Comment Report Form for WECC-01011
Posting 4
The WECC-0101 Variance Drafting Team (DT) thanks everyone who submitted comments on the proposed documents.
Posting
This document was last posted for a 30-day public comment period from May 18 through June 17, 2015.
WECC distributed the notice for the posting onMay 15, 2015. The DT asked stakeholders to provide feedback on the proposed document through a standardized electronic template. WECC received comments from five companies representing five of the eight Industry Segments, as shown in the table on the following page.
Location of Comments
All comments received on the document can be viewed in their original format on the project page under the “Submit and Review Comments” accordion.
Changes in Response to Comment
After consideration of comments received, the DT opted to make no further changes to the project.
MOD-026-1
MOD-027-1
Action Plan
The DT will agreed by majority vote to forward the project to the WECC Standards Committee (WSC) with a request for ballot. The WSC is scheduled to meet in August 12, 2015.
Action Items – Technical Paper 2 (Paper) – Complete
No further action items are pending for this project as a result of any posting for comment.
Technical Study 2 produced by WECC staff at the request of and under the guidance of both stakeholders and the drafting team was delivered to the drafting team on June 23, 2015. The paper will be made available for industry review via posting on the Submit and Review Responses accordion assigned to the WECC-0101 DT along with the posting of these responses.
The parameters of the Paper were such that the staff preparing the Paper were not asked to opine on whether the proposed changes to the NERC Standards were “better or worse.” The parameters of the paper are empirical from which each reviewing entity can glean its own conclusions.
Each entity reviewing the Paper should couple that review with the data provided in the original technical paper provided with the initial filing of this project. Once that empirical review is completed, each entity will need to determine whether or not the enhanced value to the Western Interconnection is outweighed by the burden of the individual entity required to perform the underlying reliability-related tasks.
Cost Analysis
It should be noted that the DT repeatedly invited the industry to provide cost estimates to implement the proposed project. All cost estimates provided have been preserved in the Response to Comments of this project. The DT has not taken a position on whether the costs are excessive as that which is expensive is an entity-specific value.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact the Manager, WECC Standards Processes, W. Shannon Black, at . In addition, there is a WECC Reliability Standards Appeals Process.
The WECC Standards Voting Sectors are:
1 — Transmission Sector
2 — Generation Sector
3 — Marketers and Brokers Sector
4 — Distribution Sector
5 — System Coordination Sector
6 — End Use Representative Sector
7 — State and Provincial Representatives Sector
8 — Other Non-Registered WECC Members and Participating Stakeholders Sector
Commenter / Organization / WECC Standards Voting Sectors1 / 2 / 3 / 4 / 5 / 6 / 7 / 8
1 / Kristie Cocco / Arizona Public Service / X / X / X / X / X
2 / Jennifer Young / Pacificorp / X / X / X / X / X
3 / Sergio Banuelos / Tri-State Gen and Transmission / X / X / X / X / X
4 / Joshua Anderson / Salt River Project / X / X / X / X / X
5 / Ericka Doot[1] / United States Bureau of Reclamation / X / X
Index to Questions, Comments, and Responses
Question
- The Drafting Team welcomes comments on all aspects of the document. Please indicate which of the two documents your comments apply to. The drafting team asks that comments not be submitted on the Measures and Compliance sections as these will be addressed in a subsequent posting.
- The Drafting Team welcomes comments on all aspects of the document. Please indicate which of the two documents your comments apply to. The drafting team asks that comments not be submitted on the Measures and Compliance sections as these will be addressed in a subsequent posting.
Summary Consideration: / See summary in the preamble of this document.
Commenter / Yes / No / Comment
Arizona Public Service / AZPS does not believe that there is a need for the suggested variance, nor does AZPS believe the variance is technically justified. Creating a variance to an industry developed NERC Standard, which included significant WECC participation throughout its development, should require a demonstrable technical need for the variance and not requested simply due to the continuation of a legacy policy.
The DT appreciates APS’ position noting APS’s concerns that: 1) WECC’s representation during the drafting of the underlying standard should not be overridden, and 2) there is a need for greater technical studies to support the project. As to APS’s belief that there is not a need for the suggested variance, the DT notes APS’s comment was asked and answered in Posting 2 of the project. (See Posting 2, APS Response, Issue 1: “The need for a Variance”, page 9.)
1) Override of significant WECC participation
The DT notes that although WECC was well represented on the underlying development team (four team members), WECC was represented to a greater degree in the BES definition process. Unlike the underlying NERC Standards that set their thresholds based on a best-guess to include 80% of units within any given interconnection, the BES process was based on specific technical studies (adopted by the DT). Because WECC was better represented in the BES process, and because the BES process is based on technical studies (unlike the underlying NERC Standards), this DT chose to adopt the BES threshold as being more soundly based on technical studies and more broadlyrepresentative of the input from WECC stakeholders than was the underlying project.
As a secondary observation regarding support and participation, the DT also notes that adopting the BES threshold adopts a threshold less stringent than WECC’s existing Generator Unit Validation Policy (Policy), set at 20/75 MVA since 2006, vetted by the WECC Planning Coordinating Committee (PCC), and affirmatively balloted by the PCC’s estimated 200 subject matter experts. The DT encourages APS to review its response to APS in Posting 1, Issue 3 “Applicability Threshold – PCC approved” and Issue 4: “Retain the Applicability Threshold supported by the NERC Technical Studies”, pages 10-13.
2) Demonstrable Technical Need
The DT responded to this concern in depth in Posting 3 of this project, further vetting the issue in multiple DT calls and via open comment at the WECC Standards Committee. The DT would point APS to the Posting 3, Action Plan, pages 3-5. Specifically, the DT promised to provide a second technical paper (Technical Paper 2)(Paper)) for industry review prior to this project going to ballot.
WECC staff completed the requested Paper to estimate the sensitivity of the WECC Master Dynamics File and simulation results to model changes made in response to the five-year revalidation policy.
Staff was asked to make no value judgment as to the study’s outcome so that each reviewing entity could draw its own conclusion as to the value of the proposed project. Staff noted in its Summary, “The (modeled) system damping is very dependent upon the models subject to the (current Generating Unit Model Validation Policy)(Policy)), and clearly the frequency of validation impacts the study results. The system damping is very dependent upon the models subject to the Policy.” (Paper, Summary, Page 18.)
The summary also noted that, “model differences could result in different operating limits that effectively alter reliability margins and revenue potential or capital costs.” As such, the DT maintains its position that the additional information to be provided under the proposed variance brings substantive added value to WECC’s modeling systems and should be embodied in the proposed variance.
As previously noted, the DT understands that meeting the proposed reliability-related tasks of the proposed variance is an added burden that is an entity-specific burden. The DT encourages those reliant upon the Interconnection to weigh the reliability value-added against the imposition of burden under which WECC members have voluntarily been cooperating for over a decade.
The paper will be made available for industry review via posting on the Submit and Review Responses accordion assigned to the WECC-0101 DT along with the posting of these responses.
Pacificorp / PacifiCorp does not support a WECC regional variance that introduces obligations that are more onerous than the NERC MOD-026-1/MOD-027-1 requirements. PacifiCorp believes that the WECC region should adhere to the MOD-026-1/MOD-027-1 reliability standards as currently written and enforceable nationwide.
The DT appreciates PacifiCorp’s concerns regarding the additional entity-specific burden that could be imposed should the proposed variance be adopted by the industry. The DT would point Pacificorp to the above response provided to APS addressing “Demonstrable Technical Need”. The DT encourages Pacificorp to review the Technical Paper 2 data to determine whether the operational/planning benefit afforded to the Interconnection is outweighed by the burden already being incurred voluntarily by WECC stakeholders that adhere to the Generator Units Validation Policy.
Tri-State Generation / Implementation Plan:
The suggested implementation plans for the proposed variances do not properly align with the already approved MOD-026-1 and MOD-027-1 standards. Tri-State believes these timeframes should correlate and certainly the proposed end date (100% compliance) should not be any sooner than what is required by the NERC approved versions. Entities with large footprints and numerous generating facilities need ample time to plan for the necessary outages.
Currently MOD-026-1 and MOD-027-1 Implementation Plans state that for R2:
30% complete by 7/1/2018, 50% complete by 7/1/2020, and 100% complete by 7/1/2024
The proposed implementation plan for the variances is: (These should be modified to match the thresholds and dates above.)
30% complete by 7/1/2019, 50% complete by 7/1/2020, 75% complete by 7/1/2021, and 100% complete by 7/1/2022
10 year versus 5 year testing interval:
Tri-State has yet to see the promised technical justification that would explain/support the need for the proposed 5-year interval. We can agree that the data and work that has gone into building a robust model in the Western Interconnection over the previous ~15 years has established a solid foundation. However, we feel that the requirements and associated intervals (R2 & R4) in the NERC standards are adequate for future preservation and maintenance of that model. Proposing a regional variance based solely on the continuation of a legacy policy is not a valid reason. If the SDT were to present a technical study that demonstrated a tangible need for the WECC variances, then Tri-State would consider supporting the variances. However, we have yet to see that.
1) Implementation Plan
For clarity, the DT notes that its Implementation Plan is different from the Effective Dates. The Implementation Plan has been posted in the preamble of the document. The DT does not believe the implementation plan creates any undue burden and will not be making changes to the plan. The Implementation Plan is as follows:
“Implementation Plan
The DT has performed a gap analysis on the proposed Effective Dates and concluded that, if adopted, the Effective Dates should not impose any undue burden or surprise compared to the existing Effective Dates of the underlying standard.
Currently within WECC the Generating Units Modeling Validation Policy (Policy) already requires entities to model their units at a more stringent level than the requested Facilities threshold. Because the proposed variance largely reflects conditions that have been in effect within the Western Interconnection pursuant the Policy for roughly a decade, most if not all WECC entities will already be in compliance with the majority of the proposed variance.”
2) Effective Dates
No changes were made to the Effective Dates.
In Posting 2, the DT addressed Effective Date concerns noting: 1) the dates would apply equally to digital and analogue units, 2) there was an asymmetrical jump between the 50% and 100% compliance targets that needed remediation, and 3) that the procedural development of the proposed variance with its more stringent thresholds would consume a considerable amount of time, all the while the clock would be running on the NERC Standard Effect Dates. (See Posting 2 Response to Comments, APS, Issue 5: Effective Dates, page 13-14.)
Generally, the Effective Dates as proposed are an equitable balance between creating sufficient time to comply in years 0-5 and avoiding undue delay in years 6 and beyond. The DT concluded that matching the NERC timelines could early on place an entity in compliance jeopardy simply because the clock has already begun to run on the NERC standard; whereas, the variance is still in the developmental phase. The DT also concluded that the NERC timeline was overly generous and created an incentive to delay actions in years 6 and beyond. The tiered approach offered by the variance addresses both sides of these concerns. (This approach was also in support of and in response to comments received by Xcel in Posting 2 (Response to Comments, Posting 2, “Effective Date Concern”, page 27.)
Requirement R2, MOD-26/27-“1” / DT Response in Posting 2 to APS; and current proposal
30% by 7/1/2018 / 30% - The latter of 7/1/2019 or regulatory approval
50% by 7/1/2020 / 50% - The latter of 7/1/2020 or regulatory approval
75% - The latter of 7/1/2021 or regulatory approval
100% by 7/1/2024 / 100%- The latter of 7/1/2022 or regulatory approval
2) 10 year / 5 year Testing Interval
The DT appreciates Tri-States patience regarding the Paper. The DT also appreciates Tri-States’ affirmation that “the data and work that has gone into building a robust model in the Western Interconnection over the previous ~15 years has established a solid foundation.” Although the WECC staff members completing the Technical Paper 2 study were not asked to opine on whether the proposed variance was “better or worse”, the DT believes the Paper supports Tri-State’s positon and would refer Tri-State to the DT’s response above to APS, “2) Demonstrable Technical Need.”
After reviewing the Paper, the DT is more firmly convinced that the variance provides a greater reliability benefit to the Interconnection than the burden imposed on those in WECC that are not already in adherence with the Generator Unit Validation Policy. (See also: Response to Comment, APS, Posting 2, “Issue 1: The need for a Variance”, page 9”.
Salt River Project / Currently WECC allows for generator testing to be deferred. This is beneficial when there is a planned change to the excitation control system or plant volt/var control function that would alter the equipment response characteristics. If testing cannot be deferred, an entity may choose not to make the changes to the excitation control system or plant volt/var control function so they are not required to re-test that unit. SRP recommends that this standard allows for a single deferment for up to one year to allow for such changes to be completed.
1) Allow for a Single Deferment for up to One year
United States Bureau of Reclamation / The following comment from the US Bureau of Reclamation (Bureau) was received out-of-time at 12:25 PM, June 18, 2015, via email from Erika Doot of the Bureau.
“Reclamation suggests that the WECC regional variance allow for extensions to the 5-year WECC model validation window for circumstances including unforeseen equipment outages and planned equipment upgrades. Reclamation suggests that any extensions granted under the WECC regional variance should not be allowed to exceed the 10-year model validation timeframe in MOD-026 and MOD-027.”
1) Unforeseen Circumstances
Western Electricity Coordinating Council
[1] These comments were received “out-of-time” via email and addressed as a courteous by the DT.