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2016-EPR-02 Enhanced Periodic Review of VAR Standards | Template for VAR-002-4

Description:

Start Date: 02/28/2017
End Date: 04/13/2017

Associated Ballots:

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Hot Answers

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

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

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., RF, Segments 2

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A technical guide in the measure would be sufficient. Generator control is typically from the low side of GSU, and the TOP generator voltage schedule is typically at the BES Point of Interconnection. If a generator does not monitor from the assigned TOP voltage schedule monitoring point, a generator must then have an alternative method to monitor and providing evidence of maintaining voltage schedule.

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

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Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

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R2.3 is unnecessary as a Requirement. Voltage information is available when needed.

Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Dominion, Segment(s) 3, 5, 1, 4/6/2017

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Part 2.3 is not required.

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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This is an “or” question that does not have a yes/no answer as written. In the review document, the concern is that the requirement is not written as performance based. Based on the review document, agree, rewrite R2.3 and M2  to be performance based such as "The Generator Operator shall monitor the voltage specified in the voltage schedule either directly or by a conversion methodology." which takes some of the pressure off of M2 to be the requirement and it can be reworded as well.Needs to be a requirement but rewritten to be effective.

Entergy/NERC Compliance, Segment(s) 1, 5, 3/1/2017

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BPA believes this works as a requirement.

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Generator must have a way to know they are meeting TOP voltage schedule requirements.  Typicall, TOP monitors generator at point of interconnection. If Gnerator does not have access to this point, then alternate means of monitoring performance on generator side must be provided.  A Technical Guide should be adequate.

 

Jesus Sammy Alcaraz, On Behalf of: Imperial Irrigation District, , Segments 1

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 It is not needed as a sub requirement - the primary objective is for the GOP to follow the schedule, not how it is accomplished.    

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

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Yes, the requirement is unreasonable in VAR-002-4 because it places an additional monitoring requirement on the generator that isn’t in the spirit of the overall requirement to maintain a voltage schedule.  Requirement 2.3 should be worded consistently as a results based requirement by replacing ‘monitor’ with ‘maintain’. Requiring that the GOP consider how to maintain the voltage schedule if the TOP and GOP schedule maintenance point is different supports reliability.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 2

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We believe that it is necessary.  However, it should be consistent with VAR-001-4.1 in that it should stipulate that just having the methodology provided to the TOP is not sufficient, it should be approved by the TOP. 

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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The Requirement provides necessary flexibility for the GOP in the method of monitoring the voltage.   We don’t disagree that a measure or guidance would provide a similar result but Exelon does not see any reason to change the requirement.

(As an aside, the question is confusing, we are answering that the Requirement is necessary. Others may be responding affirmatively to “is it sufficient as a measure”?)

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

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R2 requires each GOP to maintain generator voltage.

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

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Yes, Requirement R2, Part 2.3 is necessary as a Requirement to ensure accuracy and eliminate ambiguity.  Requirement R2, Part 2.3 requires a methodology for converting the voltage to the point being monitored by the GOP.  The GO monitors the voltage to track compliance within the voltage parameters as specified by the TO.  Requiring a conversion methodology ensures that the GO and the TO will communicate to affirm that the voltage being targeted by the GO aligns with the voltage parameters set by the TO.  As a Measurement, there is no assurance that the steps necessary to precisely align the GO voltage readings with that of the TO would be taken, resulting in a reactive rather than a proactive approach to voltage control.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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A Measure is sufficient.

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

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LS Power Transmission's comments address a problem wth both and are therefore separately attached..

John Seelke, On Behalf of: John Seelke, , Segments 1

LS Power Transmission Comments Project 2016-EPR 04.13,17.docx

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Transmission Operators rely on Generator Operators to maintain voltage at the point of interconnection (or point that the issued voltage schedule is based on).  If Generator Operators are monitoring a different point (e.g. low side generator terminals), it may cause confusion with the Transmission Operator.  Including this as a requirement, makes the expectation clear.

Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 4/13/2017

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The NSRF agrees that R2.3 is not necessary. We recommend moving it to technical guidance. 

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 4/13/2017

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Duke Energy does not believe that Part 2.3 is necessary as a requirement, and agrees with removing it from the standard altogether.

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

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R2 Part 2.3 requires revision to include the following “Generator Operator (GOP) will monitor voltage based on existing equipment at its Facility”, to clarify that it is required to monitor and not just imply that. The requirement should state that the GOP shall monitor the voltage. How the GOP monitors the voltage is left up to the GOP. Examples of how the monitoring is to be done could be put into the technical guidance.

David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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The SPP Review Group recommends that the drafting team leave Part 2.3 associated with Requirement R2.  However, we suggest revising the current language associated with Part 2.3 to be consistent with Guideline Technical Basis (GTB).

SPP’s proposed language is as follows:

“Generator Operators that do not monitor the voltage at the location specified in their voltage schedule shall have a methodology for converting the scheduled voltage specified by the Transmission Operator to the voltage level being monitored by the Generator Operator.”

SPP Standards Review Group, Segment(s) , 4/13/2017

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The requirement set forth in VAR-002-4, R2.3 should be retained.  Texas RE has encountered several instances in which generation facilities have monitored voltage at different points than specified by their TOP. For example, voltage monitoring has typically been required at the Point of Interconnection. In several instances, however, generators have monitored voltage at other points on facility site. In several cases, there is a significant distance between these points, resulting in significant variations in voltage levels due to line losses. Without a common, documented conversion methodology, generators may not meet their voltage schedule requirements. Given this experience, Texas RE recommends that this requirement be retained to ensure generators properly satisfy their voltage schedule requirements in the manner intended by the TOP.

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

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We find the yes-no question confusing with the conjunction “or” present.  We believe Requirement R2, Part 2.3 is unnecessary, as the development of a methodology falls under Paragraph 81 criteria, particularly Criterion B3: Documentation.  Another possible alternative is the creation of a white paper identifying the methodology necessary to convert a scheduled voltage to a GOP-measureable voltage point.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 4/13/2017

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ISO/RTO Standards Review Committee, Segment(s) 2, 4/13/2017

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Reclamation asserts that Requirement R2, Part 2.3 is not necessary as a requirement and should be addressed in the technical guidance. Further, some Transmission Operators provide bus voltage but not generator voltage. Reclamation suggests that VAR-002-4 R2 be revised to “…maintain the voltage or Reactive Power schedule provided by the Transmission Operator…”

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Hot Answers

This notification requirement and associated communication can be addressed via IRO-010-2.

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

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

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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IRO-010 provides the vehicle for the RC to obtain reliability related information. It is redundant to mandate that the RC receive specific information regardless of its impact on reliability.

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., RF, Segments 2

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While there is a reliability impact, we believe the RC may already request such information in accordance with directives currently provided in IRO-010-2.

 

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

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The number of generators and the relative impact to reliability of a limited sub-set reporting AVR status changes would likely not result in useful information to entities without direct operational responsiblity for transmission voltage.

Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

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The requirement to notify within 30 minutes is too stringent and does not have commensurate reliability benefits. Typically after knowing that an AVR is out, the TOP simply makes a note and no action is taken since R2.1 assures that the generator produces the same amount of VAR even in manual voltage control mode. Even if the TOP were to receive this information in 60 to 120 minutes, reliability will not be impacted. The AVR information is not automatically updated in RTCA and hence RTCA results do not change. Unless the TOP and the RC automatically update the real time simulation programs for AVR status, the requirement for notification within 30 minutes does not provide a reliability benefit and places an undue compliance administrative burden. If the Drafting Team thinks otherwise, please provide real system scenario examples where the reliability would have been impacted.

Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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IRO 10 provides the vehicle for the RC to obtain reliability related information.  It is redundant to mandate that the RC receive specific information regardless of its impact on reliability.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

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Voltage is a local requirement that impacts the TOP, GOP and DP. Change in AVR status notification is not a high level system impact that the RC should be concerned about.

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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This requirement is addressed in IRO-010, the RC needs to specify this in their data spec if it is needed and avoid spreading similar data requests across multiple standards.

Entergy/NERC Compliance, Segment(s) 1, 5, 3/1/2017

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BPA believes the impact would be minor for a single unit change in AVR status. BPA believes TOP-001, R9 appears to close the gap on notification to the RC for an AVR status change.

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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RC needs to request data via IRO-010.

Jesus Sammy Alcaraz, On Behalf of: Imperial Irrigation District, , Segments 1

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 IRO-010-2 gives the RC the ability to request this if it is determined to be needed.  

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

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The RC can specify this as required data in their documented specification for data from IRO-010-2.

Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 2

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In our opinion the GOP should only notify the TOP. This forces the TOP to be in the loop and aware of the voltage/reactive issues which are more local than global (at least at the start of an event). To the extent the TOP cannot address the voltage issue, with say distribution or transmission capacitors or other devices, and then the RC can be in the solution loop.  However, we believe that the TOP should notify the RC.  This is minimal and with the continuous dialogue between TOP and RC really not a logistical problem either.

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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The RC can get this information from other sources / standards.   

The Functional Model for the RC has no real time tasks listed for the RC to receive info from a GOP.

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

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

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Yes, if the RC does not receive information when the AVR status has changed after 30 minutes, then the RC study results may not be accurate.  If the RC is not aware that an AVR is not working properly, the study results could indicate that there is not a risk to the BES when there could be.  The TOP and RC do similar reliability studies.

Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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The RC is notified as part of the IRO-010 data submission. 

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

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John Seelke, On Behalf of: John Seelke, , Segments 1

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 4/13/2017

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The TOP should act as a filter for the RC.  One generator AVR out of service may not have a significant reliability impact.  The TOP’s 30-minute assessment may identify an issue at that time and should notify the RC. 

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 4/13/2017

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Duke Energy does not believe that reliability is impacted by the lack of notification of AVR status change to the RC. We believe that a notification to the TOP is sufficient, with the TOP having discretion to escalate to the RC if escalation is deemed appropriate by the TOP.

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

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The Reliability Coordinator should receive in real time the AVR & PSS status. The requirement as written is only applicable to Transmission Operator. Referring to the NERC Functional Model, the RC must maintain a wide area view and is responsible for establishing IROL and SOL in some cases therefore, the RC needs to be notified of AVR & PSS status changes.

David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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The review group does not find any reliability impact with the RC not receiving the notifications from either the GOP or TOP in reference to the AVR status change. However, as registered RC, SPP finds the AVR notification data to be very valuable to other processes associated with the RC function. For example, this particular data can help increase the accuracy of the network applications as well as the Real-time Assessment. In our review and interpretation of the IRO Standards, it is our understanding that the IRO-010-2 Standard addresses the RC receiving this type of data and eliminating any concerns for reliability issues.

SPP Standards Review Group, Segment(s) , 4/13/2017

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Texas RE does not have comments on this question.

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

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By its definition, a TOP is the entity responsible for the reliability of its “local” transmission system.  A change in the state of an AVR after 30 minutes should be identified as a “local” reliability concern.  We feel the inclusion of notifying the RC would be burdensome, particularly when monitoring and assessing the Wide Area view of the BES.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 4/13/2017

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IRO 10 provides the vehicle for the RC to obtain reliability related information.  It is redundant to mandate that the RC receive specific information regardless of its impact on reliability.

ISO/RTO Standards Review Committee, Segment(s) 2, 4/13/2017

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Reclamation asserts the communication between GOPs and TOPs regarding the status of AVR/PSS equipment and VAR capacity is important, and the existing 30 minute time frame for the GOP notification to the TOP is adequate. Reclamation suggests the TOP, having a wider view of the BES, would be the logical entity to analyze the AVR/PSS equipment availability as it applies to the system, and if needed, notify the RC.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Hot Answers

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

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

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., RF, Segments 2

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

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2.2 - should be included in the Measure as a potential means for providing notification, not the requirement.  Also, as mentioned TOP-003 allows the TOP to identify the method for providing data.  The measure should also include "or other method prescribed by the TOP". 

Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Dominion, Segment(s) 3, 5, 1, 4/6/2017

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No comments

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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From review template.

2.1 – Agreed,

2.2 Means of notification is agreed between GOP and TOP and is not need to be specified in the requirement. This should be addressed in detail in the TOP's TOP-003 Data Specification. If it is clarified that telemetry can be used, clarify that this is at the discretion of the TOP's TOP-003 Data Spec (may not be acceptable to all TOPs, while it is allowed by NERC).

2.3 Agree

2.4 Already clear, no additional clarity needed.

2.5 Clear as is, not needed, but if changes are made they need to be made in R3 per the structure of the requriement.

2.6 and 2.7, agree that this content needs to be clarified and that the Section 4, Applicability, is the appropriate place to do that.

Entergy/NERC Compliance, Segment(s) 1, 5, 3/1/2017

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No Comment

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Jesus Sammy Alcaraz, On Behalf of: Imperial Irrigation District, , Segments 1

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 Item 2.2:   This clarity is not needed since the TOP specifices the notification methods via BAR-0001-4.1, R5.2 and possbily in TOP-003-3.  

Item 2.3:   Not needed as R4 of VAR-002-4 already states "… a change in reactive capability".    

Item 2.5:   The use of status in the main requirement of R4 refers to changes of the status of control detailed in R3, namely the change in status of the AVR, power system stabilizer, or alternative voltage controlling device.   The "on" found at the beginning of the second line of R3 in VAR-002-4 is what needs to be changed to "of".    

Item 2.6:   We disagree with removing this bulleted section of R4.  It clearly exempts dispersed generating resources from R4 if this is retained.   The purpose of this exemption was so that the status of individual inverters at such a site would not have to be individually reported.     

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

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Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 2

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For 2.2, if telemetry is stipulated to be acceptable for notification of AVR status change, it should be emphasized that email is not appropriate for notification.  Most TOP operators work shifts and even if an email addresses is available for a group, the operator may not be monitoring emails in a timely manner to be sufficient for notification of operational issues. 

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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

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

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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No comment.

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

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John Seelke, On Behalf of: John Seelke, , Segments 1

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 4/13/2017

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The NSRF agrees.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 4/13/2017

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Part 2.2: Duke Energy agrees that telemetry is a sufficient method of notification to the TOP of an AVR status change. An issue could arise wherein the GOP relies on telemetry to serve as a notification to the TOP, only to find out that the telemetry was not working properly, or failed to alarm, during the status change.

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

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David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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SPP Standards Review Group, Segment(s) , 4/13/2017

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Texas RE appreciate the SDT's efforts and careful review of the VAR-002-4 Standard. To that end, the SDT has identified a number of typos and non-substantive corrections that should be addressed. However, the in identication of these technical edits, the SDT indicated in item 2.2 that a future SDT may wish to clarify that "telemetry is a sufficient means of providing notification."  From Texas RE's perspective, this constitutes a substantive departure from standard applications of notification requirements. Put differently, Texas RE views the notification requirements in VAR-002-4, R3 as designed to specifically highlight changes in generator voltage regulation capability. Such changes could be lost in a broad stream of telemetered data, potentially reducing a TOP's situational awareness regarding the level of voltage control available at specific generation resources in real-time.

 

While it may be possible to provide adequate notice through telemetry of AVR status changes, such an issue goes beyond a mere clarification and will require substantive development regarding possible impact. As such, the inclusion of this element is inappropriate as an errata item and should be fully vetted as a substantive change in any possible future projects involving a new version of VAR-002. 

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

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We thank the Periodic Review Team for identifying these administrative type observations.  However, we believe Paragraph 81 requirements do exist within this standard, particularly with Requirement 6 which requires GOs to provide certain modeling data upon request.  Nonetheless, we believe pursuing a resolution to these administrative type concerns is a step in the wrong direction for a standard that is not often violated.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 4/13/2017

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ISO/RTO Standards Review Committee, Segment(s) 2, 4/13/2017

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Reclamation agrees with the proposed errata.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Hot Answers

ERCOT does not believe a revision to the standard is necessary.  However, if a project is established, ERCOT suggests that the term “Automatic Voltage Regulator” could be defined to add clarity.  

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

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In VAR-001-4, we commented that Attachment 5, point 5.3 was a valid point. It applies here to Requirements 5 and 6.

In the Québec interconnection, a number of step-up transformers are owned by TOs. Standards like FAC-008-3 and PRC-025-1 allow for this possibility. This standard does not (R6). We believe that when this standard is revised, this change should be made in order to make the standard consistently applicable.

These same two requirements R6) (and the matching requirement in VAR-001-4.1) do not seem to be RBS. In particular, they do not specify a performance to be achieved, only a means - tap changes - by which an unspecified goal must be attained. In the Enhanced Periodic Review, some parties stated that such a requirement regarding tap changes was necessary in some regions. Nevertheless, such a requirement currently calls out a single manner of achieving an unnamed goal. Currently, the requirements, as written, cause us no problems: As TOP, we do not micro-manage our GOPs transformer taps. However, when the standard is revised, it should be rewritten to reflect a performance-based approach.

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

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., RF, Segments 2

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

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Attachment 5, 14.2: Greater clarity is required regarding the initial status of the PSS.  Currently R1 and R3 create ambiguity.  A review of NERC Notices of Penalty (NOPs) appears to indicate that precedent exists for notification to the TOP for changes to the expected state of the PSS upon startup and synchronization of the Generator to the Interconnection.  Data specifications created by TOPs under TOP-003 create another source of guidance to the GOP further complicating a definitive understanding of the requirement.

Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Dominion, Segment(s) 3, 5, 1, 4/6/2017

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No comments

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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From the review template:

2.1 Disagree, this needs to stay for clarity

2.2 Agree, to be in keeping with TOP standards, "would violate safety, equipment, regulatory, or statutory requirements"

4.1 agree

4.2 Agree

4.3 agree

4.4 Neutral, seems adequately clear without but is not harmed by adding the verbiage.

6.1 For 5.1.2, agree

10.1 and 10.2: Agree that this requires clarity, but this should be taken care of in section 4, Applicability. (see note for 2.6/2.7 above)

14.1 Recommend identifying the "GSU owner" and not tying it to any functional entity.

14.2 Agree that clarity is needed, but recommend that a new "Requirement 4" be inserted to treat PSSs. Include addressing "initial expected state" in new requirement as well.

16.1 Agree, see comments on 14.2

Entergy/NERC Compliance, Segment(s) 1, 5, 3/1/2017

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It is unclear to BPA if all of the observations in Attachment 5 would be considered revlevant to VAR-002 if a drafting team was convened.  BPA believes it may be more efficient to have a small technical review team evaluate these observations and then make a determination and recommendation to NERC.

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Jesus Sammy Alcaraz, On Behalf of: Imperial Irrigation District, , Segments 1

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Item 2.1:    Subrequirement R2.3 of VAR-002-4 is not needed and should be move to a technical guidance section of the standard.   

Item 4.4:   No additional statement is needed for M1 because the phrase "voltage schedule" does not appear any where in R1 or M1 of VAR-002-4.   

Item 6.1:  Simply removing "fixed" from R5.1.2 will resolve the concern.   

Item 10.1:   The suggested change would be more appropriate for sites that contain the plant voltage controller, as the individual generator usually is not a voltage controller.   The individual generator controller receives var or pf commands typically from a site voltage controller.   In contrast, adding this term may cause problems for existing DGR facilities that do not have site voltage controllers.    Would they be required to add equipment to be able to comply?    

Item 10.2:   The concern of this section is not clear.   R2 of VAR-002-4 specifies that a GOP follow the voltage schedule.   R3 of VAR-002-4 specifies that the GOP must notify the TOP of changes the voltage controlling equipment in the first 30 minutes of the change.  These two requirements are not misunderstood by GOP's.   

Item 14.2:   Any requirement for the existance of a PSS is dictated either by the interconnection requirements of the TOP or by regional requirements, and does not need to be dictated by NERC.  

Item 16.1:   This level of details for PSS settings is not qppropriate for the NERC standard.    Detailed requirements and guidelines for PSSs should be addressed at the regional level, which is the current practice. 

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

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Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 2

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For 2.1, Requirement R2, Part 2.3 should not have the clause “specified by the Transmission Operator” removed.  It is not unnecessary.  We believe that the GOP should not be able to have a methodology of their choosing without approval from the TOP.  For example a GOP methodology might be advantageous to providing lower MVAR resources. 

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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Reference 14.2 should also address Startup/Shutdown operation of a Power System Stabilizer (PSS) for cases where the PSS is external (i.e., a standalone component) or if the PSS is internal to an AVR. 

In addition, a PSS is typically not enabled automatically until a certain MWe when ramping a unit up in power and subsequently disabled at a certain MWe on ramping a unit down in power.  This should be recognized in the Standard to eliminate unnecessary communications for routine operations.

Reference 14.2 is not clear that the "on/off" position of a PSS could be external or internal to an AVR.   

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

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

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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No comment.

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

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John Seelke, On Behalf of: John Seelke, , Segments 1

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 4/13/2017

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Many of the corrections / revisions involve changes to time horizons, VSLs and minor wording changes do not rise to the level of securing a SDT for revisions.  NSRF would support an ‘errata’ change for corrections. 

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 4/13/2017

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

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David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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SPP Standards Review Group, Segment(s) , 4/13/2017

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Texas RE does not have comments on this question.

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

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We thank the Periodic Review Team for identifying these other observations regarding the standard.  However, we believe pursuing a resolution to these administrative type concerns is a step in the wrong direction for a standard that is not often violated.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 4/13/2017

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ISO/RTO Standards Review Committee, Segment(s) 2, 4/13/2017

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Reclamation agrees with the proposed observations.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Hot Answers

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

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

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., RF, Segments 2

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

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Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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It is difficult to determine the cost impacts relative to the reliability benefits without additional studies and information.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

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No comments

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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Entergy/NERC Compliance, Segment(s) 1, 5, 3/1/2017

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Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Jesus Sammy Alcaraz, On Behalf of: Imperial Irrigation District, , Segments 1

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 Any changes made to the standard which may cause existing facilities to not have automatic controls systems that are capable of meeting the new requirement should be evaluated on feasiblity and cost.    

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

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Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 2

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David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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

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

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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Cost effectiveness is always a concern but should not take precedence over reliability issues. 

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

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John Seelke, On Behalf of: John Seelke, , Segments 1

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 4/13/2017

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MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 4/13/2017

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

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David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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SPP Standards Review Group, Segment(s) , 4/13/2017

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Texas RE does not have comments on this question.

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

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ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 4/13/2017

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ISO/RTO Standards Review Committee, Segment(s) 2, 4/13/2017

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Reclamation does not have any concerns related to the cost effectiveness of VAR-002-4, but asserts that the standard would be more cost-effective after incorporating the above suggestions.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Hot Answers

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

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The EPR has identified a number of issues. However, most issues identified so far seem relatively minor. We do not see a pressing need to revise the standard at this time.At some point, the standard will have to be revised and cleaned up though.

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

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Other Answers

Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., RF, Segments 2

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

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The standard should be revised to address R3 and the initial status of the PSS.

Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Dominion, Segment(s) 3, 5, 1, 4/6/2017

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Requirement 2 should list how long the voltage can be outside the TOP provided Generator Bus Voltage schedule. It should provide guidance as to how long the operator has to return the voltage to within the schedule. This guidance would provide assistance to the auditor and to the GOP who is determining when to submit a self report.

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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Entergy/NERC Compliance, Segment(s) 1, 5, 3/1/2017

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Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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Jesus Sammy Alcaraz, On Behalf of: Imperial Irrigation District, , Segments 1

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 With the exception of the items noted in this comment form, we are in general agreement with the findings of the periodic review team.    

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

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Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 2

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Realize that if VAR-001 is changed significantly with any requirements removed, then in response VAR-002 may need to be changed. 

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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  1. It would be beneficial if there were some guidance/example on what constitutes a "change" in reactive capability that falls within the scope of the Standard.

  2. The Standard is not clear that it applies to an external PSS AND to newer technology AVRs that have an internal PSS input (enable/disable).  The SDT should ensure that the guidance is clear to the industry on the various applications of a PSS.

  3. The SDT should consider developing a technical justification/rational for the 30 minute requirement to communicate a status change or reactive capability change.

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

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

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Louisville Gas and Electric Company and Kentucky Utilities Company, Segment(s) 3, 5, 6, 4/13/2017

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

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John Seelke, On Behalf of: John Seelke, , Segments 1

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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RSC no ISO-NE, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 4/13/2017

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NERC VAR-002 R4 does not contain magnitude criteria for the change in reactive capability that requires coordination.  Requiring coordination of any and all changes in reactive capability could negatively impact reliability, by distracting from other reliability functions.  NSRF does not believe that this was the intention of this requirement or NERC would not allow the exemption of the individual generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electric System definition. 

The TOP should specify the magnitude of Reactive Power required to be coordinated based on their system studies.  This is something that could be addressed in the TOP data specification required in TOP-003-3.  However, There is concern that this may not be the case as the reactive reserve requirement no longer exists.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 4/13/2017

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Duke Energy recommends that the drafting team consider whether the language used in R3 (and R4) requiring a GOP to notify its TOP within 30 minutes of a status change in AVR, PSS, or alternative voltage control device is open to varying interpretations. For example, if a GOP recognizes that the status changed 15 minutes after the change occurred, the GOP evaluates and initially feels they can address and restore the status within the 30 minutes. The GOP ultimately is not able to restore in the remaining 15 minutes. Is the GOP non-compliant if they do not notify the TOP  until minute 31? We feel that revising the language, or issuance of additional guidance on this topic would be beneficial to industry stakeholders.

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

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Clarification is required for R1 “The Generator Operator shall operate each generator connected to the interconnected transmission system in the automatic voltage control mode (with its automatic voltage regulator (AVR) in service and controlling voltage)” to specify that AVR shall be in automatic voltage control mode and PSS (if provided) in service, as there can be cases where the PSS is an external device and is monitored differently than when the PSS is an internal function of the AVR.

 

The following Note 1 requires revision: “1 Start-up is deemed to have ended when the generator is ramped up to its minimum continuously sustainable load and the generator is prepared for continuous operation.” There may be cases when the generator is at the minimum continuously sustainable load and the PSS based on the settings is not in service at that power level (i.e. PSS I/S when P>30%)

 

R4 the 30 minutes requirement can be interpreted as not satisfied if and end core cooling alarms is received and the entity will take time to investigate the validity of the alarm. We can only know that the degradation of the End Core cooling will impact the reactive power capability when required to operate in the leading mode.

 

R5 Part 5.1 clarification required with respect to step-up transformers primary/secondary and voltage levels.

R6 - Clarification required regarding equipment limiters versus equipment ratings

David Ramkalawan, On Behalf of: David Ramkalawan, , Segments 5

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SPP Standards Review Group, Segment(s) , 4/13/2017

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Texas RE frequently encounters wind farms that do not recognize that the technology to maintain voltage is an AVR.  Wind Farm Management Systems (under a variety of names) clearly demonstrate the capability to control volatage and are used daily but, because it is not specifically called an “AVR”, entities often miss responsibilities.  With the penetration of wind, it is imperative that this get corrected globally, rather than one-off awareness (via an compliance discovery method) or workshops that are not necessarily attended by all parties.  Texas RE has done outreach and will continue to do so but would encourage a project to clarify the VAR standards. 

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

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We thank you for this opportunity to provide these comments.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 6, 4/13/2017

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ISO/RTO Standards Review Committee, Segment(s) 2, 4/13/2017

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Reclamation identifies the following issue for consideration:

  • Reclamation asserts that registered entities’ internal compliance programs’ auditability of R4 would be enhanced if examples of “a change in reactive capability due to factors other than a status change described in Requirement R3” were provided in the measures or a guidance document.

Reclamation asserts that VAR-002-4 should be modified to include the above proposed requirements, errata, and observations. Reclamation supports periodic reviews of standards like these as essential, and appreciates the work of the Periodic Review Team.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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