Comment Report Form for WECC-0119C

Posting2

The WECC-0119C PRC-006-WECC-CRT-2, Underfrequency Load Shedding (WECC PRC) 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 fromJuly 11 through August 11, 2016.

On July 8, 2016, WECC distributed notice of the postingvia the Standards Email List.

The DT asked stakeholders to provide feedback on the proposed document through a standardized electronic template. WECC received comments from four entities as shown in the following table.

Location of Comments

All comments received on the document can be viewed in their original format on the WECC-0119Cproject page under the “Submit and Review Comments – RA Removal PRC-006-WECC-CRT-2” accordion.

Changes in Response to Comment

The DT appreciates the participation of the each of the contributors. After review and consideration of each comment, the DT opted to make no further changes.

Minority View

The DT reviewed and considered all comments. The following suggestions were not adopted.

  • WR11 and WR 12 were not deleted because they are more specific than the parallel data requirements in PRC-024-2, Generator Frequency and Voltage Protective Relay Setting.
  • A request to create or modify a requirement to better define the generator’s “portion” of the Off-Nominal Frequency Load Shedding Plan (Plan) was declined as creation would create ambiguity regarding the “portion” and would be incapable of capturing all of the possible permutations included in the Plan.
  • A request to delete the attestation portion of WM5 was declined as the burden is minimal.
  • A request to assign duties to the Under Frequency Load Shedding Review Group (UFLSRG) was declined as the tasks assigned in WR1-WR4 as currently approved are resident in the UFLSRG Charter. Inclusion in both documents is redundant.
  • An indirect request to align inconsistencies between the Plan, PRC-006-2, Automatic Underfrequency Load Shedding, and the WECC Criterion was declined. Inconsistencies were noted; however, they presented no conflicts
  • A request to change the Purpose statement inverse to its currently approved verbiage was declined as outside of the scope of the project.
  • A request to change the applicability of Transmission Operatorrequirements to Planning Coordinator was declined as the WECC Criterion is based on the Plan. The Plan should be changed first.

Effective Date and Implementation Plan

The proposed effective date is immediately on approval by the WECC Board of Directors (Board).

Justification

The WECC PRC is currently in effect as are all the supporting documents. There should be on change in operations or business practices as a result of the proposed changes.

Action Plan

On August 18, 2016, the DT concluded by a majority vote that the project should be forwarded to the WECC Standards Committee (WSC) with a request for ballot. The next scheduled meeting of the WSC is in September 2016.

There are no further DT meetings contemplated for this project.

Contacts and Appeals

If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC Consultant, at . In addition, there is a WECC Reliability Standards Appeals Process that can be found in the Reliability Standards Development Procedures.

Commenter / Organization
1 / Leland McMillan / Talen
2 / Jeri Freimuth on behalf of Kristie Cocco / Arizona Public Service
3 / Desmond Chan,
Stephanie Imamovic / Seattle City Light
4 / Eleanor Ewry / Puget Sound

Index to Questions, Comments, and Responses

Question

1. The drafting team welcomes comments on all aspects of the document.

  1. Response Summary

Summary Consideration: / See summary in the preamble of this document.
Commenter / Comment / Response
Talen / Talen Montana, LLC (TALN) appreciates the work of the drafting team and this opportunity to comment. TALN suggests that the drafting team consider removing applicability to Generator Owners (GOs) from this criterion. Currently WR11 and WR12 apply to GOs as follows:
WR11.Each Generator Owner shall implement the Coordinated Plan. WM11. Each Generator Owner shall have and produce upon request, evidence that it implemented the Coordinated Plan. Evidence may include, but is not limited to production of reports or other documentation demonstrating that it has complied with WR11.
WR12.Each Generator Owner shall annually compile and submit to the Review Group, no later than June 1, their respective Coordinated Plan data and dynamics file for its generation, in the format defined in Attachment B of this criterion. WM12. Each Generator Owner shall have and provide upon request, evidence that it submitted its respective Coordinated Plan data and dynamics file for its generation, in the format defined in Attachment B of this criterion, to the Review Group, meeting the criteria set forth in WR12. Evidence may include, but is not limited to, production of reports or other documentation demonstrating that it has complied with WR12.
TALN believes that, similar to the recent retirement of WECC criterion PRC-024-WECC-CRT-0.1, the above requirements are addressed by PRC-024-2. Since these requirements are adequately address by a mandatory NERC standard, TALN suggests that WECC consider removing applicability to GOs for PRC-006-WECC-CRT-3, Underfrequency Load Shedding.
Leland McMillan • Manager, NERC Compliance
(406) 237-6917o •
Talen Montana, LLC • 303 N Broadway, STE 400
Billings, MT 59101
Retirement of WR11 and WR12
The DT opted to retain WR11.
PRC-006-WECC-CRT-2, WR11 and WR 12 are applicable to the Generator Owner, as identified in Section 4.1.3 of that document.
WR11 requires the Generator Owner to “implement the Coordinated Plan.” To implement the Coordinated Plan, “online generators that protect for off-nominal frequency operation should have relaying protection that accommodates” specified criteria contained in the Plan. Although in a different format, PRC-024-2, Attachment 1, appears to mirror the data specified in the Coordinated Plan (Section 12) giving credence to retirement of WR11 because of duplication.
However, Section 13 of the Plan requires that the Generator Owner have contractual relationships providing for automatic load shedding under specified circumstances. Sections 16 and 17 specify the types of equipment that should be used under specific circumstances. These specifications are lacking in PRC-024-2. There does not appear to be a one-to-one correlation between the two documents that would allow for deletion of the WR11.
The DT opted to retain WR12.
WR12 requires the Generator Owner to annually compile and submit its respective Coordinated Plan data and dynamics file for its generation – in a specific file format per the Excel reporting Form, and on a specific schedule.
Although the language is similar in PRC-024-2, there is no parallel language in PRC-024-2 specifying the file format. This specification appears to be an intricate part of the Plan as it states in Section G, Members and Data, that “Each…Generation Owner…must: 2)Annually compile data and dynamics files for their entire loads, in the format specified by WECC and in accordance with applicable Reliability Standards.” (Emphasis added.) Further, the WECC Criterion prescribes a specific due date whereas neither PRC-024-2 nor the Plan contain such a prescription. Although the language of PRC-024-2 and the Plan are similar in nature to WR12, they are not a duplication warranting retirement.
The DT notes that if the discrete elements of WR12 could be moved to the Plan itself, there would be need for WR12; retirement would be warranted. To do so is outside of the scope of this project.
APS / AZPS thanks the Drafting Team membersfor their work on this project.
AZPS recommends changing references from "Each UFLS Entity shall implement the Coordinated Plan" to something to indicate "its portion of the Coordinated Plan," or the like. Same for "Each Generator Owner shall implement the Coordinated Plan." Examples are WR3, WR7 and WR8.
AZPS also disagrees with the requirement in WM4 of an attestation for NOT designating an agent and recommends striking the last sentence of that measure.
Indicating “Its portion” of the Plan
No change was made.
The concern with adopting APS’ approach to create a new or limiting requirement is two-fold: 1) it leaves open for interpretation “what is the generator’s portion of the Coordinated Plan?”, and 2) it creates a new requirement that would be redundant to the Plan.
WR7 is linked to WR10 thereby creating a foundation of documentation describing what must be done, likewise WR8. WR7 has a direct link to the Plan at Section F, Sub-Sets. WR7 and WR8 are tied to Section G., Members and Data, that specifically requires that the applicable entitiesimplement/WR7 and coordinate/WR8 their actions regarding the Plan.
As APS points, there is no parallel requirement for the generator, only a requirement to “implement the Plan.”
If a more discrete requirement was drafted to limit the generator’s requirement to implement the entire Plan, the requirement, like WR7 and WR8, would need to sweep in each of the generator permutations contained in the Plan. For example, subsets of the requirement would include: 1) online generator settings, (E. Coordinated Plan Details, Section 12), 2) tripping requirements under variable circumstances (Section 13), data provision (Section 14), and specified equipment use (Sections 16 and 17) under specific circumstances. That would be the generator’s portion of implementing the Plan.
Further, the structure of such a proposed requirement would plant the seeds for ambiguity when trying to memorialize generator requirements that are: 1) merely “preferred”, (Section 12), 2) offer an either/or choice (Section 13), or are, 3) generator-specific depending on the range of response (Section 16 and 17).
The DT concluded the better choice was to leave the generator-specific requirements in the Plan where they are illuminated by adequate narrative rather than creating a new or limiting requirement.
Request to strike Attestation
No change was made.
There is no requirement is WM4 to attest to anything. Rather, attestation may be used if no agent is selected. Since this is a WECC Criterion – not a standard – there is no stated obligation of document retention or maintenance. The requested evidence would only be required for presentation in the event of a challenge to adherence. As such, a simple written statement produced on request represents a minimal burden of proof.
Seattle City Light / 1. The removal of WR1 -WR4 entirely toremove the Reliability Assurer (WECC) also remove the responsibility of the Review Group on reviewing the Coordinated Plan and conduct simulations of the coordinated planevery other year. The new WR2 does not clearly indicate the Review Group is responsible for conducting simulations of the Coordinated Plan to ensure the Coordinated Plan meets all the requirements of NERC Reliability Standard PRC-006 as stated in the Rationale.
2. Where will be the Coordinated Plan be located if it is removed from the Criterion attachment?
3. Thereareinconsistencies between the NERC PRC-006 standard and WECC Criterion for thePlanning Coordinator (PC) and Transmission Operator (TOP) functions. For example, the WECC Criterion does not mention PC at all.
Responsibility for Plan Review
No change was made.
As drafted, WR1 through WR4 tell WECC to tell the Under Frequency Load Shedding Review Group (UFLSRG) to: 1) (WR1) review the coordinated plan annually, 2) (WR3) conduct simulations, and, 3) (WR2 and WR4) verify the UFLSRG did their job.
Retirement of WR1 through WR4 neither eliminates oversight of the UFLSRG nor the responsibilities assigned to the UFLSRG. Rather, retirement eliminates the redundant charge for that oversight and the assigned responsibilities.
As to oversight, the UFLSRG “is a member review group established by the Joint Guidance Committee (JGC)”; as such, oversight falls to the JGC as opposed to WECC – the corporation. (See USFLRG Charter, Revised May 30, 2013)
As to responsibilities, the UFLSRG Charter, approved by the Joint Guidance Committee and maintained by the Group, states:
“Purpose/Responsibilities
The purpose of the UFLSRG is to annually review the WECC Off-Nominal Frequency Load Shedding Plan (Plan)…
The UFLSRG shall:
a. Annually review the Plan’s consistency with the requirements of PRC-006.
b. Conduct annual simulations of the Plan to assess consistency with the performance requirements of PRC-006.
c. Review the submitted UFLS data consistency and accuracy of modeling.
d. Collaborate with all applicable entities to develop an annual report of the findings of the review and simulations.”
Since the charge to perform the tasks is held in the group’s charter there is no need to replicate that charge in the WECC Criterion.
Location of the Coordinated Plan
The location of the Off Nominal Frequency Load Shedding Plan (AKA: Coordinated Plan) should not change. It never was actually “located” in the WECC Criterion. The WECC Criterion was one of many links to the location.
The document is currently located here; however, the location of the document falls to the Operating Committee and its staff liaison. As such, the link may change or expire over time. That propensity towards a dead link is why the specific link has been removed from the WECC Criterion. Additionally, the link was removed to avoid any question regarding incorporation by reference that could lead to requiring changes to the Plan only under the WECC Reliability Standards Development Procedures (Procedures).
Inconsistencies between NERC PRC-006-2, Automatic Underfrequency Load Shedding, the WECC Criterion, and the Plan
No change was made.
The DT is not concerned with the inconsistencies so long as those inconsistencies do not create a conflict. The DT did not find a conflict – only differences.
Seattle is correct; there is no reference to the Planning Coordinator in the WECC Criterion, and there is no reference to the Transmission Operator in PRC-006-2. The DT can only speak to WECC Criterion.
The Purpose of the WECC Criterion is:
“To document the WECC Off-Nominal Frequency Load Shedding Plan (Coordinated Plan), and to assure consistent and coordinated requirements for the Coordinated Plan among all WECC applicable entities.”
Because the Purpose is to address the Plan, and whereas the Plan does not reference Planning Coordinators, the WECC Criterion does not address Planning Coordinators.
As to the Transmission Operator, there is no mention of the Transmission Operator in PRC-006-2; however, the Transmission Operator is mentioned in the Plan. The Plan states in Section G., Members and Data, pages 12-13:
“Each…Transmission Operator…must:
1. Implement and coordinate its actions; and create, maintain, and submit documentation as necessary to carry out this Coordinated Plan.
2. Annually compile data and dynamics files for their entire loads, in the format specified by WECC and in accordance with applicable Reliability Standards.
3. Submit their compiled data and dynamics files upon request.
This requirement has been carried over into the WECC Criterion. Noting that Seattle requests no changes, none were made.
Puget Sound Energy / PSE appreciates the work being completed by the drafting team and this opportunity to comment on the criterion. In general PSE agrees with the comments submitted by Talen Montana and Seattle City Light
  1. Being a member of the Undervoltage Load Shedding Review Group (UFLSRG) and having assisted earlier this year with reviewing the GO data submitted through Attachment B, we do not feel that the WECC Criterion is the appropriate vehicle through which to request generator protective relay settings. While we understand that this information is critical to the simulation of the Coordinated Plan, we feel it would be more appropriate to encourage the TP and PC to request this data from their respective GOs through PRC-024-2 Requirement R4. This direct communication between the TP/PC and the GO may help foster a better understanding of the processes and procedures for populating the MDF and dynamic models and would provide a better avenue through which to request this data.
  2. The removal of WR1 -WR4 entirely toremove the Reliability Assurer (WECC) also removes the responsibility of the Review Group on reviewing the Coordinated Plan and conduct simulations of the coordinated planevery other year. The new WR2 does not clearly indicate the Review Group is responsible for conducting simulations of the Coordinated Plan to ensure the Coordinated Plan meets all the requirements of NERC Reliability Standard PRC-006 as stated in the Rationale. While it is recognized that this information is covered in the UFLSRG Charter, there is less transparency on how the UFLSRG is tasked with performing this work.
  3. What is the proposed location for the Coordinated Plan if it is removed from the Criterion? The Purpose statement of the document should be reworded to indicate that we are no longer documenting the Coordinated Plan in the Criterion.
  4. Thereareinconsistencies in the applicable functional entities between the NERC PRC-006 standard and the WECC Criterion. The Criterion makes no mention of the Planning Coordinator (PC) to which the NERC Standard is applicable. It is proposed that the requirements in the Criterion that are applicable to the Transmission Operator be assigned to the Planning Coordinator instead, to better align with the NERC Standard and provide participating entities with clear evidence that they are meeting the requirements of PRC-006 through participation in the UFLSRG.

Attachment B
See response to Talen located above.