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Transmission Vegetation Management Project 2007 by pop14118


									Transmission Vegetation Management
Project 2007-07

Richard Dearman, Drafting Team Chair, TVA
Reliability Standard FAC-003-2
October 5, 2009 2PM-3PM ET
Project Overview

  FAC-003-2 Transmission Vegetation Management
  Applicable Entities Affected
    • Transmission Owner
    • Planning Coordinator
  Scope
    • Develop a Standard to prevent vegetation-related outages which
      could lead to Cascading by effective vegetation maintenance
      while recognizing that certain outages such as those due to
      vandalism, human errors and acts of nature are not preventable.

Project Schedule to Completion

  Currently posted for 45 day comment period
  Ballot completion expected February 2010
  Expected presentation to NERC Board May 2010
  Projected Effective Date - the first calendar quarter one
   year after applicable regulatory authority approval for all
   requirements; or, in those jurisdictions where no
   regulatory approval is required, the first calendar day of
   the first calendar quarter one year following NERC Board
   of Trustees adoption.
  The foregoing dates based on conducting 2 comment
   periods only.
Team Approach

  The industry comments were over 220 pages (final
   response 259 pages)
  Built an 18X66 matrix of questions for % agree/disagree
  Sub-teams worked on questions/with high % disagree to
   find themes
  Themes of disagreement were compared by full team
   and full team made the changes to the standard
  Team focused on a gradations for requirements i.e.
   documentation, clearances, imminent threats, and
   outages by type.

FAC-003-2 Vegetation Management

 SAR approved by the NERC Standards Committee in July 2007 to
 address FERC directives in Order 693 related to FAC-003-1
 Key FERC Order 693 Directives
    • Avoid “fill in the blank” requirements such as Clearance 1 & 2
      and minimum personnel requirements
    • Apply NERC Standard guidelines including VRFs and VSLs &
      separation of documentation and implementation requirements
    • Address applicability of IEEE 516 to determine clearance
    • Address applicability of sub 200kV lines
    • Address minimum vegetation inspection frequency
    • Address applicability to federal lands
    • Update references to RRO
FAC-003-2 Vegetation Management

 Key Elements of First Posting - Initial October 2008 version
    • Introduced CCZ concept to replace Clearance 2 and trigger for
      imminent threat procedure
    • Established a clear process to designate sub 200kV lines
    • Clarified applicability to federal lands
    • Requirement for minimum vegetation inspection frequency
    • Eliminated reporting requirement for Category 3 outages
    • Specified certain sustained outages are a violation
    • Removed “fill in the blank” requirements Clearance 1 and
      minimum personnel qualifications

FAC-003-2 Vegetation Management

 Analysis of Industry Comments - Key areas of general industry
 •   Applicability and designation of sub 200kV lines
 •   Separation of documentation and implementation requirements
 •   Minimum inspection frequency
 •   Elimination of Clearance 1 and Personnel Qualification “fill in the blank”
 •   Use of Gallet equation is superior method to determine spark-over
 •   Specifying certain sustained outages are violations of the standard
 •   Interim Corrective Action to replace Mitigation Plans
 •   Eliminate reporting requirement for Category 3 outages

FAC-003-2 Vegetation Management

 Analysis of Industry Comments - Key areas of general industry
 •   Use of term “Bulk Electric System” in purpose statement (52%)
 •   Actions required by Transmission Operator for imminent threats
 •   Use of Critical Clearance Zone (CCZ) as threshold for
     implementing imminent threat procedure (57%)
 •   Use of CCZ as boundary for determination of minimum clearance
     violations (94%)

 ** There were comments from 66 entities, 259 pages, making this one of the
      largest comment documents of any NERC draft standard.

FAC-003-2 Vegetation Management

 Response to Industry Comments
 After careful consideration, the SDT addressed those requirements with the
 greatest disagreement and adopted several industry recommendations in other
 areas where there may have been general agreement
 Key Changes to 2nd Posting
     • Removed Bulk Electric System from purpose statement
     • Revised R1.4 in response to comments about imminent threat process
     • Replaced CCZ with a “real time” method to determine minimum
       clearance distances and threshold for imminent threat process
     • Added R1.6 Maintenance Strategies to address comments about the
       elimination of Clearance 1
     • Separate requirements for IROL and non-IROL lines to allow VRF/VSL
       gradation for violations related to sustained outages
     • Clarified R1.5 Interim Corrective Action, is temporary in nature
     • Defined Vegetation Inspection as a NERC Glossary term
FAC-003-2 Vegetation Management

  Comment Form Overview/Format
    Must be Submitted by October 24th

       • Background as it Relates to SAR

       • Key Changes from First Posting

       • Identified Areas of Improvement as Compared to V1

       • Analysis of Industry Comments for 1st Posting of V2

       • Eighteen Questions for Feedback to SDT

FAC-003-2 Vegetation Management

  Comment Form – Question Highlights

   • Questions 1 to 11 - Requirement Changes

   • Question 12 - Feedback on the Requirement Sequencing

   • Questions 13 to 16 - General interest questions from the SDT

   • Question 17 - Feedback if V2 will maintain or improve overall

   • Question 18 - General Comments

FAC-003-2 Vegetation Management

  Comment Form – General Info
   • VRFs and VSLs were developed in accordance NERC Drafting
     Team Guidelines.
   • If you agree with a change, do not provide any comments unless
     you have an improvement suggestion (Process is such the SDT
     must respond to all comments).

   • If you disagree, please explain and propose an alternative
     suggestion in the comment field.

Implementation Plan

  There are no other Reliability Standards or Standard
   Authorization Requests (SARs), in progress or approved,
   that must be implemented before this standard can be
  There are no proposed revisions to requirements in other
   already approved standards. There is a new definition
   and a revised definition in the proposed standard.
  FAC-003-1 will be retired when FAC-003-2 becomes

Supporting Materials
   Technical Reference Document:
     •   Is not in itself a compliance tool or standard
     •   Is supplementary and explanatory in nature
     •   Generally follows the sequence of FAC-003-2’s requirements
     •   Serves as an “FAQ” reference
     •   Includes a comprehensive technical paper that sets forward the Gallet Equation Method for
         determining MVCDs
     •   Explains that MVCD encroachments are assessed in real time, not hypothetically or by
     •   Explains “Maintenance Strategies” required by FAC-003-2
     •   Gives guidance for developing Imminent Threat procedures and Interim Corrective Action
     •   Elaborates on Applicability
     •   Gives pictorial examples of Active & Inactive R/W
     •   Mentions some “best management” vegetation practices

   Reliability Standard Audit Worksheet (RSAW)
     •   The SDT will make recommendations for changes to the RSAW document to assist the Regional Entities during audits   14
     •   These changes cannot be finalized until the Standard is finalized.

 Project Overview and Schedule
 Reviewed initial posting and consideration of
  industry feedback
 Reviewed key changes in second posting
 Second Comment Period ends October 24, 2009
 Implementation Plan
 Technical Reference document

Information Link
Vegetation Management Project 2007-07

   Richard Dearman, TVA
   Harry Tom, NERC Project Coordinator


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