) 1, 3, 5, 9/16/2015

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Hot Answers

Oshani Pathirane, 9/16/2015

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We believe that unless there is an urgent reliability gap, revisions to PRC-005 should be limited to no more than once per year.  Frequent modifications to these requirements can have detrimental effects on electric system reliability due to rushed standards development and the possibility of inadequately reviewed relay test plans.

While we agree with the approach in the current implementation plan, we question the process of having multiple versions that have resulted in the conundrum that we face today.  Each effective version of PRC-005 should supersede all previous versions and include all current requirements for clarity.  We understand and appreciate that there are varied implementation dates for different requirements, but maintaining multiple versions is cumbersome, burdensome, and creates risk that a requirement is missed.  We believe confusion would be alleviated if the NERC Standards Department had a policy of requiring each standard revision have a whole number for the next applicable version.  For example, if PRC-005-2 is to be superseded, then PRC-005-2 would be retired and PRC-005-“3” would take precedence.  We strongly urge NERC to discontinue the practice of creating sub-sets with standard versions, such as “PRC-005-2(i)”.

ACES Standards Collaborators - PRC-005 Project, Segment(s) 1, 3, 5, 6, 4, 9/16/2015

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Other Answers

John Fontenot, 8/10/2015

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Meghan Ferguson, On Behalf of: International Transmission Company Holdings Corporation, MRO, SPP RE, RF, Segments 1

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Barbara Kedrowski, On Behalf of: WEC Energy Group, Inc., RF, Segments 3, 4, 5

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Andrew Pusztai, 9/4/2015

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Thomas Foltz, AEP, 5, 9/8/2015

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Jamison Dye, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Leonard Kula, Independent Electricity System Operator, 2, 9/9/2015

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The NSRF suggest the following up date as we believe it was a cut and paste error.

Tables 4-2(a), 4-2(b) and 4-3 have a note contained within the header that needs to be corrected.  The note states “Note:  In cases where Components of Sudden Pressure Relaying are common to Components listed in Table…”

The notes in these tables should be changed from Sudden Pressure Relaying to Automatic Reclosing.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 9/9/2015

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Gul Khan, 9/10/2015

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We strongly support the consolidation of the various PRC-005 Implementation Plans and believe this effort will eliminate much confusion and provide for a much more manageable change process.

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

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Eliminating multiple revisions of this standard will facilitate improved understandability of the standard while reducing the potential for errors in implementing the standard.

Adam Padgett, On Behalf of: TECO - Tampa Electric Co., FRCC, Segments 1, 3, 4, 5

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Southern Company supports the proposed implementation plan but, as noted early, feel that the the enforcement date of the already approved PRC-005-3 should immediately be placed on hold in order to coincide with the approval of this version of PRC-005.

Southern Company, Segment(s) 1, 3, 5, 6, 3/27/2015

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John Fontenot, 9/14/2015

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John Fontenot, 9/14/2015

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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John Coggins, 9/15/2015

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With the number of revisions, keeping track is becoming a full time job.

Molly Devine, 9/15/2015

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Texas RE understands registered entities need time to implement standards, but the extended timeframes for testing and maintenance of the components in the series of standards listed above is too long.  If registered entities are aware of the future need they should already be working to identify the Components (and associated maintenance schedules).  Texas RE is concerned there would be significant reliability risk if a registered entity was not maintaining a list of the relays it has implemented and when testing was completed on those implemented relays.  The extended timeframe, now possibly beyond 2030, could lead to misinterpretations and inconsistencies in registered entities practices and could impact auditing. 

 

Texas RE made the following additional observations:

  • There does not appear to be consistent use and applicability of relay types associated with term “relay” (e.g. In Table 4-1 there is a distinction made in Row 1 (page 34) between “microprocessor relays” and “non-microprocessor relays” AND “microprocessor supervisory relays”.)  This could lead to confusion.   If there is a “non-microprocessor supervisory relay” does an entity need to “Test and, if necessary calibrate”? It appears that verification requirements will apply to reclosing and supervisory relays and an additional requirement for microprocessor supervisory relays has been added.  Is that the intent? In Row 2, no distinction is made (i.e. “Verify: Settings are as specified” will apply to both reclosing relays and supervisory relays);

  • Section 1.3 “Compliance Monitoring and Assessment Processes” does not follow the Standards template; and

  • In Table 3 “Ac” at the beginning of a sentence on page 32 needs capitalized Page 18 Table 1-1 has similar issue).

Rachel Coyne, Texas Reliability Entity, Inc., 10, 9/15/2015

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We do not believe this standard is needed.

PSEG, Segment(s) 1, 3, 5, 6, 7/21/2015

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Manitoba Hydro disagrees with the imposed maintenance requirements introduced in PRC-005-6 through the merging of developed maintenance requirements from PRC-005-4.

Manitoba Hydro disagrees with the 6 calendar year maximum maintenance interval proposed in Table 5, relating to sudden pressure relays. Manitoba Hydro has never seen evidence that maintaining sudden pressure relays will in any way prevent instability, cascading outages, or islanding. If such evidence or peer-reviewed publications exist, please share them. Without such evidence, enforcing this maintenance falls outside of NERC’s mandate. Moreover, the System Protection and Control Subcommittee (SPCS) errs in believing that it is “more important to base intervals for fault pressure relaying on similar Protection System Components than transformer maintenance intervals.” (p 105 of the “PRC-005-4 Supplementary Reference and FAQ – October 2014”). Justification for this perspective is that maintaining sudden pressure relays necessitates transformer outages, which is not the case with most other protection system component maintenance. To avoid unnecessary reliability risks from these transformer outages, sudden pressure relay maintenance should be based on the transformer maintenance intervals, which in Manitoba Hydro’s case greatly exceeds six years.

As proposed, PRC-005-6 is mandating a reduction in the availability of equipment (transformers), reducing the reliability of the BES during these maintenance forced outages, without providing any additional security to the BES. The maintenance frequency appears to be arbitrarily aligned with maintenance intervals of other protective systems, which do not require outages or impose notable reliability risks to the BES during such maintenance.

Mike Smith, Manitoba Hydro , 3, 9/15/2015

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David Jendras, Ameren - Ameren Services, 3, 9/16/2015

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Duke Energy is supportive of the proposal to combine the Implementation Plans for all of the listed versions of PRC-005. Based on the approaching effective date of PRC-005-3, we encourage that the proposal to combine all Implementation Plans be considered and approved prior to PRC-005-3 effective date.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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Chris Mattson, 9/16/2015

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NPCC--Project 2007-17.4 PRC-005 FERC Order No. 803 Directive - PRC-005-6, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 9/16/2015

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Jennifer Losacco, On Behalf of: NextEra Energy - Florida Power and Light Co., FRCC, Segments 1

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IRC Standards Review Committee, Segment(s) 2, 5/15/2015

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The proposed implementation plan and request by NERC to align the implementations seem to address prior concerns with the staggered and confusing implementation dates.  Thank you for the effort.

SPP Standards Review Group, Segment(s) 1, 3, 5, 9/16/2015

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