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Howard Rulf

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We Energies

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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?

No

1) If not, please provide specific suggestions.

As requirement R2 is written, Distribution Providers that have less than or equal to 50 feeders shall implement the modified UFLS program described in R2.  By using the word “shall” in R2, a Distribution Provider with less than or equal to 50 feeders does not have the option to implement the UFLS program described in R1. 
Requirements R7 through R10 need to be revised to show coordination among Planning Coordinators when an identified area of credible islanding is part of multiple Planning Coordinator areas.  R5 of the NERC Board of Trustees approved continent-wide UFLS standard (PRC-006-1) provides an example of such coordination. 
The following text in requirement R9.1 is grammatically incorrect: 
“…where the amount of additional UFLS capability Load to be shed in the island area…”  The text should state “…where the amount of additional UFLS capability in the island area…”
In addition, the text “in excess of the 25% specified in R1.1 or R2.1” needs to be deleted from R9.1.  Any additional UFLS capability installed in an area of credible islanding that has the same setpoints as the UFLS capability required in R1.1 or R2.1 should be allowed to be counted as part of the overall 25% UFLS capability required in R1.1 or R2.1.  There is no technical reason that the UFLS capability installed in an area of credible islanding cannot serve the dual purpose of mitigating an underfrequency event in the area of credible islanding as well as mitigating an overall system UFLS underfrequency event.  The UFLS relays are going to trip load in either case, as the UFLS relays cannot distinguish between the types of underfrequency events that initiated the tripping. 
Table 1 of requirement R12 must be revised to insert the word “Under” between the words “Automatic” and “Frequency” in the Minimum Time Delay column for the ≥ 59.5 Hz. entry as automatic overfrequency tripping would not be allowed per the table’s current construct. 
Requirement R11’s grammatical structure appears to have a circular reference within R11 regarding the use of the words mitigation plan.  R17 provides an example of how R11 should be worded.  The following is suggested text for R11 based on R17’s wording. 
“Each Distribution Provider, Transmission Owner and Generator Owner shall implement the Planning Coordinators mitigation plan (as determined in Requirement R9) within three years of the completion date of the Planning Coordinators mitigation plan (as determined in Requirement R9).  “
Requirement 14.6 is written too open ended as evidenced by the use of the text “…additional Load shedding schemes…” or “…any other schemes...”  It should be left to the Planning Coordinator to determine what specific additional information is required for the Planning Coordinator’s database. 
As such, R14.6 needs to be reworded to strike the text after “load-restoration schemes.”  An example of the reworded requirement is: 
“Information describing non-Fault clearing tie-tripping schemes, islanding schemes, and automatic load-restoration schemes.  “
Requirement 15.2 as written is too open ended as evidenced by the use of the text “…any other schemes…”  It should be left to the Planning Coordinator to determine what specific additional information is required for the Planning Coordinator’s database.  As such, R15 .2 needs to be deleted. 
Similar to our comments regarding requirements R7 through R10 above, R16 needs to show coordination among Planning Coordinators when an identified area of credible islanding is part of multiple Planning Coordinator areas. 
Additionally, due to following text at the end of R16:  “…and shall include, but not be limited to the following…,” the Planning Coordinator would be non-compliant if the Planning Coordinator only considered R16.1, R16.2, and R16.3 in its assessment. 
Requirement 17 as written is too open ended as evidenced by the text “...other protection system…”  Requirement 17 needs to focus on UFLS program changes only.  As such, replace the text “or other protection system” with the text “program” 

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.

In Measurement M12, the word “that” needs to be inserted after the text “Each Generator Owner”
In Measurement M14, the text “UFSL” needs to be changed to “UFLS” 

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?

Yes

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?

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.

For clarity, R11 and R17 should be added to the Implementation Plan.
The draft RFC UFLS standard appears to have multiple requirements that are either duplicate or less stringent requirements than that of the NERC Board of Trustees approved continent-wide UFLS standard (PRC-006-1).  At a minimum, RFC should delay this standard until after the NERC continent-wide UFLS standard is effective. At such time, the SDT can align the RFC UFLS standard with the NERC continent-wide UFLS standard.  However, in light of the new NERC continent-wide UFLS standard, the SDT should re-evaluate the reliability need for a RFC regional UFLS standard and consider retiring the legacy guides after the NERC continent-wide UFLS standard becomes effective. 
Per the RFC Standards Development Procedure, there are missing compliance elements in the draft standard.
In accordance with the ReliabilityFirst Reliability Standards Development Procedure, Board Approval December 6th, 2007 Standards Committee Modified April 1st, 2008 - Board Concurrence May 22nd, 2008, "A Standard shall consist of the format requirements shown in the Regional Reliability Standard Template. These requirements apply to the development and revision of Standards. These requirements are necessary to achieve Standards that are measurable, enforceable, and consistent… "
Within the Compliance Monitoring Process, please include these missing required elements:
Define for each measure:
• The specific data or information that is required to measure performance or outcomes.
• The entity that is responsible to provide the data or information for measuring performance or outcomes.
• The time period in which performance or outcomes is measured, evaluated, and then reset.
• Measurement data retention requirements and assignment of responsibility for data archiving.

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