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

2010-07.1 Vegetation Management | FAC-003-3 SAR

Description:

Start Date: 08/24/2015
End Date: 09/28/2015

Associated Ballots:

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

Filter:

Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

We support the changes to FAC-003, as they are aligned with the directives in FERC Order No. 777.  

ACES Standards Collaborators - FAC-003 Project, Segment(s) 1, 3, 5, 6, 4, 9/28/2015

- 0 - 0

Other Answers

John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

- 0 - 0

Tammy Porter, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

- 0 - 0

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

- 0 - 0

Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

- 0 - 0

The NSRF agrees with the SAR to update Table 2 MVCD’s with the EPRI findings.  

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

- 0 - 0

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

- 0 - 0

Molly Devine, On Behalf of: Molly Devine, , Segments 1

- 0 - 0

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

- 0 - 0

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

- 0 - 0

Duke Energy agrees with the scope and objectives of the SAR which appear to align MVCD with the empirical data stemming from the EPRI study.

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

- 0 - 0

Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

- 0 - 0

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

- 0 - 0

NPCC--Project 2010-07.1 Vegetation Management - FAC-003-3, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 9/28/2015

- 0 - 0

We agree with the scope and objective of the SAR. However, we would suggest to the drafting team to conduct a thorough evaluation of how the Gallet Equation was used in the previous calculation of the Minimum Vegetation Clearance Distance (MVCD) and current EPRI Study. We feel this evaluation will help develop a structural value for FAC-003 and ensure all concerns have been addressed in reference to the previous and future calculations for the gap factor.

SPP Standards Review Group, Segment(s) , 9/28/2015

- 0 - 0

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

- 0 - 0

Yes, FE Energy Delivery -Transmission Vegetation Management agrees with the scope and objectives of the SAR.
As a result of testing conducted by EPRI, at NERC's request, the MVCD listed in Standard FAC-003-3 required to prevent a flashover and improve the reliability of the Bulk Power System (BPS) will need to be increased. The EPRI report determined “that the proposed minimum vegetation clearance distances (MVCD), based on a gap factor of 1.3, should be increased and the corresponding gap factor reduced to a more conservative value of 1.0.” TVM clearances far exceed the new MVCD Table distances, therefore no objections or comments are necessary.

FE RBB, Segment(s) 1, 3, 4, 5, 0, 3/3/2015

- 0 - 0

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

- 0 - 0

Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

We would appreciate guidance regarding compliance with Table 2 in the interim while the proposed revisions of this SAR go through the development process and eventually approved by FERC and becomes enforceable.  FAC-003-2 requires that the MVCDs utilize a gap factor of 1.3, which is the current enforceable standard.  Is there going to be a change in compliance monitoring approaches prior to the issuance of FAC-003-4?  Any additional information relating to the NERC Advisory and how it relates to compliance with the standard would be helpful.

 

Thank you for the opportunity to comment.

ACES Standards Collaborators - FAC-003 Project, Segment(s) 1, 3, 5, 6, 4, 9/28/2015

- 0 - 0

Other Answers

John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

- 0 - 0

Tammy Porter, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

- 0 - 0

APS agrees with the findings of the EPRI study and supports modifications to the gap factors of the Gallet equation.

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

- 0 - 0

Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

- 0 - 0

Limit the FAC-003-4 modifications to the Table 2 MVCD update, only.

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

- 0 - 0

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

- 0 - 0

Molly Devine, On Behalf of: Molly Devine, , Segments 1

- 0 - 0

Page 2 - under Detailed Description; Dominion suggests the last sentence which says; “The drafting team will be modifying the standard based on the final report, which is scheduled to be released in July 2015.” be updated to reflect when the final report was released (July 2015 has past).

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

- 0 - 0

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

- 0 - 0

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

- 0 - 0

Southern Company, Segment(s) 1, 6, 3, 5, 4/13/2015

- 0 - 0

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

- 0 - 0

On page 2 of the SAR the last sentence under Detailed Description reads:

“The drafting team will be modifying the standard based on the final report, which is scheduled to be released in July 2015.”

This sentence should be revised to reflect the actual release date of the final report (August 15, 2015 from the NERC Website).

 

NERC’s May 14, 2015 Industry Advisory FAC-003-3 Minimum Vegetation Clearance Distances (MVCD) refers to “alternating current system voltages…”  Was any testing done for high voltage DC voltages?  The report apparently refers to only AC voltages.  The SAR should stipulate this.  What is the intention for addressing HVDC clearances?

The SAR should address a flexible Vegetation Control Cycle based on historic vegetation inspections from each area. 

NPCC--Project 2010-07.1 Vegetation Management - FAC-003-3, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 9/28/2015

- 0 - 0

SPP Standards Review Group, Segment(s) , 9/28/2015

- 0 - 0

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

- 0 - 0

FE RBB, Segment(s) 1, 3, 4, 5, 0, 3/3/2015

- 0 - 0

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

- 0 - 0