WECC Planning Coordination Committee
Voting Record
BES Inclusion Guideline
July 16, 2014
I. Motion:
The Reliability Subcommittee (RS) requests that PCC approve the BES Inclusion Guideline.
Motion made by Brian Keel and duly seconded by Marv Landauer.
Explanation:
The BES Inclusion Guideline was presented to the WECC Planning Coordination Committee (PCC) during the July 15-16 meeting. The RS posted the BES Inclusion Guide for comment 30 days before the PCC meeting. During the October 2013 PCC meeting, the RS was directed to develop criteria or procedures where consideration is given for inclusion of non-BES elements as part of the BES. This is in response to Recommendation 17 of the Arizona-Southern California Outages on September 8, 2011. RS developed the BES Inclusion Guideline document which is intended to serve as a guideline to industry and WECC staff for making inclusion decisions. Below are the PCC ballot results:
Voting Class / Yes / No / AbstainTransmission Customers / 6 / 3 / 3
Transmission Providers / 18 / 1 / 3
State and Provincial / 0 / 0 / 1
Total / 24 / 4 / 7
Result: PASSED
Minority Opinion:
The following reasoning for negative votes were provided by John Martinsen with Snohomish County Public Utility District and Joseph Wilson with Tacoma Power.
John Martinsen with Snohomish County Public Utility District
Snohomish appreciates the opportunity to respond to our negative vote on the Bulk Electric System ("BES") Inclusion Guideline presented at the July 16, 2014 WECC PCC meeting. Snohomish shares many of the concerns presented by Tacoma Power in addition to the comments noted below.
Snohomish understands the need to develop a consistent criterion to benchmark exception requests and assess facilities that do not clearly fit the bright-line BES definition and applauds Vishal Patel and the WECC RS's work to initiate this effort. Through Snohomish involvement in the development of the BES definition, it became clear that a major goal in the applications of the new BES definition require transparency and consistency throughout the NERC region. The proposed WECC BES Inclusion Guideline provided the transparency but does not address consistent application throughout NERC. Recommendation 17 from the NERC and FERC staff report regarding the Arizona-Southern California Outages on September 8, 2011 complicated this effort, as the identification of non-BES facilities that are material to the reliability of the Western Interconnection would also be similar to those that impact the Texas Regional Entity and Eastern Interconnection.
Snohomish was actively involved in developing criteria and promoted holding a meeting at WECC’s Salt Lake City offices to receive WECC member and staff input as the proposal heavily reference the WECC TPL criteria. However there was little interest in providing comments or participating in this effort. This was an opportunity to develop and provide criteria that could be universally applied throughout the NERC regions to ensure the exceptions process was transparent and consistent. However there was little appetite to develop a technical guidance document to assess BES elements so the resulting exceptions guidance was very general and clearly does not provide definitive criteria for Ken Wilson and other WECC staff assessing exception requests the ability to make definitive determinations. Snohomish is sympathetic to this dilemma but believes this effort should be coordinated through NERC and the other regions to ensure consistent application of the approved BES definition.
Vishal Patel, noted in the presentation that the guideline was a living document and not a standard and it would be updated as more guidance and experience with the BES definition became available. This alleviated some of Snohomish’s concerns, but not all of them. Snohomish still was apprehensive in supporting the guideline because historically the use of guidelines, criteria, bulletins and other reference documents have often been used in WECC compliance activities to clarify and judge adherence with Reliability Standards and definitions. It is clear the BES Inclusion Guideline goes beyond the FERC approved BES definition and if applied would classify facilities as BES that would not be classified under the approved BES definition. Although not as big of a concern, it appears that a number of the inclusion guidelines are already addressed in the new BES definition.
As a Transmission Dependent Utility Snohomish is registered as a TO, TOP, and TP, but does not have an Open Access Transmission Tariff ("OATT") or provide transmission service. Snohomish supports Reliability Standards and benefits from a reliable system and strongly support WECC and NERC’s ability to accurately, consistently, and transparently assess BES exception. However, we believe this task must be addressed in coordination with NERC and the other regions so BES definition and exception requests are consistently applied throughout all NERC regions.
Joseph Wilson with Tacoma Power
Below is the response to your request for reasons behind a negative vote on the RS’s BES Inclusion Guideline on 7/16/14. First, I’d like to understand if my opportunity to make advance comments was disadvantaged by not receiving a notice of the guideline’s readiness for review and comment.
The reason for my negative vote is that the following guidance is both in conflict with the categorical BES definitional exclusions and the criteria do not provide clear reasons why a BES inclusion should be considered to ensure the reliability of the BES:
· Where a BES element’s single-contingency outage causes on any non-BES element:
1. A change in flow of more than 10 percent of the non-BES element’s continuous rating, and
2. A subsequent flow above 90 percent of the non-BES element’s continuous rating.
· Non-BES elements (e.g. generators, transformers, lines) where a single contingency outage of that element causes a change in flow on any BES element that is more than 10 percent of the BES element’s continuous rating.
An obvious candidate for ROP inclusion exception is the 92kV facilities that contributed to the SW Blackout of 2011. The above criteria don’t suggest cascading or likely tripping of BES components. The first bullet should overload at exceedance levels comparable to PRC-023 criteria. The 2nd bullet should be raised from 90 percent to “130 percent of the BES element’s continuous rating.”
Alternatively & preferably, the RS’s paper could have adopted inclusion criteria consistent with PRC-023-2’s Attachment B established criteria for evaluating sub-100kV components. The criteria that were chosen for the RS’s BES Inclusion Guideline are far more sensitive than is practical for ROP consideration of exceptions evaluation.
The following comment was provided by Xcel Energy before the PCC meeting.
Hari Singh: Xcel Energy Comments
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[1] 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.
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 http://www.nerc.com/pa/RAPA/BES%20DL/BES%20Exception%20Evaluation%20Guideline%202-4-14%20REMG%20App.pdf
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.
The following comment was provided by Metropolitan Water District after the PCC meeting.
Ann Finley: Metropolitan Water District of So. Cal.
I am sending MWD’s suggested changes we discussed in redline below to the “Process” section of the BES Inclusion document.
Process
This process applies to the following entities responsible for identifying facilities that affect the reliability of the Western Interconnection: Planning Authorities, Reliability Coordinators, Transmission Operators, Transmission Planners, and Balancing Authorities, and owners of system facilities. Consistent with FERC Order 773 and Recommendation 17, each of these responsible entities should review its system planning and operations reliability assessments and should otherwise actively share and identify with facility owners which of its non-BES facilities are necessary for the reliable operation of the Western Interconnection.
5
[1] 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.2
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.3
2 Order No. 773 at P 27.
3 Order No. 773 at P 269.