VIEWS: 3 PAGES: 6 POSTED ON: 2/15/2012
Industry Comments for CAN-0027 Comment Topics Main Points Industry Suggestions Our concern is that "status" would imply real-time information which is entirely different than the intent of information related to coordination of planned (scheduled) outages. Specifically, to demonstrate coordination for PLANNED outages would be to show specific Scope We suggest removing this implied change in scope. examples of planned coordination. But, the word status in this text would imply to some CEA personnel every moment coordination and requiring demonstrating that level of coordination is certainly an increase in scope for this Requirement. Most CANs apply either retroactive enforcement or enforcement from the date the CAN becomes effective. In both cases, entities should be provided adequate time to adjust their The CAN should not use retroactive effective dates and NERC should incorporate a reasonable Effective Period of CAN programs, policies, systems or hardware to conform to these newly defined or clarified implementation period for all CANs. requirements. We believe that to plan and coordinate means entities work together and share information Evidence of Compliance in advance of outages to make certain that all involved parties make needed preparations to Please refer to evidence for real-time implication. ensure and verify resources are available to maintain the reliability of the BES. # of entities # of entities represented Category Comments with identical Entity in one response response We believe that everything discussed in this CAN is adequately and clearly described in TOP-003 R2 and therefore this particular CAN is not needed. However, if NERC decides to issue this CAN, we have a concern with the word “status “in the second bullet point on page 2 which states, “The GOP provides information on the availability, status, real and reactive capability, and real and reactive de-ratings of generating units to both the BA and the TOP”. Our concern is that "status" would imply real-time information which is entirely different than the intent of Scope 1 Ameren information related to coordination of planned (scheduled) outages. Specifically, to demonstrate coordination for PLANNED outages would be to show specific examples of planned coordination. But, the word status in this text would imply to some CEA personnel every moment coordination and requiring demonstrating that level of coordination is certainly an increase in scope for this Requirement. We suggest removing this implied change in scope. FE agrees with the comments as provided by EEI that this is an inadvertent interpretation of R2 for the GOPs. We believe that this CAN incorrectly require the GOP to provide certain specified information to both the TOP and the BA. Whereas in R1, the GOP provides outage information to the TOP. The TOP then provides this information to affected BA(s) and TOPs. In R2 of TOP-003-1, we feel that the TOP has the 1 FirstEnergy responsibility for coordinating any outage of system voltage equipment requested by the GOP, with the affected BA(s) and other TOPs. The CEA must also be aware of any Regional Entity reporting requirements. Constellation is concerned with the background description in draft CAN-0027, specifically “knowledge of the generating unit commitment and planned dispatch which defines the dynamic reactive support available.” Coordination of unit commitment and planned dispatch are part of normal operations planning and though this impacts outage scheduling and system configuration the CAN should avoid inference that 1 Constellation generating unit commitment and planned dispatch are Planned Outage Coordination activities. Excerpts from CAN-0027 TOP-003 R1.1 and R2: Since the reliable operation of the BA’s area is dependent on system voltage regulating equipment, the BA shall be knowledgeable of the planning and coordination of scheduled outages of system voltage regulating equipment, such as automatic voltage regulators on generators, supplementary excitation control, synchronous condensers, shunt and series capacitors, reactors, etc. with affected BAs and TOPs as required. 1 FMPP Agree that the BA shall be knowledgeable, but the BA cannot be knowledgeable about scheduled outages on equipment that it does not own unless the TOP informs the BA. The MRO-NSRF does not see any vague or ambiguous wording in TOP-003 R2 that requires a Compliance Application Notice. The CEA should look to TOP-003-1, M1 for guidance to verify that the Balancing Authority coordinated with the Generator Operator and the Transmission Operator pursuant to TOP-003 R2. Measure 1 states “Evidence that the Generator Operator, Transmission Operator, and Balancing Authority reported and coordinated scheduled outage information as indicated in the requirements above.” Therefore, NERC should not issue this 1 16 MRO NSRF Compliance Application Notice as NERC appears to be using the CAN process to train its auditors rather than to clarify standards. The MRO-NSRF believes the first sentence in the first paragraph, “A CEA is to verify that a BA provided dispatch information to the TOP including Although EEI generally agrees with most of the background information provided for the BAs and TOPs, we do have some concern that NERC has made an inadvertent interpretation as it relates Requirement R2 for GOPs. We believe that bullet 2 on page 2, incorrectly obligates GOPs to communicate certain specified information to both BAs and TOPs as it relates to the resources they operate. We submit that this is a misinterpretation that is based on the incorrect inclusion of both real and reactive resource planning where only reactive resource planning is specified in R2. In the context of TOP-003 R2, it is the TOP not the BA who is the responsible entity for the balance of reactive power. Therefore, the GOP in most circumstances would be the entity to coordinate with the TOP not the BA; however, we offer that R2 does not specifically or 1 * EEI clearly identify which functional entity is responsible for notifying and coordinating with the TOP. We believe that this was intended by the Drafting Committee to accommodate regional differences where the BAs are performing these activities. Therefore, we do not support a CAN that prescriptively requires GOPs to coordination with both the BAs and TOPs but allows GOPs to coordinate with either the BA or TOP as required by regional practices. We do, however, agree that an interpretation may be necessary to ensure coordination is being conducted appropriately in all regions given known differences by region. The requirement does not apply to the RC. Thus, the RC does not need to be included in a communication on BA, TOP, and GOP compliance. While the BA does know the unit commitment and planned dispatch, the unit commitment and planned dispatch does not necessarily define the dynamic reactive support available. The TO may own a synchronous condenser which provides dynamic reactive support and the BA may have no knowledge of the synchronous condenser since it would be dispatched by the TOP. Thus, the first sentence of the second paragraph should be modified. 1 7 ACES This section expands the meaning of Requirement R2 beyond the simple basic meaning especially when it is considered in conjunction with other standards and requirements. Coordination of voltage regulating equipment among the GOP, TOP and BA means that the GOP (per VAR- 002-1 R3 and TOP-002-2b R14) will notify both the TOP and BA when it plans to take an outage of the its voltage regulation equipment and the BA and TOP can approve or deny the outage for their operations. The TOP will evaluate the request for the outage against its existing outage schedule. The BA and TOP will work together to be sure that the TOP or BA does not cause outages to be shifted into time periods that will cause TOP-003 R2 does not require that a Balancing Authority report "generating unit commitment and planned dispatch" to the Transmission Operator, therefore CAN-0027 is not necessary. TOP-003 R2 explicitly states the need to plan and coordinate scheduled outages of system voltage regulating equipment which is a very specific type of equipment. The issue should be how the Transmission Operator, Balancing Authority, and Generator Operator plan and coordinate the outages of system voltage regulating equipment. The issue should be modified to reflect the actual requirement or the CAN should be rescinded. 1 * NRECA NERC should ensure that revised draft CAN-0027 does not establish new requirements that are not part of the FERC-approved Reliability Standards. This is consistent with FPA Section 215, which requires that “[t]he Electric Reliability Organization shall file each reliability standard or modification to a reliability standard that it proposes to be made effective under this section with the Commission.” Pursuant to FPA Section 215, NERC is required to follow the Standards Development process and obtain FERC approval prior to enacting new Reliability Standards or modifying existing Reliability Standards. Please change TOP compliance application text to read: TOP is responsible for the system configuration, managing the required must-run units for voltage and reactive control, and determining needs for system support. It provides voltage and reactive schedules to the GOP and requests that the BA dispatch provides additional capacity for 1 Seattle City Light system support as necessary, including reactive support to replace capacity being slated for planned outages . This change is suggested because CAN-0027 relates only to planning and coordinating outages, and the language should reflect that fact. The requirement TOP-003 R2 is with regard to planned outages of reactive sources. The bulleted items in the CAN are mixed with coordination of planned outages and awareness of resource capability. We recommend the following revisions to the bullet points for consistency and conformity with requirement TOP-003 R2: • The BA has knowledge of generation unit commitment and planned dispatch, which it must communicate to the TOP. Additionally, the BA provides dispatch orders for generation to the GOP based on requests for dispatch changes from the TOP. 1 KCPL • The GOP provides information on the availability, status, real and reactive capability, and real and reactive de-ratings of generating units to both the BA and the TOP. • The TOP is responsible for the system configuration, managing the required must-run units for voltage and reactive control, and determining needs for system support. It provides voltage and reactive schedules to the GOP and requests that the BA dispatch additional capacity for system support as necessary, including reactive support. BPA thanks you for the opportunity to comment and BPA has no comments or concerns at this time. 1 BPA We respectfully suggest the compliance guidance offered in this section can easily be obtained through reading the Standard as written and although there is little harm with the information provided, we question the value of the guidance. We feel that NERC should not elaborate on 1 Southern Co. the plain language of a reliability standard requirement but instead focus on areas of the reliability standard where compliance guidance and clarification are in fact needed. AEP remains concerned that the scope of CANs continues to expand and evolve without a clear understanding of their implications, with this CAN in particular serving as an example. Rather than provide clarification, this CAN clearly adds to the existing standard by specifying evidentiary requirements not stated within the standard itself. 1 AEP A CAN is not the correct tool for this application. Issues such as those raised in this CAN should be dealt with through the standards development process, such as through a revision or formal interpretation request. There is a wealth of information within this CAN, that transcends other standards. Guidance such as that provided in this CAN, though well meaning, should be afforded due process and industry vetting. The requirement is to coordinate scheduled outages. The CAN goes well beyond the requirement by implying that scheduled dispatch also needs to be coordinated, which has nothing to do with outages. Coordination of unit commitment is also beyond scope. If a unit is not committed, that is not the same as a scheduled outage. The unit would still be available if the TOP needed it to start to help support voltage. Hence, the BA is the 1 FMPA passive entity in the coordination required. The GOP tells the BA about scheduled outages. The TOP tells the BA if a GOPs proposed outage schedule is rescheduled due to voltage regulation needs. In addition, the BA has no responsibility to actual perform unit commitment, but only to balance the resources made available to it. Hence, the BA’s only responsibility is to be coordinated with. Please refer to our comments above for real-time implication. We believe that to plan and coordinate means entities work together and share Evidence of Compliance information in advance of outages to make certain that all involved parties make needed preparations to ensure and verify resources are 1 Ameren available to maintain the reliability of the BES. With the suggested changes to draft CAN-0027, NRECA requests that the following be removed from this CAN: "A CEA is to verify that a BA provided dispatch information to the TOP including generating unit commitment. The CEA is to verify the BA coordinated generation related outages." It is responsible that the CEA verify that the Transmission Operator, Balancing Authority, and Generator Operator shall plan and coordinate scheduled outages of system voltage regulating equipment. 1 * NRECA NRECA believes that the following statement provides no value and recommends removing the statement from the CAN: The CEA is to verify these activities regardless of whether the BA operates under a vertically-integrated company or an unbundled, full-service market structure. Entity structure is not relevance in determing compliance with TOP-003 R2. EEI questions the tone and direction provided under this section fearing that this CAN may have unintentionally confused some functional responsibilities related to reactive resource planning. Specifically, BAs are the functional entity responsible for balancing real power while the TOPs are responsible for balancing reactive power. In the context of this Standard, R2 specifically addresses the coordination of reactive resources. Relative to who plans, coordinates and communicates GOP resources, EEI believes that there are regional differences that impact reporting (i.e., in some areas GOPs perform this function while in other areas BAs perform the function). We further believe there may be no 1 * EEI clear answer as to what must take place and suggest that the inclusion of “as required” was intentional allowing regional differences to take place as long as the activity is conducted. Specifically, we believe the key purpose of R2 is to ensure that the three entities identified (i.e., TOPs, BAs and GOPs) understand their roles and then plan and coordinate reactive resource outages in a manner that supports BES reliability and stability. The MRO-NSRF believes the first sentence in the first paragraph, “A CEA is to verify that a BA provided dispatch information to the TOP including generating unit commitment” goes beyond the scope of this Standard Requirement and does nothing towards verifying the planning and coordination of scheduled outages of system voltage regulating equipment. The second paragraph seems out of place and does nothing to help a CEA verify the planning and coordination of scheduled outages of system voltage regulating equipment. This paragraph does not provide any information for Evidence of Compliance that a CEA should be looking for. The third paragraph, “Additionally, a CEA is to verify that the BA responded to any requests from the TOP, including but not limited to requests 1 16 MRO NSRF to dispatch additional units for reactive capacity” goes beyond the scope of the Standard Requirement. The MRO-NSRF does not believe this paragraph supports the Issue Statement of this Compliance Application Notice: What is the responsibility of the Balancing Authority under TOP- 003 R2? The fourth paragraph in this Section seems out of place. This paragraph would be more appropriate in the Compliance Application Section. The MRO-NSRF believes that all the guidance needed by the CEA to assess whether the Balancing Authority fulfilled its responsibility to The effective and presents some challenges. R2 of be term in Measure 1 of this Standard. communicatedate coordinate under TOP-003 Usecan the found“effective period” implies that there is a compliance obligation associated with the CANs when, in fact, the compliance obligation remains within the Reliability Standard language. In all cases, CANs should be forward looking from the time a CAN is posted as final and should not be applied retroactively to any circumstance. Moreover, the effective date language in these CAN revisions states: 1 Constellation “[The CAN] supersedes all prior communications and will remain in effect until such time that a future version of a FERC or other applicable government authority approved standard or interpretation becomes effective and addresses the specific issue contained in this CAN.” This language is troubling given that the effective date authority is expressly provided for in the Reliability Standards. The proposed effective We respectfully suggest the compliance guidance offered in this section can easily be obtained through reading the Standard as written and although there is little harm with the information provided, we question the value of the guidance. We feel that NERC should not elaborate on 1 Southern Co. the plain language of a reliability standard requirement but instead focus on areas of the reliability standard where compliance guidance and clarification are in fact needed. TOP-003 R2 does not require the BA to provide dispatch information to the TOP. Other requirements do. Since this CAN only covers the compliance application of TOP-003 R2, the sentence in the first paragraph stating that the CEA should verify the BA supplied dispatch information should be struck. For TOP-003 R2, the CEA should not be required to verify that the BA responded to any requests from the TOP to dispatch additional units. The CEA should only be required to verify the BA responded to requests specifically generated due to the outage of 1 7 ACES voltage regulation equipment. The TOP may request dispatch for other reasons such as thermal overloads but TOP-003 R2 only deals with voltage regulation equipment. Thus, the third paragraph of this section should be modified accordingly. We agree that that BA should not be expected to know anything about other reactive resources besides generation. The standard simply requires that the Generator Operator, Transmission Operator, and Balancing Authority plan and coordinate scheduled outages of system voltage regulating equipment. R2 of the standard as written allows the entity to develop best practices and procedures surrounding the retaining and provision of evidence proving that planning and coordinating activities took place. The standard does not provide specificity regarding the exact nature of this evidence, and it is improper for a CAN to specify such evidence outside of the standard itself. 1 AEP Regarding “The CEA is to verify these activities regardless of whether the BA operates under a vertically-integrated company or an unbundled, full-service market structure”, what about cases where the BA employees also serve as GOP employees? Guidance in this CAN suggests that evidence must be provided showing that the BA communicated with itself (the GOP). Dispatch and unit commitment are not scheduled outages. 1 FMPA EEI believes that NERC needs to incorporate a reasonable implementation period for all CANs. Generally, we have observed that CANs routinely apply either retroactive enforcement or enforcement from the point of “Final Posting”, such as in this CAN. In either case, if entities are not Effective Period afforded any ability to adjust their programs, policies, systems or hardware to conform to these newly defined or clarified requirements this may 1 * EEI result in many, if not most, registered entities continually self reporting their potential non-compliance. This is troubling particularly at a time when NERC is pursuing Find, Fix, Track and Report as a way to redirect compliance resources to those issues that pose the greatest risk to Bulk Power System reliability. Southern Company requests that NERC incorporate a reasonable implementation period for all CANs. We have observed that most CANs apply either retroactive enforcement or enforcement from the date the CAN becomes effective. In both cases, entities are not provided adequate 1 Southern Co. time to adjust their programs, policies, systems or hardware to conform to these newly defined or clarified requirements. The third statement is misplaced. “Additionally, a CEA is to verify that the BA responded to any requests from the TOP, including but not limited to requests to dispatch additional units for reactive capacity.” 1 Constellation TOP-003 R2 covers planning and coordinating scheduled outages while dispatch of resources is an operational activity. The CAN needs to be limited to version 0 and 1 of the standard. TOP-003-1 is actively undergoing revision. Because compliance must be demonstrated over the entire audit cycle, the new version of TOP-003 will become effective while this CAN will need to remain in effect. 1 7 ACES Proposed TOP-003-2 R2 deals with the TOP distributing its data specification. Thus, by not limiting the CAN to version 0 and 1, the CAN would apply to version 2 even though it has no real application.
Pages to are hidden for
"CAN-0027 Analysis Spreadsheet"Please download to view full document