2010-17 10-05-11 WECC Position Paper on BES Definition

WECC Position Paper for the initial ballot of Project 2010-17 – Definition of Bulk Electric System (BES) and Detailed Information to Support BES Exceptions Request, being balloted September 30 – October 10, 2011

NERC is conducting an initial ballot of Project 2010-17 – Definition of Bulk Electric System from September 30 – October 10, 2011. Because of the nature of this specific project, two separate ballots are being conducted simultaneously. The first ballot is for approval of the Definition of Bulk Electric System. The Definition of Bulk Electric System Standard Drafting Team has also posted a draft application form titled Detailed Information to Support BES Exceptions Requests. The form contains general instruction and questions that must be completed and submitted if an entity wishes to either exclude a facility that is included in the Bulk Electric System based on the proposed definition or include a facility that is not included in the Bulk Electric System based on the proposed definition

Members of the Project 2010-17 – Definition of Bulk Electric System Ballot Pool will be able to cast two separate votes, one for the Definition of Bulk Electric System, and a second vote for the proposed Detailed Information to Support BES Exceptions Request. This paper summarizes the WECC staff’s considerations for both of these ballots.

Bulk Electric System Definition

WECC staff supports the core definition of the Bulk Electric System as proposed. WECC staff believes that the clarifying changes from prior versions are responsive to industry comments. WECC staff also supports the proposed Inclusions and Exclusions identified in the Definition of Bulk Electric System, but believe that there is room for clarification as identified below.

For Inclusion 3 we agree that Blackstart units should be considered vital to the overall operation of the BES, and therefore included in the definition of the BES. However, we do not agree with the deletion of the cranking path from Inclusion 3. The cranking path should be included in the definition since NERC standards EOP-005 and CIP-002, R1.2.4 require documenting the cranking path and the revised CIP-002-4 identifies the cranking path as a critical asset in Attachment 1. To be able to count on a Blackstart unit to perform as designed in the Blackstart Restoration Plan, it must be ensured that the cranking path is available.

We believe that additional clarity is needed in the wording of Inclusion 4. It is our understanding, for example, that Inclusion 4 is not intended to include each individual wind turbine generating unit in a wind farm as a BES element, but rather to include the point at which the aggregation becomes large enough to meet the aggregate capacity threshold of 75 MVA. However, the response to comments from the last comment posting and the current wording of Inclusion 4 do not provide sufficient clarity to answer this question. We believe that the wording of Inclusion 4 could be modified to add clarity on this topic.

We believe that Inclusion 5 should be modified to identify some minimum Reactive Power threshold for static or dynamic devices similar to that identified for generating sources in Inclusion 2. As worded a 1 MVA device supplying or absorbing Reactive Power that is connected at 100 kV or higher would be included in the BES.

We believe that Exclusion 2 should be modified to include a size threshold for individual generating units, similar to that identified in Inclusion 2. As currently worded Exclusion 2 places the same threshold (75 MVA) on a single generating unit as is placed on multiple generating units.

Detailed Information to Support BES Exceptions Request

1 WECC Staff believes that the proposed Technical Principles for Demonstrating BES Exceptions Request does not provide the necessary clarity as to what applying entities must provide to support their request, nor does it provide any criteria for consistency among regions in their assessment of requests. We believe that the checklist items for transmission and generation facilities are appropriate questions that must be answered in considering all requests. However, without objective criteria defining what must be submitted and how to assess the materials submitted, the current methodology leaves it to each region to develop their own methodology and criteria for evaluating the submittals. We believe the lack of clarity regarding what studies must be submitted and what must be demonstrated by the studies submitted will be overly burdensome on the submitting entity and the Region, as multiple studies may be required for the two to agree that there is sufficient justification for an exemption request.

We believe that additional work is necessary to develop clear, objective methods and criteria for identifying which facilities may be excluded from or should be included in the Bulk Electric System. Clear, objective methods and criteria will enable the submitter of requests to understand what is necessary for submitting an exception request and will provide for consistency among the regions in their initial assessment and recommendations to the ERO.

WECC staff believes that a Yes vote for the Technical Principles for Demonstrating BES Exceptions Request will result in minimal changes to today’s process under the current definition which includes the language “as defined by the Regional Reliability Organization.” While the proposed Technical Principles for Demonstrating BES Exceptions Request includes a checklist that must be submitted with exception requests, a yes vote will still require each region to develop their own methods and criteria for assessing materials submitted with exemption requests. We believe that a No vote with guidance to the drafting team that objective methods and criteria must be developed and applied continent-wide will result in the desired uniformity and consistency among regions in their assessment of exception requests.

To allow sufficient time to complete this difficult task, we believe that the Detailed Information to Support BES Exceptions Request should not be part of the Phase 1 Bulk Electric System Definition effort, but should be postponed and included in the Phase 2 effort.

Based on the information above, WECC staff will be voting YES with comment to approve the Definition of the Bulk Electric System and voting NO with comment to reject the Detailed Information to Support BES Exceptions Request.

A complete copy of the proposed definition, the Detailed Information to Support BES Exceptions Request, and associated materials can be viewed at: http://www.nerc.com/filez/standards/Project2010-17_BES.html

If you determine that you will be voting NO for either the Definition of Bulk Electric System or the Detailed Information to Support BES Exceptions Request it is important that you provide a comment with your vote indicating the reason(s) why you voted NO, and provide suggested modifications that would make the definition or the Detailed Information to Support BES Exceptions Request proposal acceptable. The NERC Standards Development Procedure requires the Definition of Bulk Electric System drafting team to consider all comments received, provide a response to comments, and conduct either a successive or recirculation ballot

All WECC entities that are registered in the Project 2010-17 – Definition of Bulk Electric System Ballot Pool are urged to cast their ballots prior to the close of the ballot period.