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Patrick O'Loughlin

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Buckeye Power, Inc.

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1) Subsequent to a review performed by NERC staff, the SDT has reformatted and modified certain requirements of the draft PRC-006-RFC-01 standard. Do you agree with the reformatted structure and modified requirements of the standard?

Yes

1) If not, please provide specific suggestions.

 

2) Time Horizons have been added to the Requirements. Do you agree that the Time Horizons are appropriate for the requirements?

No

2) If not, please provide specific suggestions.

The implementation plan for R1 and R2 are too fast for DPs that do not currently have UFLS systems to design, engineer, procure and appropriately deploy a UFLS system.  Also does not allow time to evaluate and develop mutal agreements to aggregate loads as allowed for in R1.

3) The Measures have been modified to include more examples on how to assess performance and outcomes for the purpose of determining compliance with the requirements.  Do you agree that the Measures are appropriate?

Abstain

3) If not, please provide specific suggestions.

 

4) The Violation Severity Levels (VSLs) have been modified to be consistent with the modified requirements and based on NERC and the FERC guidelines.  Do you agree that the VSLs are appropriate?

No

4) If not, please provide specific suggestions.

The differences in implementation levels between lower, moderate, high and severe are relatively minor and not in accordance with the descriptions.

5) The Violation Risk Factors (VRFs) have been modified to be consistent with the modified requirements and based on NERC and the FERC guidelines.  Do you agree that the VRFs are appropriate?

Yes

5) If not, please provide specific suggestions.

 

6) The Standard Drafting Team believes the standard is ready for Category Ballot.  Do you agree?

No

6) If not, please provide specific suggestions that would make it acceptable to you.

See previous comments

Created at 9/7/2012 10:09 AM by System Account
Last modified at 9/7/2012 10:09 AM by System Account