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

Project 2015-09 Establish and Communicate System Operating Limits | FAC-011-4

Description:

Start Date: 07/14/2016
End Date: 08/12/2016

Associated Ballots:

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

Filter:

Hot Answers

We ask the drafting team for the rationale in the proposed new definition of SOL exceedance. We believe there are two sets of duplicated conditions:

 

First Set (Bullets 2 and 3):

 

·       Calculated post-Contingency flow on a Facility is above the highest Emergency Rating

·       Calculated post-Contingency flow on a Facility is above a Facility Rating for which there is not sufficient time to reduce the flow to acceptable levels should the Contingency occur

 

What is the intent of the second bulleted condition since the first condition does not say whether or not there is sufficient time to reduce the flow to acceptable levels? If there is sufficient time, then it’s not an exceedance (i.e., not the condition presented in the next bullet). If there isn’t sufficient time, then it is duplicating the next bullet.

 

Since some TOs may provide more than just the Emergency Rating, which can be a 5-minute rating or a 15-minte rating for a transmission line could the term “Emergency Rating” be better stated as “applicable rating”?  A TO may also provide 30-minute rating, or 1-hour or 4-houir rating, and requests the TOP and/or the RC to apply the 30-minutes or 1-hour rating (hence the applicable rating). In this case, if and when a contingency occurs, the TOP needs to return loading of the facility to within the applicable rating, NOT the emergency rating. The applicable rating (NOT the Emergency Rating) thus sets the limitation for the calculation of SOL.

 

Second Set (Bullets 5 and 6):

 

·       Calculated post-Contingency bus voltage is outside the emergency system voltage limits

·       Calculated post-Contingency bus voltage is outside emergency system voltage limits for which there is not sufficient time to relieve the condition should the Contingency occurs

 

Our comment and suggestion are similar to the above (for the first set).

 

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team.  Additionally, we don't believe that every facility limit is an SOL nor is reaching a normal rating of a facility is an SOL exceedance.  A different term is needed for this. 

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

- 0 - 0

Other Answers

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

- 0 - 0

The following answers for all questions 1 - 24 are provided by our City Light SMEs.  After the submittal, the SMEs asked to make some additional changes to the original submittal.  If yes/no vote changed I placed it in the comment section. Thank you.

The new definitions appear to be superior to the old versions, but we still have some comments: 

1. The new SOL definition includes Facility Ratings and Voltage Limits as separate items.  I think this is appropriate, but elsewhere in this document, it is stated plainly several times that the drafters expect that FAC-008-3 Facility Ratings should include voltage ratings.  I have never seen voltage ratings included with FAC-008-3 ratings and the standard (including the definition of “Facility Ratings”) is not clear on whether it is required.  There should be some effort to clarify where the responsibility for developing voltage limits lies, although depending on the desired direction, this may have to be in FAC-008 and not in this standard.   

2. In the SOL Exceedance definition, the third bullet says “a Facility Rating” where the term “Emergency Rating” seems more appropriate.  “Emergency Rating” is used in the explanation for that bullet item and in the parallel item for voltage limits (sixth bullet) the term “emergency system voltage limits” is used.

3. Including Bullet #1 in the SOL Exceedance definition may restrict TOP operations.  It would require a TOP to report exceeding a SOL for instances where a facility exceeded its normal SOL but was less than emergency time SOL for even a few scan cycles.  Currently, this is not considered “unacceptable system performance.”  Recommend the following wording for Bullet #1:

*Actual or pre-Contingency flow on a Facility is above a Facility Rating for which there is not sufficient time to reduce the flow below the Normal Rating.

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

- 0 - 0

The proposed definition for the new term SOL Exceedance is too broad and would create and undue burden for TOPs notifying their RCs when the reporting threshold for an exceedance has been met. To align the definition of the new term with our RC's current SOL Methodology, we propose the following changes to the definition of SOL Exceedance:

“An operating condition characterized by any of the following:

-Actual or pre-Contingency flow on a Facility is above the Normal Rating, for the associated time frame

-Calculated post-Contingency flow on a Facility is above the highest Emergency Rating

-Calculated post-Contingency flow on a Facility is above a Facility Rating for which there is not sufficient time to reduce the flow to acceptable levels should the Contingency occurs

-Actual or pre-Contingency bus voltage is outside normal System voltage limits, for the associated time frame

-Calculated post-Contingency bus voltage is outside applicable system voltage limits for which there is not sufficient time to relieve the condition should the Contingency occur

-Operating parameters indicate the next Contingency could result in instability.”

 

The rationale for the changes is as follows. Actual thermal and voltage limits may have associated timeframes which, if not exceeded, do not compromise the integrity of the equipment or the BES. Also, the bullet “calculated post-Contingency bus voltage is outside the emergency system voltage limits” is redundant with the bullet “Calculated post-Contingency bus voltage is outside applicable system voltage limits…”

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

However, in the SOL Exceedance definition, we are unable to appreciate the distinction between bullet 5 (outside the emergency system voltage limits) and bullet 6 (outside the emergency system voltage limits for which there is not sufficient time to relieve the condition) - please provide a more detailed explanation of the intended difference between them.

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

- 0 - 0

The new definition of SOL is appropriate.  The last bullet of the "SOL Exceedance" definition needs to limit the instability to BES facilities.  Bullet 3 and bullet 6 of the SOL Exceedance definition should state, “should the Contingency occur” instead of “should the Contingency occurs.”

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

AZPS respectfully suggests that the last bullet in SOL Exceedance definition (Operating parameters indicate the next Contingency could result in instability) be clarified or deleted.  AZPS agrees that the previous bullets thoroughly define what constitutes a SOL Exceedance in pre-, actual, and post- contingency conditions. However, the last bullet implies that, following a contingency, a system  must immediately meet stability limits for the next contingency - even before system readjustments have been completed and even prior to the expiration of the Tv time period. This could create a contradiction and associated confusion relative to registered entity obligations within this reliability standard.  . 

The phrase “stability limitation” is not a defined term and, to ensure consistent interpretation, should be defined.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

Manitoba Hydro strongly believes that it is necessary to respect actual operating parameters such as Facility Ratings, System voltage limits and any known stability limitation in the real-time operating horizon.   

 

The new SOL definition is much clearer than the existing one.  However, by including stability limitations in the definition of an SOL, it is much more difficult to differentiate between an SOL and an IROL based on the existing definition of an IROL.  By their very nature, stability limits are determined to prevent instability, uncontrolled separation or cascading outages.   Perhaps the IROL definition also needs revision to help determine which stability limitations warrant special IROL designation and more careful scrutiny. However, the standard tries to address the “special nature” of the IROL.  The existing IROL definition is confusing in the context of all these other revisions.   

 

Manitoba Hydro does not support the proposed definition of SOL Exceedance for the following reasons.

 

  1. Post contingency bus voltage and timing

    It is difficult to differentiate between the following operating conditions:

      • Calculated post-Contingency bus voltage is outside the emergency system voltage limits;

      • Calculated post-Contingency bus voltage is outside emergency system voltage limits for which there is not sufficient time to relieve the condition should the Contingency occurs;

 

It appears that this definition is meant to mirror system operating conditions associated with post-contingency facility ratings (second and third bullets in SOL exceedance definition). While emergency Facility Ratings can reflect a maximum mitigation timeframe to address a thermal rating overload to manage equipment loss of life, voltage limits are not dynamic in the same way.  Adding the mitigation timeframe doesn’t make sense in the context of voltage – it’s just confusing. 

 

  1. Potential SOL exceedance and  actual SOL exceedance

    While Manitoba Hydro believes that it may be necessary to take some pre-contingency action to operate the power system in a secure manner, a potential SOL exceedance and an actual SOL exceedance are not the same and should not be treated in the same manner. For example, if real-time contingency analysis identified a potential SOL exceedance, it does not make sense to notify the RC.  The utility can take preventive action to address the potential SOL exceedance.  On the other hand, an actual SOL exceedance should be reported to the RC.

     

    Under the fourth bullet of “Overview of the proposed revisions to FAC-011-3, FAC-014-2 and defined terms SOL and SOL exceedance” it says that   “A potential SOL Exceedance may be identified by an OPA, or an actual SOL Exceedance may be identified by an RTA”.  However, NERC glossary of term defines Real-time Assessment (RTA) as, “An evaluation of system conditions using Real-time data to assess existing (pre-Contingency) and potential (post-Contingency) operating conditions….”

    These two statements contradict each other. As described in the definition, RTA identify the actual SOL exceedance (corresponds to existing or pre contingency condition) and potential SOL exceedance (corresponds to post contingency condition).  You’ve made a distinction here between the two time frames that is not reflected in the definition and requirements.

     

  2. IROL exceedance Vs. SOL exceedance

    Manitoba Hydro has concerns with the following bullet in the SOL exceedance definition:

  • Operating parameters indicate the next Contingency could result in instability

     

Is this an SOL or an IROL?  This operating condition is another reason to examine the IROL definition to add clarity.

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

- 0 - 0

See MISO TOP-IRO Task Team response.

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

The first bullet in the SOL Exceedance definition should take into account the timeframes and level of risk that the TOP has determined when defining SOLs in accordance with the RC’s SOL Methodology. As currently written, the proposed definition for SOL Exceedance redefines SOL (i.e. System Operating Limits) from what the team is proposing for SOL. Note that the SOL definition imports all of the meaning of the defined terms used within the proposed SOL definition. The first bullet of the proposed SOL Exceedance definition ignores that flow can be above the Normal Rating of a Facility without being above the System Operating Limit (i.e. not an SOL Exceedance) since the condition being experienced could be a post-contingency condition where the amount of flow is within the relevant flow limit for a limited period of time. Suggested wording: “Actual or pre-Contingent flow on a Facility is above the applicable rating for longer than the allowable time frame for that Rating”. By similar argument, the same wording should be used for the fourth bullet: “Actual or pre-Contingent voltage on a Facility is outside the applicable voltage limit for longer than the allowable time frame for that voltage limit.” The fifth bullet should be removed as the sixth bullet correctly covers the time frame to resolve the bus voltage outside of the emergency voltage limits.

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

- 0 - 0

NPPD supports the comments submitted by the MISO TOP-IRO Task Team. In addition we have the following comment:

Recommend adding “as applicable” or some similar term after stability limits in the definition of System Operating Limit.  Not all Facilities will have stability limits. In addition, stability limits can and do involve a set of Facilities and not just a single Facility.  The definition must be flexible enough to recognize these nuances in the way stability limits are developed and utilized. The current definition is not clear.  A situation where a Compliance Enforcement Entity is looking for stability limits for every facility to demonstrate compliance would be very cumbersome and should be avoided.

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Definition of SOL: Duke Energy requests more clarification on the lack of inclusion/distinction between normal and emergency ratings in the proposed definition of SOL. This implies that if an entity had a 2 hour rating (long term emergency rating), and the entity was operating within that 2 hour rating, this would be an SOL, and based on the proposed definition SOL Exceedance, you would have exceeded the SOL. We think clarification as to whether the definition of SOL will includes only normal ratings, or both normal and emergency ratings would greatly increase clarity, and becomes more relevant when reviewing the proposed definition of SOL Exceedance.

Definition of SOL Exceedance: Duke Energy questions the assertion made in the first bullet under the proposed definition of SOL Exceedance. The instance in which an Actual Flow exceeds a Normal Rating, should not be considered as an SOL Exceedance. An entity would have Emergency Rating that would cover this instance. Also, there may be some confusion on the difference between Actual and pre-Contingency used in bullets 1 & 4. We suggest replacing that language with “Actual Flow on a Facility”. We think the addition of the language “and pre-Contingency” is a relative term and confusing and doesn’t really add any clarity to the definition. We also suggest the drafting team consider reducing the definition of SOL Exceedance to the 1st and 4th bullets. We disagree with the assertion that calculations or computer models of instances that haven’t actually occurred yet should be considered as an SOL Exceedance. If the drafting team insists on including instances discovered by tools, calculations, or computer models, we suggest the team consider breaking the definition down into Actual and/or Potential Exceedances.

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

- 0 - 0

SOL Exceedance definition:

3rd bullet uses the term sufficient.  This term is undefined and open to interpretation.  Suggest re-phrasing to read: “…for which the flow cannot be reduced to acceptable levels within 30 minutes should the Contingency occur.”

6th bullet also uses the term sufficient.  Suggest rephrasing to read: “…for which the condition cannot be relieved within 30 minutes should the Contingency occur.”

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

- 0 - 0

System Operating Limits are not reliability limits.  SOL Exceedance defines abnormal operating conditions that, although must be cleared, for the most part do not present a reliability problem.  Suggest removing “Reliability” from the SOL definition. 

 

The sixth bullet embellishes the wording of the fifth bullet by the addition of the words “…for which there is not sufficient time to relieve the condition should the Contingency occurs…”.  The fifth and sixth bullets are redundant, and only the sixth bullet is needed.

 

Suggest changing the wording in the bullets of SOL Exceedance from “flow on” to “flow through”.

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

We disagree with the proposed revision to the SOL definition.  In particular, the removal of the “most limiting” language introduces additional challenges since each component of the definition (Facility Ratings, System voltage limits, and stability limitations) are now individually and simultaneously SOLs for a given facility.  This introduces unintended complexities compared to the existing definition.  The rationale that the current definition presumes an operating paradigm whereby a study or analysis is performed ahead of time to establish an SOL and the proposed definition somehow does not is incorrect.  In order to determine any limit an analysis has to be done.  Also, the notion that entities continuously assess system performance based on actual operating conditions for each of these components is incorrect as well.  While some TOPs have implemented real time voltage stability analysis they are by far the exception.  Also, real time transient stability analysis is even more rare.  Requiring all TOPs to perform these assessments in real time through the SOL definition will cause undue burden on the industry.  While we don’t necessarily agree that the current definition needs to be changed we do think it could be simplified by tweaking the proposed language to:  “System Operating Limits:  The value (such as MW, Mvar, amperes, frequency, or volts) that is the most limiting of the known Facility Ratings, system voltage limits, and stability ratings for a Facility and/or a group of Facilities and system configuration”. 

We disagree with the proposed definition of SOL Exceedance. Proposed definition of SOL Exceedance does not align with the concept of SOL exceedance described in NERC white paper on SOL definition and exceedance clarification. Proposed definition does not factor in the legitimacy of Emergency Ratings.  Emergency Ratings are designed to reliably support the flow for a defined time frame.  Actual flow between the Normal and Emergency Rating should not be an SOL Exceedance unless the flow is not reduced to the normal rating within the time frame associated with the Emergency Rating. If all flow/voltage normal limit exceedances are treated as SOL Exceedances TOP-001-3 R15 will require the Transmission Operator to inform the RC of actions taken to return the System to within limits even when flows or voltages are within defined limits for acceptable timeframes. This will be detrimental to reliability since it will create unnecessary burden and distractions for the TOP and RC.  

The SOL exceedance definition states” Calculated post-Contingency flow on a Facility is above a Facility Rating for which there is not sufficient time to reduce the flow to acceptable levels should the Contingency occurs”. This criterion is not practical as it will require the operator to monitor and evaluate all post contingent flows which are above normal rating but below emergency rating and determine operating actions feasibility. This will create significant burned with very little or no reliability value. This criterion should be removed from the definition from SOL exceedance.

The criterion “Calculated post-Contingency bus voltage is outside the emergency system voltage limits” and “Calculated post-Contingency bus voltage is outside emergency system voltage limits for which there is not sufficient time to relieve the condition should the Contingency occurs” seem contradictory as one states post contingent bus voltage outside emergency system limit is SOL exceedance while other states that it is an SOL exceedance when there is not sufficient time to relieve the condition. The definition should only include one criterion which should state “Calculated post-Contingency bus voltage is determined to be outside emergency system voltage limits for a timeframe longer than the allowable timeframe associated with that limit during implementation of mitigating steps should the Contingency occurs”.

 The SOL Exceedance definition states:

  • ‘Actual or pre-Contingency bus voltage is outside normal System voltage limits’

  • ‘Calculated post-Contingency bus voltage is outside the emergency system voltage limits’. 

    This definition does not account for practical differences between the impacts of high voltage and low voltage limits. Equipment tripping as a result of high voltage is much different than voltage collapse.  Exceeding high voltage limit may not necessarily risk the reliability of the system but may cause local equipment outage. The high voltage limit exceedance should be treated as SOL exceedance only if the contingency of equipment experiencing high voltage shows other potential SOL exceedances. Treating all high voltage normal limit exceedances as SOL Exceedances will require initiation of the Operating Plan to mitigate the SOL Exceedance which may require unnecessary actions such as opening other transmission lines which can create more severe operating challenges compared to having facilities experience voltages between normal and emergency limits.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Within the SOL Exceedance definition, the 4th bullet refers to “System voltage limits” while the 5th bullet refers to “system voltage limits”.  Consistent capitilzation suggested.    

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

SRP agrees with the proposed definition of Sytem Operating Limit.

SRP does not support the definition for SOL Exceedance as it does not allow for the timely operation in a contingency state where the "Calculated post-contingencyflow..." under this definition operators would be required to operate to an N-1-1 state.

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

- 0 - 0

Texas RE has several concerns with the proposed definition of System Operating Limit (SOL). 

  • “Reliability limits” is undefined.  The prior definition contained values to be operated within which is preferable because of a consistent approach with compliance monitoring and enforcement. Texas RE is unaware of any confusion around SOLs and since the FACs were effective there have been little to no violations related to SOLs which some may argue is evidence that there is not confusion around this issue that the SDT purports on the part of industry and the ERO.

  • Currently, the Standards appear to ignore Normal and Emergency Ratings (FAC-008-3) regarding Facility Ratings for Generator Owners.  Texas RE is concerned this issue will be exacerbated by the proposed definitions and possibly allow more unreliable behavior.  When an entity decides to create a new rating other than Normal or Emergency, which is done, there is not clarity on how this definition would be applied.  Texas RE suggests only allowing Emergency and Normal Ratings to be defined and have those be different values (which unfortunately does not always occur and reliable operations suffer because of lack of clarity.) 

  • The explanation indicates SOLs are only used in the operating horizon.  Although TPL-001-4 does not specifically address SOLs or IROLs, the studies performed in order to meet the Requirements of TPL-001-4 may identify stability limits and IROLs that are more limiting than the Facility Ratings. These studies will likely be more in-depth than an OPA or RTA, and will allow a better opportunity to stress the System in order to identify potential stability limits and IROLs.  If the Planning Coordinator is not required to establish a criteria for identifying stability limits and IROLs (FAC-010-3), it is likely that these limits will not be identified or there will be inconsistencies across the Planning Coordinator Area in identifying the limits. 

  • Texas RE is concerned with eliminating FAC-010-3.  All aspects of SOLs, as currently defined and proposed, will not be met by TPL-001-4 without supporting mechanism to recognize SOLs (as determined by FAC-010).  Also, without an SOL methodology for the planning horizon (FAC-010-3), there may be inconsistencies in steady state voltage limits across the Planning Coordinator Area, as TPL-001-4 R4 indicates the TP and PC are allowed to independently specify criteria for steady state voltage limits, post-Contingency voltage deviations, and the transient voltage response for its System.

     

    Texas RE suggests the SDT consider the following:

     

  • If the Planning Coordinator (PC) is no longer required to have an SOL methodology, it is unlikely that the PC will identify IROLs. Does this mean that elements of an IROL are no longer applicable in FAC-003-4 since they were not identified by the PC?

  • The Applicability section 4.1.1.3 of CIP-014 includes Transmission Facilities at a single station or substation location that are identified by its Reliability Coordinator, Planning Coordinator, or Transmission Planner as critical to the derivation of Interconnection Reliability Operating Limits (IROLs) and their associated contingencies. If the PC and TP are no longer required to identify IROLs, does this mean that these Facilities will not be identified as applicable until a real-time IROL is identified? If so, the implementation of physical security measures may not be completed for years after the IROL is identified.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  We have a concern that the proposed definitions do not consider whether ‘calculated’ post-contingency values are valid or not.  The concern is that if the calculated value is found to not be valid (possibly used incorrect input data), then there may not be an actual ‘exceedance’.  We also wish to point out that IRO-018/TOP-010 have requirements related to quality of RTA.  However, those two standards do not apply to OPA.  As written, the proposed definitions may lead to ‘bad’ OPA/RTA results being considered exceedances.  Some guidance should be given that identified exceedances should be validated as real at some point in the identification process and then once found to be real, then labeled officially as an exceedance.  Our concern is also related to the obligation in reporting from TOP-001-3 R15.

We also request some further guidance on the last bullet on the proposed SOL exceedance definition.  We are concerned it may lead to an interpretation that there is a requirement to have ‘online stability tools’ in order to adequately be determining whether or not SOLs are being exceeded.  We understand the bullet to apply to those who DO have online stability tools, and have an indicated exceedance as well as those who may have an ‘unsolved’ RTCA contingency.  Does the team support the concept that an entity may be able to only evaluate stability against any stability limits previously identified from their TPL studies, rather than being required to have online stability analysis?

It is still not clear to us when exceedances that are in the process of being mitigated or exceedances above the highest limit available cross the line into ‘compliance violation’ territory.  We understand the requirements in TOP/IRO regarding how we are supposed to have a plan, and then implement the plan.  However at some point some situations would require load shed that the entity may elect not to shed pre-contingent.  How long is acceptable for an entity to be in an exceedance situation above the highest limit before it becomes a compliance issue?

We also wanted to point out that there is a typo in the proposed SOL Exceedance definition. The last word in a couple of the bullets is “occurs”. This should be changed to “occur”. 

We also have a concern that now with ‘exceedance’ being broadened to include possibly more issues, the volume of necessary data collection/logging could be significant.  We ask the team to consider any impact to reliability by requiring operators to now further increase gathering proof of implementing Operating Plans for each and every exceedance.  RTCA runs very frequently (10 times per hour) and may have several new issues come in and out. 

Also, what is the team’s thinking in regard to needing to log when a flow is drifting above and below the established limit, but very minimally. For example the post-contingent calculated flow hovering near the Emergency limit +/- a few MW’s.  Do we need to be concerned about capturing those instances in the consideration of ‘zero tolerance’?

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

WAPA agrees with the broad intent for definition of SOL Exceedance, but WAPA would official request the SDT draft language regarding:

1)      Definition of an SOL Violation, e.g. Is an SOL Violation = Actual flow above the highest posted rating exceeding the associated time limit? 

2)      From the material it was stated a Calculated Post-Contingent Exceedance identified in an OPA (one of more days out) is a potential SOL Exceedance that may need an Operating Plan? But it is not clear in the Standard that interpretation is the case. To that point reiteration of the process for an RTA may be helpful to Industry, as RTA inherently implies a process to validate system conditions and results. It would appear that a “post-Contingency flow or System Voltage calculated as part of the valid analysis supporting the RTA” would qualify as an SOL Exceedance for bullets 2,3,4 and 5.

2) Add BES to the definition. In light of the “Approved” edits to TOP-001-4 it would be beneficial to be explicit.

3) Change Bus Voltage to System Voltage.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

We do not agree with the proposed definition because it lends itself to confusion between the limit and the performance criterion.

 For example, new requirement 4.2 states that the SOL methodology shall:

“Require that stability limitations are established to meet the BES performance criteria specified in Part 4.1 for the following Contingencies”

In this requirement, what is the difference between “stability limitations” and “BES performance criteria”?  As an example, is the statement “transient voltage dip must not be lower than 0.8 pu” a BES performance criteria or a stability limitation.

We do not agree with the proposed new definition of SOL exceedance. Specifically, we believe there are two sets of duplicated conditions:

First Set (Bullets 2 and 3):

  • Calculated post-Contingency flow on a Facility is above the highest Emergency Rating.

  • Calculated post-Contingency flow on a Facility is above a Facility Rating for which there is not sufficient time to reduce the flow to acceptable levels should the Contingency occur.

We believe the definition needs only to present the second bulleted condition since the first condition does not say whether or not there is sufficient time to reduce the flow to acceptable levels. If there is sufficient time, then it’s not an exceedance (i.e., not the condition presented in the next bullet). If there isn’t sufficient time, then it is duplicating the next bullet. We therefore suggest removing the first bulleted condition.

Second Set (Bullets 5 and 6):

  • Calculated post-Contingency bus voltage is outside the emergency system voltage limits.

  • Calculated post-Contingency bus voltage is outside emergency system voltage limits for which there is not sufficient time to relieve the condition should the Contingency occurs.  

Our comment and suggestion are similar to the above (for the first set).

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

- 0 - 0

We have a concern that the proposed definitions do not consider whether ‘calculated’ post-contingency values are valid or not.  The concern is that if the calculated value is found to not be valid, then there may not be an actual ‘exceedance’.  We also wish to point out that IRO-018/TOP-010 have requirements related to quality of RTA.  However, those two standards do not apply to OPA.  As written, the proposed definitions may lead to ‘bad’ OPA results being considered exceedances.  Some guidance should be given that identified exceedances should be validated as real at some point in the identification process and then once found to be real, then labeled officially as an exceedance.  Our concern is also related to the obligation in reporting from TOP-001-3 R15.

We also request some further guidance on the last bullet on the proposed SOL exceedance definition.  We are concerned it may lead to an interpretation that there is a requirement to have ‘online stability tools’ in order to adequately be determining whether or not SOLs are being exceeded.  We understand the bullet to apply to those who DO have online stability tools, and have an indicated exceedance as well as those who may have an ‘unsolved’ RTCA contingency.  Does the team support the concept that an entity may be able to only evaluate stability against any stability limits identified from their TPL studies, rather than being required to have online stability analysis?

It is still not clear to us when exceedances that are being mitigated, or exceedances above the highest limit available cross the line into ‘compliance violation’ territory.  We understand the requirements in TOP/IRO regarding how we are supposed to have a plan, and then implement the plan.  However at some point some situations would require load shed that the entity may elect not to shed pre-contingent.  How long is acceptable for an entity to be in an exceedance situation above the highest limit before it becomes a compliance issue.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

NIPSCO agrees with comments submitted by the MISO TOP-IRO Task team.  NIPSCO believes the proposed definition by the MISO TOP-IRO Task Team provides a definition for SOL Exceedance based on the way the system is designed, engineered and operated.  NIPSCO would also like point out an inconsistency withEOP-004 (which is effective at this time).  In EOP-004 a voltage deviation on a facility is defined as reportable in Requirement 1 which refers to Attachment 1.   On page 9 of the standard, attachment 1 defines a voltage deviation on a facility as: "TOP Observed within its area a voltage deviation of ± 10% of nominal voltage sustained for ≥ 15 continuous minutes."  The time frame is not included in any of the proposed definitions.  Does anyone feel there is a problem with reporting a voltage deviation as part of EOP-004 but not in the SOL definition?  This seems like an inconsistency that needs to be addressed possibly by the SDT.  NIPSCO feels the time frame should be removed from EOP-004 and a reference the SOL exceedance added.

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

  1. We agree with the definition of SOL.  We agree with much of the definition of SOL Exceedance.  However, the definition does not account for Operator action.  For example – “Actual or pre-Contingency flow on a Facility is above the Normal Rating” does not factor in the legitimacy of Emergency Ratings.  Emergency Ratings are designed to reliably support the flow for a defined time frame.  Actual flow between the Normal and Emergency Rating should not be an SOL Exceedance unless the flow is not reduced to the normal rating in the time frame used to develop the Emergency Rating, i.e. 15 minutes, 30 minutes, etc.
  2. We have a concern that the proposed definitions also fail to consider whether ‘calculated’ post-contingency values are valid or not.  If the calculated value is found to not be valid, then there may not be an actual ‘exceedance’.  We also wish to point out that IRO-018/TOP-010 have requirements related to quality of RTA.  However, those two standards do not apply to OPA.  As written, the proposed definitions may lead to ‘bad’ OPA results being considered exceedances.  Some guidance should be given that identified exceedances should be validated as real at some point in the identification process and then once found to be real, then labeled officially as an exceedance.  Our concern is also related to the obligation in reporting from TOP-001-3 R15.
  3. Guidance on the last bullet on the proposed SOL exceedance definition is needed.  We are concerned it may lead to an interpretation that there is a requirement to have ‘online stability tools’ in order to adequately be determining whether or not SOLs are being exceeded.  We understand the bullet to apply to those who DO have online stability tools, and have an indicated exceedance as well as those who may have an ‘unsolved’ RTCA contingency.  Does the SDT team support the concept that an entity may be able to only evaluate stability against any stability limits identified from their TPL studies, rather than being required to have online stability analysis?
  4. It is still not clear to us when exceedances that are being mitigated, or exceedances above the highest limit available cross the line into ‘compliance violation’ territory.  We understand the requirements in TOP/IRO regarding how we are supposed to have a plan, and then implement the plan.  However, at some point some situations would require load shed that the entity may elect not to shed pre-contingent.  How long is acceptable for an entity to be in an exceedance situation above the highest limit before it becomes a compliance issue?

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern believes that the bulleted items of the proposed new SOL Exceedance definition should be included in the proposed definition of System Operating Limits.  Our concern is that every time we have a OPA contingency analysis that identifies a contingency overload that is greater than the emergency rating of a facility, it would be declared at that time as an actual SOL Exceedance. We believe this condition should not be part of the definition of SOL Exceedance.  Southern suggests a third definition, “Potential SOL Exceedance”.

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

We would note that the SDT is presented with considerable challenges to address in this project and are grateful for the opportunity to offer our comments, which are shared with the greatest respect and appreciation for the work of the SDT.

We address our concerns and offer suggestions, below, to address: Proposed SOL Exceedance term; Measurable Compliance Thresholds; Consideration of Risk; Applicability; and a Practical Suggestion.

Exceedance: The word “exceedance” is used throughout the Reliability Standards, including Standards that incorporate the definitions for OPA, SOL, and IROL. As noted in the Project 2015-09 System Operating Limits Technical Conference Background Materials (TCBM), referencing “SOL Exceedance White Paper” (SOLEWP) section, “SOL Definition and Exceedance Clarification” (See TCBM, pp. 5-9), the proposed SOL Exceedance definition attempts to align with how the word “exceedance” is used throughout the Standards and to add clarity. The use of “exceedance” as proposed suggests something that may or may not represent noncompliance and, therefore, creates what it seeks to solve, ambiguity and a lack of clarity.

Background. “Exceedance” is used in Standards and in conjunction with OPAs, SOLs and IROLs; it also informs associated Violation Severity Level (VSL) descriptions. The Project 2014-03 SOLEWP seeks to characterize SOL exceedance as, “…unacceptable system performance as indicated by Real-time Assessments [equating] to SOL exceedance.” (SOLEWP, p.7). The SOLEWP continues by identifying unacceptable system performance with scenarios which are now incorporated, in some form, as part of the proposed SOL Exceedance definition. The elements listed in the proposed SOL Exceedance definition, if accepted, create a compliance threshold. We believe compliance thresholds should be unambiguous and clearly identify, as in this case, a given system condition that consistently, without waver, represents either compliance or noncompliance. However, the scenarios do not necessarily represent system conditions that provide a consistent, without waver, determination of either compliance or noncompliance. For example, the proposed SOL Exceedance condition, no. 7, does not contemplate there are contingencies that can cause “unit instability (local)” that would not cause “System instability (regional)”. This situation would likely fall within condition no. 7 but is not an instance of noncompliance.

Discussion. The use of “exceedance” as proposed—SOL Exceedance—muddies compliance obligations and creates an unmeasurable threshold for compliance when considering how “exceedance” is already used throughout the Standards and used to create a compliance threshold.

The dictionary definition of “exceedance” supports that a limit is traversed, which is how the word is already used throughout the Standards. The proposed elements for the definition of SOL Exceedance characterize conditions of the BES but may not necessarily represent going over a material limit that impacts the BES.

Suggestion: Alternative Term for SOL Exceedance. Since the proposed term, SOL Exceedance, will be used to identify conditions that will determine issues of compliance and, yet, does not establish a clear compliance threshold, we respectfully encourage the use of another term. We recognize that would be a bold stroke for the SDT and, while not perfect substitutions, offer the following alternative terms:

“SOL States”, “SOL Elements”, “SOL Factors”, “SOL Operating Conditions”

Other Issues

Measurable Compliance Thresholds. The current proposed SOL Exceedance definition does not offer clear and measurable thresholds to establish compliance obligations. The current language provides a characterization of the operating system and incorporates an interpretation, to determine limits, from, for all intents and purposes, FAC-011-2.

Suggestion: Do not add a SOL Exceedance definition and incorporate the operating conditions from the proposed definition into the TOP-002 or TOP-007 Standards to establish the operational compliance thresholds.

Consideration of Risk. There are occasions when the State Estimator and the Real-time Contingency Assessment produce invalid results. Also, actual and calculated conditions can oscillate just below and just above a limit and, when considered with TOP-007, necessitate continuous reporting to the RC. Invalid results and oscillating conditions beg the question, “What is really necessary to report to the RC to maintain the reliability of the BES?”

When we think about the fact freeway traffic routinely drives above the speed limit without accidents, does an exceedance on the BES that is only 0.1% really represent a reliability risk substantial enough to require reporting?

Granted, operating the BES is not like traffic on a freeway but the analogy highlights that whatever the definition or characterization of operating conditions of the BES is used, consideration of the risk of unfavorable impacts to the BES needs to be a part of the equation.

Suggestions: To highlight consideration of risk, we offer the following:

Add the word “valid” before “post-Contingency” in the proposed SOL Exceedance definition, as provided, below.

Also, while not a risk issue, the instability referenced in condition no. 7 can only be inferred. We suggest adding the NERC Glossary term, “System,” before “instability” to clarify the object of the instability.

SOL Exceedance: An operating condition characterized by any of the following:

  1. Actual or pre‐Contingency flow on a Facility is above the Normal Rating

  2. Calculated valid post‐Contingency flow on a Facility is above the highest Emergency Rating

  3. Calculated valid post‐Contingency flow on a Facility is above a Facility Rating for which there is not sufficient time to reduce the flow to acceptable levels should the Contingency occurs

  4. Actual or pre‐Contingency bus voltage is outside normal System voltage limits

  5. Calculated valid post‐Contingency bus voltage is outside the emergency system voltage limits

  6. Calculated valid post‐Contingency bus voltage is outside emergency system voltage limits for which there is not sufficient time to relieve the condition should the Contingency occurs

  7. Operating parameters indicate the next Contingency could result in System instability.

Suggestion: The proposed SOL Exceedance definition is, for the most part, without limitation. In further consideration of risk and the evaluation of the impact on BES reliability versus the compliance burden, we would suggest an engineering study, or some form of empirical analysis, to potentially establish a range to the applicability of the SOL Exceedance definition. For example, the study or data may determine applying the definition to Facilities under 200kV offers little benefit to increasing reliability and carries a high cost. Also, if such a change was made, that the applicability would continue to be evaluated as experience is gained operating within the limits to ensure reliability had not been unfavorably impacted.

Practical Suggestion. Recognizing the standards’ formatting guidelines may be driving the format of the proposed SOL Exceedance term, we would offer replacing bullet points with numbers or letters, making it easier to cite to a particular element in the definition.

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

The drafting team should make a stronger distinct between ratings and limits. Every piece of equipment has a rating, thermal, voltage, frequency that is defined to protect the equipment from damage. The system is operated to limits that are determined by OPA’s, RTA’s. Limits may also be determined by a stability condition, transient or equipment stability. Operators are responsible for operating to the most limiting of conditions determined through the OPA’s and RTA’s. The propose definitions have lost the concept of a ‘safe operating region’ by removing the reference to most limiting condition. This concept should be revisited in the current standards or captured in the IRO and TOP Standards.

 

We recommend a change to the proposed SOL definition to include the following concepts:

 

System Operating Limits:

Reliability limits used for operations to meet acceptable BES performance,

identified through OPA’s and RTA’s,

from facility ratings that include thermal, voltage and frequency ratings,

that result in transfer Limits, system voltage limits, and stability limitations

 

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

The MISO TOP-IRO Task Team disagrees  with the definition of SOL.  In particular, the removal of the “most limiting” language introduces additional challenges since each component of the definition (Facility Ratings, System voltage limits, and stability limitations) are now individually and simultaneously SOLs for a given facility.  The notion that entities continuously assess system performance based on actual operating conditions for each of these components is incorrect as well.  While some TOPs have implemented real time voltage stability analysis they are by far the exception.  Also, real time transient stability analysis is even more rare.  Requiring all TOPs to perform these assessments in real time through the SOL definition will cause undue burden on the industry.  While we don’t necessarily agree that the current definition needs to be changed we do think it could be simplified by tweaking the proposed language to:  “System Operating Limits:  The value (such as MW, Mvar, amperes, frequency, or volts) that is the most limiting of the known Facility Ratings, system voltage limits, and stability ratings for a Facility and/or a group of Facilities and system configuration”.  

In addition we cannot see how the SOL Exceedance definition can be made clear without relating it to “pre- and post- Contingency” concepts.

We do not agree with the definition of SOL Exceedance. 

The SDT proposed definition of the SOL exceedance fails to recognize the important difference between actual, pre-contingency SOL exceedance and calculated, post-contingency risk of SOL exceedance. This attempt to include both of them under the single, generic term “SOL exceedance” may easily cause an incorrect expectation that TOP/RC control action response to these two types of Exceedances should be similar.

The actual, pre-contingency SOL Exceedance is a real-time condition exceeding the equipment’s rated capabilities, while the calculated, post-contingency risk of SOL Exceedance requires another event to happen in order to become real and actual issue.   It is clear that both of these types of exceedances require some control action to be implemented, but they might be treated differently in terms of urgency and severity of mitigating control actions, as they have different repercussions on system reliability. However, the distinction between the actual, pre-contingency SOL Exceedance and the calculated, post-contingency risk of SOL Exceedance has to be recognized in the definition, so that misconceptions that are incorporated in the definition do not subsequently cause confusion and inadequate response from real-time personnel in control centers.

In addition the proposed SDT SOL Exceedance definition does not factor in the collaboration on the RC and TOP in development of joint operating guides and in particular post contingency action plans.

The MISO TOP-IRO task team recommends a definition for SOL Exceedance that better reflects the difference in actual, pre-contingency SOL Exceedance, and the calculated, post-contingency risk of SOL Exceedance, which allows flexibility for TOPs and RCs to manage post-contingency risk of exceeding an SOL while taking operating actions to address that risk.  As long as a post-contingent action plan exists or is agreed upon by the TOP and RC, the calculated, post-contingency risk of SOL Exceedance would not be considered as an SOL Exceedance.  Our proposed definition of SOL Exceedance follows.

A.     SOL exceedance identified in real-time monitoring (pre-contingency) based on real time system conditions

·         Actual steady state flow on a BES Facility is greater than the Facility’s highest Emergency Rating for any time period.

·         Actual steady state flow on a BES Facility is above the Normal Rating but below the next Emergency Rating for longer than the time frame of the next Emergency Rating.

·         Actual steady state voltage on a BES Facility is greater than the emergency high voltage limit for time frame identified by the TOP.

·         Actual steady state voltage on a BES Facility is less than the defined emergency low voltage limit for any time period.

·         Any established Stability Limit (non-IROL) is exceeded for longer than 30 minutes or defined by Operating Plan.

B.     SOL exceedance identified in the real-time assessment based on Post Contingent system conditions

·         Projected Post Contingent Flow on a BES Facility > highest Emergency Rating and no specific post-contingency action plan agreed upon by TOP and RC. The post-contingent action plan must address potential impacts were the contingency to occur prior to normal congestion management procedures returning projected Post Contingent Flow within the highest Emergency Rating. 

·         Projected Post Contingent voltage on a BES facility< emergency low voltage limit and no specific post-contingency action plan developed by TOP or RC to address potential impacts were the contingency to occur..

Also, we do not agree that “Actual or pre-Contingency flow on a Facility above the Normal Rating” and “Actual or pre-Contingency bus voltage outside normal System voltage limits” are SOL exceedances. In both cases, we recommend use of Emergency Rating as opposed to Normal Rating, and have reflected this in the proposed definition of SOL Exceedance above. The technical rationale for our recommendation is based on the TOP rating methodology which considers all limiting factors for transmission facilities and assesses no reliability repercussions as long as the flow on facility or voltage in the bus is returned below normal rating during time that was assigned for the emergency rating. In the matter of fact, this is one of main reasons that transmission operators are given an emergency ratings and that fact should be correspondingly recognized in the SOL exceedance definition.

We disagree with the bullets 3 and 6 in the SDT proposed definition due to use of the term “sufficient time to relieve the condition should the Contingency occurs”. We believe that the fundamental principle of the SOL Exceedance definition should be that it is clear, simple and understandable to transmission operators and RCs in control center. It will be quite challenging task for operators to determine “sufficient time” especially for those exceedances that occur suddenly due to unforeseen and not previously analyzed system conditions or after forced outages. Furthermore, this part of the SDT’s proposed definition of SOL exceedances is currently being addressed by emergency operations in operating plans of TOPs. In other words, if TOPs realize, during real-time events, that the flow on facility would not be able to be returned below normal rating within the time assigned for emergency rating, TOPs would implement emergency control actions such as load shedding or generator tripping. Therefore, these types of issues do not need to be separately included into the SOL exceedance definition, and have been removed from our proposed definition of SOL Exceedance above.

Finally we disagree with treating high and low voltage the same in the SOL Exceedance definition.  The definition does not account for practical differences between the impacts of high voltage and low voltage limits.  Equipment tripping as a result of high voltage is much different than voltage collapse.  Usually occurring at low loads and low transmission loading, exceeding high voltage limit may not necessarily risk the reliability of the system but may cause local equipment outage

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

The MISO TOP-IRO Task Team disagrees  with the definition of SOL.  In particular, the removal of the “most limiting” language introduces additional challenges since each component of the definition (Facility Ratings, System voltage limits, and stability limitations) are now individually and simultaneously SOLs for a given facility.  The notion that entities continuously assess system performance based on actual operating conditions for each of these components is incorrect as well.  While some TOPs have implemented real time voltage stability analysis they are by far the exception.  Also, real time transient stability analysis is even more rare.  Requiring all TOPs to perform these assessments in real time through the SOL definition will cause undue burden on the industry.  While we don’t necessarily agree that the current definition needs to be changed we do think it could be simplified by tweaking the proposed language to:  “System Operating Limits:  The value (such as MW, Mvar, amperes, frequency, or volts) that is the most limiting of the known Facility Ratings, system voltage limits, and stability ratings for a Facility and/or a group of Facilities and system configuration”.  

In addition we cannot see how the SOL Exceedance definition can be made clear without relating it to “pre- and post- Contingency” concepts.

We do not agree with the definition of SOL Exceedance. 

The SDT proposed definition of the SOL exceedance fails to recognize the important difference between actual, pre-contingency SOL exceedance and calculated, post-contingency risk of SOL exceedance. This attempt to include both of them under the single, generic term “SOL exceedance” may easily cause an incorrect expectation that TOP/RC control action response to these two types of Exceedances should be similar.

The actual, pre-contingency SOL Exceedance is a real-time condition exceeding the equipment’s rated capabilities, while the calculated, post-contingency risk of SOL Exceedance requires another event to happen in order to become real and actual issue.   It is clear that both of these types of exceedances require some control action to be implemented, but they might be treated differently in terms of urgency and severity of mitigating control actions, as they have different repercussions on system reliability. However, the distinction between the actual, pre-contingency SOL Exceedance and the calculated, post-contingency risk of SOL Exceedance has to be recognized in the definition, so that misconceptions that are incorporated in the definition do not subsequently cause confusion and inadequate response from real-time personnel in control centers.

In addition the proposed SDT SOL Exceedance definition does not factor in the collaboration on the RC and TOP in development of joint operating guides and in particular post contingency action plans.

The MISO TOP-IRO task team recommends a definition for SOL Exceedance that better reflects the difference in actual, pre-contingency SOL Exceedance, and the calculated, post-contingency risk of SOL Exceedance, which allows flexibility for TOPs and RCs to manage post-contingency risk of exceeding an SOL while taking operating actions to address that risk.  As long as a post-contingent action plan exists or is agreed upon by the TOP and RC, the calculated, post-contingency risk of SOL Exceedance would not be considered as an SOL Exceedance.  Our proposed definition of SOL Exceedance follows.

  1. SOL exceedance identified in real-time monitoring (pre-contingency) based on real time system conditions

  • Actual steady state flow on a BES Facility is greater than the Facility’s highest Emergency Rating for any time period.

  • Actual steady state flow on a BES Facility is above the Normal Rating but below the next Emergency Rating for longer than the time frame of the next Emergency Rating.

  • Actual steady state voltage on a BES Facility is greater than the emergency high voltage limit for time frame identified by the TOP.

  • Actual steady state voltage on a BES Facility is less than the defined emergency low voltage limit for any time period.

  • Any established Stability Limit (non-IROL) is exceeded for longer than 30 minutes or defined by Operating Plan.

     

  1. SOL exceedance identified in the real-time assessment based on Post Contingent system conditions

  • Projected Post Contingent Flow on a BES Facility > highest Emergency Rating and no specific post-contingency action plan agreed upon by TOP and RC. The post-contingent action plan must address potential impacts were the contingency to occur prior to normal congestion management procedures returning projected Post Contingent Flow within the highest Emergency Rating. 

  • Projected Post Contingent voltage on a BES facility< emergency low voltage limit and no specific post-contingency action plan developed by TOP or RC to address potential impacts were the contingency to occur..

Also, we do not agree that “Actual or pre-Contingency flow on a Facility above the Normal Rating” and “Actual or pre-Contingency bus voltage outside normal System voltage limits” are SOL exceedances. In both cases, we recommend use of Emergency Rating as opposed to Normal Rating, and have reflected this in the proposed definition of SOL Exceedance above. The technical rationale for our recommendation is based on the TOP rating methodology which considers all limiting factors for transmission facilities and assesses no reliability repercussions as long as the flow on facility or voltage in the bus is returned below normal rating during time that was assigned for the emergency rating. In the matter of fact, this is one of main reasons that transmission operators are given an emergency ratings and that fact should be correspondingly recognized in the SOL exceedance definition.

We disagree with the bullets 3 and 6 in the SDT proposed definition due to use of the term “sufficient time to relieve the condition should the Contingency occurs”. We believe that the fundamental principle of the SOL Exceedance definition should be that it is clear, simple and understandable to transmission operators and RCs in control center. It will be quite challenging task for operators to determine “sufficient time” especially for those exceedances that occur suddenly due to unforeseen and not previously analyzed system conditions or after forced outages. Furthermore, this part of the SDT’s proposed definition of SOL exceedances is currently being addressed by emergency operations in operating plans of TOPs. In other words, if TOPs realize, during real-time events, that the flow on facility would not be able to be returned below normal rating within the time assigned for emergency rating, TOPs would implement emergency control actions such as load shedding or generator tripping. Therefore, these types of issues do not need to be separately included into the SOL exceedance definition, and have been removed from our proposed definition of SOL Exceedance above.

Finally we disagree with treating high and low voltage the same in the SOL Exceedance definition.  The definition does not account for practical differences between the impacts of high voltage and low voltage limits.  Equipment tripping as a result of high voltage is much different than voltage collapse.  Usually occurring at low loads and low transmission loading, exceeding high voltage limit may not necessarily risk the reliability of the system but may cause local equipment outage

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

2015-09_FAC-011-4 - Comment Form Questions - TOP-IRO TT response to Q 1 - 3 Aug 11..docx

- 0 - 0

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

- 0 - 0

We would like to acknowledge the great effort and work of the SDT in improving the SOL related standards and we support the new definitions of SOL and SOL Exceedance. We would like to point out the following for consideration by the SDT.

1- Concerning the language “sufficient time to …” in bullets 3 and 6, it is unclear how the “time evaluation” to address the issue needs to be managed in real time when actual system conditions may vary from the day-ahead OPA and Operating Plan used to mitigate the SOL Exceedance.  We understand and agree that the day-ahead OPA may identify a “time to relieve the condition” that exceeds the allowed time to respect the Facility Rating or voltage limit, but in real-time the actual availability of resources and time to complete the operating actions may vary widely. For example, what happens if the time to get the appropriate reactive resources available to mitigate a voltage-related SOL is different in real time from what was planned in the OPA? How often does the “sufficient time” need to be evaluated in real-time by the TOP to take the decision of treating a SOL Exceedance (initiate an Operating Plan before the contingency actually occurs)?

2- There is confusion between bullets 5 and 6, both addressing the post-Contingency bus voltage outside the emergency limits. In particular, bullet 6 is logically redundant to bullet 5.

3- Concerning the last bullet, “Operating parameters indicate the next Contingency could result in instability”, we understand that the intent is to capture all the possible stability limitations that could be identified in real-time. However, since industry practice includes a good proportion of “maximum MW transfer” on equipment and interfaces to manage stability constraints (often with offline studies), it would seem appropriate to add a separate bullet (or at least some additional rationale) to clearly state that “Pre-Contingency flow on an interface exceeds the identified stability limit” constitutes an SOL Exceedance. There are 3 bullets to address Facility Ratings, thus it would make sense to be more explicit on stability related SOLs.

4- In terms of the SOL definition itself – Assuming all limits are Facility Ratings, Systems voltage limits and stability limitations, the definition can be aligned more closely with the purposes of the standards and avoid the use of the ambiguous “Reliability limit”– i.e. “SOL -  Facility Ratings, System voltage limits and stability limitations relevant for the reliable operation of the BES” or perhaps “Limits relevant to the operation of the BES arising from Facility Ratings, System voltage limits and stability limitations”.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

The revised definition of SOL is good.  The SDT might consider using “Stability Limits” in the definition and then revising the definition of Stability Limits in the NERC glossary so that it goes well with this definition of SOL.  The stability limitations language in the current definition can work but it may lead to some confusion.  

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

  • BPA recommends the following language be added to the first bullet of the SOL Exceedance definition: “Actual or pre-Contingency flow on a Facility is above the Normal Rating **for more than (X) minutes, as defined in the TOP’s Operating Plan.” 

 

  • BPA also recommends the following language be added to the fourth bullet of the SOL Exceedance definition: “Actual or pre-Contingency bus voltage is outside normal System voltage limits **for more than (X) minutes, as defined in the TOP’s Operating Plan.”

Many times in operations, a facility may exceed its Normal Rating for two minutes and then resolve below the Normal Rating.  BPA believes this additional language would prevent the potential need for a TOP to document and/or report every occurrence of operating above the Normal Rating.  From a pragmatic perspective, this language would eliminate a potential resource burden to complete a compliance reporting task that does not enhance reliability. (**As noted by the SDT in paragraph 1 in the explanation column of ‘Proposed New Definition of SOL Exceedance’ table.)

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

The two post contingency bus voltage bullets seem to be in disagreement.  The first says an exceedance is if you are outside the voltage limits.  The second is outside limits AND there is not enough time to relieve the condition.  You can never reach the second bullet due to the first bullet that doesn’t allow time.  Otherwise I like the revised definition.

 

 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

While we agree that the combination of a revised definition of SOL and a new definition of SOL Exceedance could support a better distinction between “what the limits are” and “how the system should be operated”, we do not agree that the Facility Ratings, System voltage limits, and stability limitations are the actual SOLs, nor do we agree with the revised definition of SOL and the proposed definition of SOL Exceedance. Please see our comments under Q1, above.

 

While we agree that the combination of a revised definition of SOL and a new definition of SOL Exceedance could support a better distinction between “what the limits are” and “how the system should be operated”, we do not understand what the reliability need is to identify that the Facility Ratings, System voltage limits, and stability limitations are the actual SOLs.  Also, we request the drafting team to provide the rationale for the new definition of SOL and the proposed definition of SOL Exceedance. Please see our comments under Q1, above.

 

Note: ERCOT and CAISO do not support the above comments.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team.  Additionally, we don't believe that every facility limit is an SOL nor is reaching a normal rating of a facility is an SOL exceedance.  A different term is needed for this. 

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

- 0 - 0

Other Answers

The proposed definition for bullet item #2 states, “Calculated post-Contingency flow on a Facility is above the highest Emergency Rating”. What if there are two (2) levels of Emergency Ratings, say a 30 minute rating and a 15 minute rating? In this case, it would appear there is no SOL Exceedance and thus no operating plan needing developed until the 15 minute rating is exceeded.

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

- 0 - 0

No comments

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

See AZPS’s answer to Question #1

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

See the above comments

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

- 0 - 0

See MISO TOP-IRO Task Team response.

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

The SOL Exceedance definition ignores the possibility that the system can be operated in real-time operation above the Normal rating of a Facility but within an Emergency rating for less than the time allowed by the Emergency rating and not be an exceedance of the SOL.

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

- 0 - 0

NPPD supports the comments submitted by the MISO TOP-IRO Task Team.

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

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

- 0 - 0

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

- 0 - 0

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

We disagree with SOL and SOL Exceedance definitions. Refer to comments on question 1 for SOL Exceedances.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

PJM agrees that Facility Ratings, System voltage limits, and stability limitations comprise the set of SOL.  Removing performance criteria from the limit definition helps to clarify the limits.    

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

Given the language within the Reliability Standards there still remains confusion between "SOL Exceedance" and violating and SOL or IROL.

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

- 0 - 0

Texas RE is concerned the proposed definition of an SOL Exceedance provides more confusion then clarification.  Texas RE recommends the following in order to provide clarification:

  1. For Actual or pre-Contingency flow on a Facility is above the Normal Rating, the definition should consider post-Contingency above Normal Rating (which could be below Emergency Rating).

  2. For Calculated post-Contingency flow on a Facility is above the highest Emergency Rating, Texas RE inquires as to how there can be multiple Emergency Ratings.  As written an entity could claim there is a “higher” Emergency Rating and avoid compliance, lower reliability, and submit the System/Facility/Element to a higher risk.  Typically, the RC and TOP will define pre-contingency and post-contingency voltage limits.  Texas RE recommends using these terms in place of “emergency system voltage limits” in the SOL exceedance definition and updating FAC-011-4 R3 to address these limits.

  3. Calculated post-Contingency flow on a Facility is above a Facility Rating for which there is not sufficient time to reduce the flow to acceptable levels should the Contingency occurs. This would be more helpful if there is a defined time period and a definition for “acceptable level”. 

  4. Actual or pre-Contingency bus voltage is outside normal System voltage limits—System voltage may not be equivalent to bus voltage.  This will result in System voltage being set to the extreme edges of what the most extreme bus voltage may be present. System configurations change and elements must remain within element limitations.  A 1.07 pu voltage may be reasonable in an industrialized location but not across the Interconnection.

  5.  For Calculated post-Contingency bus voltage is outside the emergency system voltage limits, a definition of “emergency system voltage limits” would increase clarity. 

  6. For Calculated post-Contingency bus voltage is outside emergency system voltage limits for which there is not sufficient time to relieve the condition should the Contingency occurs—This is vague in that it does not describe who sets these limits, how are the limits are communicated, and whether or not there is a methodology. 

  7. For Operating parameters indicate the next Contingency could result in instability, Texas RE recommends defining “operating parameter”.  It appears that instability itself may not be considered an SOL exceedence.  Was this the SDT’s intent? 

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  Yes, after much study and reflection.  It is a somewhat complicated situation.     

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

Today, there is a very clear distinction between the performance criteria that we’re attempting to observe (e.g. voltage declines at a bus must be less than 10%) and how the system is operated to meet this criteria (e.g. establishing SOLs, directly monitoring criteria and adjusting dispatches if a criteria violation is observed).  We’re not sure that these proposed definitions add any more clarity – in fact our concern is that these proposed definitions confuse the ideas of “performance criteria” and “system operating limits” (see our comments to 1). 

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

- 0 - 0

Yes, after much study and reflection.  It is a somewhat complicated situation.     

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

NIPSCO agrees with comments submitted by the MISO TOP-IRO Task team.

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1. We agree Facility Ratings, System voltage limits, and stability limitations are the actual SOLs.  However, the SOL Exceedance definition does not allow for Operator action. 

An example:

a.      Excursions above the normal rating, but below the emergency rating should not be SOL Exceedance if flow is reduced to the normal rating in the time frame used to develop the Emergency rating.

b.      Excursions outside of the normal voltage limits should not be SOL Exceedances if returned within the normal range within a specified time.  IROL have a default 30 minutes criteria for operator action.  SOL Exceedances should be given similar opportunity for operator action.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern believes a SOL exceedances should only be applied in real time.  Bullet #2 of the proposed definition of SOL Exceedance, suggest that OPA contingency analysis identifying potential SOLs that violate emergency ratings is a SOL Exceedance.  

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

We incorporate our response to Question 1.

Additionally, while we support the SDT’s direction of simplifying the SOL definition, the language, “any identified stability limitations” is vague and not measureable. The use of “any identified” does not provide a clear compliance threshold. Also, while this may have already been addressed by the SDT, “Stability” and “Stability Limit” are NERC Glossary Terms and it is unclear if the intent is to incorporate the words as Glossary Terms. Granted, “Stability Limit” does not necessarily define “stability limitations,” so there is the potential for confusion.

Suggestion: We offer the following modification to the proposed revisions to SOL.

Reliability limits used for operating the BES, to include Facility Ratings, System voltage limits, and limitations established by the Reliability Coordinator’s System Operating Limit methodology.

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

see Q1

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

We agree Facility Ratings, System voltage limits, and stability limitations are the actual SOLs.   However, the removal of the “most limiting” language introduces additional challenges since each component of the definition (Facility Ratings, System voltage limits, and stability limitations) are now individually and simultaneously SOLs for a given facility.  The notion that entities continuously assess system performance based on actual operating conditions for each of these components is incorrect as well.  While some TOPs have implemented real time voltage stability analysis they are by far the exception.  Also, real time transient stability analysis is even more rare.  Requiring all TOPs to perform these assessments in real time through the SOL definition will cause undue burden on the industry.  While we don’t necessarily agree that the current definition needs to be changed we do think it could be simplified by tweaking the proposed language to:  “System Operating Limits:  The value (such as MW, Mvar, amperes, frequency, or volts) that is the most limiting of the known Facility Ratings, system voltage limits, and stability ratings for a Facility and/or a group of Facilities and system configuration”.  

In addition we cannot see how the SOL Exceedance definition can be made clear without relating it to “pre- and post- Contingency” concepts.

 

The SOL Exceedance definition needs to be changed to reflect appropriate control action responses from TOPs/RCs in accordance with our technical rationale provided in answer to the previous question.

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

We agree Facility Ratings, System voltage limits, and stability limitations are the actual SOLs.   However, the removal of the “most limiting” language introduces additional challenges since each component of the definition (Facility Ratings, System voltage limits, and stability limitations) are now individually and simultaneously SOLs for a given facility.  The notion that entities continuously assess system performance based on actual operating conditions for each of these components is incorrect as well.  While some TOPs have implemented real time voltage stability analysis they are by far the exception.  Also, real time transient stability analysis is even more rare.  Requiring all TOPs to perform these assessments in real time through the SOL definition will cause undue burden on the industry.  While we don’t necessarily agree that the current definition needs to be changed we do think it could be simplified by tweaking the proposed language to:  “System Operating Limits:  The value (such as MW, Mvar, amperes, frequency, or volts) that is the most limiting of the known Facility Ratings, system voltage limits, and stability ratings for a Facility and/or a group of Facilities and system configuration”.  

In addition we cannot see how the SOL Exceedance definition can be made clear without relating it to “pre- and post- Contingency” concepts.

 

The SOL Exceedance definition needs to be changed to reflect appropriate control action responses from TOPs/RCs in accordance with our technical rationale provided in answer to the previous question.

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

We agree that this approach allows for a clear distinction.

In addition, although we understand IROLs, as a subset of SOLs, are addressed by the SOL Exceedance definition and OPA/RTA concept, it would be helpful to have more guidelines and rationales on the application of the SOL Exceedance definition to address IROL[GM1] .

 

 

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

Related to our comments in Q1 and Q2, above, we ask the SDT to elaborate why:

 

a.      There is no variability that a Facility rating may or may not be an SOL; and

b.      The Emergency Rating is used instead of applicable rating since in some cases, a TOP may apply a rating that is lower than the Emergency Rating; and

c.       There are apparent duplicated conditions for SOL exceedance.

 

Note: ERCOT and CAISO do not support the above comments.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

No comment

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

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

- 0 - 0

We agree with removing the language from the definition of SOL. System Operating Limits are limits no matter if they are the most limiting or not.  It makes more sense to move the operating language from the old SOL definition to the SOL Exceedance definition.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

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

- 0 - 0

See MISO TOP-IRO Task Team response.

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

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

- 0 - 0

NPPD supports the comments submitted by the MISO TOP-IRO Task Team.

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

While Duke Energy agrees with the removal of the phrases listed in the question, we still have concerns regarding the proposed definition. As written, it appears that the definition of SOL is not a standalone definition in that it does not distinguish between a normal or emergency rating, and needs the definition of SOL Exceedance which includes this distinction, to provide some clarity.  The proposed definition of SOL Exceedance includes references to Pre- and post- Contingency, so it could be argued that the phrases the drafting team points to in the question have not been completely removed, as they are still present in the SOL Exceedance definition. We reiterate that a specific reference to both Normal and Emergency Ratings could aid in clearing up the ambiguity that presently exists in the definition of SOL.

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

- 0 - 0

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

- 0 - 0

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

We disagree with removal of most limiting criterion. Refer to comments in Q1.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

A limit, including SOL, is a parameter.  Removal of the identified terms eliminates performance criteria from the SOL definition.  Married with the proposed new definition for SOL Exceedance, this change to SOL makes the definition much cleaner with SOL being a set of parameters, each of which must be addressed within RTA/OPA.    

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

The removal of “most limiting criteria” creates a scenario where multiple SOLs may exist, causing confusion as to which limits the System should be operated to.  Also, the removal of “specified system configuration” may prevent stability limits from being identified in real-time, as entities may work under the assumption that stability limits are based on study cases and not real-time System conditions.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS] 

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

We agree providing that our comments above are duly addressed.

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

- 0 - 0

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

NIPSCO agrees with comments submitted by the MISO TOP-IRO Task team.

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.      SOL Exceedance need to have a time frame to allow operator action.   SOL Exceedances, by themselves, may not considered non-compliance issues.  However, not allowing operator action to avoid declaring an SOL Exceedance will create an unnecessary burden of evidence capture for condition that the System Operator have under control.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

the most limiting criteria: The phrase, even with the parenthetical examples, was subject to unlimited interpretations.

specified system configuration: The new and future enforceable Standards focus on Facilities and their impact to the System. The term does not add clarity in light of the new and future enforceable Standards.  

operation within acceptable reliability criteria: The word, “Acceptable,” is vague and not measurable.  “Reliability criteria” is undefined, vague and can only be inferred.

pre- and post- Contingency: Contingency awareness is addressed in TOP-002-4.

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

No. We believe a fundamental concept of system operations is lost with the removal of most limiting criteria. This defines a safe operating range for operators to meet acceptable BES performance. From a 2007 NERC document, we need to tie the concept of boundary conditions – the specific set of study assumptions and associated outcomes that resulted in acceptable interconnection performance – to the system operating limits within which system operators must operate the system. We also agree that SOL's may be constently changing and that RTAs are very dynamic. However this suggestion puts a boundary on compliance obligations, without limiting what an entity chooses to do on his own system.

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

We do not agree with removing the terms  “pre- and post- Contingency” and “the most limiting criteria” from the definition of SOL, as previously stated.

 

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

We do not agree with removing the terms  “pre- and post- Contingency” and “the most limiting criteria” from the definition of SOL, as previously stated.

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

Yes.  It’s not fully clear whether this will eliminate the risks outlined above, since it seems there is still potential that the Facility Ratings provided by the TO may not provide what is required, but it will depend on what the actual RC methodology says.

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

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

- 0 - 0

The word “determine” in the requirement can be confusing.  The requirement could be interpreted that the Transmission Operator calculates the facility ratings.  The following language may be more clear, “Reliability Coordinator shall include in its SOL Methodology the method for Transmission Operators to determine which of the owner-provided Facility Ratings should be used in operations. The method shall address the use of common Facility Ratings between the Reliability Coordinator and the Transmission Operators in its Reliability Coordinator Area.”

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

AZPS does agree that the TOP should determine the appropriate Facility Ratings; however, the last sentence in the requirement is confusing.  Because the RC does not derive the facility ratings, the use of the word “common” is confusing. AZPS respectfully requests that the sentence be clarified.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

Facility owners should decide what kind of risk they are willing to take in operating their facilities. These assumptions are rolled in to the facility rating methodology. It is not appropriate to take this away from the facility owners.

 

Some RCs serve a very large geographic area with varying environmental conditions (i.e. Northern Canada vs. Southern US). These RC will have a difficult time developing uniform criteria valid for the entire region.  

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

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

- 0 - 0

The intent of the requirement as outlined in the explanation/rationale and the question is not clear from the requirement.  The requirement should be clear that the RC SOL Methodology must utilize Facility Ratings that are provided by the TO and operate within those Facility Ratings.  As written, it may be implied that the RC SOL Methodology may require the TOP to develop ratings that are different or use different methodologies than the TO’s Facility Ratings.  Recommend R2 be rewritten as:  “Each Reliability Coordinator shall include in its SOL Methodology the method for Transmission Operators to determine the applicable Facility Ratings provided by the Transmission Owner to be used in operations. The method shall address the use of common Facility Ratings between the Reliability Coordinator and the Transmission Operators in its Reliability Coordinator Area.”

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Duke Energy does not agree with the proposed direction of having the TOP to determine the appropriate Facility Ratings for use in operations. We believe that the TO/GO should be determining the rating, as they already have their own ratings methodology (FAC-008). We disagree with the premise that the RC may overtake the TO’s ratings methodology. We suggest the drafting team consider bypassing the requirement of an RC creating an SOL Methodology, and require that the TOP create its own SOL Methodology under FAC-014. Dependence on the actions/intervention of the RC may vary by region, and we suggest that if a particular region relies more heavily enough on the RC to require an RC SOL Methodology, perhaps a specific regional standard should be created for that region.

An overarching clarification we would like made, is in regards to the apparent shift towards considering the actual Facility Rating as the SOL. If this is the drafting team’s intent, we ask how the outlining of a specific SOL Methodology affects the determination of a Facility Rating being the SOL. Will the SOL Methodology be used to re-visit the Facility Rating and its appropriateness as the SOL? More clarification as to how these two approaches will interact would be appreciated.

Lastly, based on our review, it appears that some aspects of the proposed would require entities to operate in a more limiting fashion, and in some cases intruding upon current TPL standards. For example, the proposed definition of SOL Exceedance has appeared to eliminate the possibility of an entity using its Emergency Ratings pre-Contingency. This conflicts with current TPL standards. For single contingency under the TPL standards, the requirement is that you do not have consequential or inconsequential load loss. There is nothing there about not being able to use your long term Emergency rating on a pre-contingency basis.

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

- 0 - 0

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

- 0 - 0

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

By definition, Facility Ratings are one factor in determining SOLs so all Facility Ratings need to be incorporated into the determination of SOLs.  The requirement should be modified to “Each Reliability Coordinator shall include in its SOL Methodology the method for Transmission Operators to incorporate the Facility Ratings in establishing SOLs. The method shall address the use of common Facility Ratings between the Reliability Coordinator and the Transmission Operators in its Reliability Coordinator Area.”

 

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

PJM agrees that the TOP is the appropriate reliability entity for Facility Rating usage in the agreed upon manner established by their RC.    

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

The TOP should be developing their own Facility Rating methodology. As the individuals most familiar with their system.

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

- 0 - 0

Texas RE recommends this requirement include additional details that the SOL determined by the TOP should not exceed the Facility Rating.  Part 3.1 of proposed FAC-011-4 includes a requirement that “System voltage limits are not outside of the Facility voltage ratings”, but there is no requirement that SOLs should not exceed the thermal limit component of a Facility Rating.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS] 

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

Given FAC-014-3/R2 requires the TOP to establish SOLs, there can (and often does) exist a time lapse between a TO establishing a Facility Rating and the TOP using that Facility Rating to establish/implement the SOL.  Similarly, sometimes the “schedule (per FAC-008-3/R6)” is different between RCs and TOPs, leading to different entities having different Facility Ratings information depending upon when they were informed by the TO.  Suggested comment is: recommend modifying the applicability of FAC-014-3 to include Transmission Owners.  Likewise, recommend adding a requirement that, when a Transmission Owner changes a Facility Rating prior to a scheduled request, the Transmission Owner shall provide the updated Facility Rating to its associated Reliability Coordinator(s), Planning Coordinator(s), Transmission Planner(s), Transmission Owner(s) and Transmission Operator(s). 

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

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

- 0 - 0

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

NIPSCO is concerned that the requirement does not provide adequate assurance that the RC will respect the ratings established by the TO or the TO’s FAC-008 methodology.  As written, the language is vague and could be interpreted as allowing an RC to determine the ratings that a TOP must use (including normal and emergency ratings and seasonal changeover dates) without respecting the TO’s authority to establish such Facility Ratings. 

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.      We agree that the TOP should make the determination, but ask the SDT to take into consideration that TOPs have existing documented processes and methodologies that would no longer apply when determining Facility Ratings for use in operations.  This requirement imposes a process onto TOPs that may drastically deviate from existing practices, therefore we suggest an addition to this requirement that the RC gather and review existing methodologies from each TOP in their reliability area and come to a mutually agreed upon methodology with the affected TOPs.

2.     Also the standard should require the RC to obtain TOP agreement anytime the SOL Definition inserts the usage of “sufficient time” into the determination of an SOL Exceedance. 

3.     Additionally, will the RC set requirements for the TOP determine equipment ratings for set ambient temperature ranges and establishing emergency ratings on set time lengths, such as 30 minutes – or 2 hours?

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

if the SDT wants to standardize existing methodologies, this is not the place to do it as FAC-008 addresses facility ratings.

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

Concern: The Requirement states the “…Reliability Coordinator shall include in its SOL Methodology the method for Transmission Operators to determine the applicable Facility Ratings to be used in operations.” The language is broadly written to, likely, provide flexibility to the RC in creating its Methodology. However, the potential unintended effect with the RC unilaterally determining the Methodology is it may not address the materiality of Facilities, possibly requiring assessment of each Facility on the TOP’s system and creating an onerous task for TOPs executing the Methodology—all with little benefit to reliability.

For example: In R3, the TOP is required to provide a “System Voltage Limit.” For the purpose of this example, an unbound Methodology, one without a single high and low limit that is appropriate for the TOP’s System, could require calculation of System Voltage Limits for every Facility on the TOP’s System.

Also, while collaboration between the RC and TOP can be inferred, the proposed revised Standard is without explicit guidance or recourse should the TOP have concerns about the scope of the RC’s Methodology.

Suggestion: Add language to provide that the RC create its Methodology in consultation and collaboration with the TOPs. Also, that the RC and TOPs come to a consensus regarding the scope of the Methodology. We recognize, for purposes of compliance determinations, it is difficult to provide evidence supporting “consultation and collaboration” so focused the suggested Requirement language on consensus.  We offer the following Requirement and Measure language as a framework for further consideration.

FAC-011-4

R1.1

Each Reliability Coordinator shall come to a consensus through consultation and collaboration with the Transmission Operators regarding  the following points of its SOL Methodology:

R1.1.1

The method Transmission Operators use to determine the applicable Facility Ratings to be used in operations and the use of common Facility Ratings between the Reliability Coordinator and the Transmission Operators in its Reliability Coordinator Area.

R1.1.2

The method Transmission Operators use to determine the applicable steady-state System voltage limits to be used in operations.

R1.2

Each Reliability Coordinator shall come to a consensus through consultation and collaboration with the Transmission Planners regarding  the following points of its SOL Methodology:

R1.2.1

The study models and the level of detail the Reliability Coordinator requires determining the stability limitations to be used in operations.

R1.2.2

How stability limitations are established when there is an impact to more than one Transmission Operator in the Reliability Coordinator Area.

Measures for R1

The Reliability Coordinator shall have evidence the Transmission Operators and Transmission Planners accepted the points of the SOL Methodology as listed in R1.

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

The MISO TOP-IRO TT is only responding to Questions 1, 2 and 3

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

We agree with R2, although we are concerned that the non-uniformity of the Facility Ratings provided by the TO can add burden to the application of the method to all scenarios. Also, guidelines regarding an appropriate method would be helpful in the final version of the standard.

To “address" the use of common FR does not require the common FR be used. 

Suggestion:  “The method shall require the use of common Facility Ratings between the RC and the TOPs in its RC area.”

The language can also be simplified slightly –

Suggestion:  “The method shall require the same Facility Ratings by used by the RC and the TOPs in its RC area.”

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

BPA believes the TOP should follow a consistent methodology, and continue to provide the RC its application Facility Ratings used in Operations. BPA believes this benefits all TOPs.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

As mentioned in the response to question 1 above, while this document states that FAC-008-3 should include facility voltage ratings, that is not something that we have seen TOs do in practice.  If the intention is that they are required, then it needs to be clarified and communicated somehow. If these facility voltage rating exist, why can they not be used directly instead of requiring the TOP to develop separate system voltage limits?  Lack of voltage monitoring? Are there voltage considerations that the TOP would have that wouldn’t be covered under a rating (and wouldn’t be covered under voltage stability limits)?

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

AZPS respectfully suggests that Requirement 3.3 is troublesome because the minimum operating system voltage under multiple contingencies could be below the highest UVLS settings where the UVLS is used as a safety net.  Because it is acceptable for UVLS to act and stabilize the system voltage to a more acceptable level, the “lowest allowable System voltage” could differ depending upon the system topology and characteristics in effect.   Stated another way, while the intent of requirement 3.3 is reasonable for the all lines in service condition, it may not be for an N-1 or N-2 conditions.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

See our comments to question 4 above. Duke Energy has no issue with the TOP establishing the System voltage limits or even the criteria proposed, however, we do not see justification to impose the RC’s SOL Methodology onto the TOP.

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

- 0 - 0

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

- 0 - 0

The Transmission Operator and Transmission Owner should establish voltage limits because of Facility considerations.  Regarding Part 3.5, common voltage limits may not be appropriate between the Reliability Coordinator and Transmission Operators in its footprint.  Voltage limits should be identified uniquely between a RC and each of its TOPs.

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Requirement text should be modified to “Each Reliability Coordinator shall include in its SOL Methodology the method for Transmission Operators to incorporate the steady-state System voltage limits in operations establishing SOLs.

We agree that TOP should establish the system voltage limits pursuant to RC SOL methodology however there seems to be redundancy between this requirement and existing VAR-001-4 R1. The intent of VAR-001-4 R1 is for TOP to system establish voltage schedules which may use low and high limits in accordance with SOLs. If FAC-011-4 R3 will require establishment of system voltage limits then the VAR-001-4 R1 should be removed as it creates duplicate requirement.

R3.2 should be modified to state ‘Require that System voltage limits are not outside of voltage limits identified in Nuclear Plant Interface Requirements for buses/equipment identified in NPOA’.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

PJM agrees that the TOP is the appropriate reliability entity for this determination and with the predominant sentiment of the requirement.  

  • However, the proposed R3 does NOT provide sufficient clarity in its present draft construct.  Nor does it remain true to the intended objected stated within the SOL Definition Explanation of Proposed Revision section [above] to respect advancements in technology.   R3.1 & R3.2 require that “System voltage limits are not outside” of the Facility voltage ratings or NPIR requirements.  Technology advancements permit the setting of discrete limitations, including facility voltage limitations, on any bus on a given system.  For facilities where no discrete facility voltage limitation is applied, the system can implicitly apply the System voltage limit on a voltage class or per unit level, which may be outside the limits for any given discrete facility ratings. Each can be analyzed, monitored and controlled reliably within OPA/RTA, without the requirement that the System voltage limit not be outside of the Facility voltage ratings and/or NPIR requirements.
  • Suggested language change options:
    •  (3.1) Require that Facility voltage ratings are respected by and coordinated with System voltage limits;
    •  (3.2) Require that  Nuclear Plant Interface Requirements are respected by and coordinated with System voltage limit    

 

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Texas RE recommends the RC SOL methodology address pre-contingency and post-contingency voltage limits, with the SOL exceedance definition updated to match this terminology. 

 

Texas RE noticed FAC-011-3 R1 is not fully mapped to FAC-011-4 Part 3.1, as Part 3.1 does not address thermal limits.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  We believe an additional bullet (3.7) should be added that says “Address coordination of System voltage limits between adjacent Reliability Coordinator Areas.”  There should be some coordination so that along RC Area seams there do not continue to be issues where differing voltage limit criteria results in real-time issues.

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

In regards to System Voltage.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

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

- 0 - 0

We believe an additional bullet (3.7) should be added that says “Address coordination of System voltage limits between adjacent Reliability Coordinator Areas.”  There should be some coordination so that along RC Area seams there do not continue to be issues where differing voltage limit criteria results in real-time issues.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

NIPSCO is concerned that the requirement does not provide adequate assurance that the RC will respect the Facility voltage ratings established by the TO or the TO’s FAC-008 methodology.  As written, the language is vague and appears to allow the RC to determine the voltage ratings that a TOP must use.

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.      We agree that the TOP should make the determination, but ask the SDT to take into consideration that TOPs have existing documented processes and methodologies specific to their needs that would no longer apply when establishing System voltage limits for use in operations.  This requirement imposes a process onto TOPs that may drastically deviate from existing practices, therefore we suggest an addition to this requirement that the RC gather and review existing methodologies from each TOP in their reliability area and come to a mutually agreed upon methodology with the affected TOPs.

2.      To avoid issues where differing voltage limit criteria result in Real-time issues, we believe an additional bullet (3.7) should be added that says “Address coordination of System voltage limits between adjacent Reliability Coordinator Areas”  to allow for coordination along RC Area seams.  

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Yes it provides clarity but Requirement 3.5 should be handled via a revision of FAC-008.

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

We incorporate our response to Question 4.

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0


 

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

We agree with the intent of R3, but the sub-bullets are a burden to compliance with no benefit to reliability. They tell the “how” more than the “what” and should be part of the guidelines to the requirements. Why is R3 so detailed regarding the content of the method compared to R2? More uniformity of structure between R2, R3 and R4 would be beneficial. More precisely, we think that 3.4 is redundant with the body of the requirement and not needed, and 3.3 addresses the allowed use of UVLS in SOL determination that should be a separate requirement (combined with allowed use of RAS in R4). Alternately, if 3.3 is maintained, it should take into consideration voltage triggered RAS.

3.5 should be reworded in line with our suggestion for R2. Require the “same” System voltage limits be used by the Reliability Coordinator and the Transmission Operators in its Reliability Coordinator instead of "common".

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

With regard to proposed requirement R3.1, equipment/facility voltage ratings come from Transmission Owner and Generation Owner.  While the establishment of equipment/facility voltage ratings may be implied through the NERC definition of Facility Ratings, there is no direct requirement in FAC-008-3 for TOs and GOs to determine equipment/facility voltage ratings. There may be value in having a corresponding requirement added to FAC-008-3 requiring TOs and GOs to determine equipment/facility voltage ratings and to communicate those upon request. This would close the loop, allowing TOPs to have access to the equipment/Facility voltage ratings they need in order to establish system voltage limits.  The SDT might also consider adding “equipment voltage ratings” to proposed requirement R3.1.  

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

We interpret System voltage limits to mean voltages on the system or specific buses. We do not believe a definition is needed. However, if one is needed, then the one proposed above seems reasonable. Still, that definition does not imply that System voltage limits are SOLs.

 

Note that the proposed definition of System voltage limits more or less concurs with our comment under Q1 that System voltage limits may not be the SOL. There are a number of places in the Eastern Interconnection that have SOL defined as the total MW flow on an interface (e.g. in IESO, NYISO, APS, etc.) that are restricted by the post-contingency voltage levels in the area (on buses) near or within the defined interfaces.

 

We suggest the SDT consider distinguishing between a voltage limit and a voltage rating. Where the rating is set to protect equipment damage or the ability for equipment to operate and the voltage limit is a value to operate to, to protect the voltage ratings.

 

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

It would be helpful to have a definition for System Voltage Limits.  In addition to the definition considered above, it may be useful to add that the system voltage limits, “and is within applicable facility voltage ratings”.

 

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

It is clear what System voltage limits are - and to the extent it is not, this clarity must be covered within the RC's SOL Methodology.  There is no need to create a NERC Glossary definition for this.

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

- 0 - 0

A definition for System Voltage Limits would be beneficial.  There seems to be some confusion if system voltage limits are system-wide voltage limits or if each facility can have different voltage limits similar to System Operating Limits.  Also FAC-008 does not seem to mention voltage limits.  Where is the requirement for the facility owners to provide facility voltage ratings to be used in the calculation of System Voltage Limits?

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

It would be helpful to define the “System Voltage Limits” so that it is clear that the system voltage limit is not one value, but could be different values at each bus.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

New definition for “System Voltage Limits” is not required.

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

 Although a System Voltage Limits definition is needed, the proposed definition, as found in the question, ignores that the acceptable voltage levels can vary according to the duration of the voltage excursion. The drafting team would review the recently released NERC draft Reliability Guidelines for Reactive Power Planning and Operations and its explanation of the need to permit something other than static voltage limits from the planning horizon into the operating horizon (i.e. note pages 24-25 of the document found here http://www.nerc.com/comm/PC/Documents/Reliability%20Guideline%20-%20Reactive%20Power%20Planning%20and%20Operations.pdf).     

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Duke Energy believes that it is clear what System voltage limits are. However, if the SDT chooses to pursue an industry wide definition, we would support the definition proposed in question 6.

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

- 0 - 0

System voltage limits does not require a definition in the NERC glossary.  Most users, owners, and operators of the BPS are familiar with the term and the proposed definition is not necessary.

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

- 0 - 0

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

The System Voltage Level in the definition should refer to steady state condition to avoid nuisance SOL Exceedances.  In addition SOL Exceedance definition should have a time frame to allow System Operator action to return voltage within the normal range, such as reactive device switching, generator voltage schedules.  IROL Exceedance has a time frame to allow System operator action, so should SOL Exceedances.

It is not clear what System voltage limits are. For example, system voltage schedules are required per VAR-001-4 R1. Is a system voltage schedule a System voltage limit? System Voltage Limit should be defined and the term system voltage schedule should no longer be used to avoid redundancy as having both creates confusion.

The proposed draft definition of system voltage limits should not use terms maximum and minimum and normal and emergency. The definition should define these as System Operating Limits that that provide for reliable system operations. Using the terms maximum/minimum and normal/emergency may make it prescriptive as TOP can determine these limits based on SOL methodology specified by RC and voltage ratings determined by TO.

  • Actual or pre-Contingency bus voltage is outside normal System voltage limits;

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Texas RE does not agree with the proposed definition of “System Voltage Limits”, as the term emergency voltage limits is not clear.  Texas RE recommends modifying the definition and using the terms pre-contingency and post-contingency in place of Normal and Emergency.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  It is not clear if a TOP would be required to provide a “System Voltage Limit” for EACH Facility on its system, or if a single high and low limit that is appropriate for its system should be provided.

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

Please develop language clarifying System Voltage from a Single Bus Voltage.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

It is not clear what system voltage limits are without a definition.  Using another term in place of system voltage limit like “allowable voltage range” may help clarify.

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

- 0 - 0

It is not clear if a TOP would be required to provide a “System Voltage Limit” for EACH Facility on its system, or if a single high and low limit that is appropriate for its system should be provided.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

NIPSCO does note that like ATC believes that the definition of system voltage limits does need to allow for differing time components that may be associated with short term or dynamic ratings.

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.     It is not clear if a TOP would be required to provide a “System Voltage Limit” for EACH Facility on its system, or if a single high and low limit that is appropriate for its system should be provided.

2.     The System Voltage Level in the definition should refer to steady state condition to avoid nuisance SOL Exceedances.  In addition SOL Exceedance definition should have a time frame to allow System Operator action to return voltage within the normal range, such as reactive device switching, generator voltage schedules.  IROL Exceedance has a time frame to allow System operator action, so should SOL Exceedances.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Yes it is clear; however, we do not feel a definition of System Voltage Limits should be created.

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

We support a new System Voltage Limits definition. Definitions clarify compliance determinations and entities’ implementation of Standards.

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

I would like to suggest that System Operating Limits are determined by factility voltage ratings that are processed through the OPA/RTA.

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

We think that the proposed definition is useful and a useful addition to the SOL related standards. Again, guidelines on the determination of those limits with regards to the applicable requirements would be helpful.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Peak supports the proposed definition and believes it is a good idea to create a definition for system voltage limits.  Doing so will bring more clarity.

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

Yes, BPA has a clear understanding of System voltage limits.  BPA supports the SDT’s draft definition of “System Voltage Limits”, as it would be valuable to the industry.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

No Comment

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Duke Energy disagrees that the use of the term “limitations” is a better choice than “limit”. The term “limit” is already widely used and accepted throughout the industry. Replacing it with a term unfamiliar to the industry without clearly stated justification, would be confusing to some in the industry.

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

- 0 - 0

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

- 0 - 0

Limitation is defined as “the act of limiting or the state of being limited, a restriction”.  A limit is a “boundary, something that confines or restricts”.  Requirement R4 addresses Contingencies which are better described by “limit”.

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

As stated in comments for requirements above the text of this requirement should be changed to “Each Reliability Coordinator shall include in its SOL Methodology the method for incorporating stability limitations in establishing SOLs.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Texas RE has no comments on this question.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS] 

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

As noted in Q1 there seems to be confusion between the words “limitation” and “criterion” which is evident in 4.2.   There needs to be clarity.

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

- 0 - 0

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.      This requirement does not state that the TOP would determine the minimum stability limitations, based on the RC’s methodology.  This needs to be revised to similar wording in Requirement R2 and R3. 

2.      We agree that the TOP should make the determination, but ask the SDT to take into consideration that TOPs have existing documented processes and methodologies specific to their needs that would no longer apply when establishing stability limitations for use in operations.  This requirement imposes a process onto TOPs that may drastically deviate from existing practices, therefore, we suggest an addition to this requirement that the RC gather and review existing methodologies from each TOP in their reliability area and come to a mutually agreed upon methodology with the affected TOPs.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

As previously noted, “Stability” and “Stability Limit” are NERC Glossary Terms and it is unclear if the intent is to incorporate the words as Glossary Terms. Also, “Stability Limit” does not necessarily define “stability limitations,” so there is the potential for confusion.

Additionally, we agree that “limit” does not capture the system’s phenomena..

Suggestion: Use “limits,” the plural form to capture the system’s phenomena.

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

The SDT might consider using “Stability Limits” in the revised SOL definition and then revising the definition of Stability Limits in the NERC glossary so that it goes well with this definition of SOL.  The stability limitations language in the current definition can work but it may lead to some confusion.

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

What is the difference between a voltage limit and a steady state voltage stability limit?

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

Stability criteria in Parts 4.1.1 - 4.1.4 are adequate - no additions or deletions recommended.

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

Yes, the RC methodology should have criteria that consider all the items. There are no additional criteria that should be included. There are no criteria listed that should be excluded.

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

This requirement is too long, and too prescriptive to be in the standard. We recommend removing the criteria from the requirement. We suggest stating the requirement, and then state directly that a TOP must determine an SOL consistent with the requirement. It is unproductive to be this prescriptive in a requirement, and require an RC to have an SOL Methodology. An RC would be able to just copy what is in the requirement, and place in its methodology. There is no need for a methodology when the requirement is this prescriptive. We do not disagree with the content of the criteria, just that it is placed in the requirement.

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

- 0 - 0

Yes, it should include all of the defined criteria.

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

- 0 - 0

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Each RC area should have a criterion for each stability item identified in Parts 4.1.1-4.1.4.  However for any particular TOP or RC area of the BES a particular criterion may at the present time have little bearing on determining SOLs.  Over time, this may change and therefore the need for a review and criteria is important. However, coordination should be considered with the requirements of TPL-001-4. Having significantly different criteria between the RC and the PC’s within an RC’s area could become problematic if issues are “missed” in the planning assessments due to the differences in criteria. 

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

Transient studies should be performed "offline"

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

- 0 - 0

Texas RE has no comments on this question.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  There are too many questions here to answer.  We wish to answer Yes that all items in 4.1.1 – 4.1.4  should be included and also wish to say No there are no additional criteria that should be included.

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

On a case by Case basis: In the Operations Horizon and specifically OPA/RTA time frames, angular, frequency deviation (not listed), and system damping thresholds should not be considered.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

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

- 0 - 0

Yes, all of the criteria should be included. No, additional items are needed.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

No additional criteria are neccesary.  No criteria are included that should not be.

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

We agree, and do not believe there should be any additional criteria included.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

 No other criteria are needed.    

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

The SOL Methodology for determining the stability limitations to be used in operations shall be primarily based on 0ff-line studies with an exception of limited number of facilities that are of critical importance for reliability of BES where on-line stability tools have to be used. This has to be clearly stated due to limited availability of high quality on-line stability tools and applications and their challenging robustness and accuracy.

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

Yes, for the first question and no for the second and third questions.

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

- 0 - 0

We agree with the proposed criteria, but would all RCs be automatically obligated to define criteria for all the 4.1 sub-bullets? What if angular stability is not relevant in a particular RC area?

TPL-001-4 R6 should be revised to include all these elements.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

BPA supports the proposed revisions and believes specifying a regional performance criteria is a great addition.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

Contingencies listed in Parts 4.2.1 and 4.2.2 are adequate - no additions or deletions recommended.

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

Requirement 4.2.1 contains the phrase “or without a fault.” Because the “with” fault condition is more severe, if performance is acceptable with the fault condition, it would be acceptable without the fault also.  For this reason, AZPS recommends that this phrase be removed.  If the SDT disagrees, AZPS requests that it provide an explanation or example of why the no fault case is needed. It should also be made clear that stability studies are not expected in real time (using RTCA for example).

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

The standard should explain what it means by “or” for single phase versus three phase faults. This is important because the system is often operated beyond how the system is evaluated in the planning horizon. Specifically, the TPL standards only require the system to be studied for single line to ground faults with a failure of a protection system. However, when a protection system is removed from service in the operating horizon, which is required to perform maintenance, any operating horizon requirement to examine three phase faults puts the TOP in a condition beyond what the TP has designed the system for. By using “or” between single phase and three phase, or by adding words like, “whichever is more severe”, the TOP will likely be forced to study a three phase fault for this short duration operating scenario, regardless of the very low probability of a three phase fault occurring while the protection system is out of service for maintenance. Suggested wording: “Loss of one of the following by three phase Fault for Normal Clearing scenarios, single phase Fault for delayed clearing scenarios, or without a Fault.”

Additionally, The single block DC should also clarify it means a single faulted pole as three phase fault for a DC circuit is undefined and could be ambiguous.

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

See our comment to question 8 above. We do not disagree with the content of the criteria, just that it is placed in the requirement in this manner.

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

- 0 - 0

Yes, it should include all of the defined contingencies.

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

- 0 - 0

Sub-Part 4.2.1 should read “…by single phase Fault to ground, or three phase Fault with normal clearing…”. 

 

To include all Elements that could affect stability, suggest revising sub-Part 4.2.1 to read in its entirety:

 

     4.2.1  With normal clearing, with or without a Fault, the loss of any System Element.

 

This encompasses all faults. 

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Concerned with the premise identified in R5 that the RC may identify a methodology beyond that studied and documented by the Transmission Planner as required in TPL-001-4.  Both the RC and the Transmission Planners should have a mutual understanding of the stability issues of the system and how these could impact an SOL.  This should be discovered through the review of a planning assessments required to be performed in TPL-001-4, not an SOL methodology.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Texas RE has no comments on this question.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  There are too many questions here to answer.  We wish to answer Yes that all items in 4.2.1 – 4.1.2 should be included and also wish to say No there are no additional criteria that should be included.

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

We suggest removing “loss of any” as the terms “loss” and “contingency” are redundant.

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

- 0 - 0

Yes, all of the criteria should be included. No, additional items are needed.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

No additional contingencies are neccesary.  No contingencies are included that should not be.

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

We agree, and do not believe any additional contingencies should be included.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

 Yes on Part 4.2.1.  No on Part 4.2.2.   

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

Yes for the first question and no for the second and third questions.

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

- 0 - 0

We agree with the listed contingencies as the minimum to be considered for SOL evaluation, but it is not clear why they are listed in R4 and applicable only to stability related SOLs. What about Facility Ratings and System Voltage limits? What contingencies need to be used for “Calculated post-Contingency flow on a Facility is above the highest Emergency Rating”? In TPL-001-4, “Applicable Facility Ratings shall not be exceeded” for the contingencies listed in the tables: the same approach should apply here. We suggest removing the contingencies from R4 and providing a table, perhaps as an attachment that would be used for defining the single Contingencies relevant for this standard.

4.2.2 needs to be reworded : “Multiple Contingencies identified in Requirement R5.” Delete “loss of any”.

 

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Contingencies identified are adequate.

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

BPA supports the criteria.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Does R4.2 mean that every possible event that meets the criteria be simulated to find limitations?  Or is the intent to allow the RC and/or TOP to select the events most likely to be cause a severe event and test those?    The requirement should be written to clarify that either way since the current writing would allow for either interpretation.   

 

 

 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

We believe Part 4.3 as presented is sufficient. There is no need to indicate “offline analyses” or “forced or planed outages” since whether the SOL is determined on or off-line is irrelevant for. Further, whether or not SOLs need to be developed for outage conditions or their development considers planned or forced outages is a matter of what SOLs are needed for the anticipated or encountered conditions, not a part of methodology to be documented.

 

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

We would like to change our vote to NO at this time but edit mode does not allow me to since I already submitted once. 

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

We support using the qualifier "realistic" in Part 4.3. 

Specifying "off-line analyses" is not necessary since, as currently worded, Part 4.3 seems to allow use of both on-line and/or off-line analyses.

All credible contingencies to consider must be addressed in R5 - do not muddy the water by specifying contingencies in Part 4.3.  Wouldn't all planned outages already be included in the day-ahead or hour-ahead operations base case?  We do not see the need for planned outages to be specifically mentioned in Part 4.3.

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

- 0 - 0

The descriptions of additional types of information in a, b, and c are not needed.  4.1 already requires stability performance criteria for single contingency and multiple contingencies.  The additional language in a, b, and c, may limit TOP and RC flexibility in developing their processes for identifying instability risks.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

To retain its flexibility the RC Methodology should not require any additional items.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

Proposed 4.3 is sufficient

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

The standard should avoid being overly prescriptive. The RC should determine for itself what forced outages should be included. The RC should determine for itself what planned outages should be included.

 

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Duke Energy does not believe that these items should be included in an SOL Methodology. Perhaps planned outages may be appropriate, but disagree with the addition of “offline analyses” and N-1-1.

Also, as written, it is not clear how section 4.4 in the proposed FAC-011 will adequately synch up with what is required in FAC-014. Each RC or TOP must consider what limitations a Planning Coordinator provides in its planning assessments, but it is not clear on what information is supposed to be conveyed, and how it should be applied.

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

- 0 - 0

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

- 0 - 0

Part 4.3 is not required.  The information being asked for can be gleaned from the preceding Parts.  “How” should not be in a requirement.

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

The type of stability studies, online verses offline, should be left to the individual TOP or TP.  As for Parts b and c, these are studied as part of TOP-002.  This work would include voltage schedule, unit output, and other adjustments as typically considered when performing stability analysis.  If anything, a reference only to the already required studies might be appropriate.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

If the RC and TOPs are dependent on an OPA and RTA to identify stability limitations, Texas RE recommends all outages be considered in these assessments.  If the SOL definition is modified to remove the “specified system configuration”, it is important that the Standard specifies that stability limits and IROLs be determined with all known outages applied.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  4 questions here....Yes there should be more discussion of any intended requirements regarding “online vs offline” stability analysis.

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

4.3 is Administrative in nature and open to Auditor interpretation and as such needs to be rewritten.

Moving forward it would be expected that Stability studies should be assessed in the Outage Coordination (IRO-017) time frame – for those entities without Real Time Stability Tools - and per engineering judgement Parts a, b, and c can be addressed in that venue and do not need to be stated explicitly here.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

We believe Part 4.3 as presented is sufficient. There is no need to indicate “offline analyses” since whether the SOL is determined through on-line or off-line studies is irrelevant. Further, whether or not SOLs need to be developed for outage conditions or their development considers planned or forced outages is a matter of what SOLs are needed for the anticipated or encountered conditions, not a part of methodology to be documented.

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

- 0 - 0

Yes there should be more discussion of any intended requirements regarding “online vs offline” stability analysis.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

A.     Yes.  NIPSCO believes “offline analyses” should be included. 

B-C. NIPSCO believes that specifying N-1-1 or planned outages reduces the flexibility that the SDT is trying to preserve for the RC.

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.     Regarding item ‘a.’ – Yes, there should be more discussion of any intended requirements regarding “online vs offline” stability analysis.

2.     Regarding item ‘b.’ – No, forced Transmission and generation outage information isn’t necessary.

3.     Regarding item ‘c.’ – Yes, planned outage information should be included.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

a-yes

b-no

c-yes

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

We agree that the Part 4.3 should specifically include the term “offline analyses”. We do not agree that the Part 4.3 should include N-1-1 outages, as that may contradict the underlying strength of the transmission infrastructure during the planning phase and consequently may flag issues in operations that may not be solvable. We do agree with including known planned outages in the base case for studies being performed well in advance and for sensitivity studies. However, we do not agree to (possibly unintended) expectation that stability studies have to be re-run for each planned outage.

 

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

We think that “the levels of transfers, load and generation dispatch” is general to SOLs and should be applicable outside of R4, not only for stability limitations (e.g. offline load flow study that is used to identify System Voltage limits violations). The planned or forced outages to consider in the studies should be defined by the RC Methodology according to “expected” or “credible” operating conditions.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Something to consider for FAC-011-3 R4 is for the RC to identify the criteria that will qualify a stability limitation to be considered an IROL.  In other words, RC should specify a clear criteria as to when a stability limitation becomes an IROL.  Regarding N-1-1 forced outage operations, it might be a good idea for there to be a requirement in FAC-011 for the RC’s SOL Methodology to specifically address SOL/IROL establishment for N-1-1 scenarios, where the first N-1 is either a planned outage or a forced outage.  No need for offline analysis to be addressed in FAC-011.

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

BPA believes bullet ’a’ is not needed as long as there is flexibility between on and offline analyses.  Bullet ’b’ should be included. However, there needs to be more description of what a forced outage is. Bullet ’c’ should be included.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

I also comment some in question 11.  

I suggest being a little more detailed in what the RC should provide.. IE

-If simulating a specific time then outages planned for that time

- If simulating a generic time (Summer Peak) then room for the RC to specify that certain N-1-1 or G-1+N-1 combinations are run, but not require a brute force running of all N-1-1.  Alternatively, criteria that the RC sets and then the TOP determines what N-1-1 to test.  For example, the RC could require that the TOP select their most limiting events and run them in N-1-1 configuration with each other. 

4.3 should specify that it requires offline studies but does not precluding the use of real time simulation.

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

We do not agree with the use of “realistic’ in place of ”expected”. As a general practice, personnel conducting SOL calculation would usually assumes anticipated system conditions for the period that the SOL would apply. Every assumed condition is “anticipated” or “expected” based on the information available at the time of SOL calculation, hence nothing is “realistic” until real-time. If the intent is to assess potential risk if the anticipated or expected conditions do not materialize, then a more appropriate stipulation could be: “a range of expected….”. Even with that, it will become an argument when it comes compliance audit time whether or not the responsible entity looks and if not, why not. Keeping it simple with “expected” will achieve the intent of calculating SOL that is valid for the expected conditions.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

SMEs would like to Change to NO. 

Wording should be changed to read:  Describe how instability risks are identified, considering realistic maximum and minimum  levels of  expected transfers, Load and generation dispatch

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

We support using the qualifier "realistic" in Part 4.3.

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

- 0 - 0

A lot more transfer impacts fall within the “loop flow” category and therefore by stating “realistic transfers”, it is all encompassing.  By including a reference to firm and non-firm transfers, entities may only include transmission service that they have sold and not all transfer impacts on their system.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

The term realistic is sufficient

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

Recommend that “severe but credible” is another alternative to “expected”.

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

We disagree with the use of the term “realistic” as opposed to using the term “expected”. We see no justification to change an already familiar and understood term by the industry.

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

- 0 - 0

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

- 0 - 0

Part 4.3 is not required.  The information being asked for can be gleaned from the preceding Parts.  “How” should not be in a requirement.

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

PJM believes additional clarifying language is needed.  Suggest the following language which is taken from the Explanation of Proposed Revision for R4.3:
(4.3) Describe how instability risks are identified, considering realistic levels of transfers, Load and generation dispatch as anticipated within the operations time horizon;   

 

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

The term “Realistic” is too vague, and may allow entities to apply a single scenario to all of its assessments.  Texas RE recommends using the term “Anticipated” as it implies that the entity will apply forecasted conditions to its assessments.  In this scenario, “Anticipated” is stronger language and would require entities to apply current conditions to its assessments.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  The use of the word ‘realistic’ should be sufficient.

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

WAPA agrees with the intent and suggests more clarification should be added in the RC’s Methodology and Outage Coordination documentation, i.e.  The terms:  “realistic levels of transfers”, “consider”, and “unacceptable quantity” are subject to interpretation.  

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

We do not agree with the use of “realistic” in place of “expected”. As a general practice, personnel conducting SOL calculations would usually assume anticipated system conditions for the period that the SOL would apply. Every assumed condition is “anticipated” or “expected” based on the information available at the time of SOL calculation. If the intent is to assess potential risk if the anticipated or expected conditions do not materialize, then a more appropriate stipulation could be: “a range of expected….”.  Keeping it simple with “expected” will achieve the intent of calculating SOL that is valid for the expected conditions. To force an entity to re-calculate the SOL, an additional requirement could be to stipulate that the methodology presents the conditions under which the SOLs are valid. This is in fact a general practice for most entities that currently calculate SOLs.

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

- 0 - 0

The use of the word ‘realistic’ should be sufficient.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

The use of the word ‘realistic’ seems appropriate.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

 The term "realistic" is sufficient.    

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

Concern: The term “realistic” is vague and not measurable. We agree “…that “unrealistic” stressing scenarios may be more of an academic exercise to “break the system” and may not translate to actual operations preparedness.”

Suggestion: We offer the following revisions for consideration.

Describe how instability risks are identified, considering historical and future loadings of transfers, Load and generation dispatch.

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

Realistic is better than "expected". “Credible” would also be appropriate and is used in other standards.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

BPA agrees with the term “realistic”. We do not feel additional language is needed.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Overall I really like the intent of the requirement. 

I read Realistic as "Expected".  Now that I've read this and think about that was my mistake, however I won’t be the only one to not think deep enough into what I’m reading.  So I believe a little more clarification would help even if it’s in technical supporting material like the TOP standards used. 

If the intent is to require the RC to look at more than expected, then a little more language is probably called for. 

For example, specify that not just expected but also realistic stressed condition such as different load levels, transfer conditions, typical nonfirm, typical (but not expected) generation patterns, etc should be run.  (It could also be lower load or lower transfer).  It should also allow the RC room to specify unrealistic conditions if they want, if someone is willing to undertake the exercise we should not preclude them if they find value in it.  The requirement could follow the TPL 001-4 model of requiring that the RC select one or more sensitivities “expected to stress the system” be run in addition to the base expected conditions. 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

We believe not specifying the “entire RC Area” does not leave any reliability gap since a responsible entity needs to consider the reliability impact on its own and adjacent area when it determines the SOLs.

 

Note: ERCOT does not support the above comment

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team.   

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

- 0 - 0

Other Answers

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

- 0 - 0

NO!

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

Part 4.5 is adequate as currently worded.

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

AZPS recommends that the requirement 4.5 be deleted entirely or defer responsibility for the study model details to the TOP.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

Current description is sufficient. Manitoba Hydro agree that it is not necessary for reliability that the entire RC Area is studied; instead, the area modeled may vary depending upon the facts and circumstances of the particular footprint or electrical area

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

Duke Energy agrees with the SDT that it is not necessary for reliability that the entire RC Area is studied. We recognize the flexibility that would be provided allowing an entity may choose to model a smaller area, or model the entire RC Area if necessary.

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

- 0 - 0

‘realistic’ is an adequate descriptor.

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

- 0 - 0

Part 4.5 is not required.  The information being asked for can be gleaned from the preceding Parts.  “How” should not be in a requirement.

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Texas RE does not agree that the entire RC Area should not be studied.  Study models should include the entire RC Area in order to determine the consequences of any actions that may be taken to mitigate instability issues.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  We request that the team review the inclusion of non-BES data and Facilities as is currently being included in a revision to TOP-001 (Project 2016-01).  The RC should address whether or not those facilities may be required to be included in the model also.

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

The entire RC Area should be Studied and Stable and the question (not the Standard) implies that RC does not have to study its entire Area which is incorrect.

As the Standard is written WAPA agrees that a finer detailed study would be more applicable as the conditions arise.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

We believe not specifying the “entire RC Area” does not leave any reliability gap since a responsible entity needs to consider the reliability impact on its own and adjacent area when it determines the SOLs.

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

- 0 - 0

We request that the team review the inclusion of non-BES data and Facilities as is currently being included in a revision to TOP-001 (Project 2016-01).  The RC should address whether or not those facilities may be required to be included in the model also.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.      We request that the team review the inclusion of non-BES data and Facilities as is currently being included in a revision to TOP-001 (Project 2016-01).  The RC should address whether or not those facilities may be required to be included in the model also, as determined by the TOP.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

The proposed 4.5 is appropriate regarding the study model description, but the allowed use of RAS should be in a separate requirement (see next question) and the study model is relevant to all SOLs, not just stability.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

FAC-011 should not require that the study models used for SOL establishment include the entire RC Area.

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

I think 4.5 is almost perfect.  I do wonder if RAS should get a little more description on what you mean.  For example is the intent to allow the RC to decide if the SOL limit should be set to avoid RAS triggering or allowing for RAS triggering?  If so maybe that should be a little more descriptive. 

There is too much diversity among the RC systems to be specific in what the model should include.  In some cases, it might even make sense for an RC to have multiple smaller models that give them a better range of results for the same investment then a single large model would.  As written 4.5 allows that and the measure should be written accordingly. 

 

 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

Proposed change: Stability Analysis should also be aware of UVLS and UFLS. However as stated by FERC should not be used to set stability limits.

 

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

YES.

Other types of protective schemes can have significant impact on system performance.  UVLS and UFLS can prevent cascading.  Automatic load restoration and switching schemes can significantly vary expected system conditions post-contingency.   The wording should be changed to be:   Include a description of the study models, including the level of detail that is required and the use of protective isolation and load restoration schemes.

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

It would make sense to include UVLS since many of them are installed to prevent voltage instability resulting from credible multiple contingencies.  But UFLS could be excluded since the unacceptable frequency response mitigated by UFLS is trypically caused by multiple contingencies associated with extreme events.

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

Use of UVLS and other scheme should be allowed for their intended use but should not be required.  For example, UVLS should be allowed for multiple or extreme contingencies.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

The requirement should include reference to other protective schemes, such as UFLS and UVLS so the full event is considered when determining stability SOLs.

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

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

- 0 - 0

No, but language should be added to include any other study schemes that could have an impact upon stability performance.

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

- 0 - 0

Part 4.5 is not required.  The information being asked for can be gleaned from the preceding Parts.  “How” should not be in a requirement.

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

If the system maintains stability these schemes should not play a significant role in determining an SOL.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Since UVLS action can improve voltage stability, it should be considered in identify stability limitations.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  The RC can still dictate the allowed uses of UVLS and UFLS in relation to SOLs without it being in the standard, correct?

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

Regardless if the assumption is that UVLS/UFLS are the Interconnection wide safety nets and not a part of identified local uvls/ufls the stability assessment should still consider their impact.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

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

- 0 - 0

The RC can still dictate the allowed uses of UVLS and UFLS in relation to SOLs without it being in the standard, correct?

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.      The RC is allowed to direct uses of UVLS and UFLS in relation to SOLs without it being in the standard.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

This will cause more confusion and burden than benefit to reliability.

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

A separate requirement should address the allowed use of RAS and other protections schemes (including UVLS and UFLS) in SOL determination. This should include the description of the allowed loss of load (consequential/non-consequential, single versus multiple contingencies, adverse system conditions, etc.). A mapping is required with FAC-011-3 R2.3. In any case, RAS and other protection schemes should be addressed for the different types of limits, not just stability limitations.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

The SDT should consider using broader language here rather than limiting the application of R4.5 specifically to RAS. One suggestion is to use the phrase “automatic post-Contingency mitigation actions”, which could include any automatic action that is designed to render the system in a state of acceptable post-Contingency system performance upon occurrence of identified Contingency event(s). The RC’s SOL Methodology could then address UVLS and UFLS in their SOL Methodology as they deem necessary.

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

BPA believes that UVLS, UFLS and runback schemes should be included, as these types of actions are included in the contingency definitions which allow for increased transfer capability.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

If the intent that the SOL should be set to avoid UVLS and UFLS activation for a range of realistic system conditions, then that should probably be specified somewhere.  I believe the UVLS is mentioned in the system voltage limits, but perhaps should be addressed in this later section as well.

 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

I believe the SME's changed this vote to NO.  Stability limitations should be established the same way no matter how many TOP’s are effected. 

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

The RC SOL methodology will define stability limitation as proposed in R4. Why would it vary from one TOP to other?

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

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

- 0 - 0

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

- 0 - 0

Part 4.6 is not required.  The information being asked for can be gleaned from the preceding Parts.  “How” should not be in a requirement.

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

It will force communication of potential issues between TOP areas in determining SOLs and identifying a common limit.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Texas RE has no comments on this question.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS] 

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

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

- 0 - 0

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

It should also include adjacent systems in other RCs.

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

No additional comments.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

This will cause more confusion and burden than benefit to reliability.

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

 R4 already requires a description of the method used in operations to determine stability limitations. R4.6 is not necessary.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

BPA believes criteria specifically addressing stability will allow for consistency amongst TOPs in a regional area.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Yes.  As written, this gives quite a bit of flexibility to the RC to handle their different areas.  In some areas it may be sufficient that the RC Specify that both TOP's agree to the limit, and in other areas the RC may need to be more specific in how that is done.  The ideal situation for some requirements is that the encourage correct behavior, without ever actually being invoked. 

 

 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

We agree that the RC should have a process to specific the multiple contingencies that should be considered/applied in the calculation of SOL, but not in “the evaluation for potential System instability, Cascading outages or uncontrolled separation”. The intent is that the RC needs to consider or include in its assessment when calculating SOLs and IROLs which are applied in real-time to prevent System instability, Cascading outages or uncontrolled separation. Evaluating the potential for such occurrences does not drive home the notion of what’s presented in the Explanation column, namely, to “establish stability limitations and IROLs”. We therefore suggest R5 be revised to:

 

R5. Each Reliability Coordinator shall include in its SOL Methodology the method for determining the multiple Contingencies used in the calculation of SOL to mitigate the potential for System instability, Cascading outages or uncontrolled separation.

 

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

No opinioin

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

Transmission operators and planners are most knowledgeable of their system. Therefore, it is best to leave the task of coming up with contingencies to planner and operators. What additional role the RC can play in this regard is not clear.

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

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

- 0 - 0

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

- 0 - 0

Sub-Part 4.2.2 addresses multiple Contingencies, and refers to Requirement R5.  Requirement R5 is a “how” requirement, and not needed.  Sub-Part 4.2.2 should be revised to remove the reference to Requirement R5.

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Texas RE recommends this Requirement include additional details about what must be included in the RC’s method for determining the multiple Contingencies used in the evaluation for potential System instability, Cascading outages or uncontrolled separation. As this Requirement is currently written, an RC would be allowed to create a method that would not identify any multiple contingencies, and therefore no multiple contingencies would be considered.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS] 

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

Specifically related to Operational Credibility vs Planning Credibility for Multiple Contingencies as these two are not the same.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

The RC should have a process to specify the multiple contingencies that should be considered in the calculation of SOL, which is more precise than just saying “used in the evaluation for potential System instability, Cascading outages or uncontrolled separation”. The intent is that the RC needs to consider multiple element contingencies in its assessment when calculating SOLs and IROLs, which are applied in real-time, to prevent System instability, Cascading outages or uncontrolled separation. Evaluating the potential for such occurrences does not drive home the notion of what’s presented in the explanation column, namely, to “establish stability limitations and IROLs”. We therefore suggest R5 be revised to:

 

R5. Each Reliability Coordinator shall include in its SOL Methodology the method for determining the multiple Contingencies used in the calculation of SOL to mitigate the potential for System instability, Cascading outages or uncontrolled separation.

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

- 0 - 0

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

We agree and have no additional comments.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Is the intent to REQUIRE every RC to have a method of determining multiple contingencies and including them?  Alternatively, is the intent to give them permission to do so?  If the intent is to give permission, but not require, then the requirement needs to be a little less directional or the measure could identify that an acceptable "method" is to not have any. 

 

 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

We do not think that a separate requirement to specify how an entity would implement the multiple Contingencies given that Requirement R5 already stipulate the need to include multiple contingencies in SOL calculations (especially with our proposed language change).

 

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

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

- 0 - 0

“The Reliability Coordinator shall describe how the multiple contingencies identified in R5 will be used by the RC and TOP for identifying SOLs and IROLs.”

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

How multiple contingencies are used should be left up to the RC.

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

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

- 0 - 0

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

- 0 - 0

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

A requirement specifying when and how multiple contingencies should be evaluated fits better with TOP-001-3 than with this Standard. These multiple contingencies should be evaluated in the OPA and RTA, especially with the proposal to remove the planning horizon from the SOL definition. 

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS] 

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

The TOP(s) should identify the Credible Multiple Contingencies and implementation used in the Operations time frame in question.

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

Please see our answer to question 15.

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

- 0 - 0

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

No additional comments.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

An additional requirement isn't necessary to specifically identify how an entity would implement the multiple Contingencies.  NERC standards are to address "what" and not "how".  Specifying "how" isn't flexible nor useful in a mandatory standard.

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

“how an entity would implement the multiple Contingencies” should be addressed in the guidelines. Addressing the methodology for performing OPA and RTA, if necessary, should be addressed elsewhere, probably in a distinct standard.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

The proposed language allows for adequate flexibility for the RC’s SOL Methodology.

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

Does the current R5 allow for the monitoring of a double within the OPA and in real time for finding potential system instability, cascading outages or uncontrolled separation?   If so, does that monitored double also have to meet the Facility ratings (SOL Exceedance) criteria? 

For example can a RC monitor a common structure and not react if it is over its emergency rating as long as there is no risk of potential system instability, cascading outages or uncontrolled separation as defined by the RC?  

For that matter if an RC or TOP decides to monitor a Multiple Contingency, does that obligate them to list it under R5 and meet that criterion? 

 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

No additional criteria are necessary.

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

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

- 0 - 0

No additional criteria needed.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

The acceptable amount of load or supply loss should be determined by TOP and not by RC. This is because much depends upon the size of the TOP total load and the specific operational and topographical aspects of the TOP’s system. For example, a 500 MW load loss in a metropolitan city may not be large enough to cascade; however, the same load loss in a rural area could be large enough to cascade. Because TOPs are most familiar with their systems and associated operations, the determination of the acceptability of a certain amount of load or supply loss should be determined by the TOP.  AZPS recommends that the SDT revise this requirement to reflect this.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

IT depends on the RC footprint.

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

The proposed criteria are fine.

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

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

- 0 - 0

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

- 0 - 0

Requirement R6 should not specify the method (“how”).  In the Parts for Requirement R6, what is unacceptable?

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Texas RE has no comments on this question.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  Yes it should be included.  Nothing else is needed

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

6.4 is a catch all that captures 6.1 – 6.3.  Therefore listing 6.1 – 6.3 is not necessary.  However, if industry feels that this is required, then a subpart should be added to reflect “unacceptable loop flow” through neighboring systems.

 

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

- 0 - 0

Yes it should be included.  Nothing else is needed.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.   Yes, we agree that all criteria should be included.

2.   No, we do not believe anything additional is needed.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

We agree with the intent of R6, but we think it deserves some rewording:

1- 6.3 could be limited to “Unacceptable inter-area oscillations”. However, we don’t think 6.3 captures the “non-localized or uncontained instability” concept described in the explanation.

2- Unacceptable quantity of load loss (or supply loss) should be independent of “due to “System instability, Cascading outages or uncontrolled separation”. An unacceptable quantity of load loss (or supply loss) can itself cause “System instability, Cascading outages or uncontrolled separation”. What if a system condition makes the loss of a major transformer a contingency for which the “Calculated post-Contingency flow on a Facility is above a Facility Rating for which there is not sufficient time to reduce the flow to acceptable levels should the Contingency occurs”…which could overload another transformer beyond its protection setting, that would then trip and cause an unacceptable quantity of supply loss? Thus, we suggest combining 6.1 and 6.2 with “Unacceptable quantity of load or supply loss” and removing the reference to instability, etc.

3- A bullet should be added to specifically address unacceptable “System instability, Cascading outages or uncontrolled separation” (that would cover the “non-localized or uncontained instability” concept) in relation with the definition of IROL.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

BPA believes no additional criteria are required.

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

I think R6 is good as written, however changes should be considered as the team reviews the results of surveying the RC's IROL methodologies.  The Requirement or Measure should specify that the unacceptable quantity of load can be a set MW value, a percentage of system load, or could even be a different value for different areas of the system.  In our region we have TOP's that only have 800 MW of load, and TOP's that consider an 800 MW substation a medium size substation.   Therefore, a one number for the whole region may not set a meaningful threshold for everyone. 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

The thresholds are best left to each RC according to its area’s consideration, criteria and restrictions.

 

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

6.1 wording: Unacceptable quantity of load loss equal to 500MW or greater due to System instability, Cascading outages or uncontrolled separation.  This value is 2.5 times the EOP-004 firm load loss reporting requirement and represents significant impact to the public.

6.2 wording: Unacceptable quantity of supply loss greater than the value of the interconnection’s MSSC due to System instability, Cascading outages or uncontrolled separation.  This is based on a loss bigger than an interconnections MSSC.

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

Giving RC the discretion to determine what thresholds are most suitable for its RC Area would be best.

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

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

The minimum threshold should be 1% of the RC area peak load, and a maximum threshold should be 10% of the RC area peak load. This is based upon the fact that we are dealing with multiple contingencies and loss of less than 1% of the RC area peak load loss should be acceptable and not be called cascading.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

Again, it depends on the RC footprint.  There needs to be some latitude/discretion for the RC to make the best decisions for its footprint.

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

The RC should determine appropriate thresholds.

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

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

- 0 - 0

No, establishing a hard minimum and maximum could be counter-productive to reliability since facts and circumstances determine the appropriate values.

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

- 0 - 0

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

Mark Holman, On Behalf of: Mark Holman, , Segments 2

- 0 - 0

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

- 0 - 0

Texas RE has no comments on this question.

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

- 0 - 0

[THESE COMMENTS REPRESENT SPP STAFF COMMENTS]  Each RC’s needs may be different.

Jason Smith, On Behalf of: Southwest Power Pool, Inc. (RTO) - MRO, WECC, SPP RE - Segments 2

- 0 - 0

sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

- 0 - 0

The thresholds are best left to each RC according to its area’s consideration, criteria and restrictions.

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

- 0 - 0

Each RC’s needs may be different.

SPP Standards Review Group, Segment(s) , 8/12/2016

- 0 - 0

Sarah Gasienica, On Behalf of: Sarah Gasienica, , Segments 1, 3, 5, 6

- 0 - 0

1.      Each RC’s needs may be different.  Including minimum or maximum criteria to the statements would create a one size fits all areas which would not be appropriate across the Interconnections. As well the criteria across a single RC Area may not be appropriate do to the vast differences within the RC’s Area. (Example: The criteria used around critical Load areas such as major Department of Defense facilities might not be the same as sparsely populated areas where there are hundreds of square miles - might not qualify under the one size rules.)

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4, 8/12/2016

- 0 - 0

Southern believes that the criteria should be left to the RC to define.  However, if the SDT were to establish the criteria, we believe that the minimum criteria should be established in generic terms to give RCs in different geographical areas the flexibility to define the criteria themselves.

Southern Company, Segment(s) 3, 5, 6, 4/21/2016

- 0 - 0

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

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Gregory Campoli, On Behalf of: New York Independent System Operator, , Segments 2

- 0 - 0

Terry Volkmann, On Behalf of: MISO TOP-ISO Task Team, MRO, SPP RE, RF, Segments 1, 2

- 0 - 0

The criteria identified in proposed Parts 6.1 through 6.4 should allow for Regional and Local variances regarding determination of  a minimum or maximum threshold.

Terry Harbour, On Behalf of: Berkshire Hathaway Energy - MidAmerican Energy Co., , Segments 1, 3

- 0 - 0

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

- 0 - 0

Definitely not. This is way too system specific. It is the responsibility of the RC to define such thresholds. However, guidelines to explain the industry practice regarding this topic would be appropriate.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

- 0 - 0

While prescribed thresholds would improve clarity and consistency for IROL establishment, doing so might also have an unintended consequence of undermining the flexibility needed for RCs to address the unique situations and challenges in the RC Area.

Jared Shakespeare, On Behalf of: Peak Reliability - WECC - Segments 1

- 0 - 0

Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

There is an enormous range of system sizes across the country.  Setting a range that is meaningful for an TOP whose peak load is 800 MW but is also meaningful for a TOP that find 800 MW to be a typical substation would result in such a large range as to not be of value. 

A percentage might be of more value, however the same scaling factor occurs.  A threshold of 10% would result in a TOP with only 10 substation to not be able to lose one station, and by the same token might mean 20 substations for an entity with two hundred stations.

Perhaps a threshold based on substations, rather than MW.  That you are not allowed to lose more then so many stations be in generation or load. 

Or perhaps set a range, but allow exceptions with explanation. 

Aaron Staley, On Behalf of: Orlando Utilities Commission, FRCC, Segments 1

- 0 - 0

Hot Answers

No, the IROL Tv definition should not be modified to remove the 30 minute not-to-exceed time limit. Rather, the proposed R7 should have that last sentence removed.

 

Note: ERCOT does not support the above comment.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 8/12/2016

- 0 - 0

We agree with the comments of the MISO TOP-IRO Task team. 

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

- 0 - 0

Other Answers

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

- 0 - 0

No!

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

- 0 - 0

Con Edison, Segment(s) 1, 3, 5, 6, 0, 6/24/2016

- 0 - 0

We are not in a position to provide feedback on modifying the IROL Tv definition until we review the revised IROL definition being proposed.

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

- 0 - 0

For IROLs identified in real-time the 30 minute threshold does not give the operators much time to assess the situation and could lead to load-shed for non-IROL exceedences.  In some instances such as real-time identified IROLs versus pre-defined IROLs,  a greater than 30 minute Tv could be warranted and should be allowed.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

The 30 minutes limit on Tv is arbitrary and should be eliminated.

Jeri Freimuth, On Behalf of: Jeri Freimuth, , Segments 1, 3, 5, 6

- 0 - 0

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

- 0 - 0

Robert Roddy, On Behalf of: Robert Roddy, , Segments 1, 5

- 0 - 0

The 30 minute maximum time limit is appropriate for IROLs.

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

- 0 - 0

Don Schmit, On Behalf of: Don Schmit, , Segments 1, 3, 5

- 0 - 0

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

- 0 - 0

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

- 0 - 0

RSC no Con Edison and ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 8/12/2016

- 0 - 0

Establishing all critical time to be no longer than 30 minutes; may not be realistic depending on the viability of the contingencies required to fulfill the IROL. If a Tv has not been established than using the no longer than 30 minutes would be appropriate.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

- 0 - 0

 The time limit can remain in the IROL Tv definition and reside within R7 as proposed.   &n