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2022-01 Reporting ACE Definition and Associated Terms | Standard Authorization Request

Description:

Start Date: 02/09/2022
End Date: 03/10/2022

Associated Ballots:

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

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Hot Answers

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

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While Santee Cooper supports the intent of this SAR to allow Automatic Time Error Correction in any Interconnection that chooses to implement it, we believe that the scope should be revised to clarify the proposed new definitions and how the impacted standards will be addressed.

Santee Cooper, Segment(s) 1, 3, 5, 6, 3/10/2022

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Other Answers

No comments.

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

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

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Texas RE supports the purpose of the SAR to better align common terms across Interconnections.

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

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The ATEC component should be available to all interconnections and will allow for better management of interconnection time error and inadvertent. 

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

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Steven Rueckert, On Behalf of: Western Electricity Coordinating Council, , Segments 10

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

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

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Dwanique Spiller, On Behalf of: Berkshire Hathaway - NV Energy, WECC, Segments 5

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None.

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

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AZPS recognizes the need to clarify the current definition of Reporting Area Control Error (ACE) as it presents conflict with the Western Interconnection’s Automatic Time Error Correction (ATEC) process and the proposed change would reduce any confusion, however, AZPS agrees with EEI’s comments in that greater specificity in detail and technical justification is needed.  

AZPS supports the following commented submitted by EEI:

EEI notes that the SAR may have  merit but presently it lacks sufficient detail and technical justification to support its approval.  The SAR states that “Reporting ACE and Area Control Error (ACE (standalone term)) are both used over 100 times in the set of standards, guidelines, and reference documents” and therefore any change will have substantial impacts.  Therefore, EEI believes that any project that proposes to make change of this magnitude should be backed with a technical whitepaper explaining the need and containing a proposed solution. 

Among the questions that should be addressed in the whitepaper include the following:

1.     Please explain in greater detail the current accumulated time error issues within the Eastern Interconnection, and its cause.

2.     Please provide details to the proposed solution that the Resources Committee (RS) has developed to address the issue within the Eastern Interconnection, and other interconnections should it be needed.

3.     Please provide details and analysis on the impact of the proposed change; noting the expansive use of the terms Reporting ACE and ACE (standalone term) in Reliability Standards and Guidelines.

4.     The project also proposes to change the ATEC definition  used by WECC within their BAL-004-WECC-03 Reliability Standard.  How will the SDT ensure that any change made to this defined term will not have negative impacts on WECC processes and their BAL-004 Reliability Standard?  If this has already been done, those details should be included in the whitepaper.

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

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Casey Perry, On Behalf of: PNM Resources - Public Service Company of New Mexico - WECC - Segments NA - Not Applicable

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MRO NSRF, Segment(s) 2, 3, 5, 1, 4, 6, 1/20/2022

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

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Nazra Gladu, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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Marc Donaldson, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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EEI notes that the SAR may have  merit but presently it lacks sufficient detail and technical justification to support its approval.  The SAR states that “Reporting ACE and Area Control Error (ACE (standalone term)) are both used over 100 times in the set of standards, guidelines, and reference documents” and therefore any change will have substantial impacts.  Therefore, EEI believes that any project that proposes to make change of this magnitude should be backed with a technical whitepaper explaining the need and containing a proposed solution. 

Among the issues that should be addressed in the whitepaper include the following:

  1. Please explain in greater detail the current accumulated time error issues within the Eastern Interconnection, and its cause.
  2. Please provide details to the proposed solution that the Resources Committee (RS) has developed to address the issue within the Eastern Interconnection, and other interconnections should it be needed.
  3. Please provide details and analysis on the impact of the proposed change; noting the expansive use of the terms Reporting ACE and ACE (standalone term) in Reliability Standards and Guidelines.
  4. The project also proposes to change the ATEC definition  used by WECC within their BAL-004-WECC-03 Reliability Standard.  How will the SDT ensure that any change made to this defined term will not have negative impacts on WECC processes and their BAL-004 Reliability Standard?  If this has already been done, those details should be included in the whitepaper.

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

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We support the proposed scope as described in the SAR.

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 3/2/2022

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ISO/RTO Council (IRC) Standards Review Committee (SRC), Segment(s) 2, 3/10/2022

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CAISO agrees with comments submitted by the ISO/RTO Counsel (IRC) Standards Review Committee

Darcy O'Connell, On Behalf of: California ISO, , Segments 2

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

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

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SPP RTO, Segment(s) 2, 3/10/2022

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Hot Answers

MISO supports the comments submitted by the MRO NERC Standards Review Forum (MRO NSRF). Thank you.

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

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Santee Cooper, Segment(s) 1, 3, 5, 6, 3/10/2022

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Other Answers

No additional comments.

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

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

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

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

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Steven Rueckert, On Behalf of: Western Electricity Coordinating Council, , Segments 10

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

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

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Dwanique Spiller, On Behalf of: Berkshire Hathaway - NV Energy, WECC, Segments 5

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None.

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

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N/A

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

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No additional comments.

Casey Perry, On Behalf of: PNM Resources - Public Service Company of New Mexico - WECC - Segments NA - Not Applicable

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To ensure industry awareness, the MRO NSRF recommends the Standard Drafting Team (SDT) consider providing the list of applicable NERC documents (i.e. Standards, Reliability Guidelines and/or Technical Reference Documents) which have the potential to be impacted by proposed changes to the existing definitions as part of the Detailed Description on page 2. This is an efficient way to inform industry of potential impacts, thereby enhancing situational awareness which will aid entities in ensuring all compliance obligations are met.

MRO NSRF, Segment(s) 2, 3, 5, 1, 4, 6, 1/20/2022

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

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Nazra Gladu, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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Marc Donaldson, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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

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NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 3/2/2022

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ISO/RTO Council (IRC) Standards Review Committee (SRC), Segment(s) 2, 3/10/2022

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Darcy O'Connell, On Behalf of: California ISO, , Segments 2

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

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SPP recommends that the SAR Drafting Team consider adding a list of the applicable documents (Standards, Reliability Guideline, and Technical Reference Documents) which are impacted by the proposed definitions to the Detailed Description on page 2. Such action is an efficient way to ensure industry’s situational awareness of the various NERC documents that are impacted by these proposed definition revisions; and will aid registered entities in its compliance goals.

SPP RTO, Segment(s) 2, 3/10/2022

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