WECC-0101 Posting 1 Generator Validation Conversion Response to Comments - 5-6-2014

Comment Report Form forWECC-0101

Consideration of Comments

Comment Report Form for WECC-0101

Variance to MOD-026-1

Verification of Models and data for generator Excitation Control System or Plant Volt/VAR Control Function

Variance to MOD-027-1

Verification of Models and Data for Turbine/Governor and Load Control or Active

Power/Frequency Control Functions

Posting 1

The WECC-0101 Variance Drafting Team (AKA: Generator Validation Conversion Drafting Team) (DT) thanks everyone who submitted comments on the proposed documents.

Overview

The project is generally targeted to add a Variance to the existing MOD-026-1 and MOD-027-1 to include the following:

Changing the Facilities section so that the Variance applies to generation in the Western Interconnection at the 10 MVA level for individual generators and at the 20 MVA level for aggregated units, as opposed to the 75 MVA level.
Replacing the Effective Dates so that analog units will be tested each five years with all other units being tested at ten years.Effective Date, Sections 5.3 and 5.4 would be deleted.This differs from the existing MOD in that it replaces multiple layers of staging with only two stages: five years for analog and 10 years for all other units.
Replacing Requirement R2.1.1 to include a Requirement that comparison of model responses to recorded responses using staged test data with specific characteristics would be used.
Replacing the existing list of features with a WECC-specific list of features currently used in the WECC but not included in the existing standards.
Add a new Requirement and associated Measure assigning WECC as the final authority on model selection when parties cannot agree.

Posting

This document was last posted for a45-day public comment period fromMarch 14, 2014 through April 28, 2014.

WECC distributed the notice for the posting onMarch 13, 2014.The Drafting Team asked stakeholders to provide feedback on the proposed document through a standardized electronic template.WECC received comments fromfive companies representingfive 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 formathere.

Changes in Response to Comment

After consideration of the comments, the drafting team made no changes to the document.The drafting team acknowledged that additional technical studies are needed in order to justify the change in the facilities applicability section.

Minority Comments Summary

A number of parties disagreed with the proposed change to the facilities applicability threshold noting that the proposed change is not supported by technical evidence.

Action Plan

This report will be forwarded to the WECC Standards Committee (WSC) with a request for posting.The WSC is scheduled to meet again May 20, 2014.

The DT will perform a gap analysis on the proposed Effective Dates to make sure that the proposed dates do not create any windows of decreased reliability.

The DT will conduct further technical analysis before making a final facilities-applicability threshold recommendation.

The proposed technical support will include determination of:

The percentage of generation that would be added to the model at the lower threshold compared to the NERC threshold;
The value-added for the lower threshold (which could include a very high level estimation of costs);
The specific level at which connectivity takes place;
What physical and operational differences actually warrant the lower threshold.

As the DT performs its technical justification it will also examine:

The number of analogue units covered;
An estimated drift incurred by these units;
The net effect of the cumulative drift. (Does drift over and under negate the net affect?).

Contacts and Appeals

If you feel your comment has been omitted or overlooked, please contact the Manager, WECC Standards Processes, W. Shannon Black, at addition, there is a WECC Reliability Standards Appeals Process.[1]

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 Sectors
1 / 2 / 3 / 4 / 5 / 6 / 7 / 8
1 / Edwin Tso / Metropolitan Water District of Southern California / X
2 / Alex Chua / Pacific Gas and Electric / X / X / X / X / X
3 / Janet Smith / Arizona Public Service Company / X / X / X / X / X
4 / David Lemmons / Xcel Energy / Public Service Company of Colorado / X / X / X / X / X
5 / Andrea Jessup / Bonneville Power Administration / X / X / X / X

Index to Questions, Comments, and Responses

Question

Do you agree with the changes to the applicability threshold?
Please explain your answer and specify the document(s) to which your answer applies.
Do you agree with the change in the effective dates?
Please explain your answerand specify the document(s) to which your answer applies.
Please feel free to comment on any other aspects of the proposed variances.The drafting team thanks you for your continued involvement in the standards development process.

- 1 -

Do you agree with the changes to the applicability threshold?

Summary Consideration: / Of the five respondents, four disagreed with the applicability threshold; one agreed.
Commenter / Yes / No / Comment
MWD of SC / X
PG&E / X
APS Co. / X
Xcel / X
BPA / X

Please explain your answer and specify the document(s) to which your answer applies.

Summary Consideration: / No changes were made to the document; however, the drafting team is in accord that additional technical studies must be completed to support a change in the facilities applicability threshold.
Commenter / Yes / No / Comment
MWD of SC / MWDSC appreciates the opportunity to participate in WECC’s survey on the WECC Variance to NERC MODs 026-1 and 027-1 Reliability Standards.
MWDSC disagrees with WECC’s regional variance on the applicable facility threshold for a generator owner in the Western Interconnection at: 1) Individual generating unit greater than 10MVA (gross nameplate rating); 2) Individual generating plant consisting of multiple generating units that are directly connected at a common BES bus with total generation greater than 20MVA (gross aggregate nameplate rating).
MWDSC recommends WECC to modify its applicable facility threshold to be consistent with NERC’s Compliance Registry Criteria for a Generator Owner to be enforceable.
Applicable facility threshold for NERC’s Compliance Registry Criteriafor a Generator Owneris as follows: 1) Individual generating unit > 20MVA (gross nameplate rating) and is directly connected to the Bulk Power System, or; 2) Generating plant/facility > 75 MVA (gross aggregate nameplate rating) or when the entity has responsibility for any facility consisting of one or more units that are connected to the Bulk Power System at a common bus with total generation above 75 MVA gross nameplate rating.
Adherence to the Established Applicability Threshold
The drafting team (DT) concurs with MWD and other respondents in that the published white paper lacks sufficient detail to technically justify the lower MVA threshold; however, the initial analysis shows that adhering to the NERC threshold could exclude as much as 50percent of the generation from the model resulting in less accuracy and granularity.Further, enhancing the threshold to match the WECC policy may add an incentive for entities to be more accurate in their reporting.
The DT has agreed to conduct further technical analysis before making a final facilities applicability threshold recommendation.
The proposed technical support will include determination of:

The percentage of generation that would be added to the model at the lower threshold compared to the NERC threshold;
The value-added for the lower threshold (which could include a very high level estimation of costs);
The specific level at which connectivity takes place;
What physical and operational differences actually warrant the lower threshold.

As the DT performs its technical justification it will also examine:

The number of analogue units covered;
An estimated drift incurred by these units;
The net effect of the cumulative drift. (Does drift over and under negate the net affect?)

Once the justification is complete, the DT will re-examine the proposed threshold.
PG&E / It is difficult to agree to the proposed applicability threshold without any supporting evidence. PG&E votes to keep applicable facilities consistent with the MOD-026.
Please see the above response provided above to MWD of SC.
APS Co. / AZPS supports the need for accurate generator model information and we value the work done by the MOD-026-1 and MOD-027-1 drafting teams.We believe significant attention was paid to developing the applicability limits as demonstrated by the variation across interconnections.AZPS does not believe there has been sufficient, if any, technical justification for the revised, more stringent applicability threshold.Creating a variance to a NERC Standard should require that a demonstrable need for the variance exists and is not simply reflective of continuing a current policy.
Please see the above response provided above to MWD of SC.
Xcel / Please refer to PSCO’s comment to the final question.
The drafting team appreciates your comment.Please see the team’s response below.
BPA / Both MOD-026-1 and MOD-027-1 with variance posting
The drafting team appreciates your comment.

Do you agree with the changes to Effective Dates?

Please explain your answer and specify the document(s) to which your answer applies.

Summary Consideration: / No changes were made to the document.
Of the five respondents, two agreed with the proposed Effective Dates and two did not.One did not comment.The DT agreed to do a gap analysis of the Effective Dates to ensure the proposed dates did not create a window of decreased reliability.
Commenter / Yes / No / Comment
MWD of SC / MWD of SC has no comment to the effective dates.
Thank you.
PG&E / No comment
Thank you.
APS Co. / AZPS supports the need for accurate generator model information.However, we believe there is very limited benefit to creating a variance to require analog units to be tested every five years.The population of analog units is small and decreasing as units are upgraded or retired.AZPS believes that it is not appropriate to pursue a variance unless a technical justification for the variance has been demonstrated.It should not simply be a continuation of an existing policy.
Analogue Testing each Five Years
The WECC database model contains a material number of analogue units.Unlike digital units, drift of these units tends to be more substantial between testing periods.The degree of drift is not precisely identified; however, knowing that drift is a concern, the more frequent testing will enhance accuracy.
As the DT performs its technical justification it will examine:

The number of analogue units covered
An estimated drift incurred by these units
The net effect of the cumulative drift. (Does drift over and under negate the net affect?)

Lack of Supporting Evidence
Please see the MWD comment above regarding further studies.
Xcel / As proposed, PSCo believes the effective dates would cause significant confusion.Additionally, the proposal could be argued to be less stringent than the continent-wide standard.
Please see below responses for Xcel below.
BPA / Both MOD-026-1 and MOD-027-1 with variance postings.
The drafting team thanks BPA for its continued participation in the standards development process.

Please feel free to comment on any other aspects of the proposed variances.The drafting team thanks you for your continued involvement in the standards development process.

Summary Consideration: / No changes were made to the document.
Commenter / Yes / No / Comment
MWD of SC / No comment.
Thank you.
PG&E / No comment.
Thank you.
APS Co. / No comment.
Thank you.
Xcel / Public Service Company of Colorado Comments on WECC-0101 Regional Variance to MOD-026 and MOD-027
Public Service Company of Colorado (PSCo) appreciates the opportunity to comment on the proposed regional variance to the recently approved NERC Standards MOD-026 and MOD-027. At this time, PSCo can not support the proposed regional variance. In PSCo’s view, the drafting team has not sufficiently supported the proposed variance. The NERC Drafting Team could have more appropriately addressed these issues during the standards development process, prior to the approval of the new standards.Full participation by the WECC membership in the NERC Standard Drafting process would minimize the number of WECC variances in future projects. Regional variances are used in cases where there is a clear difference in the attributes of the region. Based on the information provided at this time, PSCo does not see a need for the regional variance for two reasons: 1. the drafting team has not provided a clear statement of what difference they are trying to address, and; 2. the NERC Standard already has a different level of reporting requirement between the Eastern and Western Interconnections.PSCo therefore believes that any regional difference is already addressed by the NERC Standard.
Need for a WECC Variance
The approved versions of MOD-026 and MOD-027 already have a different level of reporting requirements for the Eastern and Western Interconnections. Therefore, WECC already has one variance or difference from other Interconnections. PSCo is concerned that the proposed variance would be located inconspicuously in the back of the approved Standard.This presents a lack of clarity about the additional variance and poses a potential risk to entities.Since this standard already separates the Eastern and Western Interconnection applicability, a second applicability level near the back of the document will increase the risk to entities significantly. While PSCo realizes that the drafting team did not cause this issue, the drafting team must address this issue if they desire to move forward with a proposal to change the size of unit for which this standard is applicable.
Next, while the drafting team has developed a white paper, it does not provide sufficient technical support for the drafting team’s position that the proposed reporting requirement is needed. In fact, the argument could be made that by attempting to include more units, the drafting team would actually decrease reliability through providing less margin for error in the determination of the needed resource response. Finally, the drafting team needs to support the desire for more information through looking at an event that is to be used for planning purposes. As written, it is unclear what event the drafters used as a basis for the white paper.
Unless additional justification is provided, PSCo asserts that the WECC should first implement the newly effective MOD-026 and MOD-027 as approved and later evaluate the need for improvements. In other words, take the “Ready, Aim, Fire” approach rather than the “Ready, Fire, Aim” approach currently being considered.
Align the Modeling Threshold with the BES Definition
The DT should align the Facilities threshold with that of the existing BES definition.To do otherwise seems contradictory to FERC’s stated intent in the BES Order.
Specifically, the proposed threshold is contrary to FERC’s stated intent to eliminate “subjectivity and regional variations that [were] possible under” the previous BES definition (BES Order).
If the proposed threshold is adopted it will have the effect of changing the BES definition for this specific “regional variation.”Further, in light of the multi-year process by which the existing BES definition was created, it is suggested that the industry has already opined on the matter, concluded that a lower threshold would not be acceptable, and the required consensus on the matter will not be forthcoming.
If the DT decides to pursue the lower threshold, the following questions should be considered:
Technical justification for a lower threshold must be forthcoming prior to a ballot on the Variance.
The proposed Variance applies to generation in the Western Interconnection at 10 MVA for individual generators and 20 MVA for aggregated units, as opposed to the NERC threshold of 20 MVA individual and 75 MVA aggregate.This means the Variance would apply to generators not currently listed on the NERC Compliance Registry (see NERC Statement of Compliance Registry, Version 5, pages 8-9).It also means that only the additional generators that are identified as “material to the reliability of the bulk power system” can be added to the registration criteria.
· What are the objective criteria for determining whether a generator is “material to the reliability” of the grid?
· What is the open and transparent process for making that determination?(An open and transparent process would be in order as violation of the proposed Variance could result in financial penalties imposed via the compliance process.)
· What group decides which additional generator is “material to the reliability” of the grid?
Before the industry can vote on approval of a Variance that includes a lower threshold, it must be informed of the material criteria; otherwise, it lacks notice that it may be subject to liability and compliance.To do otherwise might be considered a violation of due process.
The NERC/FERC approved process for adding facilities to the BES should not be circumvented by a regional Variance.
Although there is NERC procedural allowance for drafting a RRS that is more stringent than a NERC-wide standard, if the DT adopts its proposed changes to the Facilities section by lowering the threshold of included generation, the practical affect will be to rewrite the definition of the BES for purposes of this single RRS thereby including additional facilities.This approach essentially circumvents the NERC/FERC approved process for including facilities that would otherwise be excluded.
If additional Elements should be included for reliability purposes, Appendix 5C of the NERC Rules of Procedures, “Procedures for Requesting and Receiving an Exception from the Application of the NERC Definition of Bulk Electric System” (Exception Process), Effective July 1, 2014 would seem to be a better choice than circumventing that process via a one-size fits all Variance.
That process states that “an entity must request and obtain an Inclusion Exception pursuant to an Exception Request under this Exception Procedure before any Element that is excluded from the BES by application of the BES Definition shall be included in the BES” (1.1 Purpose; emphasis added).
· Since NERC already has a FERC-approved process to include additional facilities into the BES, it appears that the drafting team is attempting to include into this standard generators expressly excluded without first utilizing the approved process. Does the drafting team believe this is appropriate?
If the drafting team believes it is appropriate, the drafting team must first show that there is a reliability benefit. Reading through the drafting team’s white paper, it appears that the primary argument for this position is that because the WECC has seen improvements to their model in the past, we must have a standard requiring more data. However, the data being used for this justification, information from 1996 compared to more recent data does not appear to be relevant.
The drafting team is proposing to require re-testing of non-digital controls every five years based on the changes seen in the model when testing was emphasized. However, there is no support in the white paper that the drift seen in non-digital controls is significant. Rather the white paper emphasizes that testing has shown errors, primarily in the initial tests.Very little is mentioned related to any errors found in the subsequent testing.
Finally, the drafting team must show a cost/benefit analysis for the proposed variance from the NERC Standards. The drafting team should compare the costs to test the small units under the proposed variance to the perceived value of having the model more accurate. Without this evaluation, the WECC should not move forward any proposed variance.
Thank you for the opportunity to comment on this proposed standard. PSCo looks forward to working with the drafting team to address our concerns.
Lack of Evidence and Use of Relevant Models
Please see responses above.The DT will continue to examine the matter to determine whether sufficient technical support can be provided.
Already Addressed at NERC / There is an Existing Process
As mentioned above, the DT will continue its research into technical justification prior to making a final recommendation.
As to using the FERC-approved “Inclusion” process as opposed to an all-inclusive approach, the DT does not believe examination of any specific single unit could ever materially impact the reliability of the grid.As a result, use of the Inclusion process will not be the most effective means of ensuring reliability. Finally, as to what constitutes “material” impact, the WECC Reliability Subcommittee is currently drafting a white paper that is targeted toward making that determination.That paper is being vetted using the due process associated with the over-arching Planning Coordinating Committee (Standing Committee) and could be wed to this project moving forward.
Varying Applicability at Different Locations in the Document: Lack of Clarity
Xcel raises concerns that MODs-26/27 already have a specific WECC applicability threshold that would be compounded by adding another specific applicability level in the proposed variance.This could lead to confusion.Xcel suggests and the team agrees that if the project is approved, WECC will request that an explanatory statement be added to the Applicability section of the existing MOD-026/27 to clarify the multiple applicability references.Both Xcel and the DT agree that answering the request is in the sole purview of NERC.
Cost Benefit Analysis
The aforementioned technical analysis will attempt to illustrate the reliability side of the benefit analysis.The actual dollar cost analysis will be unit/entity-specific and conclusions on the “dollar” side of the analysis should be made by each specific entity.
BPA / No comment.
Thank you.