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Gregory Miller

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BGE

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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.

BGE would like to comment on the following requirements:
R1.8 A “low as practical” requirement adds too much subjective uncertainty to an auditable standard. Leave the “not greater than 75% of nominal” requirement.
R3. SDT should include a stronger statement excluding capacitors that are not connected to the BES. BGE recommends a modification to the proposed language like “existing BES-connected capacitor banks”.  Although distribution banks provide reactive support to transmission, they are frequently located on the regulated side of tap changers or line-regulators, and therefore are not relevant to the concern. It should also be noted that fixed banks are appropriately used in many distribution applications.
R12. It is unclear as to how a discretionary trip would fall into the values in Table 1. For example, if the only UnderFrequency protection was a discretionary trip at 58 Hz, would more protection need to be installed to meet the 15 seconds and 120 seconds trip points as described in Table 1? Or is a single trip point sufficient?

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.

BGE feels the time horizons are appropriate.

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.

BGE has no comments regarding the modifications to the Measures.

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.

BGE has no comments regarding the modifications to the VSLs.

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.

BGE has no comments regarding the modifications to the VRFs.

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.

BGE feels that the SDT needs to address the concerns expressed under Q1 prior to the Standard being ready for Category Ballot.

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