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Enhanced Periodic Review - Standards Grading

Description:

Start Date: 06/30/2016
End Date: 08/01/2016

Associated Ballots:

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

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Hot Answers

BPA has no issues or comments on EOP-011-1

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

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No comment.

Douglas Webb, On Behalf of: Great Plains Energy - Kansas City Power and Light Co., SPP RE, Segments 1, 3, 5, 6

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Other Answers

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Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

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N/A

Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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Southern believes there are some additional clarifications to the Requirements that should be considered when developing the final content scores for the requirements. EOP-011-1, R5 needs to be reworded such that the requirement is to notify impacted BA and TOPs within the RC area, and impacted neighboring RCs.

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

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Duke Energy agrees that while the standard’s content is generally well-understood, there are some aspects of the standard that could use further clarification. Requirement 3.1.2 requires that the RC “Review each submitted Operating Plan(s) for coordination to avoid risk to Wide Area reliability.”  Duke Energy believes the  requirement’s language is too broad and the scope should be narrowed to help provide direction for the phrase “coordination to avoid risk”. It will benefit the industry to help define the types of coordination that the RCs should be evaluating to avoid risks to the BES. Without set objectives for an RC to use in reviewing the appropriateness of an Operating Plan, the requirement could be carried out differently and possibly impact the effectiveness of the evaluation. We suggest that consideration be given to clearly outline objectives for an RC to use in the evaluation of a BA/TOP’s Operating Plan.

Also, Duke Energy believes some ambiguity may exist regarding the use of the term “address” in R4. R4 requires that “Each Transmission Operator and Balancing Authority shall address any reliability risks identified by its Reliability Coordinator pursuant to Requirement R3 and resubmit its Operating Plan(s) to its Reliability Coordinator within a time period specified by its Reliability Coordinator.” We feel that the term “address” could be interpreted differently depending on the reader. Does “address” mean to provide a written response to the RC that the concerns the RC raises on the Operating Plan will be remedied at some date in the future? Or, does “address” mean that the issue must be remedied prior to the response from the BA or TOP being sent to the RC? More clarity around the use of the term “address” may be beneficial to industry stakeholders.  

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

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These comments are on behalf of the ISO RTO Council (IRC) and their Standards Review Committee (SRC). These comments have been reviewed and approved by IESO, ISO-NE, MISO, ERCOT, NYISO, PJM, SPP, and CAISO and are submitted on their behalf.

Please see collective Comments from all ISO's under Question #5 below.

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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We believe a RC should be familiar with its responsibilities identified within requirements R3, R5, and R6.  While some may question if R3 falls within Paragraph 81 criteria, we feel that some accountability must be identified to complement the RC-reviewed Operating Plan development listed in R1 and R2 for TOPs and BAs, respectively.  In requirement R4, we feel the EPRSRT has an opportunity to address an unnecessary burden placed on TOPs and BAs if their RC identifies an unreasonable time period for resubmittal of Operating Plans (i.e. same day).  It appears the disagreement identified within the EPRSRT is that the RE representative felt “time frame requirements” should be clarified in R3 and added in R4.  We disagree entirely and feel the whole review process implied within the standard should be retired, and instead incorporated into a reliability guideline that is approved and maintained by the NERC Operating Committee.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 8/1/2016

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EOP-011-1 (subject to future enforcement), Requirement R3 requires the Reliability Coordinator to review Operating Plans submitted by the TOP and BA, “on the basis of compatibility and interdependency with other Balancing Authorities' and Transmission Operators’ Operating Plans.”  This requirement is ambiguous as to what exactly the Reliability Coordinator is looking for when reviewing the Operating Plans.  This requirement is difficult to measure and doesn’t really have a technical basis in engineering operations.  How often have conflicts occurred between TOPs and BAs Operating Plans?  These conflicts seem like they would rarely occur and if so, should probably be coordinated between the conflicting TOPs or BAs instead of the Reliability Coordinator.  EOP-011-1, Requirements R4, R5, and R6 seem straightforward.

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

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No comment.

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

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In our evaluation, the only requirement that is unclear is R3 due to the way it is stated.  As stated, it appears the RC is to review the Operating Plan (so that) the operating Emergency will be mitigated.  That is not the intent of the requirement but the phrasing can lead to that interpretation.  A better way to word R3 would be:

‘The Reliability Coordinator shall review the Operating Plan(s) developed for R1 and R2 above and submitted by a Transmission Operator or a Balancing Authority in order to identify any reliability risks between those Operating Plans’.

We would like to have had more insight into why the EPRSRT couldn’t agree on whether the requirements weren’t clear.  Particularly which parts were unclear?  

 

SPP Standards Review Group, Segment(s) , 8/1/2016

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HQT has commented on this standard in the attachment at the end. Aside from the nits, we note:

  • Purpose: The purpose of the standard focuses on the development and coordination of the Operating Plans. Since the requirements require that the entities must implement the Operating Plans, the purpose should reflect the implementation aspect. This would align the language of EOP-011's purpose with the language of EOP-010's purpose.

  • R1, R2 – Without specified delays, the notion of maintenance cannot be enforced.

  • R2.2.6. Reduction of internal utility energy use = 'utility' is perhaps not defined in the context of NERC reliability standards.

  • R3 - the notion of 'between Operating plans' is ambiguous. However, the requirement and rationale do not set expectations for what kind of risks should be considered (in-plan, in between different plans at the same time, in between plans in a temporal sense, out-of-plan, or all of the above).

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

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/1/2016

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Hot Answers

BPA has no comment.

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

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No Comment.

Douglas Webb, On Behalf of: Great Plains Energy - Kansas City Power and Light Co., SPP RE, Segments 1, 3, 5, 6

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Other Answers

MH believes the language is sufficient in indicating that the standard is only applicable to BES elements. 

Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

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As NERC only has jurisdiction over BES facilities (and elements), additional clarity does not appear necessary.  In addition, the current applicability section, specifically Section 4.1.2.3 and 4.1.2.6, specify that any transformers with a low side of either below 100kV or between 100 and 200kV must be part of the BES, eliminating any ambiguity.  The other applicability sections do not appear to be ambiguous as they contain language specific to Transmission lines or voltages that are clearly BES.

Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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

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Duke Energy believes that additional language may be necessary to clarify that the standard only applies to BES elements. It is the understanding of industry stakeholders that all Reliability Standards are applicable to BES elements, unless it is explicitly stated otherwise in a standard or requirement. However, we do believe that some ambiguity exists regarding the exception process to the BES definition, and whether some of the language in section 4.2 “Circuits” alludes to the BES exception process. Currently, it is unclear whether the language “that are part of the BES” wording in 4.2.1.3, 4.2.1.6 and 4.2.2.2 is intended to account for elements included under the exception process. If this is the intent, the same language “that are part of the BES” is also needed in 4.2.1.1, 4.2.1.4 and 4.2.2.2 to eliminate any confusion on applicability.

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

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These comments are on behalf of the ISO RTO Council (IRC) and their Standards Review Committee (SRC). These comments have been reviewed and approved by IESO, ISO-NE, MISO, ERCOT, NYISO, PJM, SPP, and CAISO and are submitted on their behalf.

Please see collective Comments from all ISO's under Question #5 below.

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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We do not understand the question, but we agree the applicability section of this standard could be modified to clarify that it only applies to BES elements.  If the EPRSRT needs to revise its initial assessment to align its numbers with this concern, then we have concerns with the overall grading process.  We will address these concerns in question no. 5 below, when asked for our comments on process improvements.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 8/1/2016

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We agree that additional language to clarify that the standard only applied to BES elements would be helpful.  A low content score reflecting that fact seems warranted.

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

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Texas RE recommends BES elements be specified in the applicability of the Standard.  There should not be an assumption as to applicability to BES elements or non-BES elements and the language of the Standard should properly reflect applicability.

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

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We are unaware of any confusion on applicability of PRC-023-4. However, we feel that the EPRSRT may need to provide a summary on what led them to conclude that the Content and Quality scoring for PRC-023-4 isn’t properly aligned. The industry can’t provide solutions or accurate comments if we don’t know what details led the EPRSRT to this current position in the grading process. Additionally, we would suggest that the EPRSRT use the PRC-025 Standard as a guideline in reference to structuring PRC-023-4 when clarifying applicability.

SPP Standards Review Group, Segment(s) , 8/1/2016

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Regarding the applicability section, it would have been clearer to write the exemption first and then clarify the inclusions, i.e.

4.2. Circuits:

All GSU transformers and Elements that connect the GSU transformer(s) to the Transmission system that are used exclusively to export energy directly from a BES generating unit or generating plant, which  may also supply generating plant loads, are exempted from this standard.

 

4.2.1 Circuits Subject to Requirements R1 – R5:

Elements subject to these requirements are Elements which are part of the BES and are

4.2.1.1 Transmission lines operated at 200 kV and above;

4.2.1.2 Transmission lines operated at 100 kV to 200 kV selected by the Planning Coordinator in accordance with Requirement R6.

4.2.1.3 Transmission lines operated below 100 kV and selected by the Planning Coordinator in accordance with Requirement R6.

4.2.1.4 Transformers with low voltage terminals connected at 200 kV and above.

4.2.1.5 Transformers with low voltage terminals connected at 100 kV to 200 kV selected by the Planning Coordinator in accordance with Requirement R6.

4.2.1.6 Transformers with low voltage terminals connected below 100 kV and selected by the Planning Coordinator in accordance with Requirement R6.

4.2.2 Circuits Subject to Requirement R6:

Elements subject to these requirements are Elements which are part of the BES

4.2.2.1 Transmission lines operated at 100 kV to 200 kV and transformers with low voltage terminals connected at 100 kV to 200 kV.

 

Although in principle, 4.2.1.2 and 4.2.1.5 can be combined with 4.2.1.3 and 4.2.1.6 respectively, it is useful to clarify that Transmission Lines below 100 kV can be selected by the Transmission Planner.

 

The ‘operator’ in ‘operator established emergency rating’ (R1.criteria 10) is ambiguous.  In FAC-008-3, the GO establishes an emergency rating. The history of this reliability issue suggests that the system operator (TOP) is intended.  Although the intention of the 15% margin reflects good industry practice with respect to equipment margins, if the system operator can establish the Emergency rating referred to in this requirement, why is the 15% margin required? An operator established rating with 0% margin would make more sense. As an aside, there does not appear to be a requirement that the operator establish this rating in the standards. As a specific example, transformers in Hydro-Québec operate over a greater range of temperatures than most transformers in North America, particularly due to the northern location of many of its major power transformers and therefore the relevant margins with respect to equipment ratings are sometimes less than the industry standard 15%. Obviously, the system operator must account for this reality in operations.

 

SMEs have found R1-criteria 11 difficult to parse. If our interpretation is correct, this criteria could be written more clearly as follows (modification in bold):

For transformer overload protection relays that do not comply with the loadability component of Requirement R1, criterion 10 set the relays according to one of the following:

  • Set the relays such that the transformer can operate at the overload level specified in criterion 10 for at least 15 minutes to provide time for the operator to take controlled action to relieve the overload.

  • Install supervision for the relays using either a top oil or simulated winding hot spot temperature element set no less than 100° C for the top oil temperature or no less than 140° C for the winding hot spot temperature.

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

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/1/2016

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Hot Answers

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

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The language of Requirement 8.2 Item 4 is ambiguous as to cause a reliability concern not adequately captured by the existing language and would warrant a lower content score.

Requirement 8.2, Item 4, “An impediment to service to a major load center…” is vague and ambiguous. Specifically, the term “major load center” is not defined. Vague and ambiguous terms call into question the auditability and enforceability of the Standard.

In reviewing the project materials for FAC-008-3, the Standard Drafting Team (SDT) offered in their Consideration of Comments on Facility Ratings Expansion (Project 2009-06), clarification of expressed concerns of ambiguity regarding Item 4. The SDT looked to the language of the original FERC directive (Order 693, Par. 756) and edited the Item 4 language to better reflect the directive’s intent as well as to more closely mirror the language of the FERC directive. The SDT also revised the term "a major city or load pocket" to "a major load center", with the explanation, “Power engineers and operators will be qualified to make the judgment of what a major load center is (allowing relative judgment) rather than having to specify the demographics of what a major city is or define a load pocket.” Link to Project 2009-06 Consideration of Comments of FR Expansion

Based on the available record, the SDT recognized the ambiguous language of the directive and sought to address that ambiguity, balancing it with the “intent” of the directive, and modified the language which is represented in the current language of Item 4, “major load center.” Their modified language did not substantially clarify the term and it remains ambiguous.

While we have great confidence in the expertise of engineers and operators, regardless of how good their judgment at discerning or divining whether a facility is a “major load center” or not, their expertise does not convert the vague and ambiguous term into one of clarity; it remains not auditable and, in turn, unenforceable.

Douglas Webb, On Behalf of: Great Plains Energy - Kansas City Power and Light Co., SPP RE, Segments 1, 3, 5, 6

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Other Answers

The combination of R1, R2, R7 and R8 is unnecessarily complicated. The standard defines three different locations, low side of generator step-up, high side of generator step-up and point of interconnection with TO. It’s unclear whether R7 applies only to R1. R8 implies that it refers to R2. The GO should be responsible for everything on their side of the POI and the TO on their side. We don’t think there’s a reliability gap but it would be nice if the standard could be simplified.

Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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The 30 calendar days in 8.2 is too long for facilities involved in IROLs and TTCs.

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

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

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These comments are on behalf of the ISO RTO Council (IRC) and their Standards Review Committee (SRC). These comments have been reviewed and approved by IESO, ISO-NE, MISO, ERCOT, NYISO, PJM, SPP, and CAISO and are submitted on their behalf.

Please see collective Comments from all ISO's under Question #5 below.

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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We interpret the question to read if we feel the language of the identified requirements is confusing or ambiguous, then the EPRSRT will lower their quality and content scores.  The language of these requirements is confusing or ambiguous, as one interpretation of its meaning would require the TO and GO to provide their Facility Ratings on a scheduled basis identified by each external reliability entity.  We would expect the TO and GO to provide updated information when those entities identify any updates to their Facility Ratings.  In light of the wording of this question, we have concerns with the overall grading process.  We will address these concerns in question no. 5 below, when asked for our comments on process improvements.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 8/1/2016

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In FAC-008-3, Requirement R8, the Transmission Owner and applicable Generator Owner are required to provide facility information on requested schedules unless the facility causes an IROL, a limitation of TTC, an impediment to generator deliverability, or an impediment to service to a major load center. If those triggers occur then the delivery must occur less than 30 days unless the requester schedules a greater than 30 days time period.  This standard seems confusing.  It’s very difficult to determine when the 30 day requirement is even required, it’s hard for the TO to know if it’s facility meets those requirements and even so the requester can request a longer duration schedule and therefore makes the 30 day requirement moot.  This language may not cause a reliability concern, but it does warrant a lower quality score and should at some time be revised.

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

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Yes, the language of the requirements is unclear and the content score should be lowered.   Requirement R1, which is referenced effectively by Requirement R7, has ambiguous language associated with Facility Ratings that causes inconsistencies in implementation by Generator Owners.  It is perceived that Emergency Ratings for Equipment do not need to be developed within a Facility or for the Facility itself.  If the EPRSRT wants to create a single number to represent the output capabilities of a generation site there should be new definitions created to delineate that idea.  As is, it does not make sense to expect Transmission Owners to provide Emergency Ratings and Normal Ratings for Equipment and not make Generator Owners of the same type of Equipment do the same.  Considerations for Emergency and Normal Ratings are provided within the Requirement but the development of Ratings by Generator Owners is different and subject to a great deal of professional judgement by the Generator Owner and those reviewing compliance for the Requirement. 

 

Requirement R8 uses only “Thermal Rating” as a condition for “causing” issues but IROLs may have other conditions that need considered due to the definition of IROLs.  In Requirement 8.2, items 3 and 4 are ambiguous when it comes to compliance review (e.g., companies know what a major load center is until there is a compliance question and suddenly there are no “major” load centers).

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

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R7 and R8 as written support only use of Facility Ratings and updates to those Facility Ratings in a non-time sensitive time horizon.  Operations Planning occurs in real-time.  Allowing 30 days to communicate an update of ratings on facilities could lead to reliability issues.  Facility Ratings are a key element to determining SOLs.  RCs, BAs, and TOPs must be continuously aware of the limitations on their systems.  R7 and R8 as written would only support longer term system analysis and planning functions. Alternatively, Requirements R7 and R8 can be retired due to the fact that these Requirements are being addressed in TOP/IRO Standards.

Additionally, we would suggest that the EPRSRT remove the term "associated" in both Requirements R7 and R8. We suggest the term "applicable footprints." We feel that this helps Multiple Regional Registered Entities (MRREs) provide their data to all the applicable entities that require their Facility Ratings and also protects MRREs' sensitive data from entities that intend to misuse their data (which aren’t applicable to reliability reasons).

In Requirement R8 (Section 8.2), the terms "major load center" and "impediment" were not defined.

SPP Standards Review Group, Segment(s) , 8/1/2016

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The use of ‘associated’ entity is ambiguous - is the ‘association’ with the Facility or the entity? Furthermore, the term ‘associated’ is a weak identification, in comparison to ‘responsible’ or ‘relevant’ entity.  As a consequence, its translation to French is not straightforward. Aside from this translation difficulty, this ambiguity does not cause problems in Québec since there is only one possible ‘associated’ RC, PC, TP and TOP in the Québec jurisdiction.

 

Also HQT supports NPCC comments.

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

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FAC-008-3 Requirements R7 and R8 are not confusing or ambiguous, however, the use of “as scheduled” fill-in-the-blank language results in inherently inconsistent application of the standard.  This can lead to administrative compliance issues such as where a Registered Entity has not provided an increased facility rating far enough in-advance of “As scheduled.”  If the main concern of the FAC-008-3 standard is decreases to facility ratings, then the standard should be targeted to decreases to facility ratings, not system improvements that may result in increased facility ratings.  It should be noted that FAC-008-3 is a commonly violated reliability standard.   

RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/1/2016

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Hot Answers

BPA proposes that INT-004 and the PRC family of standards be given the highest priority for EPR in 207.

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

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We would award the highest priority to FAC-008 and the PRC Family of Standards for 2017 Enhanced Periodic Review, as discussed below.

FAC-008:

The Standard’s Purpose states, “To ensure that Facility Ratings used in the reliable planning and operation of the Bulk Electric System (BES) are determined based on technically sound principles. A Facility Rating is essential for the determination of System Operating Limits. “

In summary, based on its stated purpose, the Standard is to ensure a consistent process for rating transmission facilities. The Standard requires Transmission Owners (TO) and Generator Owners (GO) to document facilities and develop facility rating methodologies. The completed facility ratings are provided to the GO/TOs’ associated Reliability Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission Owner(s) and Transmission Operator(s).

The expectations of the Standard are straight forward, however the GO/TO facility ratings are applied by the planning function entities in one manner and applied in a different manner by the operating function entities, creating the potential for harm and misoperations on the BES. The Standard is silent on the expectations for Transmission Operators (TOP) who wish to operate their systems in a “flexible” manner with apparent disregard of the planning function and the role it plays in maintaining BES reliability. While transmission planners establish operational flexibility in their studies, a TOP’s decision to operate the BES beyond the studied limits may put the reliable operation of the BES in jeopardy.  Operation of the BES outside the parameters of the transmission studies should be addressed—whether by FAC-008 or another Standard—to ensure the Standard’s purpose of “…reliable planning and operation of the [BES]…” is achieved.

The PRC Family of Standards

The PRC Family of Standards has too many Standards. Sending the PRC Standards through the EPR process will likely identify PRC Standards may be consolidated, some retired, and others improved with modifications that add clarity.

The need for fewer Standards: There are twenty active PRC Standards and seven future enforceable PRC Standards, not including pending regulatory approvals and regional PRC Standards. This accounting highlights the fact that there are too many PRC Standards. The hope of sending the PRC Family of Standards through EPR would be to identify the opportunities for retirements and consolidation, with an eye toward establishing precise reliability goals and frameworks.

The need for added clarity: The PRC Family of Standards are difficult to craft because they must be general enough to cover the spectrum of facilities and diversity of design across North America electric systems. By the same token, they must provide enough specificity that the Standard is effective, auditable, and enforceable. The EPR process could help identify Standards that would benefit from clear expression of system protection expectations—establishing a framework and validating system protection parameters.

Douglas Webb, On Behalf of: Great Plains Energy - Kansas City Power and Light Co., SPP RE, Segments 1, 3, 5, 6

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Other Answers

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Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

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These 2 standards should have the highest priority to review in 2017;

INT-004 (address no longer applicable PSE requirements, periodic review appropriate)

FAC-008 (it appears that NERC is concerned with clarity, so review appropriate)

Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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BAL-001 and FAC-008-3 should have the highest priority in 2017.

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

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

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These comments are on behalf of the ISO RTO Council (IRC) and their Standards Review Committee (SRC). These comments have been reviewed and approved by IESO, ISO-NE, MISO, ERCOT, NYISO, PJM, SPP, and CAISO and are submitted on their behalf.

Please see collective Comments from all ISO's under Question #5 below.

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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The standards and standards families that should have the highest priority for a review in 2017 should be the PRC standards and FAC-008.  The PRC family has many standards that soon will be retired based on implementation plans going into effect in 2017.  We feel this would be an opportune time to address the remainder of standards from this family.  We also feel it is an appropriate time to address the issues identified for FAC-008 to align with ongoing initiatives to mitigate database modeling risks.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 8/1/2016

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No preference.

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

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Texas RE recommends the following as a list of priority for Enhanced Periodic Review:

1.  EOP-010

2.  FAC Standards

3.  BAL Standards

4.  NUC and INT Standards

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

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FAC-008-3 is not clear in several areas.  Its relation to the standards FAC-010, FAC-011, and FAC-014 is confusing at best.  There is also the ongoing 2015-09 project that is updating these three standards in relation to the TOP/IRO revisions conducted under 2014-03.  FAC-008-3 should be updated/reviewed soon so as to stay relevant and correct.

The INT standards are in dire need of updating due to the deregistration of PSEs and IAs.  There are many requirements that are no longer applicable and should be removed from the body of standards for clarity.

SPP Standards Review Group, Segment(s) , 8/1/2016

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Following a review of the standards included in the EPRSRT exercise, HQT considers that EPRs are justified for the following standards: PRC-025-1, PRC-006-2, PRC-004-5(i), VAR-001-4.1, VAR-002-4 and PRC-023-4. Please consult the excel spreadsheet attached with our comments on the standards.

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

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/1/2016

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Hot Answers

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

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No Comment.

Douglas Webb, On Behalf of: Great Plains Energy - Kansas City Power and Light Co., SPP RE, Segments 1, 3, 5, 6

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Other Answers

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Nick Vtyurin, On Behalf of: Manitoba Hydro - MRO - Segments 1, 3, 5, 6

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The model used by the SDT should be made available for comment by the stakeholders.  At this time, the ‘grades’ are determined using a ‘black box’ methodology by NERC and Regional staff.  More stakeholder input into the model and stakeholder involvement in the actual grade derivations could lead to a more useful and meaningful grade.

Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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

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

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These comments are on behalf of the ISO RTO Council (IRC) and their Standards Review Committee (SRC). These comments have been reviewed and approved by IESO, ISO-NE, MISO, ERCOT, NYISO, PJM, SPP, and CAISO and are submitted on their behalf.

General Comments:

The ISO/RTO Council Standard Review Committee (SRC) appreciates the work of the EPRSRT team. The SRC has chosen not to specifically respond to questions 1-4 in lieu of providing general comments on the entire EPRSRT process and ranking/grading tool as noted below. While the enhanced review and scoring is fine in concept, one fundamental consideration is that the review should only be performed on standards that either have been directed to be changed or that are coming up on their 10 year review.  Additionally, for those that are on their 10 year review, the Industry should have a vote on whether the standard is acceptable as-is.  There should be a vote prior to opening a new project. Give the Industry the opportunity to vote on whether they want to keep the given standard “as-is”. If there are minor problems, such as paragraph 81 requirements, they can be handled in compliance.

Additional Comments:

  1. The SRC is concerned that this effort has begun with no industry consensus-building process, especially on the criteria, the voting process, and the definitions of criteria. The SRC recognized that the criteria were nearly the same as the 2013 criteria, but this would have been a good opportunity to update or improve on the previous criteria.

  2. NERC’s EPR idea was good, but the implementation of the idea did not work as effectively as possible, because the industry was not properly consulted. Involving the industry would have taken more time, but the end result would have been a better grading tool. More work should have been done up front before implementation of the EPR process took place by the OC/PC/NERC representatives. The SRC is concerned that the standards grading criteria were not vetted or approved through industry comment before they were applied by the EPRSRT. Other types of criteria could have been used like Technical Accuracy Criteria, Definition and Terminology criteria, and others.  Furthermore, because these criteria did not receive industry vetting, the SRC is concerned that it is too late to change methodology.

  3. The ranking/grading criteria are not weighted by importance, just given a yes/1 or no/0, such that a non-risk and risk criteria have the same value.  Simply tallying “yes’s” and “no’s” doesn’t yield a true or effective result.  Taken individually, some of the criteria, if graded poorly, negate the entire quality of the standard.  Such criteria as “is it drafted as a results-based standard?” or “are the correct functional categories identified?” are pivotal to judge the effectiveness of a standard.  If all other criteria are judged positively, the grading outcome does not accurately reflect the deficiencies of the standard. This process is not a useful tool for this type of analysis.  Furthermore, throughout the criteria, “risk” is only mentioned twice, and in the context of types of requirements.  Risk to the BES should be measured, in line with the risk-based compliance oversight.  These criteria, perhaps more than any other, should be used to help prioritize and improve standards.

  4. The ranking/grading by respondents is a flawed methodology. The SRC requests clarity on the reasoning for a quality rating of 5 versus a quality rating of 10. The criteria “can it be practically implemented?” may receive a number of different answers from respondents depending on the capability and definition of “practical” of each respondent, and isn’t measureable. How did each individual make their ranking determination? Neither the published content or quality criteria considered topics like:

    1. Violation statistics

    2. Risk-based compliance concepts (focus on High Risk)

    3. Consistency with other Reliability Standards

    4. Changes in Technology and System Conditions

    5. Risk and/or Events on the BES system

  5. In the end, it appeared that the scores in the “SRT Preliminary Grades” posted on NERC’s webpage (http://www.nerc.com/pa/Stand/Pages/Enhanced-Periodic-Review-Standards-Grading.aspx ) with few exceptions, were remarkably the same for both content and quality criteria. It would have been helpful to see how each OC, PC, Regional Entity and NERC representative originally and individually ranked each Standard and Requirement before they were discussed and leveled. Individual OC, PC, Regional Entity and NERC representative ratings should have been posted on the project page.

  6. It is not completely clear to the SRC what the EPRSRT is going to do with the ranking/grading and how the information will be used, especially in light of the existing information contained in the “Periodic Review Template” (See: http://www.nerc.com/pa/Stand/Standards%20Development%20Plan%20Library/Enhanced_Periodic_Review_Template_090214.pdf ) updated in September 2014.

  7. The Frequently Asked Questions (FAQ) document (See: http://www.nerc.com/pa/Stand/Enhanced%20Periodic%20Review%20%20Standards%20Grading%20DL/EPRSRT_FAQ_document_06302016.pdf ) notes in Q1/A1 that “The finalized grading will be appended to the Reliability Standards Development Plan (RSDP), which has been endorsed by the SC.”, but what this means and how it will help determine whether a Standard will be updated or not is still in question.

  8. The SRC questions the value to the EPRSRT effort in general. How does it differ or provide more information to the existing Periodic Review Template, which was designed to give a “red, yellow, or green” grading for a particular Standard. Will the new EPRSRT tool replace the “Periodic Review Template”? If not, why not update the template first, with industry review, comment, and approval, and then apply the new tool to the periodic review of Standards?

  9. The SRC suggests for future consideration, that when new NERC projects and new initiatives are launched, NERC allow for a longer review period, especially given the fact that a lot of time has already gone into this effort, and there is a large volume of data to review.

  10. There is little value of the resulting scores. They should not be used as a trigger to develop a Standard, but should be one of a series of inputs to an eventual decision about whether to update a particular Standard. In that regard, NERC should list all the inputs to the decision-making process about whether to update a particular Standard.

  11. The risk-based approach should be the basis for new or revised Standards. The 2016 CMEP, version 2.4, dated June 2016 states, “During 2016 and beyond, CEAs will continue deploying processes and tools used to support risk-based compliance oversight. NERC and the REs are committed to ensuring full transformation to risk-based compliance oversight, and they plan to continue communications, training, and outreach throughout 2016.”

  12. Did the EPRSRT explore alternative grading processes or approaches? If so, what alternate grading processes or approaches did they consider?

  13. The continued churn from re-opening the standards for low-value changes (and subsequent follow-up FERC directives for additional requirements) is leading to a level of chaos.   The 10-year review should only open a standard if it has a clearly identifiable fatal flaw. The SRC believes that the Standards “churn” must slow if not stop. Steady state must be achieved as quickly as possible.

  14. The risk triage process performed by Enforcement staff should be transparent and objective (e.g. serious violations are those that are related to “high impact” requirements known to cause system events or where there was an observed material impact on reliability). NERC should use event data and observations from violations (where there was an observed impact on reliability) to identify the true “high impact” requirements that would be the focus of compliance monitoring, and the development/sharing of internal controls. If there is not a clear trend threatening a BES Benchmark, a standard is probably not the correct solution.

     

Michael Puscas, On Behalf of: ISO New England, Inc., , Segments 2

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  1. Based on the supplemental information provided, it appears the EPRSRT consists of four people who are representative of the entire ERO Enterprise and industry.  We feel this is statistically an insufficient sample set to collect data.  At a minimum, the process should have incorporated sector representatives from each of the NERC Technical Committees, including the Critical Infrastructure Protection Committee, to establish a sufficient sample set.  A larger sample set would provide a better reflection of industry on this process.
  2. We believe the burden placed on the EPRSRT was significant, as the supplemental information identifies over 100 requirements with the expectation that each representative answer 19 different questions.  With almost 2000 questions to answer, these representatives likely responded on their own without collaboration with their peers or committee members.  We believe a smaller number of requirements should have been identified as part of this process.
  3. The process appears to disregard responses to the three general questions regarding Reliability Objectives, Paragraph 81 criteria, and appropriateness for guide development.  If a requirement is identified as meeting the Paragraph 81 criteria, then a project should be assigned to retire that requirement regardless of other grading identified.
  4. We believe some of the questions have identical meanings that unfairly weigh those responses with other questions.  For instance, how different is the content question “identifying who does what and when” from the question regarding the identification of the correct functional entity?  Likewise, the quality question asking if the requirement is “complete and self-contained” is nearly identical to the question asking if the requirement is “stand-alone” or should it be consolidated with other standards.
  5. There are no questions available to identify Violation Risk Factor misalignments or incomplete Violation Severity Limits.  For example, we believe requirement R4 of EOP-011-1 could inadvertently place a significant financial burden on a TOP who is required to resubmit its Operating Plans back to its RC, particularly if the RC has identified an unachievable time period (i.e. same day).   Under such conditions, the TOP would violate the requirement based on its High Violation Risk Factor and High Violation Severity Level.  We feel the failure to update an Operating Plan is administrative in nature, and should have be classified as a low Violation Risk Factor instead.
  6. We have concerns that the EPRSRT could modify their initial assessments based on after-the-fact input collected.  We believe the process should only allow the participant one opportunity to answer these questions, and let the responses speak for themselves.
  7. We thank you for the opportunity to comment.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 8/1/2016

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Average Content Question scores and Quality Question scores don’t seem to be that different from standard to standard.  There seems to be a large number of 3s and 11s.  It is difficult to determine which standards need to be updated and looked at with such similar scores.  An enhanced method that brings in additional factors like number of violations and reliability risk may help differentiate the scores.

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

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No additional comments.

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

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We feel that the EPRSRT needs to provide the context of what led them to their lack of consensus in reference to the Standards grading process. In our opinion, this would help industry provide better feedback to the Standards Grading process in the future.

SPP Standards Review Group, Segment(s) , 8/1/2016

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Value of the EPRSRT

HQT is in favor of improving the quality of existing standards. Therefore, it supports the EPRSRT in theory. Moreover, it is supporting this review by contributing some detailed comments on the standards under review in the attachment at the end of the file. Many of these comments arose during the translation process and its associated interpretations.

 

In order to improve the EPRSRT process, it also has the following comments.

 

Identification of standards eligible for EPRSRT evaluation: timing and granularity

During the scoping of the EPRSRT, it would be more helpful to name the specific standards, including versions, up for review at the beginning of the exercise. Naming a family (e.g. the PRC family for 2016) is not helpful, particularly if the family has many standards. Specifying the list of standards and versions in the Reliability Standards Development Plan would make it easier to obtain comments from company stakeholders in due time. If the specific standards are not specified at the time of the Reliability Standards Development Plan and if the EPR continues to be held during the summer, it would be helpful to have the list of standards (and their versions) up for review in the early spring so that we could have collected comments in the late spring and early summer.

 

Standards scoring: A tool for reviewing of standards, not the goal of reviewing standards

Finally, while HQT considers the questions on content and quality useful guides, the scoring exercise with its 13 yes-or-no questions cannot replace a considered holistic evaluation of a standard’s success in achieving its reliability objective. Even if a standard only has one problem and scores 12 out of 13 points, that problem, if it compromises the standard’s reliability objective, would be significant enough to warrant a review of the standard. Moreover, a standard with such a problem should be reviewed in an EPR above before a sloppy standard scoring 6 out of 13 but which is accomplishing its reliability objective.

 

Scope of review: Standards sections other than Applicability and Requirements

The focus of the standards grading is the Applicability and the Requirements section. This is understandable and even desirable, since the requirements are the foundation of the mandatory compliance regime. Furthermore, industry is mainly interested in the technical component of the standards. As a consequence, the compliance section, notably the VSL, do not seem to be revised for quality. In Québec’s regulatory regime, HQT must file the standards and the Régie de l’énergie regularly comments on aspects relating to VSLs. The VSLs could use a thorough review. They are lengthy and often include errors. Furthermore, there does not appear to be a feedback loop from compliance and enforcement into VSLs since they do not seem to capture the different shortcomings that arise in compliance monitoring.

 

The similar issue arises with the rationales and guidelines. Because these sections are not normative like the requirements, they undergo less scrutiny during quality review.  Though their quality is generally high, they contain language that can lead to confusion.

The Implementation Plan of a standard is inherently normative, since it affects the timing of the mandatory requirements and Implementation Plans have been moved off the standard document. We consider the rationales and guidelines less normative than the Implementation Plan and therefore, they should be considered for a treatment parallel to the Implementation Plan (storage on the NERC website, with a link in the one-stop-shop excel).

 

Conversely, if the guidelines and rationale warrant inclusion in the standard, perhaps the Implementation Plan should be incorporated as well, perhaps as an attachment.

 

 

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

HQT comments on standards considered in the NERC EPRSRT.docx

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/1/2016

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