WECC-0101 Generator Validation Conversion
MOD-26/27 Variance Drafting Team (DT)
Response to Comments / Posting 4
May 18, 2015 through June 17, 2015
Posting 4
The WECC-0101 Variance 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 from May 18 through June 17,
2015.
WECC distributed the notice for the posting on May 15, 2015. The DT asked stakeholders to provide
feedback on the proposed document through a standardized electronic template. WECC received
comments from five companies representing five of the eight Industry Segments, as shown in the table
on the following page.
Location of Comments
All comments received on the document can be viewed in their original format on the project page
under the “Submit and Review Comments” accordion.
Changes in Response to Comment
After consideration of comments received, the DT opted to make no further changes to the project.
MOD-026-1
MOD-027-1
Action Plan
The DT will agreed by majority vote to forward the project to the WECC Standards Committee (WSC)
with a request for ballot. The WSC is scheduled to meet in August 12, 2015.
WESTERN ELECTRICITY COORDINATING COUNCIL
155 North 400 West, Suite 200
Salt Lake City, Utah 84103-1114
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Action Items – Technical Paper 2 (Paper) – Complete
No further action items are pending for this project as a result of any posting for comment.
Technical Study 2 produced by WECC staff at the request of and under the guidance of both
stakeholders and the drafting team was delivered to the drafting team on June 23, 2015. The paper
will be made available for industry review via posting on the Submit and Review Responses accordion
assigned to the WECC-0101 DT along with the posting of these responses.
The parameters of the Paper were such that the staff preparing the Paper was not asked to opine on
whether the proposed changes to the NERC Standards were “better or worse.” The parameters of the
paper are empirical from which each reviewing entity can glean its own conclusions.
Each entity reviewing the Paper should couple that review with the data provided in the original
technical paper provided with the initial filing of this project. Once that empirical review is completed,
each entity will need to determine whether or not the enhanced value to the Western Interconnection
is outweighed by the burden of the individual entity required to perform the underlying reliabilityrelated tasks.
Cost Analysis
It should be noted that the DT repeatedly invited the industry to provide cost estimates to implement
the proposed project. All cost estimates provided have been preserved in the Response to Comments
of this project. The DT has not taken a position on whether the costs are excessive as that which is
expensive is an entity-specific value.
Contacts and Appeals
If you feel your comment has been omitted or overlooked, please contact the Manager, WECC
Standards Processes, W. Shannon Black, at [email protected]. In addition, there is a WECC Reliability
Standards Appeals Process.
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
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Commenter
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Organization
WECC Standards Voting Sectors
1
2
3
4
5
1
Kristie Cocco
Arizona Public
Service
X
X
X
X
X
2
Jennifer Young
Pacificorp
X
X
X
X
X
3
Sergio Banuelos
Tri-State Gen and
Transmission
X
X
X
X
X
4
5
Joshua Anderson
Ericka Doot1
Salt River Project
United States
Bureau of
Reclamation
X
X
X
X
X
X
X
1
6
7
8
These comments were received “out-of-time” via email and addressed as a courteous by the DT.
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Index to Questions, Comments, and Responses
Question
1. The Drafting Team welcomes comments on all aspects of the document. Please indicate which of
the two documents your comments apply to. The drafting team asks that comments not be
submitted on the Measures and Compliance sections as these will be addressed in a subsequent
posting.
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1. The Drafting Team welcomes comments on all aspects of the document. Please indicate which of
the two documents your comments apply to. The drafting team asks that comments not be
submitted on the Measures and Compliance sections as these will be addressed in a subsequent
posting.
Summary Consideration: See summary in the preamble of this document.
Commenter
Yes
Arizona Public Service
No
Comment
AZPS does not believe that there is a need for the suggested
variance, nor does AZPS believe the variance is technically justified.
Creating a variance to an industry developed NERC Standard, which
included significant WECC participation throughout its
development, should require a demonstrable technical need for
the variance and not requested simply due to the continuation of a
legacy policy.
The DT notes APS’s comment was asked and answered in earlier postings.
The DT appreciates APS’s observation as to WECC’s significant team engagement in the underlying
standard and applauds those efforts. The DT also appreciates APS position that future operations should
not “simply [be] due to the continuation of a legacy policy.”
It is the very nature of the NERC and WECC standards development processes that the industry should be
allowed to enhance, modify, retire, delete, or otherwise alter its standards based upon due process. The
proposed variances cannot override due process or unwind previous WECC endeavors - only the Ballot
Body/Ballot Pool can do that. As such, the DT encourages each entity to review all of the available
information and make a well-reasoned decision on whether the proposed parameters should be adopted
to enhance reliability or whether the existing thresholds are sufficient.
As a secondary observation regarding support and participation, the DT notes that adopting the BES
threshold accepts a threshold less stringent than WECC’s existing Generator Unit Validation Policy (Policy),
set at 20/75 MVA since 2006, vetted by the WECC Planning Coordinating Committee (PCC), and
affirmatively approved by the PCC’s membership. (The PCC has an estimated 200 members.)
2) Demonstrable Technical Need
The DT responded to this concern in depth in Posting 3 of this project, further vetting the issue in multiple
DT calls and via open comment at the WECC Standards Committee. The DT would point APS to the Posting
3, Action Plan, pages 3-5. Specifically, the DT promised to provide a second technical paper (Technical
Paper 2) (Paper)) for industry review prior to this project going to ballot.
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Summary Consideration: See summary in the preamble of this document.
Commenter
Yes
No
Comment
The DT thanks APS for its patience regarding the Paper. On June 26, 2015, WECC posted the requested
iterative technical paper to the WECC-0101 Home Page, on the Submit and Review Comments accordion.
To ensure the industry had ample time to review the document, a notice regarding its posting was sent to
the WECCSTDS Standards email exploder the same day.
WECC staff completed the requested Paper to estimate the sensitivity of the WECC Master Dynamics File
and simulation results to model changes made in response to the five-year revalidation policy.
Staff was asked to make no value judgment as to the study’s outcome so that each reviewing entity could
draw its own conclusion as to the value of the proposed project. Staff noted in its Summary, “The
(modeled) system damping is very dependent upon the models subject to the (current Generating Unit
Model Validation Policy) (Policy)), and clearly the frequency of validation impacts the study results. The
system damping is very dependent upon the models subject to the Policy.” (Paper, Summary, Page 18.)
The summary also noted that, “model differences could result in different operating limits that effectively
alter reliability margins and revenue potential or capital costs.” After reviewing the Paper, the DT
maintains its position that the additional information to be provided under the proposed variances brings
substantive added value to WECC’s modeling systems and should be embodied in the proposed variances.
As previously noted, the DT understands that meeting the proposed reliability-related tasks of the
proposed variances is an added entity-specific burden. The DT encourages those reliant upon the
Interconnection to weigh the reliability value-added against the imposition of burden, under which WECC
members have voluntarily been cooperating for over a decade. The DT also encourages the industry to
provide to the DT any specific costs projected to implement the variances. Because cost impacts are
entity-specific the DT continues to agree to post to the project page any projected costs received so that
the industry can draw its own conclusions as to the cost/benefit analysis to implement the variances.
Pacificorp
PacifiCorp does not support a WECC regional variance that
introduces obligations that are more onerous than the NERC MOD026-1/MOD-027-1 requirements. PacifiCorp believes that the
WECC region should adhere to the MOD-026-1/MOD-027-1
reliability standards as currently written and enforceable
nationwide.
The DT appreciates PacifiCorp’s concerns regarding the additional entity-specific burden that could be
imposed should the proposed variances be adopted by the industry. The DT would point Pacificorp to the
above response provided to APS addressing “Demonstrable Technical Need”. The DT encourages Pacificorp
to review the Technical Paper 2 data to determine whether the operational/planning benefit afforded to the
Interconnection is outweighed by the burden, much of which is already being incurred voluntarily by WECC
stakeholders that adhere to the Generator Units Validation Policy.
Implementation Plan:
Tri-State Generation
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Summary Consideration: See summary in the preamble of this document.
Commenter
Yes
No
Comment
The suggested implementation plans for the proposed variances do
not properly align with the already approved MOD-026-1 and
MOD-027-1 standards. Tri-State believes these timeframes should
correlate and certainly the proposed end date (100% compliance)
should not be any sooner than what is required by the NERC
approved versions. Entities with large footprints and numerous
generating facilities need ample time to plan for the necessary
outages.
Currently MOD-026-1 and MOD-027-1 Implementation Plans state
that for R2:
30% complete by 7/1/2018, 50% complete by 7/1/2020, and 100%
complete by 7/1/2024
The proposed implementation plan for the variances is: (These
should be modified to match the thresholds and dates above.)
30% complete by 7/1/2019, 50% complete by 7/1/2020, 75%
complete by 7/1/2021, and 100% complete by 7/1/2022
10 year versus 5 year testing interval:
Tri-State has yet to see the promised technical justification that
would explain/support the need for the proposed 5-year interval.
We can agree that the data and work that has gone into building a
robust model in the Western Interconnection over the previous
~15 years has established a solid foundation. However, we feel
that the requirements and associated intervals (R2 & R4) in the
NERC standards are adequate for future preservation and
maintenance of that model. Proposing a regional variance based
solely on the continuation of a legacy policy is not a valid reason. If
the SDT were to present a technical study that demonstrated a
tangible need for the WECC variances, then Tri-State would
consider supporting the variances. However, we have yet to see
that.
1) Implementation Plan
For clarity, the DT notes that its Implementation Plan is different from the Effective Dates. The
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Summary Consideration: See summary in the preamble of this document.
Commenter
Yes
No
Comment
Implementation Plan has been posted in the preamble of the document. The DT does not believe the
implementation plan creates any undue burden and will not be making changes to the plan. The
Implementation Plan is as follows:
“Implementation Plan
The DT has performed a gap analysis on the proposed Effective Dates and concluded that, if adopted,
the Effective Dates should not impose any undue burden or surprise compared to the existing
Effective Dates of the underlying standard.
Currently within WECC the Generating Units Modeling Validation Policy (Policy) already requires
entities to model their units at a more stringent level than the requested Facilities threshold.
Because the proposed variance largely reflects conditions that have been in effect within the Western
Interconnection pursuant the Policy for roughly a decade, most if not all WECC entities will already be
in compliance with the majority of the proposed variance.”
2) Effective Dates
No changes were made to the Effective Dates.
In Posting 2, the DT addressed Effective Date concerns noting: 1) the dates would apply equally to digital and
analogue units, 2) there was an asymmetrical jump between the 50% and 100% compliance targets that
needed remediation, and 3) that the procedural development of the proposed variance with its more
stringent thresholds would consume a considerable amount of time, all the while the clock would be running
on the NERC Standard Effect Dates. (See Posting 2 Response to Comments, APS, Issue 5: Effective Dates,
page 13-14.)
Generally, the Effective Dates as proposed are an equitable balance between creating sufficient time to
comply in years 0-5 and avoiding undue delay in years 6 and beyond. The DT concluded that matching the
NERC timelines could early on place an entity in compliance jeopardy simply because the clock has already
begun to run on the NERC standard; whereas, the variance is still in the developmental phase. The DT also
concluded that the NERC timeline was overly generous and created an incentive to delay actions in years 6
and beyond. The tiered approach offered by the variance addresses both sides of these concerns. (This
approach was in support of and in response to comments received by Xcel in Posting 2 (Response to
Comments, Posting 2, “Effective Date Concern”, page 27.)
Requirement R2, MOD-26/27-“1”
30% by 7/1/2018
50% by 7/1/2020
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DT Response in Posting 2 to APS; and current
proposal
30% - The latter of 7/1/2019 or regulatory approval
50% - The latter of 7/1/2020 or regulatory approval
75% - The latter of 7/1/2021 or regulatory approval
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Summary Consideration: See summary in the preamble of this document.
Commenter
Yes
100% by 7/1/2024
No
Comment
100%- The latter of 7/1/2022 or regulatory approval
2) 10 year / 5 year Testing Interval
The DT thanks Tri-State for its patience regarding the Paper. On June 26, 2015, WECC posted the requested
iterative technical paper to the WECC-0101 Home Page, on the Submit and Review Comments accordion. To
ensure the industry had ample time to review the document, a notice regarding its posting was sent to the
WECCSTDS Standards email exploder the same day.
The DT also appreciates Tri-States’ affirmation that “the data and work that has gone into building a robust
model in the Western Interconnection over the previous ~15 years has established a solid foundation”
(Affirmation). Although the WECC staff members completing the Technical Paper 2 study were not asked to
opine on whether the proposed variance was “better or worse”, the DT’s believes the Paper buttresses TriState’s Affirmation and the position of the DT as to the value of the requested reliability-related tasks.
The DT also agrees with Tri-State (and APS above) that standards should not be “based solely on the
continuation of a legacy policy.” This argument applies equally to the underlying standard as it does to the
existing GUMC Policy. To avoid the quagmire of legacy, this project is being afforded due process afresh.
The DT encourages Tri-State and all participating entities to review all of the available information and cast
its ballot accordingly.
Salt River Project
Currently WECC allows for generator testing to be deferred. This is
beneficial when there is a planned change to the excitation control
system or plant volt/var control function that would alter the
equipment response characteristics. If testing cannot be deferred,
an entity may choose not to make the changes to the excitation
control system or plant volt/var control function so they are not
required to re-test that unit. SRP recommends that this standard
allows for a single deferment for up to one year to allow for such
changes to be completed.
1) Allow for a Single Deferment for up to One year
United States Bureau of
Reclamation
The following comment from the US Bureau of Reclamation
(Bureau) was received out-of-time at 12:25 PM, June 18,
2015, via email from Erika Doot of the Bureau.
“Reclamation suggests that the WECC regional variance allow
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Summary Consideration: See summary in the preamble of this document.
Commenter
Yes
No
Comment
for extensions to the 5-year WECC model validation window
for circumstances including unforeseen equipment outages
and planned equipment upgrades. Reclamation suggests that
any extensions granted under the WECC regional variance
should not be allowed to exceed the 10-year model validation
timeframe in MOD-026 and MOD-027.”
1) Unforeseen Circumstances
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