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Louis Slade

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Dominion

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Michael Gildea, Chip Humphrey

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?

No

1) If not, please provide specific suggestions.

1. We do not agree that a reliability standard should be effective, in the US, until it is approved by FERC. We are concerned that changes could be imposed as a regional standard goes through the NERC approval process and/or as it goes through the FERC approval process. We do not think it is prudent to expend the resources necessary to comply with a reliability standard until such time as it has been approved by FERC, as the changes made during the standards development process could substantially alter the requirements as approved by either the regional board or the NERC BOT.  And, because of these concerns, we cannot agree with an implementation plan that begins with board approval.
2. We do not agree with the response of the SDT to Wisconsin Electric Power’s comments in question 5. Our interpretation of the SDT’s response is that this regional standard could be applied to Generator Owners who are not included in the NERC compliance registry. If this is the intent of the SDT, we disagree. We do agree that any generator that meets the criteria contained in NERC’s Statement of Compliance Registry Criteria (III(c)) can be registered by NERC or a Regional Entity.
3. We do not agree that R10 should apply to Generator Owner. R9 requires the Planning Coordinator to establish a mitigation plan that meets R9.1 and R9.2. If the mitigation plan involves a Generator Owner, then there should be a requirement that the Planning Coordinator provide notification to the Generator Owner. Absent such notification, R10 should not apply.
4. We do not agree that R11 should be predicted upon R9, but instead should be predicated upon R10.
5. We do not agree with R12.1 as it still requires a Generator Owner to procure a service (load shed) for which we have found no willing provider. We prefer the SDT adopt requirements similar to those contained in the version of PRC-024-1that is being developed in Project 2007-09. Alternatively, we could accept modification of the requirement so that it only applies when the Distribution Provider offers load shed service.
 

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

Yes

2) If not, please provide specific suggestions.

 

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?

No

3) If not, please provide specific suggestions.

We do not agree with the measures included in M10, M11 and M12 because we do not agree with the corresponding requirements (as indicated in our responses to question 1).

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?

Abstain

4) If not, please provide specific suggestions.

 

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?

Abstain

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.

No, for reasons indicated in responses to question 1.

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