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Jason Marshall

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Midwest ISO

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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.

We do not support the concept of identifying arbitrary islands for the purpose of establishing a UFLS program and do not believe it is necessary to identify islands to establish the program.  Many parts of the BES do not have characteristics that necessarily result in them developing into any particularly islanding scenario. 
 
We do not support Requirement 6 as it is essentially mandating a stakeholder process and is administrative.  While we are supportive of a stakeholder process, we do not believe it should be mandated in a reliability standard and do not believe this requirement provides a reliability benefit. 
 
Requirement 16 in the RFC standard potentially conflicts with Requirement 4 in the NERC standard.
 
The NERC standards reads assess the design, whereas the RFC standard reads assess the design and implementation. How we are to assess what has been implemented is not clear.  One interpretation would be the UFLS database contains a record of what is implemented in the field and we perform an assessment of that. Another interpretation would be to assess that the implementation of UFLS relays in the field has occurred.  Planning Coordinators should not be making field verifications of UFLS relays. So language should be clarified to the former.
In addition, we support the comments submitted by ATC regarding this question.

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 agree with the comments submitted by ATC for this question.

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?

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.

The work on this regional standard should be halted.  NERC recently completed their work on the UFLS standard.  It eliminates the need for regional work on UFLS standards by eliminating the "fill-in-the-blank" components.  Many of the RFC requirements are duplicative.  When RFC commenced this effort, it made sense because there was not a NERC standard but now that there is a NERC standard, the RFC standard is largely duplicative and unnecessary.  At the very least, RFC should halt the work until FERC rules on the NERC standard to see what list of directives NERC must respond to.  This might change the direction of the RFC standard.

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