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2010-07.1 Vegetation Management | FAC-003-4

Description:

Start Date: 10/30/2015
End Date: 12/16/2015

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2010-07.1 Vegetation Management FAC-003-4 IN 1 ST 2010-07.1 Vegetation Management FAC-003-4 10/30/2015 11/30/2015 12/07/2015 12/16/2015

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Hot Answers

Oshani Pathirane, 12/16/2015

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We agree with the values listed in Table 2, as derived from EPRI’s empirical studies.

ACES Standards Collaborators, Segment(s) 1, 3, 4, 5, 6, 12/16/2015

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Other Answers

John Fontenot, 10/30/2015

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William Hutchison, On Behalf of: Southern Illinois Power Cooperative, , Segments 1

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John Falsey, On Behalf of: Invenergy LLC, FRCC, MRO, WECC, Texas RE, NPCC, SERC, SPP RE, RF, Segments 5, 6

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Rob Robertson, On Behalf of: Rob Robertson, , Segments 5

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

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

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ATCO Electric, Segment(s) 1, 6/2/2014

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Maryclaire Yatsko, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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The tables are missing columns (or the headers are wrong) and have some number transpositions. In the english (ft) version of the table the range between 13000' and 14000' is missing. Additionaly the rounding mathematics used to generate the tables may not be the most conservative. For clearances one should round up in all instances.

There is no issue with the underlying clearance numbers that resulted from the laboratory testing. The issue is with the translation into the standard. It appears some more quality control and independent review should have been applied.

Herb Schrayshuen, Herb Schrayshuen, 5, 12/7/2015

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While AEP does not object to the newly-proposed English values in Table 2, these values are not equivalent to the metric values provided in the same table. AEP requests that the drafting team review both the English and Metric values, and provide corrections as necessary.

 

Thomas Foltz, AEP, 5, 12/9/2015

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See comments from TransEnergie

Roger Dufresne, 12/9/2015

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

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Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 11/11/2015

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Michelle Amarantos, APS - Arizona Public Service Co., 5, 12/9/2015

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

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Laura Nelson, 12/9/2015

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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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John Fontenot, 12/10/2015

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There are several typos in the table. In the "over 2133.6 m to 2438.4 m" column, the cell for 345 kV should be 1.5m, not .5m and the cell for 115 kV should be 0.7m, not .07m.

The added columns on the English table are missing the 13,000-14,000 ft range. The added columns on the Metric table stop at 14000 ft. The 14000-15000 ft column is not there. The two tables are inconsistent.

MVCD in the DC table did not change. Is this correct?

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

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Andrew Pusztai, 12/11/2015

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Please see WECC's position paper for details

Angela Gaines, On Behalf of: Portland General Electric Co., WECC, Segments 1, 3, 5, 6

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The following is an excerpt from the WECC position paper:

In summary, the following changes should be made before approval:

·         Correct the Functional Entity from “Planning Authority” to “Planning Coordinator”

·         The added columns in Table 2 for vegetation management over 12,000ft are superfluous and not needed.

·         Although not needed, the column for 14,000 to 15,000 is inadvertently skipped.

·         Table 2 – (meters) contains typographical errors; A) for Over 2133.6 m, 345kV MVCD should be 1.5, not .5m; and B) for Over 2133.6 m, 115kV MVCD should be 0.7, not .07m,

·         Although distances for AC lines are increased by 30% due to the study, there has been no increase in the distances for the DC lines, and no explanation is given. These distances should be considered for revision.

·         For ease-of-use, the columns from “Over sea level up to 500 ft” and “Over 500 ft up to 1000 ft” should be combined to a single column “Over sea level up to 1000 ft”…only one cell will change by one tenth of a foot in only the 765kV voltage class.

·         The elevation columns in the “meters” page of Table 2, are calculated to exactly match the elevations in feet, in the process the elevations given are un-workable.  Elevations of 304.8m, 609.6m, 914.4m, etc. should be changed to 300m, 600m, 900 m.  The MVCD’s (rounded to within one tenth of a foot) will not change.

·         In Table 2 for Direct Current, the MVCD’s are calculated to within one hundredth of a foot – this is an un-workable level of precision.

Steve Wenke, 12/14/2015

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

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Texas RE noticed the following:

  • There is not an “Over 13000 ft up to 14000 ft” column provided.  Should there be?

  • There is an incorrect value in the MVCD meters table in the last two columns.  One column references “….up to 3962m” and the final column references “Over 3692 m….” so there appears to be transposed values

  • On Table 2, there is no column for Over 13000 ft up to 14000 ft.  The values in the “Over 14000 ft up to 15000 ft”  within the Standard match the values of the “Over 13,000 ft up to 14,000 ft” values in the May 14, 2015 Industry Advisory.  Is that correct?  Based on the nature of the data (a general increase for most, if not all, 1000 ft elevation increase) it does not appear reasonable.

  • It does not appear that there is consistency in the values.  When you review the voltage levels increasing (e.g. 230 kV to 287 kV) it appears that the MVCD increase (e.g., at “sea level up to 500 ft” the MVCD increase from 4.0 ft to 5.2 ft).  The increasing pattern appears to not be followed when it reaches the 345 kV level.  The MVCD actually decreases when compared to a 287 kV level.  Why does that occur?  Was there a different parameter used in the derivation of Gallet’s equation for the 345 kV level?  Ascertaining the correct value for the 345 kV level is highly critical for the ERCOT Interconnection (in both measurement type versions of the table.)

  • Similar to the comment above, the MVCD for 345 kV lines from 2133.6m to 2438.4m is .5m, which is less than the MVCD of 1.5m and 1.6m for the altitudes immediately before and after in the table.  This appears to be a typo and the MVCD for 345 kV lines 2133.6m to 2438.4m should be 1.5m.

  • Table 2 for AC Voltages does not include lines at altitudes between 3352.8m and 3353m.

  • There appears to be an inconsistency in the “meter” version of Table 2.  The “older columns” have decimal point step increases (e.g. “Over 2133.6m up to 2438.4m”) that are carried over to the next columns as a starting point (e.g. “Over 2438.4m up to….”).  The new columns do not utilize the same formatting.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 12/14/2015

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Erika Doot, 12/14/2015

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SRP appreciates the opportunity to review and comment on the adjustments to the standard. We support the work of the drafting team, but request a review and revision of the tables to reflect issues identified in the WECC position paper including:

  • The column for 14,000 to 15,000 is inadvertently skipped.
  • Table 2 – (meters) contains typographical errors; A) for Over 2133.6 m, 345kV MVCD should be 1.5, not .5m; and B) for Over 2133.6 m, 115kV MVCD should be 0.7, not .07m,
  • Although distances for AC lines are increased by 30% due to the study, there has been no increase in the distances for the DC lines, and no explanation is given. These distances should be considered for revision.
  • For ease-of-use, the columns from “Over sea level up to 500 ft” and “Over 500 ft up to 1000 ft” should be combined to a single column “Over sea level up to 1000 ft”…only one cell will change by one tenth of a foot in only the 765kV voltage class.
  • The elevation columns in the “meters” page of Table 2, are calculated to exactly match the elevations in feet, in the process the elevations given are un-workable.  Elevations of 304.8m, 609.6m, 914.4m, etc. should be changed to 300m, 600m, 900 m.  The MVCD’s (rounded to within one tenth of a foot) will not change.
  • In Table 2 for Direct Current, the MVCD’s are calculated to within one hundredth of a foot – this is an un-workable level of precision

Diana McMahon, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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We support WECC Position paper, Dec 7, 2015: Table 2 – (meters) contains typographical errors; A) for Over 2133.6 m, 345kV MVCD should be 1.5, not .5m; and B) for Over 2133.6 m, 115kV MVCD should be 0.7, not .07m,

Seattle City Light Ballot Body, Segment(s) 1, 3, 4, 6, 5, 9/11/2015

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RSC without Con Edison, Segment(s) 1, 0, 2, 3, 4, 5, 6, 7, 12/16/2015

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BC Hydro agrees with the revised Table 2 MVCD values based on a Gallet equation gap factor of 1.0.  However we would point out one typo on the metric distance table for 345 kV in the 2133.6-2438.4 m elevation column.  The distance stated should be 1.5 m not 0.5 m as in the table and should be corrected.

BC Hydro, Segment(s) 1, 2, 3, 5, 5/6/2015

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Peter Heidrich, 12/16/2015

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Hetch Hetchy Water and Power believes the changes recommended in the attached WECC FAC-003-4 position paper should be considered prior to the approval of FAC-003-4.  

Daniel Mason, 12/16/2015

12-10-15 WECC Position Paper on FAC-003-4.docx

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Our group is in support of table 2 however, we have discovered that the values are not equivalent to the metric values provided in the same table. We would requests that the drafting team review both the English and Metric values, and provide corrections as necessary.

SPP Standards Review Group, Segment(s) 0, 12/16/2015

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Hot Answers

Hydro One Networks Inc. does not agree with the elevation levels specified in Table 2.  There are also a few minor modifications that need correction in Table 2.

Oshani Pathirane, 12/16/2015

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We recommend the SDT consider adding a graph, possibly on a logarithmic scale, to clearly list the values for each elevation.  The revised table is congested with the additional information and should be modified for easier readability.

ACES Standards Collaborators, Segment(s) 1, 3, 4, 5, 6, 12/16/2015

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Other Answers

John Fontenot, 10/30/2015

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William Hutchison, On Behalf of: Southern Illinois Power Cooperative, , Segments 1

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John Falsey, On Behalf of: Invenergy LLC, FRCC, MRO, WECC, Texas RE, NPCC, SERC, SPP RE, RF, Segments 5, 6

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Rob Robertson, On Behalf of: Rob Robertson, , Segments 5

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

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

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ATCO Electric, Segment(s) 1, 6/2/2014

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Maryclaire Yatsko, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Yes, but the tree line in North America may not be that high.

 

Herb Schrayshuen, Herb Schrayshuen, 5, 12/7/2015

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Thomas Foltz, AEP, 5, 12/9/2015

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See comments from TransEnergie

Roger Dufresne, 12/9/2015

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Table 2 - Minimum Vegetation Clearance Distances (MVCD) For Alternating Current Voltage (feet) is missing the data column located between “Over 12,000 ft” and “Over 14,000 ft”.  The column “Over 13, 000 ft” is not included in the table.

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

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Hydro-Quebec TransEnergie support NPCC comments

Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 11/11/2015

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Michelle Amarantos, APS - Arizona Public Service Co., 5, 12/9/2015

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

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Idaho Power's transmission system has no facilities at or near the stated elevation.

Laura Nelson, 12/9/2015

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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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John Fontenot, 12/10/2015

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Do not understand the need to go this high. I believe it is well above the treeline/timberline. If there is no vegetation, there is no need to manage it.

4267 meters is only 14000 feet not 15000 feet.

However, as long as the tables are consistent, we don't have any problems if they go this high.

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

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Andrew Pusztai, 12/11/2015

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Please see WECC's position paper for details

Angela Gaines, On Behalf of: Portland General Electric Co., WECC, Segments 1, 3, 5, 6

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Steve Wenke, 12/14/2015

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

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Texas RE inquires: was there any consideration for establishing MVCDs for lines that are below sea level (e.g., New Orleans or Death Valley)?

Please see Texas RE’s observations in #1.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 12/14/2015

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Erika Doot, 12/14/2015

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Diana McMahon, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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We support WECC Position paper, Dec 7, 2015: Table 2 – (meters) contains typographical errors; A) for Over 2133.6 m, 345kV MVCD should be 1.5, not .5m; and B) for Over 2133.6 m, 115kV MVCD should be 0.7, not .07m,

Seattle City Light Ballot Body, Segment(s) 1, 3, 4, 6, 5, 9/11/2015

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In table 2 Minimum Vegetation Clearance Distances (MVCD meters) the last two column headers are mislabeled. The last two columns should be “Over 3657m up to 3962m and Over 3962m up to 4267m” per the NERC report.

In Table 2 Minimum Vegetation Clearance Distances (MVCD feet), the last two column headers are mislabeled. In the NERC report the last column is labeled 13,000 ft up to 14,000 ft.

RSC without Con Edison, Segment(s) 1, 0, 2, 3, 4, 5, 6, 7, 12/16/2015

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BC Hydro, Segment(s) 1, 2, 3, 5, 5/6/2015

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However, the 'feet' and 'meter' versions of Table 2 for AC are either missing a column or the last column is mislabeled.

Peter Heidrich, 12/16/2015

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Hetch Hetchy Water and Power believes the changes recommended in the attached WECC FAC-003-4 position paper should be considered prior to the approval of FAC-003-4.

Daniel Mason, 12/16/2015

12-10-15 WECC Position Paper on FAC-003-4.docx

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SPP Standards Review Group, Segment(s) 0, 12/16/2015

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Hot Answers

While Hydro One Networks Inc. feels that the standard needs a few minor modifications and corrections, we generally support the intent of the standard.  Hydro One Networks Inc. further supports the comments provided by the NPCC.  Hydro One Networks Inc. agrees with the NPCC in that the “Planning Coordinator”, as opposed to the “Planning Authority”, should be an applicable functional entity for the standard.

Oshani Pathirane, 12/16/2015

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(1)            We question the modification from Planning Coordinator to Planning Authority.  The NERC Glossary defines the PC, but not the PA.  If the SDT is striving for consistency with FAC-014, we suggest developing a SAR to replace the outdated reference of the Planning Authority with the current Planning Coordinator term.  It is surprising that the standards still have two terms for a single registered function.  The Functional Model Working Group is conducting a review of the NERC Functional Model, and we suggest that the SDT discuss this change with them for guidance going forward.

 

(2)            The timelines of the Implementation Plan are reasonable.  However, we recommend copying the same language from the standard to the Implementation Plan for consistency.

 

(3)            We also find Section C. Compliance, Section 1.2 Evidence Retention, second bullet, redundant, as “unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation” is already listed at the beginning of the section.

 

(4)            We thank you for this opportunity to comment.

ACES Standards Collaborators, Segment(s) 1, 3, 4, 5, 6, 12/16/2015

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Other Answers

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John Fontenot, 10/30/2015

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None

William Hutchison, On Behalf of: Southern Illinois Power Cooperative, , Segments 1

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John Falsey, On Behalf of: Invenergy LLC, FRCC, MRO, WECC, Texas RE, NPCC, SERC, SPP RE, RF, Segments 5, 6

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Rob Robertson, On Behalf of: Rob Robertson, , Segments 5

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

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

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ATCO Electric, Segment(s) 1, 6/2/2014

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In the applicability section of FAC-003-4, the Standard applies in bullet 4.2.1 to “Each overhead transmission line operated at 200 kV or higher.”  Please comment on whether FAC-003-4 applies to non-BES lines in addition to BES lines.  For example, if a 230 kV line is excluded from the BES because it is a load serving only radial line, does FAC-003-4 apply to this line as it is a transmission line operated at over 200 kV?

Maryclaire Yatsko, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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It appears that the standard is moving back to the use of the term Planning Authority. NERC's practice in standards development has been moving toward the term Planning Coordinator as the common definition. This standard shold use Planning Coordinator in a future revision before final industry approval.

4.2.2. Each overhead transmission line operated below 200kV identified as an element of an IROL under NERC Standard FAC-014 by the Planning Authority. <===== should be Planning Coorindator

Herb Schrayshuen, Herb Schrayshuen, 5, 12/7/2015

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AEP agrees with the direction that the project team is taking, and supports their overall efforts. AEP’s negative vote is driven solely by the apparent lack of equivalency between the English and Metric values that have been proposed for Table 2, and we look forward to potential corrections in the subsequent version of the draft.

 

Thomas Foltz, AEP, 5, 12/9/2015

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Roger Dufresne, 12/9/2015

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Dominion supports the additional comments of NPCC. 

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

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Hydro-Quebec TransEnergie support NPCC comments

Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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The NSRF agrees with the associated changes.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 11/11/2015

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While the proposed FAC-003-4 provides additional clearance, APS believes that there are still gaps to address. The testing was done at the EPRI testing facility but not under all weather, topography, atmosphere conditions and variances in tree species.  APS is concerned these clearance distances are still too restrictive to ensure reliability of the grid.  To compound the issue, these clearances are real-time observations that don’t take into account line loading (sag), temperature and time of day.  APS would recommend an additional 10 feet of clearance to safeguard the reliability of the grid.

Michelle Amarantos, APS - Arizona Public Service Co., 5, 12/9/2015

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

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Laura Nelson, 12/9/2015

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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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John Fontenot, 12/10/2015

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Thank you for the opportunity to comment on the standard.

For appearance, all column widths on the tables should be the same. Values in some of the cells do not line up with the other values. This makes the table look sloppy.

I recognize that the ranges on the Metric table columns are exact translations of the 1000 foot ranges, but the numbers identifying the elevation for each column are not how entities that use the Metric System rather than the English System are going to think. No one is going to think in terms of 914.4 to 1219.2 meters. They are going to think in even numbered terms (900-1200 meters). Taking the direct translation rather than fixed, rounded terms is a slap in the face to those using the Metric System. That would be like labeling the English column 2952.7 - 3937.1 feet. The Metric column ranges should be even meters and the values in the cells adjusted accordingly.

R1 and R2 are identical in every way except the facilities that they refer to. Together they refer to all facilities. The VRFs and VSLs are also identical. I disagree with the need to separate them into two different requirements becasue the facilities in R1 are more significant. Compliance enforecement has the discretion to handle a violation differently if it is an element of an IROL or a Major WECC Path. The standard doesn’t need two requirements for the same thing.

We have attached a redline version of FAC-003-4 that includes addtional suggested changes and the reasons for the suggestions.

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

FAC-003-4_Results_Based_Standard_WECC Comments.docx

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ATC has identified the following recommended improvements for consideration by the SDT to the draft Standard .

  • Regarding the Applicability of Facilities Section 4.2.2., American Transmission Company (ATC) recommends revising the language for clarity, to read:  “Each overhead transmission line operated below 200 kV identified as an element of a Planning Horizon IROL…”
  • Similarly, ATC recommends revising the language of R1 to read:  “Each applicable Transmission Owner and applicable Generator Owner shall manage vegetation to prevent encroachments into the Minimum Vegetation Clearance Distance (MVCD) of its applicable line(s) which are either an element of a Planning Horizon IROL,…”
  • ATC suggests updating the language of R2 to read:  Each applicable Transmission Owner and applicable Generator Owner shall manage vegetation to prevent encroachments into the MVCD of its applicable line(s) which are not either an element of a Planning Horizon IROL,…”
  • R5 contains a grammatical error and should state:  “When an applicable…”
  • ATC recommends making updates corresponding to those above to Categories 1A, 1B, 2A, 2B, 4A, and 4B identified on pgs. 13-14:  “Category 1A — Grow-ins: Sustained Outages caused by vegetation growing into applicable lines, that are identified as an element of a Planning Horizon IROL …,” “Category 1B — Grow-ins: Sustained Outages caused by vegetation growing into applicable lines, but are not identified as an element of a Planning Horizon IROL…,” “Category 2A — Fall-ins: Sustained Outages caused by vegetation falling into applicable  lines that are identified as an element of a Planning Horizon IROL…,” “Category 2B — Fall-ins: Sustained Outages caused by vegetation falling into applicable lines, but are not identified as an element of a Planning Horizon IROL…,” “Category 4A — Blowing together: Sustained Outages caused by vegetation and applicable lines that are identified as an element of a Planning Horizon IROL…,” and “Category 4B — Blowing together: Sustained Outages caused by vegetation and applicable lines, but are not identified as an element of a Planning Horizon IROL…”
  • ATC recommends updating the proposed language in the Guidelines and Technical Basis section (pg. 24) to read:  “The special case is needed because the Planning Authorities may designate lines below 200 kV to become elements of a Planning Horizon IROL…A line operating below 200kV designated as an element of a Planning Horizon...”
  • The Project 2010-07.1 Adjusted MVCDs per EPRI Testing section (pg. 26) needs grammatical correction:  “The advisory team was comprised of NERC staff, arborists, and industry members with wide-ranging expertise in transmission engineering, insulation coordination, and vegetation management…Based on these testing results conducted by EPRI, and consistent with the report filed in FERC Docket No. RM12-4-000, the gap factor used in the Gallet equation required adjustment from 1.3 to 1.0…”
  • The Requirements R1 and R2 section (pg. 27) should be updated to read:  “R1 is applicable to lines that are identified as an element of a Planning Horizon IROL or Major WECC Transfer Path.  R2 is applicable to all other lines that are not elements of Planning Horizon IROLs,... The separation of applicability (between R1 and R2) recognizes that inadequate vegetation management for an applicable line that is an element of a Planning Horizon IROL or a Major WECC Transfer Path is a greater risk to the interconnected electric transmission system than applicable lines that are not elements of Planning Horizon IROLs or Major WECC Transfer Paths.  Applicable lines that are not elements of Planning Horizon IROLs or Major WECC Transfer Paths do require effective vegetation management, but these lines are comparatively less operationally significant.”

Andrew Pusztai, 12/11/2015

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PGE is in agreement with WECC as outlined in their position paper and is casting a "No" vote for this standard.  WECC's position paper is attached.

Angela Gaines, On Behalf of: Portland General Electric Co., WECC, Segments 1, 3, 5, 6

12-10-15 WECC Position Paper on FAC-003-4.docx

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Steve Wenke, 12/14/2015

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Duke Energy would like to point out to the SDT, that there appears to be an omission on Table 2  of the MVCD range of “over 13,000ft up to 14,000ft”. The columns currently lists ranges from 12,000ft to 13,000ft, and then moves to 14,000ft to 15,000ft skipping over the 13,000 to 14,000ft range. Duke Energy recommends adding an additional column to include the omitted MVCD range.

Duke Energy would also like to point out that there are some inconsistencies with the number of decimal places that are used in Table 2 of the currently enforceable FAC-003-3. In some instances one decimal place is used (ex. 8.2ft) and others where two decimal places are used (ex. 8.33ft). We recommend that a consistent approach be used going forward regarding the minimum MVCD levels, and that all values use the same number of decimal places in Table 2.

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

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Texas RE noticed in R1.1, the table is referenced as FAC-003-Table 2.  In the VSLs, the table is referenced as FAC-003-4-Table 2.  Texas RE recommends changing the requirement language to match the VSL language to eliminate confusion and clearly indicate the table for version 4 of the standard.

 

Texas RE noticed the VSL for R2 references FAC-003-4-Table 2 but the Requirement language itself does not.  Texas RE recommends the requirement language reference Table 2 in order to be consistent with the VSL language.  Should Requirement 2 language include the same phrase, “as shown in FAC-003-Table 2” with or without the “-4” reference, as Requirement 1? 

 

Texas RE inquires:  does the table in the supplemental material (titled “Comparison of spark-over……”) need to be changed based on the EPRI review?

 

Texas RE recommends reviewing the footnotes for consistency.  Footnotes 9, 10, and 11 reference Footnotes 4, 5, and 6, while Footnotes 17, 19, and 21 are identical but all include the full language of the footnote. Footnotes 18 and 20 are also identical, but footnote 20 includes the full language instead of “See footnote 18”.

 

For example, Texas RE noticed two footnotes with similar language.  On Page 8 of the Standard there is a footnote, #4, that is then referenced on Page 9 by footnote #9: “This requirement does not apply to circumstances that are beyond the control of an applicable Transmission Owner or applicable Generator Owner subject to this reliability standard, including natural disasters such as earthquakes, fires, tornados, hurricanes, landslides, wind shear, fresh gale, major storms as defined either by the applicable Transmission Owner or applicable Generator Owner or an applicable regulatory body, ice storms, and floods; human or animal activity such as logging, animal severing tree, vehicle contact with tree, or installation, removal, or digging of vegetation. Nothing in this footnote should be construed to limit the Transmission Owner’s or applicable Generator Owner’s right to exercise its full legal rights on the ROW. “

 

On Page 11 in Footnote #15 there is a similar sentence to Footnote #4; “Circumstances that are beyond the control of an applicable Transmission Owner or applicable Generator Owner include but are not limited to natural disasters such as earthquakes, fires, tornados, hurricanes, landslides, ice storms, floods, or major storms as defined either by the TO or GO or an applicable regulatory body.” 

 

Texas RE recommends the SDT be consistent with the language of the footnotes. 

 

The Table 2 footnote “ + Table 2- Table of MVCD….” is incorrect as the May 14, 2015. NERC Advisory did not include the 14000 to 15000 ft column.

 

On the Direct Current portion of Table 2, Texas RE noticed there is not a reference regarding line operated at normal voltages “other than those listed” as well.  Should there be?  Also, why did the SDT not extend the Direct Current portion of the Table to 15000 ft?

 

Texas RE recommends changing the language of R1 and R2.  The Requirements should read: “to prevent encroachments of the types shown below into the MVCD of its applicable lines, operating within their Rating and all Rated Electrical Operating Conditions, which are…..” instead of “operating within its Rating and all Rated Electrical Operating Conditions of types shown below:”  The current version reads as if the “types show below” is referencing Rated Electrical Operating Conditions.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 12/14/2015

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The Bureau of Reclamation supports the drafting team’s proposed revisions to FAC-003-4.

Erika Doot, 12/14/2015

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Diana McMahon, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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As mentioned above we are supporting the WECC Position Paper of Dec 7, 2015 as follows:

  • Correct the Functional Entity from “Planning Authority” to “Planning Coordinator”

  • Although distances for AC lines are increased by 30% due to the study, there has been no increase in the distances for the DC lines, and no explanation is given. These distances should be considered for revision.

  • For ease-of-use, the columns from “Over sea level up to 500 ft” and “Over 500 ft up to 1000 ft” should be combined to a single column “Over sea level up to 1000 ft”…only one cell will change by one tenth of a foot in only the 765kV voltage class.

  • The elevation columns in the “meters” page of Table 2, are calculated to exactly match the elevations in feet, in the process the elevations given are un-workable.  Elevations of 304.8m, 609.6m, 914.4m, etc. should be changed to 300m, 600m, 900 m.  The MVCD’s (rounded to within one tenth of a foot) will not change.

  • In Table 2 for Direct Current, the MVCD’s are calculated to within one hundredth of a foot – this is an un-workable level of precision.

Seattle City Light Ballot Body, Segment(s) 1, 3, 4, 6, 5, 9/11/2015

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There are inconsistency with the use of terms “Planning Coordinator” and “Planning Authorities”.

NERC has been transitioning from the term planning authority to the term Planning Coordinator over the last several years.

But in this standard it has recently been change back to Planning Authority. We believe that this is the wrong designation.

RSC without Con Edison, Segment(s) 1, 0, 2, 3, 4, 5, 6, 7, 12/16/2015

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BC Hydro recommends changing Planning Authority to Planning Coordinator to align with current terminology.

BC Hydro, Segment(s) 1, 2, 3, 5, 5/6/2015

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The SDT has established inconsistency with the use of the designations “Planning Coordinator” and “Planning Authority”. NERC has been transitioning from the term Planning Authority to the term Planning Coordinator, but in this standard revision the Planning Coordinator designation has been changed back to Planning Authority.

Peter Heidrich, 12/16/2015

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Daniel Mason, 12/16/2015

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Page 2 of the Standard….second line of the purpose definition. We would suggest to the drafting team to capitalize ‘vegetation’ since it is a defined term in the NERC Glossary of Terms.

Page 2 of the Standard….In section 4.1.1.1 of the Applicable Transmission Owner. We would suggest to the drafting team to not capitalize ‘Transmission Facilities’ since it is not a defined term in the NERC Glossary of Terms.

Page 2 of the Standard….In section 4.1.2 of the Applicable Generator Owner. We would suggest to the drafting team to not capitalize ‘Facilities’ since it is not a defined term in the NERC Glossary of Terms. However, the term ‘Facility’ is defined.

Page 2 of the Standard….In section 4.2.1, 4.2.2, 4.2.3, 4.2.4 of Facilities. We would suggest to the drafting team to capitalize ‘transmission line’ since it is a defined term in the NERC Glossary of Terms.

Page 3 of the Standard….In section 4.3.1 of Generation Facilities (first line). We would suggest to the drafting team to capitalize ‘transmission line’ since it is a defined term in the NERC Glossary of Terms.

Page 3 of the Standard….last paragraph of the Background (first, second, and third line). We would suggest to the drafting team to capitalize ‘reliability standard(s)’ since it is a defined term in the NERC Glossary of Terms.

Page 4 of the Standard… bullets 2, 3, 5. ). We would suggest to the drafting team to capitalize ‘vegetation’ since it is a defined term in the NERC Glossary of Terms. Also, we make the same suggestions in the last two paragraphs for the same term.

Page 4 of the Standard….last paragraph. We would suggest to the drafting team to capitalize ‘transmission line’ since it is a defined term in the NERC Glossary of Terms.

Page 5 of the Standard…..Requirement R1 (second line). We would suggest to the drafting team to capitalize ‘vegetation’ since it is a defined term in the NERC Glossary of Terms. Additionally, we suggest some alternative language for Requirement R1 to define or identify how these the elements of an IROL and elements of a Major WECC Transfer Path are determined. The suggested language as followed:  “Each applicable Transmission Owner and applicable Generator Owner shall manage vegetation to prevent encroachments into the Minimum Vegetation Clearance Distance (MVCD) of its applicable line(s) which are either an element of an IROL, or an element of a Major WECC Transfer Path that are determined by a particular study; operating within their Rating and all Rated Electrical Operating Conditions of the types shown below”.

Page 6 of the Standard….In sections 1.2, 1.3,1. 4 of Requirement R1. We would suggest to the drafting team to capitalize ‘vegetation’ since it is a defined term in the NERC Glossary of Terms.

Page 6 of the Standard…..Measurement M1. We would suggest to the drafting team to capitalize ‘vegetation’ since it is a defined term in the NERC Glossary of Terms.

Page 6 of the Standard….. Requirement R2. We would suggest to the drafting team to capitalize ‘vegetation’ since it is a defined term in the NERC Glossary of Terms. Also, we make the same suggestions in sections 2.2, 2.3, 2.4 for the same term.

Page 7 of the Standard…..Measurement M2. We would suggest to the drafting team to capitalize ‘vegetation’ since it is a defined term in the NERC Glossary of Terms.

Page 7 of the Standard….. Requirement R3 (line 3). We would suggest to the drafting team to capitalize ‘vegetation’ since it is a defined term in the NERC Glossary of Terms.

Page 8 of the Standard….. Requirement R6 (line 2). We would suggest to the drafting team to capitalize ‘transmission line’ since it is a defined term in the NERC Glossary of Terms.

Page 8 of the Standard….. Measurement R6 (line 2). We would suggest to the drafting team to capitalize ‘transmission line’ since it is a defined term in the NERC Glossary of Terms.

 

SPP Standards Review Group, Segment(s) 0, 12/16/2015

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