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Regional Reliability Standard (WECC) | FAC-501-WECC-3

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Start Date: 01/26/2022
End Date: 03/11/2022

Associated Ballots:

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Hot Answers

No designation as to yes or no. Insufficient information to conclude one way or another, a comment period was provided for the proposed changes by NERC. Feedback regarding consideration of comments provided is expected.

Alyssia Rhoads, On Behalf of: Public Utility District No. 1 of Snohomish County, , Segments 1, 4, 5

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SPP RTO, Segment(s) 2, 3/11/2022

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Other Answers

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

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Jessica Turk, On Behalf of: Avista - Avista Corporation, WECC, Segments NA - Not Applicable

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Hydro-Quebec Production as GO/GOP at NPCC has no comments. 

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

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

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No comments. 

Matthew Jaramilla, On Behalf of: Salt River Project, WECC, Segments NA - Not Applicable

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Jennifer Malon, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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

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

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Hot Answers

The adverse impact to reliability and commercial operation is taking additional time away from SMEs (that could otherwise be spent on entity reliability projects), to categorize and discuss the new proposed categories in Attachment A Section 2 Maintenance. I expect utilities to continue with their existing work practices. There appears to be redundant categories with the proposed two additional categories in Attachment A Section 2 Maintenance.

As it applies to Section C, M3 1.2, language and specificity is very important in interpreting applicability in which to achieve the intended and desired results being set forth in FAC-501. There is potential variation in interpretation of the proposed language. I provided a suggested edit I believe provides additional clarity.

Alyssia Rhoads, On Behalf of: Public Utility District No. 1 of Snohomish County, , Segments 1, 4, 5

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SPP RTO, Segment(s) 2, 3/11/2022

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Other Answers

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

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Jessica Turk, On Behalf of: Avista - Avista Corporation, WECC, Segments NA - Not Applicable

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Hydro-Quebec Production as GO/GOP at NPCC has no comments. 

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

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

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No comments. 

Matthew Jaramilla, On Behalf of: Salt River Project, WECC, Segments NA - Not Applicable

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Jennifer Malon, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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

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

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Hot Answers

No. However, one could argue the reduction in time spent addressing reliability issues, increases the probability for a non-desired event occurring on the BES. Compliance and reliability are not the same thing. Compliance in an internal control mechanism to document business decisions and work practices to give EROs, NERC, and FERC assurance the utility is following good work practices to prevent and/or limit impacts that occur due to an event on the BES.

Alyssia Rhoads, On Behalf of: Public Utility District No. 1 of Snohomish County, , Segments 1, 4, 5

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SPP RTO, Segment(s) 2, 3/11/2022

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Other Answers

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

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Jessica Turk, On Behalf of: Avista - Avista Corporation, WECC, Segments NA - Not Applicable

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Hydro-Quebec Production as GO/GOP at NPCC has no comments. 

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

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

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No comments. 

Matthew Jaramilla, On Behalf of: Salt River Project, WECC, Segments NA - Not Applicable

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Jennifer Malon, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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

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

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Hot Answers

Yes, time and resources impact the operating budgets and staff time burden in competitive markets. The new proposed language (added categories) could add additional burden in determining which category a maintenance methodology/work practice falls in to. The new categories potentially introduce inconsistencies across utilities, for a same/similar maintenance methodology/work practice, which would require additional correspondence with EROs about which category to define the Utility’s maintenance methodology/work practices fall in to. This would lead to additional burden on EROs to implement. As it applies to Attachment A, Section 2 Maintenance, the proposed added categories are redundant and can be combined. Recommend providing greater specificity/guidance in the existing categories, i.e.:

1. OEM manufacture based maintenance would fall under the time based approach.

2. Condition Based (a combo of health assessment and the way in which the equipment is operated)  is the same as risk based, consider combining versus a separate method, if there is a desire to provide parameters of what defines condition based maintenance then put the specifics under the condition based category section.

Again, as it applies to Section C, M3 1.2, language and specificity is very important in interpreting applicability in which to achieve the intended and desired results being set forth in NERC FAC-501. There is potential variation in interpretation of the proposed language. I provided a suggested edit I believe provides additional clarity.

Alyssia Rhoads, On Behalf of: Public Utility District No. 1 of Snohomish County, , Segments 1, 4, 5

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SPP RTO, Segment(s) 2, 3/11/2022

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Other Answers

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

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Jessica Turk, On Behalf of: Avista - Avista Corporation, WECC, Segments NA - Not Applicable

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Hydro-Quebec Production as GO/GOP at NPCC has no comments. 

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

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

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No comments. 

Matthew Jaramilla, On Behalf of: Salt River Project, WECC, Segments NA - Not Applicable

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Jennifer Malon, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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

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

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Hot Answers

  • The proposed Regional Reliability Standard has more specific criteria for the same requirements covered in a continent-wide standard.

Alyssia Rhoads, On Behalf of: Public Utility District No. 1 of Snohomish County, , Segments 1, 4, 5

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SPP RTO, Segment(s) 2, 3/11/2022

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Other Answers

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

- 0 - 0

Jessica Turk, On Behalf of: Avista - Avista Corporation, WECC, Segments NA - Not Applicable

- 0 - 0

Hydro-Quebec Production as GO/GOP at NPCC has no comments. 

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

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

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No comments. 

Matthew Jaramilla, On Behalf of: Salt River Project, WECC, Segments NA - Not Applicable

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Jennifer Malon, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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

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

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