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Andrew Pusztai

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American Transmission Company

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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.

R1 – Modify the wording of “The Distribution Providers automatic UFLS program” to “The automatic UFLS program of a Distribution Provider or a collective group of Distribution Providers”. This wording would more clearly convey the idea that the sub-requirements apply to the UFLS program of a “stand alone” Distribution Provider or the UFLS program of a collective group of Distribution Providers.
R1.1, R2.1, R7, & R14.2 – Replace “forecasted annual peak hour” with “next forecasted Year One peak hour”.
R3 & R16.2 – Replace “capacitor banks and reactors” with “capacitor banks and inductor banks” because both capacitor banks and inductor banks are reactors.
R4.4 & R7 – Insert a new R4.4, ahead of the existing R4.4, with the wording, “Areas of credible islanding shall have a next forecasted Year One peak hour Load of greater than 1,000 MW, which is within or partially within their area of responsibility”, and remove the associated qualifying wording from R7 because it would be redundant.
R8 – Modify the wording of “of applying the island methodology” to “of applying the island methodology (to as determined by R7)” to be consistent with the inclusion of this qualification in R9.
R9 – Add wording that is consistent with R16 to R9 such as “This mitigation plan shall include the effects of neighboring Planning Coordinator area and may be developed jointly with other Planning Coordinators that are within the credible island.”
R9.1 – Change the existing wording to “To cover potential generation/Load imbalances in the island area, Distribution Providers shall install additional UFLS capability in the island area in excess of the minimum requirements specified in R1.1 or R2.1 . . . determined by engineering assessments in accordance with the design requirements in R1 and R2.” for added clarity.
R10 – Expand the wording to “. . . establishment of the mitigation plan by the Planning Coordinator (as required in Requirement R9.” for added clarity.
R12.1 – Add the following qualification to the second sentence, “In those cases where a generator must be tripped for its own underfrequency protection outside the specifications in the above Table 1 and tripping of the generator prevents acceptable effectiveness of the UFLS program design . . .” The loss of a generator does not have to be compensated if the effectiveness of the ULFS program is sufficient despite the tripping of certain generators. 
R14 – Expand the wording to “with the relevant sections of Requirement R1, Requirement, R2, Requirement R3 or Requirement R11” because R14.7 refers to the provision of data for the reactive elements mentioned in R3. 
R14.x - Add a sub-requirement to R14 that identifies system model location of the UFLS data, “Transmission interconnection location of the forecasted Year One peak hour load”.
R14.7 – Replace “capacitor banks connected to the BES” with “existing capacitor banks and inductor banks to control over-voltage in accordance with the assessment performed by the Planning Coordinator in Requirement R16”. The transmission capacitor banks and inductor banks used to control over-voltage may be connected to non-BES portions of the transmission system.
R16 – Expand the wording to, “. . . may be performed jointly with other Planning Coordinators within the credible island . . .” for more clarity.
R16.1 – Consider replacing “the current frequency set points” with “the existing frequency set points”.
R16.3 – Consider replacing “Disturbance that cause” with “Disturbances that are expected to cause”.
R17 – Consider consolidating R11 and R17 into one Requirement. The revised Requirement could be the wording in R17 and simply refer to recommended changes “(as determined in R9 and R16)”.
R18, R18.2, & R18.3 – Remove the reference to ‘other entities” because with the approval of PRC-006-1, only Planning Coordinators are responsible for UFLS data and UFLS program assessments. Remove the wording of “and entities” from R8. Replace the wording of “neighboring entities” with “neighboring Planning Coordinators” in R8.2 and R8.3.
R18.1 – Add the wording of, “. . . and assessment results required in R16 . . .” to require coordination on the assessment with Planning Coordinators internal to RFC, which would be consistent with obligation in R18.2 to coordinate on the assessment external to RFC.

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 M5, the wording should be “within 15 calendar days” to agree with R5. Correct the wording at the end of the paragraph to “request per Requirement R5”.
In M8, the wording should be “within 30 calendar days” to agree with R8.
In M12, the wording might be changed to, “Each Generator Owner that owns” or Each Generator Owner owning”. Consider modifying the wording to “. . . dated evidence such as underfrequency tripping settings or procedures that demonstrate its underfrequency protection conforms to Table 1 . . .” for more clarity.
In M14, correct the wording of “Requirement 2” to “Requirement R2” and “UFSL” to “UFLS”. Per the comment on R14 above, add “Requirement R3” to the text.
In M15, the wording should be “within 45 calendar days” to agree with R15.

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.

In general, ATC thinks that that the RFC should defer development of the RPC-006-RFC-1 standard until the RFC gains enough experience with the PRC-006-1 standard to determine whether it is insufficient.
In addition, ATC does not believe that the standard is ready for Category Ballot until the comments made in Question 1 regarding R12.1 and R14.7 are adequately addressed.

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