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Doug Hohlbaugh

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FirstEnergy Corp

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Sam Ciccone, Dave Folk

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?

Abstain

1) If not, please provide specific suggestions.

See response to Question 6

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

Abstain

2) If not, please provide specific suggestions.

See response to Question 6

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.

See response to Question 6

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.

See response to Question 6

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.

See response to Question 6

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.

FirstEnergy believes further development of this standard is no longer needed based on progress made on a new NERC Board of Trustee approved PRC-006 version 1 standard.  Having this regional standard in addition to the new version 1 NERC standard causes industry confusion and duplication of compliance efforts.
 
We thank the drafting team for their dedication and hard work to draft a standard intended to support NERC's fill-in-the-blank standard PRC-006-0 which requires the Regional Reliability Organization (now Regional Entity) to document and implement UFLS requirements for its footprint.  FirstEnergy initially supported RFC’s effort to develop this PRC-006-RFC-01 standard as it served two important roles 1) elimination of legacy UFLS requirements and 2) the new PRC-006-RFC-01 standard could help influence the development of the NERC continent wide standard PRC-006-1.
 
The purpose statement of this RFC standard emphasizes the original scope as it states “To establish ReliabilityFirst requirements for automatic underfrequency Load shedding (UFLS) to support NERC Reliability Standard PRC-006.”  However, the NERC Board of Trustees approval of PRC-006-1 on November 4, 2010 eliminates the “fill in the blank” need and stated purpose of this RFC standard.    FirstEnergy concludes that this standard can not move forward without a concurrent proposal to include a regional variance in the new NERC PRC-006-1 standard to make clear that for the RFC footprint the RFC standard prevails.  Otherwise, the difference in approach between the two standards causes confusion and duplication of compliance efforts.
 
We cite these additional reasons why the RFC standard PRC-006-RFC-01 should not go further in the approval stages:
 
• UFLS Program Responsibilities - In the NERC PRC-006-1 standard, the UFLS program is developed by the Planning Coordinator (PC) per Requirement R1, while in the RFC standard PRC-006-RFC-01, the UFLS program is developed by the Distribution Providers in Requirements R1 and R2. This will make it very difficult for entities in the RFC region to comply with both standards.
 
• Generator Function Applicability and further NERC Standards Development Efforts - The RFC standard is applicable to the Generator Owner (GO) while the NERC PRC-006-1 standard is not applicable to any Generator functional entity. However, NERC is in the process of creating a separate standard, PRC-024-1 (Generator Performance During Frequency and Voltage Excursions) which will cover the Generator function. Furthermore, the settings specified in Requirement R12 of PRC-006-RFC-01 are not consistent with neither the proposed NERC PRC-024-1 standard nor the industry accepted practices described in IEEE standard C37.106 (Guide for Abnormal Frequency Protection for Power Generating Plants).
 
In conclusion, we believe that RFC should re-evaluate the need for their regional standard.  We suggest they table the effort until they have (1) carefully determined the feasibility of an entity in the RFC region to comply with both standards; and (2) determined if the BES within the RFC footprint has unique topology/characteristics that require region specific requirements to maintain BES reliability.

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