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Regional Reliability Standard (WECC-0101) | MOD-026-2 and MOD-027-2 (WECC Variance)

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Start Date: 08/10/2016
End Date: 09/23/2016

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This wording of this questionnaire is written more as a push poll, rather than seeking honest feedback from the affected members of the industry.

Patricia Lynch, On Behalf of: Patricia Lynch, , Segments 5, 6

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Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Other Answers

Janis Weddle, On Behalf of: Janis Weddle, , Segments 1, 3, 5, 6

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Southern Company, Segment(s) 1, 3, 5, 6, 8/3/2016

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Johnny Anderson, On Behalf of: Johnny Anderson, , Segments 1

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Colorado Springs Utilities feels the proposed WECC variances do not improve upon or add important requirements to the already approved NERC standards. We believe there will be minimal reliability improvements due to this variance.

Colorado Springs Utilities, Segment(s) 1, 6, 3, 5, 9/14/2015

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We feel that there is not enough information currently present to determine if the process is fair or not.

SPP Standards Review Group, Segment(s) , 9/23/2016

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Hot Answers

Patricia Lynch, On Behalf of: Patricia Lynch, , Segments 5, 6

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Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Other Answers

Janis Weddle, On Behalf of: Janis Weddle, , Segments 1, 3, 5, 6

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Southern Company, Segment(s) 1, 3, 5, 6, 8/3/2016

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Johnny Anderson, On Behalf of: Johnny Anderson, , Segments 1

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Colorado Springs Utilities feels the proposed WECC variances do not improve upon or add important requirements to the already approved NERC standards. We believe there will be minimal reliability improvements due to this variance.

Colorado Springs Utilities, Segment(s) 1, 6, 3, 5, 9/14/2015

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The primary variance to the national standards is the change in frequency of revalidations from 10 years (national) to 5 years (WECC region).  WECC has not provided justification for the increased frequency which poses additional financial cost on the GO’s in WECC. Additionally, we would ask the drafting team to provide clarity or verification on why the 5 year validation is necessary?

SPP Standards Review Group, Segment(s) , 9/23/2016

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Hot Answers

Patricia Lynch, On Behalf of: Patricia Lynch, , Segments 5, 6

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Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Other Answers

Janis Weddle, On Behalf of: Janis Weddle, , Segments 1, 3, 5, 6

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Southern Company, Segment(s) 1, 3, 5, 6, 8/3/2016

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Johnny Anderson, On Behalf of: Johnny Anderson, , Segments 1

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Colorado Springs Utilities feels the proposed WECC variances do not improve upon or add important requirements to the already approved NERC standards. We believe there will be minimal reliability improvements due to this variance.

Colorado Springs Utilities, Segment(s) 1, 6, 3, 5, 9/14/2015

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SPP Standards Review Group, Segment(s) , 9/23/2016

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Hot Answers

Non base-load boiler-steam generating unit incur significant, uncompensated cost to perform model verification tests, because they require dedicated, unscheduled startups to accomplish and satisfy the specified testing regiment.  The variance excessively and unnecessarily micromanages the details of the verification process, placing a limit on the development of more efficient verification methods.  

The five year periocity for model verification in WECC was developed at a time when most voltage regualtors were analog.  With the development and widespread use of digital AVRs and integrated DCS controllers, 5 year frequency is costly, unnecessary, and unjustified; the 10 year interval is more than adequate.  Also, the existing requirement to perform model verification for changes in the AVR or turbine governors is sufficient.

Patricia Lynch, On Behalf of: Patricia Lynch, , Segments 5, 6

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Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Other Answers

Janis Weddle, On Behalf of: Janis Weddle, , Segments 1, 3, 5, 6

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The primary variance to the national standards is the change in frequency of revalidations from 10 years (national) to 5 years (WECC region).  WECC has not provided justification for the increased frequency which poses additional financial cost on the GO’s in WECC.

Southern Company, Segment(s) 1, 3, 5, 6, 8/3/2016

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Johnny Anderson, On Behalf of: Johnny Anderson, , Segments 1

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Colorado Springs Utilities feels the proposed WECC variances do not improve upon or add important requirements to the already approved NERC standards. We believe there will be minimal reliability improvements due to this variance.

Colorado Springs Utilities, Segment(s) 1, 6, 3, 5, 9/14/2015

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SPP Standards Review Group, Segment(s) , 9/23/2016

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Hot Answers

Patricia Lynch, On Behalf of: Patricia Lynch, , Segments 5, 6

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PacifiCorp does not support any variance that introduces obligations that are more onerous than the NERC MOD-026-1/MOD-027-1 requirements.  PacifiCorp believes that all regions should adhere to the MOD-026-1/MOD-027-1 reliability standards as currently written and enforceable nationwide.

Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Other Answers

Yes.  The proposed standard/variance has more specific criteria for the same requirements covered in a continent-wide standard.

The WECC variance reduces the NERC 10-year requirement to 5 years, which is in line with the existing policy and not, of itself, unduly burdensome.  However, the existing WECC policy provides for an exemption for when a planned governor or AVR/PSS replacement is to occur.  Under the exemption, the GO provides a timeline for when equipment will be replaced and validated.  The variance does not include this exemption provision.  How this could work in practicality for Chelan PUD is that we would have to validate a unit, and then under existing schedules, have to revalidate it a year or so later when a governor or exciter is replaced.  This equates to as many as three validations in a ten year period where at most, the NERC standard would require one.  This seems an undue burden that does not improve BES reliability.

Janis Weddle, On Behalf of: Janis Weddle, , Segments 1, 3, 5, 6

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Southern Company, Segment(s) 1, 3, 5, 6, 8/3/2016

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Johnny Anderson, On Behalf of: Johnny Anderson, , Segments 1

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Colorado Springs Utilities feels the proposed WECC variances do not improve upon or add important requirements to the already approved NERC standards. We believe there will be minimal reliability improvements due to this variance.

Colorado Springs Utilities, Segment(s) 1, 6, 3, 5, 9/14/2015

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SPP Standards Review Group, Segment(s) , 9/23/2016

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