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2016-01 Modifications to TOP and IRO Standards SAR

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Start Date: 01/22/2016
End Date: 02/22/2016

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RSC no ISO-NE HQ and NextEra, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 2/22/2016

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The SDT directive to “revise TOP-001-3 R10 to require real-time monitoring of non-BES facilities” needs to be developed using clear criteria delineating when monitoring is required and what approach or parameters would constitute adequate monitoring.

Mike Smith, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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Other Answers

Jared Shakespeare, On Behalf of: Jared Shakespeare, , Segments 1

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Mark Kenny, On Behalf of: Mark Kenny, , Segments 1, 3

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

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Nicolas Turcotte, On Behalf of: Hydro-Qu?bec TransEnergie, , Segments 1

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

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 1/6/2016

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See attached document

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

Project 2016-01 IRO_TOP SAR comments City Light 2016 Feb 18.dotx

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AEP recognizes FERC’s concerns regarding identification of non-BES facilities, however, there would be far more flux involved in their identification and real-time monitoring (as suggested by the SAR) than may be widely understood or appreciated. This subset of non-BES facilities would change quite frequently, and creating obligations to govern such frequently changing identification and real-time monitoring would likely require much effort, with little to no improvement in reliability. Rather than developing additional requirements which would not likely be beneficial, we believe a more prudent approach would be to focus on the desired end state itself. We believe the argument can be made that our existing obligations, when considered as a whole, could collectively appease FERC’s concerns.

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

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

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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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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We have no concern with the Commission’s directive that there should be some additional language in reference to TOP-001-3 Requirement R10. Also, we agree that IRO-002-4 Requirement R3 can serve as a foundation for that particular language. We also suggest that the drafting team follow the Functional Model Advisory Group’s efforts very closely so that any clarified functional obligations are captured and consistent with the Functional Model.  Additionally, we would suggest the drafting team to clarify that the non-BES facilities that the TOP is required to monitor be only those facilities that were identified by the Reliability Coordinator in IRO-002-4.

As for the Commission’s suggestion of adding clarity to the term ‘redundant infrastructure’, our review group  suggests the SDT consider developing a Standards Authorization Request (SAR) to create  a definition for this particular term that can be added to the NERC Glossary, Rules of Procedure, and Functional Model. When the term “Alternative Interpersonal Communication” was created as a part of COM-001-2, the SDT included within the definition that the capability must use a different infrastructure. The definition of ‘redundant infrastructure’ could include the requirement to be diversely routed.

We don’t feel it is appropriate to have a blanket requirement for the TOP to be required to have fully redundant data exchange capabilities with each entity it has identified it needs data from.  The Transmission Operator may only receive a handful of points from certain entities, and there may be minimal impact to reliability if that data was lost.  Any new requirement or change to R19 and R20 should provide the Transmission Operator the ability to identify and declare the entities with which it needs to have fully redundant and diversely routed data exchange capability.

In addition to the directives by FERC to modify the TOP and IRO standards, we suggest that the SDT review the use of the term ‘Operating Instruction’ as found in the TOP and IRO standards.  It appears that the COM-002-4 Drafting Team did not intend to do a direct replacement of the term ‘Directive’ with ‘Operating Instruction’.  However, it appears the TOP-001-3 R3 and R4 are zero tolerance on compliance with EACH Operating Instruction. Previously the wording in the Standards required zero tolerance on the receipt of Directives.  The definition of Operating Instruction is much broader and can be interpreted to include some system to system communications that were not previously considered to be Directives.  We do not believe the intent of the term Operating Instruction in TOP-001-3 is consistent with the definition and use of the term in COM-002-4.

 

SPP Standards Review Group, Segment(s) 1, 3, 5, 2/22/2016

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ERCOT joins in the comments of the IRC Standards Review Committee (SRC).

The SRC agrees that a drafting team needs to address the directives issued by FERC in Order No 817.

Elizabeth Axson, On Behalf of: Elizabeth Axson, , Segments 2

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PJM supports the comments submitted by the ISO/RTO Standards Review Committee (SRC).

William Temple, On Behalf of: PJM Interconnection, L.L.C. - RF - Segments 2

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Florida Power and Light (FPL) appreciates the efforts of NERC drafting a SAR proposing changes to TOP-001-3 and IRO-002-4 to address concerns expressed during the FRCC Order No. 817. For the three specific concerns mentioned, Monitoring non-Bulk Electric Systems facilities, FPL believes the new TOP-001-3 standard and the BES definition addresses this concern and do not feel a standard revision is necessary. In the case of Redundancy and Diverse Routing of Data Exchange Capabilities,  FPL believes the revised TOP and IRO standards adequately address redundancy and diverse routing of data exchange capabilities and do not feel additional standard revisions are necessary. Lastly, in the testing of the Alternative or Less Frequently Used Data Exchange Capability, FPL believes RCs, TOPs and BAs should have protocols to ensure their alternative data exchange capabilities are viable in order to comply with the revised TOP and IRO standards and in good utility practice; and do not feel additional standard requirements are necessary.

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

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The suggested revision of approved NERC Standard TOP-001-3, specifically Requirement 10, to require real-time monitoring of non-BES facilities is not needed and is already covered by the existing language.  Requirement 10.1 states; "Within its Transmission Area, monitor facilities and the status of Special Protection Systems, and".  R10.1 requires TOPs to monitor facilities to determine SOL exceedances, which allows the TOP to decide which "Facilities" it deems neccessary to meet the task required by R10.  By adding the requirement to real-time monitor non-BES facilities, the Standard requires how something should be done instead of stating what is required and allowing the utility to decide how.

Joshua Smith, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 1

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: The SRC agrees that a drafting team needs to address the directives issued by FERC in Order No 817.

ISO/RTO Standards Review Committee, Segment(s) 2, 2/22/2016

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We agree that the scope of the SAR is drafted to address the FERC directives in Order No. 817.  We ask the SDT to strongly consider cost implications and to explore equally efficient and effective alternatives to developing additional requirements.  Such alternatives could include glossary term revisions, identifying existing standards that already address the directive, or the development of a reliability guideline.

ACES Standards Collaborators - TOP/IRO Project, Segment(s) 1, 5, 3, 6, 2/22/2016

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Hot Answers

The SAR should allow the SDT to explain the meaning of “diverse routing” and “redundancy”.  A glossary term may not be needed but an explanation of the intent will be required to facilitate compliance.   

Also, as a general comment, FERC wanted to limit “redundancy and diversity” to data exchange between RC, TOP and BA so the SDT will need to avoid capturing other entities like TO and DP into this requirement.

RSC no ISO-NE HQ and NextEra, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 2/22/2016

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Mike Smith, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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Other Answers

Jared Shakespeare, On Behalf of: Jared Shakespeare, , Segments 1

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Mark Kenny, On Behalf of: Mark Kenny, , Segments 1, 3

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

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Nicolas Turcotte, On Behalf of: Hydro-Qu?bec TransEnergie, , Segments 1

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

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Per section 47 of FERC Order 817, recommend adding Reliability Standards IRO-002-4, Requirement R4 to clarify what “redundant infrastructure” is, within this SAR.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 1/6/2016

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See attached document from 1

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

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Though the directives given by FERC potentially impact the same standard(s), and the“identification of non-BES elements” and “redundant data exchange capabilities”emanate from the same FERC Order, the topics appear disparate enough to drive two separate projects. Would it be preferable to create two separate project teams to pursue the FERC directives, rather than combine multiple, dissimilar directives into a single project?

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

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

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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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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SPP Standards Review Group, Segment(s) 1, 3, 5, 2/22/2016

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ERCOT joins in the comments of the IRC Standards Review Committee (SRC). 

The SRC would like NERC and the drafting team to consider alternatives to a reliability standard to address the directives included in the Order.  The types of activities contemplated in the SAR are upstream and act as controls around registered entities performing core reliability functions, such as responding to IROL’s or developing emergency plans.  Redundant and diversely routed data exchange capabilities, in addition to testing of alternate or less frequently used data exchange capabilities are not core reliability requirements. Moreover, given the relatively static nature of these types of activities (e.g., establishing communications equipment), RC/BA/TOP Certification is a more appropriate program for the ERO to use to support reliable operations than auditing.

 

Also, the SRC would like the drafting team to consider clarifying “redundant and diversely routed data exchange capabilities”. The SRC asks the SDT to consider whether data that goes to two independent control sites satisfy the concepts of redundant and diversely routed or does the SDT intend to require two independent feeds for each data sample to each site?

 

The SRC would also like the SDT to consider the applicability of non-BES Elements to the standards process. NERC is close to implementing an improved BES Definition on July 1, 2016, that will provide greater clarity to facilities that will impact the interconnected transmission system. The SDT should consider how this definition can capture elements that may not meet the core BES definition but should be BES going forward.

 

 

Elizabeth Axson, On Behalf of: Elizabeth Axson, , Segments 2

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William Temple, On Behalf of: PJM Interconnection, L.L.C. - RF - Segments 2

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

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TOP-001-3 R10 as proposed requires each TOP shall monitor Facilities and the status of SPSs within its TOP area and obtain and utilize status, voltages and flow data for facilities and status of SPS outside its TOP area.  The ERCOT region is structured to support a deregulated market in which ERCOT monitors facilities for all TOPS and has a centralized view of the entire region to maintain reliability.  TOPs operating within ERCOT currently do not have the technical capability to monitor facilities of neighboring TOPs.  This requirement imposes a “one size fits all” regional structure which would place an unreasonable financial burden on all TOPs to both install and maintain additional hardware in each station or install and maintain multiple ICCPs between control centers.  This requirement would place this financial burden on TOPs for nothing more than to replicate an RC function with no benefit to the BES. At no point in proposed Standard TOP-001-3 does it require TOs to supply neighboring TOs with this data.  Oncor requests R10 be reworded to provide flexibility for region structure.

Joshua Smith, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 1

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The SRC would like NERC and the drafting team to consider alternatives to a reliability standard to address the directives included in the Order.  The types of activities contemplated in the SAR are upstream and act as controls around registered entities performing core reliability functions, such as responding to IROL’s or developing emergency plans.  Redundant and diversely routed data exchange capabilities, in addition to testing of alternate or less frequently used data exchange capabilities are not core reliability requirements. Moreover, given the relatively static nature of these types of activities (e.g., establishing communications equipment), RC/BA/TOP Certification is a more appropriate program for the ERO to use to support reliable operations than auditing.

Also, the SRC would like the drafting team to consider clarifying “redundant and diversely routed data exchange capabilities”. The SRC asks the SDT to consider whether data that goes to two independent control sites satisfy the concepts of redundant and diversely routed or does the SDT intend to require two independent feeds to each cite?

The SRC would also like the SDT to consider the applicability of non-BES Elements to the standards process. NERC is close to implementing an improved BES Definition on July 1, 2016, that will provide greater clarity to facilities that will impact the interconnected transmission system. The SDT should consider how this definition can capture elements that may not meet the core BES definition but should be BES going forward.

ISO/RTO Standards Review Committee, Segment(s) 2, 2/22/2016

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  1. We recommend that the SDT conduct a technical conference relating to this project to explore any equally efficient and effective alternatives in lieu of modifying the existing standards.  This would allow industry an opportunity to provide initial feedback prior to any proposed standard revisions.  We also recommend that if the SDT agrees with this approach, that it considers broadcasting the technical conference via a webinar for industry stakeholders who are unable to attend in person.  A recent technical conference held for NERC Project 2007-06.2 was limited to 20 people and was not open to a large majority of industry to attend.
  2. For TOP-001-3 R10, we have concerns with the proposal of expanding the TOP’s responsibilities for monitoring non-BES facilities.  The SDT could consider alternatives including references to the existing BES exception process or the development of a reliability guideline.  In the event that the SDT decides to pursue development of the requirement instead of identifying an alternative, we recommend limiting the scope of monitoring non-BES facilities to only the facilities that were identified by the Reliability Coordinator in IRO-002-4 and agreed to by the Transmission Operator.
  3. For TOP-001-3 R19 and R20 relating to “redundant infrastructure,” the SDT should consider developing a formal glossary term to provide clarity for the requirements.  Cost considerations should also be factored into the development of these requirements.
  4. Thank you for the opportunity to comment.

ACES Standards Collaborators - TOP/IRO Project, Segment(s) 1, 5, 3, 6, 2/22/2016

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