RS Response to Psco Comments on the BES Inclusion Guideline 7-14-1204

The Reliability Subcommittee’s Response to Xcel Energy Comments

on the BES Inclusion Guideline

July 14, 2014

On June 9, 2014 the Reliability Subcommittee posted the Bulk Electric System (BES) Inclusion Guideline for the Planning Coordination Committee’s (PCC) approval. On July 8, 2014, Xcel Energy submitted reasons for not supporting the approval of the BES Inclusion Guideline. The Reliability Subcommittee (RS) thanks Xcel Energy for its comments on the BES Inclusion Guideline.To address Xcel’s concerns, the RShas developedthe following responses.

It should be noted that the Xcel Energy comments are requesting clarity in the process associated with the BES Inclusion Guideline not with the non-BES element screening guidance.

Xcel Comment

1. The document is not clearly written from an applicability or usability perspective.

The need & purpose of the document is stated as:

WECC has determined that it needs a process for identifying which non-BES facilities are material to the reliability of the Western Interconnection. To that end, the Reliability Subcommittee has developed this WECC Guideline.

However, the Process section of the document does not contain any clear description of what constitutes the WECC process (sequence of steps) to be followed to identify such non-BES facilities. Further, it is unclear where and when in the process would the evaluations be conducted for the suggested “situations for consideration”. With what periodicity and/or what trigger would such an evaluation be done? That is, it is unclear what comprises “actively identify” such non-BES facilities.

Additional confusion in the document arises due to the Process section where it states that the responsible entities have been identified “consistent with FERC Order 773 and Recommendation 17.” If so, it is unclear why Regional Entity (RE) was excluded from the responsible entities given that Recommendation 17 is clearly applicable to WECC as the RE, and the Order 773 excerpts included in the Background section[A] clearly indicate that Regional Entity is also expected to be responsible.

Confusion on the applicability and usability of the document also arises from the section heading “Reliability Subcommittee Process for BES Exception Requests” which suggests that the WECC Reliability Subcommittee (RS) has a role in the Process for BES Exception Requests. Yet, the process description (in the Process section) does not specify any role for WECC RS — instead, it directs the responsible entity to use the “BES Inclusion Exception Request in BESnet (the NERC BES exception request Web application).”

Lastly, entity awareness and availability of ‘guideline’ documents on the WECC website limits the effectiveness of any WECC guideline. Currently, guidelines are not listed in any central location (that can be easily found) so that entities can be aware of the collective expectations from the WECC RE.

RS Response

Applicability/Process

The WECC Document Categorization Policy, section 4. Applicability, states: “WECC Guidelines are applicable to WECC Members as identified in theGuideline.” In the BES Inclusion Guideline under “Process” it states: “This process applies to the following entities responsible [responsible entities] for identifying facilities that affect the reliability of the Western Interconnection: Planning Authorities, Reliability Coordinators, Transmission Operators, Transmission Planners, Balancing Authorities, and owners of system facilities.”

Per the BES Inclusion Guideline, the process requiresthat the responsible entities listed abovereview results to identify which of their non-BES facilities are necessary for the reliable operation of the Western Interconnection fromany offollowing:

1. System planning assessments,
2. Operational Planning Analysis,
3. Other study activitiesconducted in the Near-Term Transmission Planning Horizon.

Specifically, NERC Standards require the following studies be performed:

1. TPL-001-4 requirement R2 requires Planning Coordinators and Transmission Planners to conduct Planning Assessments annually,
2. TOP-002-3 requirement R1 requires each Transmission Operator to have an Operational Planning Analysis,and
3. IRO-008-1 requirement R1 requires each Reliability Coordinator to perform an Operational Planning Analysis to assess whether planned operation for the next day will exceed any Interconnection Reliability Operating Limit(IROL).

In addition, the WECC Guideline titled Project Coordination and Path Rating Process requires that project sponsors perform technical studies to establish ratings,including technical studies performed for the Near-Term Transmission Planning Horizon.

The process set forth in the BES Inclusion Guideline is that no matter which of the technical studies listed above is selected for use in the evaluation; the responsible entities are expected to compare the study results to the list of situations for consideration in the BES Inclusion Guideline to determine which non-BES facilities are necessary for the reliable operation of the Western Interconnection and to submit those facilities as an exception through BESnet.

WECC’s Responsibilities

The BES Inclusion Guideline contains the steps that WECC, as the RE, is taking to comply with Recommendation 17 and FERC Order 773. The BES Inclusion Guideline contains the screening guidance developed by WECC that the above responsible entities should apply to identify critical non-BES facilities in the course of performing planning assessments–from day-to-day operating experience, or assessment of system events–as described in paragraph 269.

In paragraph 269, FERC states: “the Commission believes that, if a study is needed outside the ordinary course of operations, it would be infrequent.” By proposing thePCC adoption of the BES Inclusion Guideline, WECC and the RS believe thatthe above responsible entities will take the actionsnecessary as part of their normal course of business to ensure that all critical non-BES facilities are being identified for inclusion as part of the BES. This is what is meant by the use of the term “actively identify.” In paragraph 269, FERC places the primary responsibility for identifying critical non-BES facilities on the responsible entities having knowledge of their systems.

Nothing in the BES Inclusion Guideline prevents WECC, as the RE, from applying the critical facility guidance contained in the guideline to studies it may conduct or when it reviews planning assessments. The NERC Rules of Procedure allows WECC to submit BES Inclusion Exception Requests. The screening guidance in the guideline could be applied as part of the justification for such a request. However, we agree with FERC that the primary responsibility for such Inclusion Exception Requests should remain with entities having knowledge of their systems.

Regarding the concern about the heading “Reliability Subcommittee Process for BES Exception Requests,”the heading is only intended to indicate that the Reliability Subcommittee’s role is to maintain the BES Inclusion Guideline and associated process. The BES Inclusion Guideline is intended to be a living document that will be modified from time to time.

Guideline Availability

All approved Guidelines are kept in the WECC library on the WECC website under Documentation Categorization Files/Guidelines available at Furthermore there are links to guidelinesonthe DocumentsWeb pagefor the subcommittee or work group that keeps and maintains themanuscript. If approved by PCC, the BES Inclusion Guideline would be posted in the WECC library with a link under documents on the Reliability Subcommittee website.

Xcel Comment

2. The document is mostly duplicative of the NERC guidance documents on this topic.

To date, NERC has published 11 documents related to the identification of and process management of the BES definition. It is unclear what additional process or considerations are detailed in this WECC Guideline document over and above the considerations already identified in the NERC BES Exception Request Evaluation Guideline. It is unclear to us why the objectives of this WECC Guideline are not satisfied by simply referencing the NERC Guideline at

Note - PSCo has not attempted to reconcile this document with the 11 NERC documents. Before voting in favor of this document, Xcel Energy will need some assurance that this document does not in any way conflict with or contradict the NERC documents related to the BES Inclusion/Exclusion/Exception processes.

RS Response

The WECC BES Inclusion Guideline supplements the NERC BES Exception Request Evaluation Guideline. The NERC BES Exception Request Evaluation Guideline contains a detailed list of considerations and identifying factors the Regional Entities and NERC will use to evaluate Exception Requests for inclusion and exclusion of elements. It does not include screening guidance to assist owners and reliability entities with deciding which non-BES elements may be critical and should be evaluated for inclusion as BES elements. More importantly,the WECC BES Inclusion Guideline provides screening guidance for eliminating non-BES elements from further consideration as BES elements. The situations identified and evaluationsconducted in the WECC BES Inclusion Guideline could be used as part of the justification for a BES Inclusion Exception Request. If adopted, the BES Inclusion Guideline provides entities with guidance for identifying which non-BES elements should and should not be evaluated further for inclusion as part of the BES.

[A] FERC indicated that a Regional Entity, Planning Authority, Reliability Coordinator, Transmission Operator, Transmission Planner, or Balancing Authority that has elements covered by an exception request within its scope of responsibility may submit an exception request for the inclusion of an element or elements owned by a registered entity.(Order No. 773 at P 27)
FERC has also stated that NERC should not necessarily stop at 100 kV and should, through the development of the exception process, ensure that critical facilities operated at less than 100 kV, and that Regional Entities determine are necessary for operating the interconnected network, are included. (Order No. 773 at P269)