Consideration of Comments on FRCC Regional Bulk Electric System Definition Clarification Project Version 1

Transcription

1 Consideration of Comments on FRCC Regional Bulk Electric System Definition Clarification Project Version 1 The FRCC Bulk Electric System (BES) Definition Clarification Task Force (TF) thanks all commenter s who submitted comments on the first draft of the FRCC Regional Bulk Electric System and Supporting Documentation. The regional definition and supporting documents were posted for a 15-day public comment period from December 7, 2009 through December 21, The stakeholders were asked to provide feedback on the regional definition and supporting documents through a special Electronic Comment Form. There were eleven (11) sets of comments from seventeen (17) entities representing five (5) of the six (6) Regional Sectors as shown below. Individual/ Group 1. Individual Dennis Minton Commenter Name Organization Florida Keys Electric Cooperative Association, Inc. 2. Individual Cairo Vanegas Fort Pierce Utilities Authority 3. Individual Silvia Parada Mitchell Florida Power & Light 4. Individual Barry Pagel 5. Individual Hassan Hamdar 6. Group Jim Howard Lakeland Electric Alan Shaffer Lakeland Electric Harry Suryo Lakeland Electric Phuong Tran Lakeland Electric Larry Watt Lakeland Electric 7. Individual Robert Grover Lee County Electric Cooperative 8. Individual Kelsi Oswald Pinellas County Resource Recovery Facility 9. Individual Paul Graves 10. Individual Anwar Saeed 11. Group Frank Gaffney Florida Municipal Power Agency Beaches Energy Services Kissimmee Utility Authority Keys Energy Services City of Vero Beach City of Lake Worth Utilities City of Bartow City of New Smyrna Beach City of Homestead Regional Sector Regional Sectors 1. Suppliers Sector 2. Non-Investor Ow ned Utility Wholesale Sector 3. Load Serving Entity Sector 4. Generating Load Serving Entity Sector 5. Investor Ow ned Utility Sector 6. General Sector

2 Consideration of Comments on FRCC Regional Bulk Electric System Definition Clarification Project Version 1 Based on the stakeholder comments, the FRCC Bulk Electric System (BES) Definition Task Force (BESDTF) made the following modifications to the following documents: FRCC Bulk Electric System Definition: Revised the description of transformers that are considered BES Elements/Facilities to differentiate between generator step-up (GSU) transformers and system transformers. Revised the exclusion statement which identifies generating plant facilities to provide additional clarity. Included reference to Appendix C: Adverse Reliability Impact Study Requirements. Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or System Exclusion: Provided clarification to the term unregistered generation. Added to the description of each example the requirement to assess whether the loss of the proposed excluded radial system results in an Adverse Reliability Impact. (Established consistency between all examples contained in the appendix.) Provided an additional example at the request of stakeholders. Appendix B: FRCC regional application of the term transmission Protection Systems : Revised the exclusion statement which identifies generating plant facilities to provide additional clarity. Minor editorial changes to improve clarity of the appendix. Based on the stakeholder comments, the FRCC Bulk Electric System (BES) Definition Task Force (BESDTF) drafted Appendix C: Adverse Reliability Impact Study Requirements. Based on the stakeholder comments, the FRCC Bulk Electric System (BES) Definition Task Force (BESDTF) revised the effective dates for the BES Definition and the associated appendices to allow for the practical application of the requirements. The latest status and information related to the FRCC Bulk Electric System Clarification Project can be found on the FRCC Website at the following URL address: 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 FRCC Manager of Reliability Standards, Peter Heidrich, at pheidrich@frcc.com. In addition, an Appeals Process is contained in the FRCC Regional Page 2 of 36

3 Consideration of Comments on FRCC Regional Bulk Electric System Definition Clarification Project Version 1 Reliability Standards Development Process and can be found on the FRCC Website at the following URL address: 0Development%20Process.pdf Page 3 of 36

4 Consideration of Comments on FRCC Regional Bulk Electric System Definition Clarification Project Version 1 Index to Questions, Comments, and Responses 1. The FRCC Bulk Electric System foundation document (definition) identifies what Elements are considered part of the FRCC Bulk Electric System within the FRCC footprint. Do you agree with the documented criteria? The FRCC Bulk Electric System foundation document (definition) identifies what Elements are NOT considered part of the FRCC Bulk Electric System within the FRCC footprint. Do you agree with the documented criteria? Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion defines a radial Element / System. The task force developed the concept of a radial System in addition to individual radial Elements. Do you agree with exclusion of radial Systems that do not cause an Adverse Reliability Impact? Do you agree that a radial Element / System is determined by how the Element / System is normally operated and that using a normally open switch to perform makebefore-break switching does not negate a radial exclusion? The TF identified one transmission source as a contiguous bus configuration (e.g. ring bus, breaker-and-a-half scheme, etc.) designated as a BES Element, operated at one voltage level 100kV or higher. Do you agree with the TF s interpretation? Do you agree with the concept of Adverse Reliability Impact (as defined in the NERC Glossary of Terms) as a determining factor when considering the exclusion of specific radial transmission Elements / Systems? Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion states Studies are necessary to determine if an Adverse Reliability Impact can result from the loss of a radial Element / System if the peak load or generation resources within the radial Element / System exceed one-half of the largest single loss of source contingency in the FRCC region. Studies will be performed by the responsible entity and approved by the FRCC Planning Committee. Do you agree with the criterion that prompts a study to be conducted?..20 Page 4 of 36

5 Consideration of Comments on FRCC Regional Bulk Electric System Definition Clarification Project Version 1 8. Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion provides five (5) examples which identify excluded radial transmission Elements / Systems. Do you agree with the conclusions of the examples and the established boundaries between BES and non-bes electrical equipment? Appendix B: Clarification to the FRCC Bulk Electric System (BES) Definition of transmission Protection Systems as Used in the PRC Standards for FRCC defines transmission Protection Systems as used in the PRC-series Reliability Standards for FRCC. Do you agree that the Protection Systems included in the definition of transmission Protection Systems are those Protection Systems that trip BES Elements (as established in the FRCC BES Definition)? Appendix B: Clarification to the FRCC Bulk Electric System (BES) Definition of transmission Protection Systems as Used in the PRC Standards for FRCC provides four (4) examples which categorize transmission Protection Systems vs. nontransmission Protection Systems. Do you agree with the conclusions of the examples and the designation of the identified Protection Systems? The FRCC Bulk Electric System foundation document (definition) establishes an Effective Date of the 1 st day of the 3 rd calendar quarter following FRCC Board of Directors approval. Do you agree with the proposed Effective Date? Please provide any other comments that the TF should consider Page 5 of 36

6 1. The FRCC Bulk Electric System foundation document (definition) identifies what Elements are considered part of the FRCC Bulk Electric System within the FRCC footprint. Do you agree with the documented criteria? Summary Consideration: Commenter Yes No Question 1 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Hassan Hamdar Jim Howard Lakeland Electric Robert Grover Lee County Electric Cooperative Paul Graves Anwar Saeed Frank Gaffney Florida Municipal Power Agency Clarification on what is included in the scope of the "Bulk Electric System" and within the scope of "transmission Protection System" is greatly needed and we appreciate the efforts. Response: The FRCC Bulk Electric System (BES) Definition Task Force (BESDTF) acknowledges your affirmative response and thanks you for your support. Silvia Parada Mitchell FPL believes the FRCC should continue to follow the NERC definition Page 6 of 36

7 Florida Power & Light and does not need to be more prescriptive in its regional definition. Response: The FRCC BESDTF believes that we are following the NERC definition of Bulk Electric System while providing additional clarity to aid the application of the definition by the functional entities within the FRCC Region. The majority of the functional entities within the FRCC Region support the additional clarification the FRCC BES definition provides. Barry Pagel Add: 4. All transformers regardless of voltage of the primary or secondary windings with Protections Systems that will trip one or more of the Transmission Elements listed above as a part of the primary protection of the transformer. 5. All transmission Protection Systems utilized in protecting the above listed Transmission Elements. Response: The FRCC BESDTF decided to make a distinction between the definition of BES and transmission Protection Systems and we do not believe NERC s intention was to make the two definitions coincide. For example, PRC and PRC have applicability to Distribution Provider that owns a transmission Protection System ; it is presumed that the Distribution Provider in this example does not own any BES Facilities. Therefore, the BESDTF chose to define BES separately from transmission Protection System and the examples provided would be covered in the definition of transmission Protection System and hence have applicability to the Distribution Provider that owns a transmission Protection System, but, the BESDTF does not believe these examples are part of the BES. Additionally, this remains consistent with Reliability First Corporation (RFC) BES definition which has been accepted by FERC, and states the inclusion of transformers (other than generator step-up) with both primary and secondary windings of 100 kv or higher. Please refer to Appendix B. Protective relays which trip BES Elements are considered transmission Protection Systems for purposes of applicability to the NERC Reliability Standards. Kelsi Oswald Pinellas County Resource Recovery Facility I do not believe that individual Electrical generation resources greater than 20 MVA should be included as part of the BES. The potential for a resource of this size to impact the BES is minimal, and the level of work required to monitor a resource of this size (for both the generator and for FRCC) is not commensurate with any benefit to be gained. Including generation plants with aggregate capacity greater than 75 MVA will adequately capture resources with the potential to impact the BES. Page 7 of 36

8 Response: The FRCC BESDTF relied on NERC s Statement of Compliance Registry Criteria for determining the size of a generator / plant that would be included in the definition of BES. The Statement of Compliance Registry Criteria, on page 8, states: III.c.1 Individual generating unit > 20 MVA (gross nameplate rating) and is directly connected to the bulk power system, or; III.c.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 Page 8 of 36

9 2. The FRCC Bulk Electric System foundation document (definition) identifies what Elements are NOT considered part of the FRCC Bulk Electric System within the FRCC footprint. Do you agree with the documented criteria? Summary Consideration: Commenter Yes No Question 2 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Silvia Parada Mitchell Florida Power & Light Hassan Hamdar Robert Grover Lee County Electric Cooperative Paul Graves Anwar Saeed Frank Gaffney Florida Municipal Power Agency Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Barry Pagel First Bullet should include: Page 9 of 36

10 A. The owner of a radial Transmission Element asserting there is no Adverse Reliability Impact for loss of this Transmission Element will be responsible for demonstrating such to the satisfaction of the Regional Entity when requested by the Regional Entity. Third Bullet Add: B., unless the Protection System for such Elements includes, as a part of the primary protection scheme for such Element, the tripping of any of the Elements listed in the above definition section. Response: A) Appendix C: Adverse Reliability Impact Study Requirements was developed to address these concerns. B) Please refer to Appendix B. Protective relays which trip BES Elements are considered transmission Protection Systems for purposes of applicability to the NERC Reliability Standards. Jim Howard Lakeland Electric What does the word balance below from the BES definitions mean? The FRCC Bulk Electric System excludes: Any radial Transmission Element or System connected from one transmission source to load serving Elements and/or generation resources not included in 1. above, where a loss of the radial Elements or System will not result in an Adverse Reliability Impact. Balance of generating plant control and operation functions which include relays and systems that automatically trip a unit for boiler, turbine, environmental, and/or other plant restrictions. Response: The BES Definition has been revised to improve clarity by modifying the statement concerning Balance of generating plant in Version 2 of the FRCC BES Definition to read as follows: Generating plant control and operation functions which include relays and systems that control and protect the unit for boiler, turbine, environmental, and/or other plant restrictions. Page 10 of 36

11 Kelsi Oswald Pinellas County Resource Recovery Facility This criterion should include language similar to that proposed for exclusion of radial Systems to exclude generation resources where loss of the generation resource does not cause an Adverse Reliability Impact. Response: The FRCC BESDTF relied on NERC s Statement of Compliance Registry Criteria for determining the size of a generator / plant that would be included in the definition of BES. The Statement of Compliance Registry Criteria, on page 8, states: III.c.1 Individual generating unit > 20 MVA (gross nameplate rating) and is directly connected to the bulk power system, or; III.c.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 Page 11 of 36

12 3. Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion defines a radial Element / System. The task force developed the concept of a radial System in addition to individual radial Elements. Do you agree with exclusion of radial Systems that do not cause an Adverse Reliability Impact? Summary Consideration: Commenter Yes No Question 3 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Silvia Parada Mitchell Florida Power & Light Hassan Hamdar Jim Howard Lakeland Electric Robert Grover Lee County Electric Cooperative Kelsi Oswald Pinellas County Resource Recovery Facility Paul Graves Frank Gaffney Florida Municipal Power Agency We believe that focusing on what is truly the integrated network of the BES by excluding radial systems will improve reliability by focusing scarce resources on what is most important to reliability. Page 12 of 36

13 Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Anwar Saeed A definition for Registered Generation will help to clarify the meaning of Unregistered Generation i.e. a generating unit less than 20 MW etc. Response: The FRCC BESDTF relied on NERC s Statement of Compliance Registry Criteria for determining the size of a generator / plant that would be included in the definition of BES. The Statement of Compliance Registry Criteria, on page 8, states: III.c.1 Individual generating unit > 20 MVA (gross nameplate rating) and is directly connected to the bulk power system, or; III.c.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 The FRCC BESDTF clarified the intent of unregistered generation as utilized in Appendix A Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion. Barry Pagel Clarification should include the statement that: The owner of a radial Transmission Element asserting there is no Adverse Reliability Impact for loss of this radial Element will be responsible for demonstrating such to the satisfaction of the Regional Entity when requested by the Regional Entity. Response: Appendix C: Adverse Reliability Impact Study Requirements was developed to address these concerns. Page 13 of 36

14 4. Do you agree that a radial Element / System is determined by how the Element / System is normally operated and that using a normally open switch to perform make-before-break switching does not negate a radial exclusion? Summary Consideration: Commenter Yes No Question 4 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Silvia Parada Mitchell Florida Power & Light Hassan Hamdar Jim Howard Lakeland Electric Robert Grover Lee County Electric Cooperative Kelsi Oswald Pinellas County Resource Recovery Facility Paul Graves Anwar Saeed Frank Gaffney Florida Municipal Power Agency Page 14 of 36

15 Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Barry Pagel Alternative configurations, such as make-before-break should be included in the BES where this action will include the normally radial element as a part of the flow between Transmission Elements as listed in the BES inclusion section. Response: The FRCC BESDTF did consider how an Element/System is normally operated in determining whether the Element/System meets the radial exclusion criteria. The FRCC BESDTF does not believe the inclusion of makebefore-break switching on a radial Element/System changes the determination that it is radial, and therefore not part of the BES. This opinion is consistent with Reliability First Corporation (RFC) BES definition which has been accepted by FERC. RFC s definition uses the concept of normal system configuration in determining which protective relays or control devices are included in the BES. Western Electricity (WECC) currently has proposal 3 of their BES definition posted for comment. In their proposed BES definition WECC addresses the exclusion of Radial Elements that have the capability to connect to the BES at more than one location in the following statement: 2. a. i. Operated normally open. Transmission Elements that are normally operated as radial elements but can be connected to the BES at more than one location through normally open switches are not deemed part of the BES provided that any switch used to parallel the Element is shown in operating diagrams or operating procedures as normally open and is closed only to transfer load. Additionally, Gerry Adamski, Vice-President and Director Standards at NERC on 8/13/2009 provided the following response to an informal interpretation request regarding the application of radial in the context of load served by multiple transmission lines: Radial refers to how the system is normally operated. For reliability, a system has been equipped with normally open tie switches. When circumstances dictate, load (only) can be transferred by closing a normally open switch, which briefly creates a loop feed which is then immediately broken by opening another switch. Such a system at 100 kv or above is not part of the BES. Page 15 of 36

16 5. The TF identified one transmission source as a contiguous bus configuration (e.g. ring bus, breakerand-a-half scheme, etc.) designated as a BES Element, operated at one voltage level 100kV or higher. Do you agree with the TF s interpretation? Summary Consideration: Commenter Yes No Question 5 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Hassan Hamdar Jim Howard Lakeland Electric Kelsi Oswald Pinellas County Resource Recovery Facility Paul Graves Anwar Saeed Frank Gaffney Florida Municipal Power Agency Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Silvia Parada Mitchell Florida Power & Light FPL believes the FRCC should continue to follow the NERC definition and does not need to be more prescriptive in its regional definition Page 16 of 36

17 Response: The FRCC BESDTF believes that we are following the NERC definition of Bulk Electric System while providing additional clarity to aid the application of the definition by the functional entities within the FRCC Region. The majority of the functional entities within the FRCC Region support the additional clarification the FRCC BES definition provides. Barry Pagel The one transmission source should not include a configuration that would allow loop flow during normal maintenance of an Element (e.g. breaker, bypass switch). The one transmission source should not include a configuration with another BES line on both sides (e.g. ring bus with another BES line between the parallel feeds to a load) of the multiple feeds to the load. Response: The FRCC BESDTF contends that the contiguous bus configuration is considered a single Bulk Electric System Element ( one transmission source ). This one transmission source acts as one node that may connect to more than one BES line and/or non-bes load elements. The removal of an element tied to a ring bus or breaker-and-a-half scheme may alter flow through the bus, but will not alter flow on BES Facilities, For example, in Example 3 from Appendix A, if Breaker D is opened, the flow around the ring bus of Breakers A, B, C and D will change, however, the flow on lines 1, 2, 3 and 4 remain unchanged. In consideration of this result of no change in BES flows on Facilities, the BESDTF believes that the ring bus acts as a single transmission source. Robert Grover Lee County Electric Cooperative LCEC requests further clarification to the term of one transmission source. Please see suggested wording below. o One transmission source is a contiguous bus configuration (e.g. ring bus, breaker-and-a-half scheme, etc.) designated as a BES Element, operated at one voltage level 100kV or higher (e.g. the high voltage side of a bulk electric substation, or a switching station, that has radial feed to a non-bes receiving substation). Response: See response to Question No.8 (Diagram). With the inclusion of the new Example Four into Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion the FRCC BESDTF believes that your concern has been addressed and that the recommended clarification to the definition of One transmission source is unnecessary. Page 17 of 36

18 6. Do you agree with the concept of Adverse Reliability Impact (as defined in the NERC Glossary of Terms) as a determining factor when considering the exclusion of specific radial transmission Elements / Systems? Summary Consideration: Commenter Yes No Question 6 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Silvia Parada Mitchell Florida Power & Light Hassan Hamdar Jim Howard Lakeland Electric Robert Grover Lee County Electric Cooperative Kelsi Oswald Pinellas County Resource Recovery Facility Paul Graves Anwar Saeed Frank Gaffney Florida Municipal Power Agency Page 18 of 36

19 Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Barry Pagel As mentioned above, the following concept must be added to clarify the use of Adverse Reliability Impact in this proposed BES definition. The owner of a radial Transmission Element asserting there is no Adverse Reliability Impact for loss of this radial Element will be responsible for demonstrating such to the satisfaction of the Regional Entity when requested by the Regional Entity. Response: Appendix C: Adverse Reliability Impact Study Requirements was developed to address these concerns. Page 19 of 36

20 7. Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion states Studies are necessary to determine if an Adverse Reliability Impact can result from the loss of a radial Element / System if the peak load or generation resources within the radial Element / System exceed one-half of the largest single loss of source contingency in the FRCC region. Studies will be performed by the responsible entity and approved by the FRCC Planning Committee. Do you agree with the criterion that prompts a study to be conducted? Summary Consideration: Commenter Yes No Question 7 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Hassan Hamdar Anwar Saeed Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Paul Graves This is vague in that the study and approval process are not defined. The standard may need to point to another FRCC document that spells out these processes. Response: The FRCC BESDTF agrees that the details involving the Adverse Reliability Impact studies and subsequent approval process require clarification and has developed Appendix C: Adverse Reliability Impact Study Requirements to address these concerns. Cairo Vanegas Fort Pierce Utilities Authority I believe some of the small radial systems are clearly below the threshold of impact and requiring a study would be unnecessary use of resources. It would make sense to set a low limit (e.g. 200MVA) below Page 20 of 36

21 which a system can be considered to have no Adverse Reliability Impact without the requirement for a study. Response: The FRCC BESDTF included a metric below which studies to determine the potential for an Adverse Reliability Impact would not be necessary as 50% of the largest loss of source contingency in Florida, which at this time is greater than 50% of 930 MW, or greater than 465 MW. Silvia Parada Mitchell Florida Power & Light FPL believes the FRCC should continue to follow the NERC definition and does not need to be more prescriptive in its regional definition. Response: The FRCC BESDTF believes that we are following the NERC definition of Bulk Electric System while providing additional clarity to aid the application of the definition by the functional entities within the FRCC Region. The majority of the functional entities within the FRCC Region support the additional clarification the FRCC BES definition provides. Barry Pagel Greater discretion (both cause and requester) should be allowed for the requesting of a study to demonstrate there is no Adverse Reliability Impact. Response: Appendix C: Adverse Reliability Impact Study Requirements was developed to address these concerns. Jim Howard Lakeland Electric Please explain why this would not be defined as the largest single loss of source as that is the criteria the region uses for loss of source (i.e. 920 MW)? The study assumptions/criteria that determine BES/non-BES status may need to be refined. As an example what is the periodicity of the studies that are used to support BES/non-BES status? Another example: an operational study, with its many facility outages captured in the model, may indicate a possible adverse effect with the loss of a non- BES element while a Planning study may not indicate a burden on the system with the loss of the same element. Suggest developing a schedule and criteria for Adverse Reliability Impact studies that are used to determine BES status. Response: The FRCC BESDTF agrees that the details involving the Adverse Reliability Impact studies and subsequent approval process require clarification and has developed Appendix C: Adverse Reliability Impact Study Requirements to address these concerns. Page 21 of 36

22 Robert Grover Lee County Electric Cooperative Although LCEC agrees with the definition of a load level at which ARI studies must be run, 50% of the single largest loss of generation appears to unnecessarily conservative. LCEC suggests 70%. Response: The FRCC BESDTF agrees that the details involving the Adverse Reliability Impact studies and subsequent approval process require clarification and has developed Appendix C: Adverse Reliability Impact Study Requirements to address these concerns. For an initial conservative threshold, 50% was selected. Kelsi Oswald Pinellas County Resource Recovery Facility I agree with the criterion to prompt a study, but I think that the BA and/or TA need to be included in the process, rather than just the responsible entity and FRCC Planning Committee. Response: The FRCC BESDTF agrees that the details involving the Adverse Reliability Impact studies and subsequent approval process require clarification and has developed Appendix C: Adverse Reliability Impact Study Requirements to address these concerns. Frank Gaffney Florida Municipal Power Agency The system is operated such that the largest single loss of source (e.g., a large nuclear unit) will not even come close to causing an "Adverse Reliability Impact", otherwise we would be hard pressed to justify running any large nuclear unit at full output. Therefore, we believe that no studies should be necessary unless the loss of the radial system could cause a supply / demand mismatch of greater than loss of the single largest loss of source. Response: The FRCC BESDTF agrees that the details involving the Adverse Reliability Impact studies and subsequent approval process require clarification and has developed Appendix C: Adverse Reliability Impact Study Requirements to address these concerns. For an initial conservative threshold, 50% was selected. Page 22 of 36

23 8. Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion provides five (5) examples which identify excluded radial transmission Elements / Systems. Do you agree with the conclusions of the examples and the established boundaries between BES and non-bes electrical equipment? Summary Consideration: Commenter Yes No Question 8 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Hassan Hamdar I found the examples to be very helpful in drawing a clear line between BES and non-bes equipment. Paul Graves Anwar Saeed Frank Gaffney Florida Municipal Power Agency Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Jim Howard Lakeland Electric The example radial/system exemptions on pages 1, 2, and 4 of Appendix A indicate the need for Adverse Reliability Impact study while examples on pages 3, 5 and 6 do not. Suggest making it explicit in all examples. Page 23 of 36

24 Response: The FRCC BESDTF acknowledges your affirmative response and agrees that the requirement which identifies the need for Adverse Reliability Impact studies should be applied to the examples on pages 2, 4 and 5 (Note: Due the revisions made to the examples in Appendix A the numbering of the examples has been altered in the revised document). The FRCC BESDTF has made the applicable revisions to Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion. Silvia Parada Mitchell Florida Power & Light We feel that examples 3 and 5 need further clarification. Response: The FRCC BESDTF has modified examples 3 and 6 (previously 5). If further clarification is necessary, please provide specific detail identifying your concerns. Barry Pagel See comments for item 10 below. Response: Please refer to the FRCC BESDTF s response to your comments submitted under Question No. 10. Page 24 of 36

25 Robert Grover Lee County Electric Cooperative LCEC agrees with the existing examples but requests an additional example be placed in the Appendix A to show that transformation from above 100kV to above 100kV does not cancel out otherwise radial nature of non-bes system. Please use the attached diagram. New Example: Line 1 A Line 2 B C Substation 1 D BES Excluded Radial System (Non-BES) Transformer 1 > 100kV > 100kV E Transformer 2 F G Substation 1 H RADIAL LOAD SYSTEM Response: The FRCC BESDTF acknowledges your request for the inclusion of the above reference diagram into Appendix A: Clarification to the FRCC Bulk Electric System (BES) Definition for Radial Transmission Elements or Systems Exclusion and has revised the document accordingly to include the requested diagram as Example Four. Page 25 of 36

26 9. Appendix B: Clarification to the FRCC Bulk Electric System (BES) Definition of transmission Protection Systems as Used in the PRC Standards for FRCC defines transmission Protection Systems as used in the PRC-series Reliability Standards for FRCC. Do you agree that the Protection Systems included in the definition of transmission Protection Systems are those Protection Systems that trip BES Elements (as established in the FRCC BES Definition)? Summary Consideration: Commenter Yes No Question 9 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Barry Pagel Hassan Hamdar Robert Grover Lee County Electric Cooperative Kelsi Oswald Pinellas County Resource Recovery Facility Paul Graves Anwar Saeed Frank Gaffney Florida Municipal Power We applaud the consistency with Reliability First Corporation's definition in this regard. Page 26 of 36

27 Agency Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Jim Howard Lakeland Electric Do the words Protection Systems include lockout relays and auxiliary relays? Response: The term Protection System is defined in the NERC Glossary of Terms. Silvia Parada Mitchell Florida Power & Light A Transmission Protection System is one that is designed to protect BES Elements regardless of what it trips. We would not consider a protection system for a distribution 13kv bus to be defined as a Transmission Protection system just because it trips transmission breakers. It protects a 13kv bus. It does not protect the transmission system and therefore not a Transmission Protection System. The question should be: What does it protect, not what does it trip. Response: The BESDTF debated whether to define transmission Protection Systems as those Protection Systems that trip, or those that protect BES Elements (trip vs. protect paradigms). There are two reasons the BESDTF chose to define transmission Protection Systems as those Protection Systems that trip BES Elements. First, such a definition is consistent with Reliability First Corp. s definition which has already been accepted by FERC (see Second, it is less ambiguous to distinguish what a Protection System trips than what a Protection System protects considering the long reach and multiple overlapping zones of protection causing a single Protection System to protect multiple Elements. So, for the sake of consistency and clarity, the BESDTF chose to use the trip paradigm as opposed to the protect paradigm. Page 27 of 36

28 10. Appendix B: Clarification to the FRCC Bulk Electric System (BES) Definition of transmission Protection Systems as Used in the PRC Standards for FRCC provides four (4) examples which categorize transmission Protection Systems vs. non-transmission Protection Systems. Do you agree with the conclusions of the examples and the designation of the identified Protection Systems? Summary Consideration: Commenter Yes No Question 10 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Hassan Hamdar Robert Grover Lee County Electric Cooperative Paul Graves Anwar Saeed Frank Gaffney Florida Municipal Power Agency Again I found these examples to be very helpful to better understand the intent of the clarifications and drawing a clear line between BES and non-bes transmission Protection Systems. Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Silvia Parada Mitchell Florida Power & Light A Transmission Protection System is one that is designed to protect BES Elements regardless of what it trips. We would not consider a protection system for a distribution 13kv bus to be defined as a Page 28 of 36

29 Transmission Protection system just because it trips transmission breakers. It protects a 13kv bus. It does not protect the transmission system and therefore not a Transmission Protection System. The question should be: What does it protect, not what does it trip. Response: The BESDTF debated whether to define transmission Protection Systems as those Protection Systems that trip, or those that protect BES Elements (trip vs. protect paradigms). There are two reasons the BESDTF chose to define transmission Protection Systems as those Protection Systems that trip BES Elements. First, such a definition is consistent with Reliability First Corp. s definition which has already been accepted by FERC (see Second, it is less ambiguous to distinguish what a Protection System trips than what a Protection System protects considering the long reach and multiple overlapping zones of protection causing a single Protection System to protect multiple Elements. So, for the sake of consistency and clarity, the BESDTF chose to use the trip paradigm as opposed to the protect paradigm. Barry Pagel 1. Appendix B Example Three Line 1 When Line 1 is greater than 200KV, the reliability of the BES would be better served if this was a portion of the BES (to at minimum the fence of a load substation) and thus included in the applicability of FAC Appendix B Example Four Line 3 and Line 4 - When Line 3 or Line 4 is greater than 200KV, the reliability of the BES would be better served if this was a portion of the BES ( to at minimum the fence of a load substation) and thus included in the applicability of FAC Appendix B Examples One, Two, Three, and Four How would the reliability of the transmission Protection System facilities owned by the Non-BES entity be enforced ( application of PRC-005) in those instances where the entity does not meet the criteria of a Distribution Provider (DP)? Response: (Note that the first two comments and their responses should probably be associated with Appendix A instead of Appendix B.) In response to comments 1 and 2, the NERC BES definition states: Radial transmission facilities serving only load with one transmission source are generally not included in this definition. NERC does not specify a bright line voltage distinction for a radial exclusion. In addition, in Examples 3 and 4, the Elements in question are radial elements serving only load, therefore, a fault on the radial Element will only cause the load to be interrupted. As a result, the BESDTF fails to see how reliability would be better served in creating a new bright line distinction for radial Elements that the NERC definition does not possess. Page 29 of 36

30 In response to the third comment, NERC s Statement of Compliance Registry Criteria states that a Distribution Provider (page 8, III.b.2): Distribution provider is the responsible entity that owns, controls, or operates facilities that are part of any of the following protection systems or programs designed, installed, and operated for the protection of the bulk power system: a required UFLS program. a required UVLS program. a required special protection system. a required transmission protection system. (emphasis added) Therefore, an entity that owns a transmission Protection System would need to register as a Distribution Provider if they are not already registered, and PRC-004 and PRC-005 would then be applicable to the Distribution Provider that owns a transmission Protection System. Jim Howard Lakeland Electric Appendix B on page 5 of 5 Is breaker G a normally open breaker? If not, substation 2 should also be considered BES as well as. According to the clarification, a breaker failure on voltage level below 100-kV be counted as BES on transmission protection system since a breaker failure condition will need to trip BES elements? Note that some LE 69-kV transmission line relays are used for a breaker failure relay that will trip a lockout and in turns trip 230-kV breakers. Response: (Note that the first comment and the response probably ought to be associated with Appendix A instead of Appendix B because it is about the BES definition and not protection systems). The comment really seems to be about the exclusion of a radial system. The BESDTF debated whether a radial system ought to be included or not. The BESDTF believes that the radial system does not impact the BES because there is no loop flow associated with a radial system because the single transmission source / bus arrangement at one voltage level shorts out any loop flow. For example, in example Four of Appendix B, page 5 of 5, loss of either line 3 or 4 has no impact on the flow of power on the BES. Therefore, the BESDTF decided that a radial system emanating from a single substation / single transmission source is equivalent to a radial Element. In response to the second comment, the BESDTF believes that an operation of a failed breaker scheme can impact power flow and cause contingency events in BES power flow. Therefore, the BESDTF believes that a breaker failure Page 30 of 36

31 scheme of a 69 kv system that trips BES Element(s) is a transmission Protection Scheme. In doing so, we are not intending to include the 69 kv system protection as a transmission Protection System, but rather, the relaying that comprise the breaker failure scheme. Page 31 of 36

32 11. The FRCC Bulk Electric System foundation document (definition) establishes an Effective Date of the 1 st day of the 3 rd calendar quarter following FRCC Board of Directors approval. Do you agree with the proposed Effective Date? Summary Consideration: Commenter Yes No Question 11 Comment Dennis Minton Florida Keys Electric Cooperative Association, Inc. Cairo Vanegas Fort Pierce Utilities Authority Silvia Parada Mitchell Florida Power & Light Barry Pagel Hassan Hamdar Robert Grover Lee County Electric Cooperative Kelsi Oswald Pinellas County Resource Recovery Facility Paul Graves Anwar Saeed Response: The FRCC BESDTF acknowledges your affirmative response and thanks you for your support. Page 32 of 36

33 Jim Howard Lakeland Electric Verification needs to be made that all entities can provide evidence that they can meet the requirements of the new expanded definition within this time period or the time needs to be extended to allow them the time necessary to meet the criteria. Response: Based on the experience of the diverse membership on the FRCC BESDTF, the task force determined that the established Effective Date was reasonable and appropriate for all functional entities within the FRCC Region. Where an expansion of the applicability to the reliability standards (i.e. transmission Protection Systems) an implementation date has been established which allows for sufficient time for functional entities to establish compliance with the applicable reliability standards. See footnote on Appendix B: FRCC regional application of the term transmission Protection Systems. Frank Gaffney Florida Municipal Power Agency The proposed effective date essentially gives a minimum of 6 months to implement any changes if the FRCC definition is inconsistent with each entity's current interpretation of the terms "Bulk Electric System" and "transmission Protection System". Such changes in interpretation could result in an entity needing to change its business practices. For instance, if the FRCC definition of "transmission Protection System" encompasses more Protection Systems than the Entity's current interpretation of "transmission Protection System, then that Entity may need to quickly due maintenance and testing of Protection Systems due to this possible increase in scope between the entity's current interpretation and FRCC's proposed definition of "transmission Protection System". Six months may be insufficient time to adjust those business practices. We suggest a minimum of 1 year. This can be done in three ways: 1) change the effective date; 2) keep the proposed effective date and develop an implementation plan; or 3) make the effective date the date the FRCC Board approved the definition but develop an implementation plan for any increase in scope of FRCC's definition as compared to each entity's existing interpretation. FMPA recommends the third alternative. Response: Based on the experience of the diverse membership on the FRCC BESDTF, the task force determined that the established Effective Date was reasonable and appropriate for all functional entities within the FRCC Region. Where an expansion of the applicability to the reliability standards (i.e. transmission Protection Systems) an implementation date has been established which allows for sufficient time for functional entities to establish compliance with the applicable reliability standards. See footnote on Appendix B: FRCC regional application of the term transmission Page 33 of 36

34 Protection Systems. Page 34 of 36

35 12. Please provide any other comments that the TF should consider. Summary Consideration: Commenter Yes No Question 12 Comment Silvia Parada Mitchell Florida Power & Light A Transmission Protection System is one that is designed to protect BES Elements regardless of what it trips. We would not consider a protection system for a distribution 13kv bus to be defined as a Transmission Protection system just because it trips transmission breakers. It protects a 13kv bus. It does not protect the transmission system and therefore not a Transmission Protection System. The question should be: What does it protect, not what does it trip. FPL believes the FRCC should continue to follow the NERC definition and does not need to be more prescriptive in its regional definition. Response: The BESDTF debated whether to define transmission Protection Systems as those Protection Systems that trip, or those that protect BES Elements (trip vs. protect paradigms). There are two reasons the BESDTF chose to define transmission Protection Systems as those Protection Systems that trip BES Elements. First, such a definition is consistent with Reliability First Corp. s definition which has already been accepted by FERC (see Second, it is less ambiguous to distinguish what a Protection System trips than what a Protection System protects considering the long reach and multiple overlapping zones of protection causing a single Protection System to protect multiple Elements. So, for the sake of consistency and clarity, the BESDTF chose to use the trip paradigm as opposed to the protect paradigm. The FRCC BESDTF believes that we are following the NERC definition of Bulk Electric System while providing additional clarity to aid the application of the definition by the functional entities within the FRCC Region. The majority of the functional entities within the FRCC Region support the additional clarification the FRCC BES definition provides. Hassan Hamdar The definition and clarifications are very well laid out and are fairly simple to understand. Grammatical Comments: line two under The FRCC Bulk Electric System excludes: states resources not included in 1. above this would read better if it stated resources not included in item 1 above the same would go for paragraph two line two of the Appendix A. The first sentence of Appendix B states This is a clarification to the definition of transmission Protection Systems. Since there is no definition of transmission Protection System the sentence should be Page 35 of 36

36 revised to say This is a clarification to the term transmission Protection Systems Response: The FRCC BES Definition Clarification TF agrees with the proposed revisions to the BES documents and has made the necessary changes to the documents. Page 36 of 36