Comment Report

Regional Reliability Standard / Request to Add Regional Variance

MOD-026-1, Verification of Models and Data for Generator Excitation Control System or Plant Volt/Var Control Functions

MOD-027-1, Verification of Models and Data for Turbine/Governor and Load Control or Active Power/Frequency Control Functions

The Western Electricity Coordinating Council (WECC) thanks all commenters who submitted comments on the proposed addition of a Regional Variance to the above listed two NERC Reliability Standards.

The proposed variances were posted for a 45-day public comment period from November 13 through December 28, 2015. There were 11 responses, including feedback from approximately 17 people from approximately 11 companies representing 5 of the 8 WECC Standards Voting Sectors as shown in the following pages. One comment was received out-of-time.

All comments submitted can be reviewed in their original format on the Regional Reliability Standards Under Development Page.

If you feel that your comment has been overlooked, please let us know immediately.Our goal is to give every comment serious consideration in this process.If you feel there has been an error or omission, you can contact the Director of Standards, Howard Gugel (via email) or at (404) 446-9693.

If you have questions regarding the WECC Reliability Standards Development Procedures, please contact W. Shannon Black, , or at (503) 307-5782.

Action Plan

In response to comments received, the drafting acknowledged a scrivener’s error whereby all five-year periodicity references did not completely migrate into the last version of the document posted for ballot, although that was the intent. To correct the error, the document was restructured importing the entirety of the Table Attachment 1 with changes made from the ten-year periodicity to the five-year as originally intended. As a result, the document will be reposted for comment at WECC.

On February 16, 2016, the WECC Standards Committee agreed to nullify the ballot results based on the scrivener’s document, instructed that corrections be made, and the project reposted for comment.

Minority Opinion

Below please find a snapshot of the minority opinion expressed:

  • Stakeholders believed the drafting team failed to provide adequate technical support for the more stringent approach to testing and validation.
  • Stakeholders believed the benefit of adding the small number of units to the model did not outweigh the burden to create that benefit.
  • Adequate maintenance, testing, and reporting procedures are already in place; the more stringent approach is not needed and could degrade reliability due to the additional testing.
  • The proposed variances represent only one of many possible methods to achieve the reliability goals.
  • Voting procedures showed be changed.
  • Some concluded that the industry at-large should comply with a continent-wide standard. If, indeed, the variance is needed, it would be better if applied on a continent-wide basis.
  • Some concluded the project carries an unnecessary burden because the costs are not rate-base supported.
  • Some concluded the project should not go forward because the premise of the variance is not based on a physical difference in the Interconnection.

With the exception of the request for a change in voting procedures and the alternative technical approach suggested by Talen, each of the above concerns were provided to the drafting team during the development process, considered at various stages, and addressed, albeit, not always to the satisfaction of the commenters.

As to the request for a change in voting procedures, the DT notes that stakeholders did not argue that any procedural error occurred under the existing WECC Reliability Standards Development Procedures. Although the issue is outside of the scope of this proceeding, the DT encourages stakeholders to engage in WECC-0117, Procedural Redraft wherein the issue can be addressed directly and contemporaneously.

As to Talen’s alternative approach, the DT considered the approach concluding that although it represented one viable means to achieve the reliability goal, it did not represent a superior approach; thus, no change was made.

Index to Questions, Comments, and Responses

  1. Do you agree the proposed standard/variance was developed in a fair and open process, using the associated Regional Reliability Standards Development Procedure?
  2. Does the proposed standard/variance pose an adverse impact to reliability or commerce in a neighboring region or interconnection?
  3. Does the proposed standard/variance pose a serious and substantial threat to public health, safety, welfare, or national security?
  4. Does the proposed standard/variance pose a serious and substantial burden on competitive markets within the interconnection that is not necessary for reliability?
  5. Does the proposed regional reliability standard/variance meet at least one of the following criteria?
  • The proposed standard/variance has more specific criteria for the same requirements covered in a continent-wide standard.
  • The proposed standard/variance has requirements that are not included in the corresponding continent-wide reliability standard.
  • The proposed regional difference is necessitated by a physical difference in the bulk power system.

Comment Report | MOD-026/027 Addition of Regional Variance 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 / Registered Ballot Body Segment
1 / 2 / 3 / 4 / 5 / 6 / 7 / 8
1. / Hamid Zakery / Calpine / X
2. / Don Lock / Talen Energy Corp. / X
3. / Shannon Mickens / SPP / X
4. / Connie Lowe / Dominion / X
5. / Erika Doot / United States Bureau of Reclamation / X / X
6. / Cain Braveheart / Bonneville Power Administration / X / X / X
7. / Patricia Robertson / BC Hydro / X / X / X / X
8. / Laura Nelson / Idaho Power Company / X / X
9. / Sandra Shaffer / PacifiCorp / X / X / X / X
10. / Jared Shakespeare / Peak Reliability / X
11. / Patrick Farrell / Southern California Edison / X / X / X / X / X
12. / Michelle Amarantos / Arizona Public Service / X / X / X / X / X
  1. Do you agree the proposed standard/variance was developed in a fair and open process, using the associated Regional Reliability Standards Development Procedure?

Summary Consideration: Of the nine respondents, all concurred that the project was developed in a fair and open process, using the associated Regional Reliability Standards Development Process. For more detail please refer to the Summary of Responses included in the preamble.

Organization / Yes or No / Question 1 Comment
SPP / Yes / We agree that the associated Regional Reliability Standards Development Process was used in the preparation of the proposed Variance for MOD-026 and MOD-027. However, we would like the review panel/drafting team to provide some clarity on some concerns that we have in reference to the proposed Variance(s). In reference to MOD-026-2, the Variance for E.A.1 is suggesting to replace the entire applicability section 4.2.2. Our review group has interpreted that E.A.1 is suggesting to include all generation in the Western Interconnection instead of using individual and aggregate units connected to the BES with the nameplate of 75 MVA or greater.
Additionally, we would suggest to the review team to add some clarity on sections E.A.3, E.A.4, and E.A.5 in reference to the Regional Standard Requirement R2 part R2.1.1. The E.A section of the Regional Variance suggests adding E.A.3 to Requirement R2 part R2.2.1.1. Through our current observation, the most recent version of the Regional Standard doesn’t contain a section labeled R2.2.1.1. However in the E.A.3 section, the drafting team references Requirement R2.1.1 pertaining to recorded response. Again in our observation and opinion, we would suggest to the drafting team to include sections E.A.4 and E.A.5 in the Requirement R2 part R2.1.1 instead of the proposed Requirement R2 part R2.1.1 for there is no Requirement label in the Regional Standard. Also, we would ask the drafting team to provide some clarity on the proposed revisions to Attachment 1 for MOD-026. We understand that there’s a suggested change in the replacement to Row 2 however, it is unclear to us if Rows 1 and 3 will be applicable in the Variance Standard or not. As for MOD-027-2, we have the same observation pertaining to E.A.1 in MOD-026 and would ask for the same clarity. Additionally, we would suggest to the review team to add some clarity on sections E.A.3, E.A.4, in reference to the Regional Standard Requirement R2 part R2.1.1. The E.A section of the Regional Variance suggests adding E.A.3 to Requirement R2 part R2.2.1.5. Through our current observation, the most recent version of the Regional Standard doesn’t contain a Requirement labeled R2.2.1.5. We’re making the assumption that the drafting team is referencing Requirement R2.1.1. Again in our observation and opinion, we would suggest to the drafting team to include sections E.A.3 and E.A.4 in the Requirement R2 part R2.1.1 instead of the proposed Requirement R2 part R2.1.1.5 for there is no Requirement label that way in the Regional Standard. Also, we would ask the drafting team to provide some clarity on the proposed revisions to Attachment 1 for MOD-027. We understand that there’s a suggested change in the replacement to Row 2 however, it is unclear to us if the other Rows will be applicable in the Variance Standard or not. Finally, we would suggest to the drafting team that whatever proposed changes are ultimately successfully balloted and approved by the WECC Board of Directors, NERC Board of Trustees and The Federal Energy Regulatory Commission, be carried over to the appropriate RSAW(s) for proper alignment of documentation and consistency.
The DT appreciates SPP’s insights. If the DT accurately interprets the narrative addressed by SPP, the section was only temporarily included as a roadmap. It will be deleted from the final project and more a more precise description will be added. Further, a renumbering has been applied to simplify the document.
SPP is correct in its interpretation of the Applicability. The variance will replace the existing Applicability section. The variance would apply to all “Generation in the Western Interconnection meeting the Bulk-Electric System definition.” Thus, it will include a larger spectrum of units than it previously did.
The DT appreciates SPPs observation regarding the Table. Corrections have been made making it clear that all referenced to ten years in the existing standard’s Table have been changed to five-years.
As to the RSAWS, creation of an RSAW is outside of the scope of the DT; however, the DT would encourage SPP and all entities to participate with their compliance enforcement entities to add additional clarity where needed.
United States Bureau of Reclamation / Yes
Calpine / Yes
Idaho Power Company / Yes
Southern California Edison / Yes
Bonneville Power Administration / Yes
Talen Energy Corp. / Yes
PacifiCorp / Yes
Peak Reliability / Yes
Dominion / No Response to the Yes/No question
Arizona Public Service / No Response to the Yes/No question / Comments received out of time.
  1. Does the proposed standard/variance pose an adverse impact to reliability or commerce in a neighboring region or interconnection?

Summary Consideration:

Of the nine respondents, one said yes agreeing that the project poses an adverse impact on reliability or commerce in a neighboring region or interconnection. Eight responded no, indicating that the project would not pose an adverse impact on reliability or commerce in a neighboring region or interconnection. For more detail please refer to the Summary of Responses included in the preamble.

Organization / Yes or No / Question 2 Comment
United States Bureau of Reclamation / No
Idaho Power Company / No
Southern California Edison / No
SPP / No
Bonneville Power Administration / No
Talen Energy Corp. / No
PacifiCorp / No
Peak Reliability / No
Calpine / Yes / Dynamic model parameters for digital control system do not typically change over time unless parameters are changed by equipment owner. There are only handful of analog controls are active. More frequent validation above and beyond implementation guideline provided in FERC approved continent-wide standards do not add to BES reliability and may cause unintentional unit issues including trips that can adversely impact BES reliability. Additionally, the necessary technical justifications to demonstrate that proposed variances will further improve BES reliability has not been communicated.
As to technical justification, please see the response to BC Hydro and APS in Question 5 that follows. Those responses annotate only one location in the five postings where technical justification was addressed.
The DT concurs with Calpine that the possibility of unforeseen circumstance always exists with each impact to the grid and its components. The DT has confidence that the professionals charged with operation and testing of the grid and its components will bring to bear those competencies when conducting the assigned tasks.
As to the value of additional information to be reaped from the variance, there is no question that the variance will add granularity of data and enhance industry understanding of the affected components. Whether the quality of that added granularity has any intrinsic value to any specific entity becomes an entity-specific judgment.
The DT respects Calpine’s judgment on the matter but respectfully disagrees in favor of greater granularity noting that NERC/FERC applauded the value of WECC’s modeling approach in its lessons learned on the September 8, 2011 outage.
“Unlike other NERC regions, WECC has more than 15 years of experience of successfully implementing generator validation procedures. The quality of the WECC dynamic database was highlighted in the FERC/NERC September 8, 2011 outage report [15] and a FERC LBNL report on frequency metrics [6]. “
Western Electricity Coordinating Council, Modeling and Validation Work Group Recommendations on WECC SAR-0101 and Power Plant Modeling Standards, May 30,2014 (AKA: Technical Paper 1) at page 4
Dominion / No Response to the Yes/No question
BC Hydro / No Response to the Yes/No question
Arizona Public Service / No Response to the Yes/No question / Comments received out of time.
  1. Does the proposed standard/variance pose a serious and substantial threat to public health, safety, welfare, or national security?

Summary Consideration:

Of the nine respondents, nine answered no, indicating the project did not pose a serious and substantial threat to public health, safety, welfare, or national security.For more detail please refer to the Summary of Responses included in the preamble.

Organization / Yes or No / Question 3 Comment
United States Bureau of Reclamation / No
Calpine / No
Idaho Power Company / No
Southern California Edison / No
SPP / No
Bonneville Power Administration / No
Talen Energy Corp. / No
PacifiCorp / No
Peak Reliability / No
Dominion / No Response to the Yes/No question
BC Hydro / No Response to the Yes/No question
Arizona Public Service / No Response to the Yes/No question / Comments received out of time.
  1. Does the proposed standard/variance pose a serious and substantial burden on competitive markets within the interconnection that is not necessary for reliability?

Summary Consideration:

Of the nine respondents, three answered yes, indicating the project poses a serious and substantial burden on competitive markets within the interconnection that is not necessary for reliability. Six answered no, indicating the project does not posea serious and substantial burden on competitive markets within the interconnection that is not necessary for reliability. For more detail please refer to the Summary of Responses included in the preamble.

Organization / Yes or No / Question 4 Comment
United States Bureau of Reclamation / No
Idaho Power Company / No
Southern California Edison / No
SPP / No
Bonneville Power Administration / No
Peak Reliability / No
Calpine / Yes / As previously indicated, more frequent governor and excitation system validation above and beyond FERC approved continent-wide MOD-026 and MOD-027 standards do not add to BES reliability. It will pose additional unnecessary burden on Independent Power Producers (IPPs) not regulated by rate base.
Thank you. Portions of the comment were addressed above.
As to the unnecessary burden not covered by rate base, the DT points out that it repeatedly reached out to the industry requesting specifics on the burden imposed in the event the variance was implemented. Because the magnitude of burden to a small entity may differ from the magnitude of burden to a large entity, the DT sought to publish burden-related information so that the industry could draw its own conclusion on the magnitude of the burden. Only one entity responded with an empirical response.
The following is an excerpt from the WECC-0101 FAQ Memo, May 2015, page 6:
“The drafting team recognizes that NERC/FERC will allow for consideration of costs when deciding on the requirements of a standard. Since neither NERC nor FERC has finalized a framework from which to discern “how much is too much” the drafting team repeatedly invited the industry to submit its cost estimates through the Procedures for presentation to the industry at-large. The drafting team opted to remain neutral on the cost issue and allow cost estimates to speak for itself. All cost estimates provided through the Procedures as part of the Comment/Response cycles can be found in the drafting team’s Response to Comment documents.”
A number of entities disagreed with Calpine noting that because the essence of the variances is already resident in the WECC Generator Validation Policy, many entities within WECC would experience no change in operations and thus would experience no new burden.
As to the value of applying the variance on a continent-wide basis, the DT agrees that a continent-wide application would benefit the continent; however, to do so is outside of the scope of this Standard Authorization Request. (Refer Western Electricity Coordinating Council, Modeling and Validation Work Group Recommendations on WECC SAR-0101 and Power Plant Modeling Standards, May 30,2014 (Technical Paper 1) at page 4)
PacifiCorp / Yes / PacifiCorp has the following concerns--- 1. Despite the fact that WECC has maintained the five-year interval for some time, and the region is complaint with the time interval, the value of more frequent has not been proven or justified. 2. The five year versus ten-year interval currently in place for WECC requires twice the resources to maintain and the value of more frequent testing has not been proven or justified. WECC lists a need for more accurate information in the models, however, the WECC regional need for more exact information has not been explained. 3. If there is a justifiable reason for more frequent testing, why doesn't the need apply to the entire continent. If WECC's reasoning is valid, this five-year time internal should apply to all regions. However, the data resulting from more frequent testing of an online, non-modified generator is negligible. Testing modified generators and new connections occur as soon as the generator is functional and models are updated. This is sufficient. WECC’s variance could lead to unnecessary modification of the NERC standard and increased testing frequency which does not improve the models.