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2014-04 Alignment of Glossary Terms & Definitions SAR

Description:

Start Date: 03/13/2015
End Date: 04/14/2015

Associated Ballots:

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

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See the Unofficial Comment Form on the Project Page for additional background information.

Hot Answers

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Other Answers

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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

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

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

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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

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

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Dominion NCP, Segment(s) 5, 6, 1, 3, 4/8/2014

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Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Herb Schrayshuen, On Behalf of: Herb Schrayshuen, , Segments 2

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ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 4/13/2015

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Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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

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SPP Standards Review Group, Segment(s) , 4/13/2015

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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

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ISO/RTO Council Standards Review Committee, Segment(s) 2, 4/13/2015

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Hot Answers

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Other Answers

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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

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

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

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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

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

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Dominion NCP, Segment(s) 5, 6, 1, 3, 4/8/2014

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Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Herb Schrayshuen, On Behalf of: Herb Schrayshuen, , Segments 2

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ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 4/13/2015

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Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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

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SPP Standards Review Group, Segment(s) , 4/13/2015

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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

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ISO/RTO Council Standards Review Committee, Segment(s) 2, 4/13/2015

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Hot Answers

There has not been a clear statement of need and the problem(s) that must be fixed.  Reviewing the project page, it looks like the team plans to go beyond the SAR and change lower case term in standards to upper case.  There will also potentially changes to definitions in the NERC glossary which can have material impact on the standards and associated compliance.

We would have no problem with NERC creating a master glossary such that if a different term with the same spelling is used in multiple places (such as the standards glossary and the Rules of procedure), that the master glossary denotes both (such as Disturbance [Standards Glossary] and Disturbance [Rules of Procedure]) followed by their associated definition.

Coming up with a single definition for the same words at NERC still leaves differing definitions between NERC and FERC, NERC and Webster’s Dictionary, NERC and IEEE, NERC and NAESB. etc..

Beyond the creation of a master glossary (similar to what is done by IEEE), there should be a general priority order if a term is used in a document that does not contain a glossary.  Since the terms defined in the NERC Glossary for standards have received the most vetting and its terms have the most consequence if misinterpreted, these terms should be the default definition if the published document does not define them.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Other Answers

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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

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Please see proposed additional scope under Q6.

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

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

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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

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

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Dominion NCP, Segment(s) 5, 6, 1, 3, 4/8/2014

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·        If changes are NOT necessary to align the terms or if the differences are appropriate, NERC could modify the words or phrases in the ROP in a way to show that it is not the exact term as in the NERC Glossary.

·        Make changes in the ROP and not in the NERC Glossary.

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Herb Schrayshuen, On Behalf of: Herb Schrayshuen, , Segments 2

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We support the SAR as written.  The inconsistencies between Glossary Terms in the Reliability Standards and the Rules of Procedure need to be addressed.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 4/13/2015

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Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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See attached red line language for questions 1, 2, 3, and 5

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

Comments to questions 1, 2, 3, and 5.doc

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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

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We agree with the drafting team in reference to the ‘Industry Need’ outlined in the SAR. The interpretation of various terms can and has lead to confusion amongst the industry and the application in several Reliabillity Standards . We would like to see more consistency across the board in reference to all ‘cross-over’ terms and their definitions listed in all pertenant documentation.

SPP Standards Review Group, Segment(s) , 4/13/2015

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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

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ISO/RTO Council Standards Review Committee, Segment(s) 2, 4/13/2015

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Exelon Companies encourage the SDT to reccommend that there be only one Glossary.

Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Hot Answers

Cataloging the differences and identifying problems with inconsistencies would be an appropriate scope.  The team could then ask the industry if particular problems need to be addressed via a Rules of Procedure change.  Again, we believe the terms in the Standards’ Glossary should take precedence.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Other Answers

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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

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Please see proposed additional scope under Q6.

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

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

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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

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

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Dominion NCP, Segment(s) 5, 6, 1, 3, 4/8/2014

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·        If changes are NOT necessary to align the terms or if the differences are appropriate, NERC could modify the words or phrases in the ROP in a way to show that it is not the exact term as in the NERC Glossary.

·        Make changes in the ROP and not in the NERC Glossary.

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Herb Schrayshuen, On Behalf of: Herb Schrayshuen, , Segments 2

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While we agree with the purpose statement, we ask the drafting team to consider additional non-defined terms that are used in various glossary terms may need to be clarified to avoid confusion, such as “awareness,” “control,” “coordinate,” “dispatch,” and “operate,” to name a few.  If such definitions were developed, a careful review of their use in the existing standards and their impact would be needed to ensure the definitions only offer clarity and do not modify the standard.

It would be helpful if the drafting team posted a list of defined terms during the next comment period for industry to provide feedback and additional terms to be reviewed and aligned.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 4/13/2015

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Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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See attached document under Q1

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

Q2.doc

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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

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SPP Standards Review Group, Segment(s) , 4/13/2015

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Tacoma Power recommends the following modification: “to identify the defined terms found in the NERC Glossary of Terms (Glossary) and Rules of Procedure (ROP) that need to be aligned; and, provide recommendations to enhance the current process(es) to prevent future misalignment or inconsistencies in NERC defined terms.”  Tacoma Power believes the industry needs to know the terms that will be subject to revision in order to correctly assess and comment on the SAR purpose, goals, objectives, and detailed description of the proposed revision process.  Identifying the impacted terms is a necessary antecedent to drafting the purpose, goals, objectives, and detailed description because of the following:  (1) Without a list of effected terms, it is not clear which resources and personnel will be needed to correctly analyze the proposed revisions; (2) without a list of effected terms, it is impossible to assess and evaluate the potential impact on existing policies, procedures, etc.

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

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The SAR is unclear regarding what process(es) the SDT is evaluating   To the extent that this is intended to evaluate or revise formal processes such as the NERC Standards Development Process, such should be indicated.  Further, to the extent that this is intended to provide flexibility to develop additional processes (either formal or informal definition development processes), such should be clarified.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 4/13/2015

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Hot Answers

Again, the standards' glossary terms should take presidence.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Other Answers

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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

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Please see proposed additional scope under Q6.

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

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The phrases "where necessary, make revisions to align the terms” in Goal 1 and “if the differences are appropriate” in the objectives for Goal 1 both infer that there may be instances when inconsistent terms would be appropriate. Could the drafting team provide some scenarios to illustrate why inconsisancies would, in some cases, be acceptable?

 

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

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If a capitalized term is used in both the Glossary and the ROP, the Glossary definition should stand, and the ROP should be revised to use a different term, if the Glossary definition will not work for the usage of the term in the ROP.  The Glossary terms all stood for a ballot by industry at one point in time, and NERC standards were approved at the time based on the then-understood Glossary definition of the term.  NERC should change Glossary definitions of existing terms only rarely, and with great care, to avoid downstream chaos of mis-interpretation caused by having multiple vintage definitions of the same capitalized term by registered entities, compliance auditors, regional entities, NERC and FERC.

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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

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

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Dominion NCP, Segment(s) 5, 6, 1, 3, 4/8/2014

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·        If changes are NOT necessary to align the terms or if the differences are appropriate, NERC could modify the words or phrases in the ROP in a way to show that it is not the exact term as in the NERC Glossary.

·        Make changes in the ROP and not in the NERC Glossary.

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Herb Schrayshuen, On Behalf of: Herb Schrayshuen, , Segments 2

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Regarding Goal 1, what would happen if the ROP changes receive different comments than the standards posting?  These are two separate processes, and it may be necessary to consider a streamlined process to make consistent language changes between the NERC Glossary and the Rules of Procedure.  If there is a new process introduced in this project, it could be used if any misaligned terms are identified in the future.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 4/13/2015

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Duke Energy  suggests  adding to the scope of the project those definitions within the NERC standards, Standard only definitions, that are inconsistent with the NERC Glossary of Term or Rules of Procedure (ROP). This would reduce the amount confusion within the industry if those identified defintions are consistent with the NERC Glossary of Terms and the ROP.

Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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-- ANSWER HAS BEEN REDACTED BY A SYSTEM ADMINISTRATOR --

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

Q3.doc

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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

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SPP Standards Review Group, Segment(s) , 4/13/2015

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Tacoma Power recommends the following modification to Goal 1: “For cross-over terms in the Glossary and ROP, identify differences and inconsistencies in the definition narrative.  Where necessary, revisions to align the terms will be addressed as part of a subsequent revision to the SAR.”  Tacoma Power believes the industry needs to know the terms that will be subject to revision in order to correctly assess and comment on the SAR purpose, goals, objectives, and detailed description of the proposed revision process.  Identifying the impacted terms is a necessary antecedent to drafting the purpose, goals, objectives, and detailed description because of the following:  (1) Without a list of effected terms, it is not clear which resources and personnel will be needed to correctly analyze the proposed revisions; (2) without a list of effected terms, it is impossible to assess and evaluate the potential impact on existing policies, procedures, etc.

 

Tacoma Power recommends the following modification to Goal 2: “Assess the current process(es) in place for development and maintenance of defined terms, and provide recommendations to the Standards Committee (SC) and NERC regarding changes or improvements to the existing definition development process(es) to allow for future development of defined terms that are consistent and aligned and to define a process for how future identified inconsistencies are handled.”  The revised verbiage would address cases that might be overlooked by Project 2015-04.

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

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Please refer to the SRC comment provided under Question 2.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 4/13/2015

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Hot Answers

See comments above.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Other Answers

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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

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Please see proposed additional scope under Q6.

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

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The phrases "where necessary, make revisions to align the terms” in Goal 1 and “if the differences are appropriate” in the objectives for Goal 1 both infer that there may be instances when inconsistent terms would be appropriate. Could the drafting team provide some scenarios to illustrate why inconsisancies would, in some cases, be acceptable?

 

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

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See note to Question 3, which could be considered a 4th goal of this SAR/development effort.

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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

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Clarifying Comment regarding Item #2 For Goal 1 above : States ” For cross-over definitions that contain inconsistencies or differences and that are currently under revision, board approved,………..”

 

ATC questions whether the SDT possibly have inserted a gap by referring to “board approved” which should be stated more correctly as “Reliability Standards that have been approved by FERC and currently enforced” , as part of the SAR Objectives. This project should be evaluating the impact that any changes to the defined terms may have on the existing Standards and ATC recommends the objective be revised to address this potential gap.

 

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

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Dominion NCP, Segment(s) 5, 6, 1, 3, 4/8/2014

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Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Items 1 and 2 can be combined to read:

 

1.  For Goal 1:  For existing cross-over terms, and cross-over terms that are currently under revision, board approved, or pending regulatory approval that are inconsistent, evaluate whether changes are necessary to align the terms or if the differences are appropriate.  This would include, but is not limited to, ensuring the content, substance, capitalization, formatting and other differences are reconciled. If changes are appropriate, propose revisions to the defined term(s) for industry approval.   

 

NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Herb Schrayshuen, On Behalf of: Herb Schrayshuen, , Segments 2

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We agree with the objectives as written.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 4/13/2015

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Duke Energy suggests adding the following revisions for  Goal 2:

 

“3. For Goal 2: Assess the current process(es) in place for development and maintenance of defined terms, and provide recommendations to the SC and NERC regarding changes or improvements to the existing definition development process(es) , if any, to allow for future development of defined terms that are consistent and aligned or propose such a process if one does not exist.”

 

We believe the scope of the project for Goal 2 should be to not only revises current processes, but also to develop any additional process(es) necessary regarding changes or improvements to existing and future NERC defined terms.

 

If our recommendation to review standard definitions is accepted, Duke Energy suggests the following revisions to Goal 1:

 

“1. For Goal 1: For existing cross-over terms that are inconsistent, either within a standard or in the NERC Glossary of Terms, evaluate whether changes are necessary to align the terms or if the differences are appropriate. This would include, but is not limited to, ensuring the content, substance, capitalization, formatting and other differences are reconciled. If changes are appropriate, propose revisions to the defined term(s) for industry approval.

 

2. For Goal 1: For cross-over definitions that contain inconsistencies or differences and that are currently under revision, , either within a standard or in the NERC Glossary of Terms, board approved, or pending regulatory approval, evaluate whether changes are necessary to align the terms or if the differences are appropriate. If changes are appropriate, propose revisions to the defined term(s) for industry approval.”

Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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We agree with the objectives, provided that the substance of our comments in questions 1, 2, and 3 are adopted.

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

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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Please see proposed wording in bold:

For Goal 1:  For existing cross-over terms that are inconsistent, evaluate whether changes to such terms are necessary to align the terms or if the differences are appropriate.  This would include, but is not limited to, ensuring the content, substance, capitalization, formatting and other differences are reconciled. If changes are appropriate, propose revisions to the defined term(s) for industry approval.

For Goal 1:   For cross-over definitions that contain inconsistencies or differences and that are currently under revision, board approved, or pending regulatory approval, evaluate whether changes to such definitions are necessary to align the terms or if the differences are appropriate.  If changes are appropriate, propose revisions to the defined term(s) for industry approval.

 

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

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SPP Standards Review Group, Segment(s) , 4/13/2015

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Tacoma Power recommends the following modification to the first objective: “Identify existing cross-over terms that are inconsistent and evaluate whether changes are necessary to align the terms or if the differences are appropriate.  If changes are appropriate, seek industry approval to revise the SAR to authorize revisions to the identified defined term(s).”  Tacoma Power believes the industry needs to know the terms that will be subject to revision in order to correctly assess and comment on the SAR purpose, goals, objectives, and detailed description of the proposed revision process.  Identifying the impacted terms is a necessary antecedent to drafting the purpose, goals, objectives, and detailed description because of the following:  (1) Without a list of effected terms, it is not clear which resources and personnel will be needed to correctly analyze the proposed revisions; (2) without a list of effected terms, it is impossible to assess and evaluate the potential impact on existing policies, procedures, etc.

 

Tacoma Power recommends the following modification to the second objective: “Identify cross-over definitions that contain inconsistencies or differences and that are currently under revision, board approved, or pending regulatory approval and evaluate whether changes are necessary to align the terms or if the differences are appropriate.  If changes are appropriate, seek industry approval to revise the SAR to authorize revisions to the defined term(s).”  Tacoma Power believes the industry needs to know the terms that will be subject to revision in order to correctly assess and comment on the SAR purpose, goals, objectives, and detailed description of the proposed revision process.  Identifying the impacted terms is a necessary antecedent to drafting the purpose, goals, objectives, and detailed description because of the following:  (1) Without a list of effected terms, it is not clear which resources and personnel will be needed to correctly analyze the proposed revisions; (2) without a list of effected terms, it is impossible to assess and evaluate the potential impact on existing policies, procedures, etc.

 

Tacoma Power recommends the following modification to the third objective: “Assess the current process(es) in place for development and maintenance of defined terms, and provide recommendations to the SC and NERC regarding changes or improvements to the existing definition development process(es) to allow for future development of defined terms that are consistent and aligned and to define a process for how future identified inconsistencies are handled.”  The revised verbiage would address cases that might be overlooked by Project 2015-04.

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

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For Goal 2, please refer to the comments to Questions (2) and (3).

ISO/RTO Council Standards Review Committee, Segment(s) 2, 4/13/2015

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Hot Answers

How can a non-exhaustive illustrative list be a detailed description?  You might want to check the Mirriam-Webster for the definition of detailed.  This appears to be an indirect way to allow expansion of the SAR.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Other Answers

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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

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Please see proposed additional scope under Q6.

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

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

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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

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

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Dominion NCP, Segment(s) 5, 6, 1, 3, 4/8/2014

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·        If changes are NOT necessary to align the terms or if the differences are appropriate, NERC could modify the words or phrases in the ROP in a way to show that it is not the exact term as in the NERC Glossary.

·        Make changes in the ROP and not in the NERC Glossary.

Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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The impact of Paragraph 81 must be considered.

NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Cooridination with the terms in the functinoal model documents should be undertaken in conjunction with this effort.

Herb Schrayshuen, On Behalf of: Herb Schrayshuen, , Segments 2

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The examples listed were appropriate terms to align.  In addition to already defined NERC standards, it would be helpful for the drafting team to develop or make recommendations to develop future definitions for certain NERC Glossary Terms, such as but not limited to “Generator Interconnection” or “Systematic Approach to Training.”  If such definitions were developed, a careful review of their use in the existing standards and their impact would be needed to ensure the definitions only offer clarity and do not modify the standard.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 4/13/2015

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Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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See attached document under Q1

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

Q5.doc

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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

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SPP Standards Review Group, Segment(s) , 4/13/2015

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Please refer to Tacoma Power’s comments on Questions 2-4.  Specifically, Tacoma Power believes the Detailed Description should include a complete list of identified cross-over terms that are inconsistent and that require changes to align the terms.  This would require a two-step process.  The first step would be identification.  The second step would be authorization to proceed with proposing revisions.  The basis for suggesting this two-step approach is that the industry needs to know the terms that will be subject to revision in order to correctly assess and comment on the SAR purpose, goals, objectives, and detailed description of the proposed revision process.  Identifying the impacted terms is a necessary antecedent to drafting the purpose, goals, objectives, and detailed description because of the following:  (1) Without a list of effected terms, it is not clear which resources and personnel will be needed to correctly analyze the proposed revisions; (2) without a list of effected terms, it is impossible to assess and evaluate the potential impact on existing policies, procedures, etc.

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

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The SAR discusses reviews regarding consistency between defined terms that are capitalized and similar terms that are not, the SRC respectfully requests that the SDT take the totality of the potential impacts to standards into consideration when proposing modiciatins to defined terms and/or lower-cased terms.  If such changes are not thoroughly evaluated for all potential impacts, unintended consequences may result.   As depicted in the Standards Process Manual, all new or revised definitions must go through the same vetting process as new/revised standards, i.e., they need to be posted for comment then balloted.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 4/13/2015

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Hot Answers

No additional comments.

Terry BIlke, On Behalf of: Terry BIlke, , Segments 2

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Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Other Answers

Jeremy Voll, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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

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We agree with all of the above, but believe that the scope of this project falls a bit short of ensuring consistency of terms across all important documents that form the basis for Reliability Standards development. The Functional Model, though not required to be approved by regulatory authorities, provides the framework for the development and applicability of NERC’s Reliability Standards. We therefore suggest that the purpose statement, scope of work, goals and detail description of work be expanded to include reviewing terms defined in the Functional Model, and ensuring consistenmcy across the Glossary, ROP and Functional Model.

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

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In addition to the potential inconsistencies identified in NERC’s glossary and ROP, there are many other inconsistancies between the terms used by NERC and the RTOs. Though we realize this the scope of project is limited to the terms used soley within NERC, we also believe there is a need to examine and ensure the consistency of terms between NERC and the RTOs.

 

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

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Registered entities must be able to depend on the published definitions for terms used in reliability standards.  One important step in that direction would be to avoid re-defining Glossary terms once they are entered into the Glossary the first time.  If that is not possible, a new term could be coined, possibly.  If a term *must* be redefined, then every requirement in every standard that uses that term (or a derivative term*) should be put up for ballot again. 
*  Example:  “Adverse Reliability Impact” has two defined terms in its definition in the Glossary:  “Bulk Electric System” and “Cascading”.

Adverse Reliability Impact :   8/4/2011, The impact of an event that results in Bulk Electric System instability or Cascading.    

Bulk Electric System2:  Unless modified by the lists shown below, all Transmission Elements operated at 100 kV or higher and Real Power and Reactive Power resources connected at 100 kV or higher. This does not include facilities used in the local distribution of electric energy. Inclusions:  I1 - Transformers with the primary terminal and at least one secondary terminal operated at 100 kV or higher unless excluded under Exclusion E1 or E3.  I2 - Generating resource(s) with gross individual nameplate rating greater than 20 MVA or gross plant/facility aggregate nameplate rating greater than 75 MVA including the generator terminals through the high-side of the step-up transformer(s) connected at a voltage of 100 kV or above.  I3 - Blackstart Resources identified in the Transmission Operator’s restoration plan.  I4 - Dispersed power producing resources with aggregate capacity greater than 75 MVA (gross aggregate nameplate rating) utilizing a system designed primarily for aggregating capacity, connected at a common point at a voltage of 100 kV or above.  [The remainder of this definition was truncated, as this is only for illustrative purposes.]

Cascading:  2/8/2005, 3/16/2007:  The uncontrolled successive loss of system elements triggered by an incident at any location. Cascading results in widespread electric service interruption that cannot be restrained from sequentially spreading beyond an area predetermined by studies.

If this definition of “Cascading” was changed, then every standard that references “Cascading” and every standard which references “Adverse Reliability Impact” should be reballoted with the new definition.

Also, NERC should consider whether it is possible to adopt a new policy for updating the Glossary to require that new or revised definitions must avoid using Glossary-defined terms as part of the definitions of other Glossary terms.  This could limit the confusion going forward.  Some usage of defined terms will be unavoidable (such as BES), but others may be possible to avoid.

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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

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

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Page 1 - SAR Requestor Information; Dominion suggests adding the SAR DT chair name and the NERC staffers name behind their phone numbers, for completeness.

Dominion does not agree with “N/A” in column labeled “Standard No.” in the box labeled “Related Standards” (page 6 of the SAR). We would prefer it indicate “as applicable” with the explanation “as applies to standards that contain terms defined in the NERC Glossary of Terms”.

Dominion NCP, Segment(s) 5, 6, 1, 3, 4/8/2014

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Scott McGough, On Behalf of: Georgia System Operations Corporation, , Segments 3, 4

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Any effort to line up the NERC Glossary of Terms which are used in Standards, with the Rules of Procedure definitions should include an effort to at least identify inconsistencies with terms found in the NERC Functional Model Version 6 and notify the Functional Model Advisory Group of any such inconsistencies.

 

On page 1 in the SAR Requester Information section suggest adding the SAR Drafting Team chair’s  name and the NERC Staffer’s name behind their phone numbers for completeness.

 

In the section labeled “Related Standards” on page 6 of the SAR suggest replacing the “N/A” in the column entitled “Standard No.” with “as applicable”.  The concomitant entry in the Explanation column to be added would be “as applies to standards that contain terms defined in the NERC Glossary of Terms”.

 

The NERC Glossary of Terms are voted on by industry, approved by the NERC BOT, and approved by FERC.  The NERC RoP changes are only adopted by the NERC BOT (with input from the MRC), and are approved by FERC.  Also, the NERC Glossary of Terms applies to NERC Reliability Standards. These standards are auditable, enforceable and sanctionable. The NERC RoP and Functional Model have other purposes, outside of compliance (i.e., the RoP contains administrative and governance procedures and the Functional Model is for registration purposes).  A “Conflicts” clause that makes one agreement or document takes precedence over all others in a conflict should be added.  Suggest the following: 

 

“The NERC Glossary of Terms shall apply and have precedence when interpreting the meaning of terms used in NERC Reliability Standards. Definitions of terms in the NERC RoP and Functional Model documents, which may or may not be in agreement or conflict, shall only be used to clarify the meaning of terms used in the RoP and Functional Model documents, and shall not have precedence over the NERC Glossary of Terms in matters of Reliability Standard interpretations, compliance audits, enforcement or in the development of sanctions. Deference and precedence should be given to the NERC Glossary of Terms in interpreting the definition of terms used in all NERC documents.”

 

OR

 

“In the event of a conflict between the definition of terms cited in the NERC Glossary of Terms, the definition used in a single reliability standard, or the definition provided in any other NERC document (e.g., RoP, Functional Model), the following order of precedence shall apply:

1.  The NERC Glossary of Terms definitions shall apply, unless superseded or modified by a Single Standard definition presented at the beginning of the standard under the Definition of Terms heading.

2.  A Single Standard definition presented at the beginning of the standard under the Definition of Terms heading shall only apply for that one reliability standard.

3.  Footnote, Rationale Box and Guidance Document definitions shall take precedence only if there are no NERC Glossary of Terms or Single Standard definitions.

4.  Definitions of terms presented in other NERC documents (e.g., RoP, Functional Model, RSAW’s) will have no standing in the presence of the NERC Glossary of Terms, Single Standard definitions or standard Footnote, Rationale Box and Guidance Document definitions. They shall only apply where the drafting history of the standard clearly supports and shows the intent of the standard drafting team and the industry balloting to support their application to the single standard.

5.  Definitions contained in approved interpretations of standards, which are appended to the original standard, are incorporated into the standard and shall therefore assume the same level of precedence as any Single Standard definition.”

NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Herb Schrayshuen, On Behalf of: Herb Schrayshuen, , Segments 2

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We agree with the direction that the drafting team is taking to address inconsistencies in the NERC Glossary.  We ask that the team consider CIP definitions in addition to the Operations and Planning standards to ensure consistency throughout all NERC terms.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 4/13/2015

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Mike Lowman on Behalf of Duke Energy, Segment(s) 1, 5, 6, 4/13/2015

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No additional comments

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

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Comparing the NERC Glossary to the information listed in the Rules of Procedure is a good idea.

Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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Our only other comment with the SAR is that it contains lengthy redundant wording.

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

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We would suggest to the drafting team to take into consideration and adding the term(s) ‘Contingency Reserves’, ‘System Operating Limit-SOL’ and ‘Interconnection Reliability Operating Limit-IROL’ to the list of ‘cross-over’ terms to be evaluated in your process. It is our concern that these specific terms are used in various Reliability Standards and the interpretation of each has caused confusion in the industry.

SPP Standards Review Group, Segment(s) , 4/13/2015

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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

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The SRC recommends clarifying the scope of the SAR to ensure consistency of terms across all important documents that form the basis for Reliability Standards development. In particular, the Functional Model, which is captured in Appendix 5 to the ROP, also exists outside of the ROP.  As it provides the framework for the development and applicability of NERC’s Reliability Standards, the SRC suggests that the purpose statement, scope of work, goals and detail description of work clarify whether the SDT is intending to include reviewing terms defined in the Functional Model, and ensuring consistency across the Glossary, ROP and Functional Model.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 4/13/2015

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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