Please enter your first and last name.

Sam Ciccone

Please enter your company name.

FirstEnergy Corp.

If this is from a group, please enter all additional members.

Doug Hohlbaugh
Jim Detweiler
Ken Dresner
Brian Orians

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?


1) If not, please provide specific suggestions.


2) R3 through R7 add specificity and scope to the NERC PRC-006-1 standard requirements pertaining to identification and mitigation of islands as noted below.   

a. The Planning Coordinator needs to include additional items in their island identification criteria (R3).

b. The Planning Coordinator shall supply their island identification criteria (R4) and respond (R5) to any comments received on the island identification criteria from affected entities.

c. The Planning Coordinator shall identify and document islands by: applying the island identification criteria at least every 60 months (R6), supplying the results of applying the island identification criteria to affected entities (R6, Part 6.1), inviting, in writing, the participation of applicable entities, in the establishment of the mitigation plan (R6, Part 6.2) and establishing a mitigation plan to balance generation and Load and restore frequency in each area of islanding should the area of islanding become separated from the interconnection (R6, Part 6.3).

d. .Affected Distribution Providers, Transmission Owners and Generator Owners shall implement their portion of any mitigation plan (for the island(s)) as determined by the Planning Coordinator (R7).

Do you agree with the added specificity and scope pertaining to how islands are identified and addressed?


2) If not, please provide specific suggestions.


3) R8 and R9 extend the scope of the NERC PRC-006-1 standard to apply to Generator Owners’ underfrequency trip characteristics in planning UFLS programs as noted below. 

a. The premature tripping of a generating unit may have a very negative effect on the Bulk Electric System during a frequency excursion, and thus it is important to include a Generator Owner requirement within a standard dealing with UFLS. Generator Owners are required to either: 1) Set underfrequency protection in accordance with PRC-006-RFC-01 Attachment 1 (Time vs. Frequency curve) for generators that have automatic underfrequency protection installed, 2) establish and follow procedures for underfrequency operation in accordance with PRC-006-RFC-01 Attachment 1, for generators that do not have automatic underfrequency protection installed, or 3) arrange for Load shedding to be installed by mutual agreement with Distribution Providers, in addition to that required by the Planning Coordinator in Requirement R1 or Requirement R2, for generators that cannot meet the specifications in PRC-006-RFC-01 Attachment 1. (R8) (Note: the Time vs. Frequency curve in Attachment 1 is consistent with the curves in the NERC PRC-006-1 and draft PRC-024-1 standards (R11)).

b. Generator Owners (which are required to comply with R8) are required to supply underfrequency trip setting data to populate the Planning Coordinator’s UFLS data base (R9).  It is important for the Planning Coordinators to have such generator data in order to perform an accurate UFLS assessment (R10).  (This requirement may be removed once the NERC PRC-024-1 standard is completed and approved.)

Do you agree with the extended scope to include Generator Owners?


3) If not, please provide specific suggestions.


4) R10 and R11 extend the scope of NERC PRC-006-1 standard by including requirements to assess UFLS program implementation (in addition to UFLS program design required in the NERC PRC-006-1 standard) as noted below. 

a. The Planning Coordinator is to perform, document and make available an assessment of the effectiveness of the “implementation” of the UFLS programs.  The NERC PRC-006-1 standard only requires an assessment of the “design” of the UFLS programs.  This assessment will assess the effectiveness of the implemented UFLS programs using the information contained in the Planning Coordinator’s database which, while satisfying the design requirements, may exceed the design specifications (R10).

b. Applicable Distribution Providers, Transmission Owners and Generator Owners are to complete any required changes to the implementation of the UFLS program based on any implementation deficiencies noted in the Planning Coordinator’s assessment.  The NERC PRC-006-1 standard only requires the applicable entities to provide automatic tripping of Load in accordance with the UFLS program design and does not account for any changes which may be found necessary based on the Planning Coordinator’s assessment of implementation.  Such changes may be necessary for the overall effectiveness of the UFLS program when arresting frequency excursions.  The three calendar year completion interval was chosen to give applicable entities a reasonable amount of time for making changes in the field (R11).

Do you agree with the need to assess UFLS program implementation as well as design?


4) If not, please provide specific suggestions.


5) The Standard Drafting Team believes the standard is ready for Category Ballot. Do you agree?


5) If not, please provide specific suggestions that would make it acceptable to you.

FirstEnergy (FE) thanks the SDT for their hard work and dedication to this standard over the past few years. When this effort began, there was no enforceable standard because FERC did not approve PRC-006-0 as it was one of the “fill-in-the-blank” standards identified in FERC Order 693. RFC felt the need to address this fill-in the blank standard and to consolidate the three legacy region requirements (ECAR, MAAC, MAIN) by starting the development of PRC-006-RFC-01. At that time, FE, along with most of the RFC members agreed with the development of the regional standard since NERC was far from development of their continent wide standard PRC-006-1.
But since then, while the RFC standard development continued on into seven draft periods, the development of NERC PRC-006-1 was expedited and completed before the RFC standard. Furthermore, FERC has just released a NOPR indicating its intent to approve PRC-006-1. The NOPR comment period ends November 21, 2011 and industry will likely see action from FERC no later than the first quarter of 2012. Also, NERC is in the process of completing PRC-024-1 which sets requirements for Generator Frequency and Voltage Excursions which will be applied in conjunction with PRC-006-1. The PRC-024-1 standard is a high priority project at NERC and is scheduled for completion by the end of the first quarter of 2012.
FE recognizes that the RFC drafting team has made substantial changes to bring their proposed UFLS standard into better alignment with NERC PRC-006-1 and has removed a number of glaring inconsistencies. However, we continue to believe that this standard development should be halted at this time. Some of the reasons we believe it should be stopped include:
1. The prescriptive text of the RFC standard, although good guidance for the development of a Planning Coordinator’s UFLS program, may be too constraining for Planning Coordinators in the RFC footprint whose territories may span more than just the RFC region. For example, the Midwest ISO is the registered Planning Coordinator in the regions of MRO, RFC, SERC and should be given the flexibility to implement a single UFLS program for its territory. Similarly PJM’s territory covers RFC and SERC.
2. This will cause burden, confusion and inefficiencies to be placed on entities required to comply with two separate UFLS standards and for the auditors who must audit multiple standards.
3. The uncertainty of the consistency of Generator Owner requirements of PRC-006-RFC-01 and the still developing NERC standard PRC-024-1. This will create possible issues when a GO is implementing the RFC standard and then may have issues implementing an inconsistent PRC-024-1 standard.
4. The RFC standard, if approved by the RFC Board, will only be enforceable upon FERC approval. This creates more uncertainty in that RFC will not know if FERC will even approve the regional standard.
RFC members have continuously voiced the desire for RFC to suspend their work on their standard due to the NERC standard PRC-006-1 development. For instance, in the last comment period, 15 of 16 respondents (the 16th commenter Abstaining) believed that the standard should not be balloted, and most (12) of respondents (including PJM and MISO) commented that they believed that the work of the RFC standard development should be suspended in lieu of the NERC PRC-006-1 standard development.
Therefore, due to the pending regulatory approval of NERC PRC-006-1 and RFC member majority opinions to halt work on this regional standard, we believe that the RFC standard is not needed from a reliability standpoint at this time. We suggest the team stop work on the standard, allow the implementation of PRC-006 and PRC-024 and then at a later time RFC can determine if there is a reliability need for RFC standard PRC-006-RFC-01.  Furthermore, we believe the excellent work of this drafting team will serve as a good starting point for the development of the Planning Coordinator’s UFLS program within the RFC region and that the implementation of NERC standards PRC-006-1 and PRC-024-1 will achieve the same end goal of reliability and avoid the inefficiencies of implementing multiple standards.

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