October 19, 2011
NPCC Composite Responses to Comments Received on the
NPCC Glossary of Terms
NPCC would like to thank those who provided comments on the draft NPCC
Glossary of Terms which was posted to the Open Process from July 28, 2011
through September 12, 2011. The NPCC responses to individual comments are
provided below.
Summary:
Below is a summary of the key comments and NPCC’s responses:
1. Some commenters expressed a concern over the inconsistent approach adopted
for listing and defining the Terms associated with Real Power Capability and
Reactive Power Capability. The term of the latter (Reactive Power Capability)
has been changed in order to make it consistent with the term for Real Power
Capability.
2. Some commenters suggested that all terms have their definitions presented in
the Glossary table as opposed to simply making a reference to the document
that contains the definition, i.e. the NERC Glossary of Terms. This suggestion
has been adopted and a note has been added to cite the source document.
3. A number of editorial changes have been made as per commenters’ suggestions,
4. Terms that are not used in any Directories are put in a different group than
those that are used by at least one Directory. However, there are terms that are
not used in any Directories but are included in the definition of another term
that is used by at least one Directory. (For example: the term “availability” is
not used in any Directories, but is referenced in the defined term “Maintenance
Outage”.)
Some commenter’s suggested that a term that is included in the definition of
another term which is used in a Directory be also grouped under “Glossary of
Terms used by Directories”. NPCC has not adopted this approach at this time
since this needs to be assessed in the context of the future structure of terms
NPCC Response to Comments on NPCC Glossary of Terms
used in NPCC documents and the treatment of terms not used in any NPCC
documents.
This is outside the scope of the current phase of NPCC Glossary of Terms
development. Nonetheless, the suggestion will be forwarded to the respective
Task Forces for consideration as we move to the next phase of glossary
development.
5. Some commenters suggested that Terms used by Directories be changed from
“bolded” to “capitalized” so as to be consistent with the approach adopted by
NERC and other standards setting organizations.
However, the posted NPCC Glossary of Terms used by Directories is a first step
toward grouping all terms in the proper places and to remove redundancy
among terms defined in the Directories and the A-07 document. In the future,
revisions to terms used in all NPCC documents will undergo a comprehensive
review to arrive at the most appropriate structure.
Additionally, defined terms are bolded in all Directories, A, B and C documents
and capitalizing the terms listed in the NPCC Glossary of Terms used in
Directories while leaving terms used in NPCC documents bolded may create
confusion. Therefore, this suggestion has not been adopted at this time.
Nonetheless, NPCC will consider changing all defined terms from bolded to
capitalized to be consistent with the approach adopted by NERC and others.
This issue will be presented to the lead Task Forces for the Directories and A, B
and C documents for their consideration.
6. Some commenters suggested material or structure changes that would require
further deliberation as we move into the next phase of Glossary of Terms
development. NPCC will forward these suggestions to the appropriate Task
Forces for their consideration as each Directory is updated or as we move into
next phase of Glossary development.
Specific responses to individual comments are provided below.
NPCC Response to Comments on NPCC Glossary of Terms
2
Comments from Michael Falvo - IESO:
We appreciate the opportunity to comment on the draft NPCC Glossary of Terms
which was posted on July 28, 2011. We offer these comments:
1. The definition of Declared Capability appearing in the draft glossary is the same
as that contained in the approved version of Directory 9. However, the
approved version of Directory 10 contains a different definition. The Directory
10 definition states:
“Declared Capability (of a generator or generating facility) – The values submitted by
the Generator Owner to the respective Transmission Operator.”
It is not clear which definition is correct so this matter needs to be resolved.
NPCC Response:
Comment accepted: The identified inconsistency will be brought to the attention of the
lead Task Force for D9 and D10 to develop a resolution as these Directories are revised.
2. Additionally, the text “(of a generator or generating facility)” should be moved
from the Definition column to the Term column.
NPCC Response:
Comment accepted: The text has been moved to the Term column.
3. There is an inconsistency in how the terms Gross and Net Real Power
Capability are listed in the glossary when compared with the terms Reactive
Power Capability, Gross and Net. This must be addressed. While there are
arguments for listing the terms in either format, for ease of locating a given term
we prefer listing the definitions in alphabetical order of the entire name, i.e.
“Gross Real Power Capability” and “Net Real Power Capability”.
NPCC Response to Comments on NPCC Glossary of Terms
NPCC Response:
Comment accepted: Changes to the Gross and Net Reactive Power Capabilities have
been made as suggested.
4. Additionally, the text “(of a generator or generating facility)” should be moved
from the Definition column to the Term column and unbolded.
NPCC Response:
Comment accepted: The text has been moved to the Term column.
5. Several NPCC defined terms listed below should also be highlighted to indicate
that they are different from similar defined terms in the NERC Glossary:
Interconnection
Operating Procedures (the NERC defined term is actually Operating Procedure)
Protection System
Rating
Reactive Power
Real Power
Available Transfer Capability
Capacity Benefit Margin
Emergency Rating
Firm Demand
Normal Rating
Peak Demand
Transmission Reliability Margin
NPCC Response:
Comment accepted: We have highlighted these terms as suggested.
NPCC Response to Comments on NPCC Glossary of Terms
4
6. NERC standard PRC-005-2 which is currently under development contains a
proposed definition of “Component”. It may be worth including a footnote
indicating that this NERC definition is currently under development.
NPCC Response:
Comment rejected: Since this term is not currently defined in the NERC Glossary
and the NPCC term is not referencing the NERC term, we do not think that adding
the suggested footnote is needed or appropriate at this time.
7. Finally, in the “Term” column, there are approximately nine instances where
capitalization of the defined term is required for overall consistency.
NPCC Response:
Comment accepted: We have revised all the non-capitalized terms to achieve
consistency.
8. We also support the review of the NPCC Glossary of Terms as part of the Phase
2 reformatting of each Directory, to determine whether maintenance of the
NPCC definition is warranted in cases where a NERC definition also exists.
NPCC Response:
Thank you for the comment.
NPCC Response to Comments on NPCC Glossary of Terms
Comments from Daniel Rogers - LIPA:
1. NPCC does not define “misoperation” or “protection system misoperation” in
the Glossary of Terms. Should it be assumed that it is the intent of NPCC to
reference the NERC definition of “protection system misoperation” where
required as it has in the NPCC C-45, Analysis & Reporting of Protection System
Misoperations?
NPCC Response:
Comment accepted: NPCC will request the lead Task Forces of those Directories
that contain the term “misoperation”, currently not defined, to review the need for
defining it with reference to the NERC definition.
Comments from Mike Garton - Dominion:
Dominion finds acceptable NPCC’s intent to establish a new Glossary of Terms with
two sections; one for A criteria terms and another for B and C terms. Dominion does
however offer the following recommendations for consideration:
1. In the NPCC Glossary of Terms Used by Directories; there should be a legend to
reflect why the terms are highlighted in blue (because the NPCC definition of
this term is different than the NERC definition).
NPCC Response:
Comment accepted: A note has been added at the top of the table as suggested.
2. Add a revision history to both Directory documents.
NPCC Response:
Thank you for the comment. NPCC will consider this as we develop the next
version.
NPCC Response to Comments on NPCC Glossary of Terms
6
Comments from Shaina Dadah - National Grid
The following comments are submitted by Northeast Utilities for the NPCC Glossary of
Terms.
1. We support the new format of the NPCC Glossary of terms and NPCC’s intent
to retire the A7 document. In addition, we suggest that all terms specified in the
glossary have the definition given along with the term, rather than referencing
other documents. Should the definition come from another source; we
recommend that it be cited.
a. Example: As the glossary is presented in the draft:
Term
Acrony
m
Definition
Area Control Error
ACE
See NERC Definition
Directories that use
this term
D2
D5
D8
We would prefer that it reads as follows:
Term
Area Control Error
Acronym
ACE
Definition
The instantaneous difference
between a Balancing Authority’s
net actual and scheduled
interchange, taking into account
the effects of Frequency Bias and
correction for meter error.
(NERC Glossary of Terms, 2008)
Directories that use
this term
D2
D5
D8
NPCC Response:
Comment accepted: This approach has been adopted. Definitions for all terms are
provided in the table, including those that are the same as NERC’s, with the
appropriate source cited.
NPCC Response to Comments on NPCC Glossary of Terms
Comments from John Seelke – PSEG Services Corporation
PSEG member companies of NPCC (PSEG Energy Resources & Trade LLC, PSEG
Power Connecticut LLC, PSEG Power New York Inc) support the development of a
new NPCC Glossary. We have these comments:
1. Capitalize proposed NPCC Glossary terms and remove all bolded terms. This
should be the final end goal. However, since more NPCC terms may be added
later from Criteria A-07 (which is NPCC’s current Glossary), in the interim,
NPCC terms that are defined in the proposed Glossary should be capitalized,
while those in A-07 can remain be bolded. That approach would help user
distinguish what’s been changed and what’s left to be changed.
NPCC Response:
Comment rejected: The proposed NPCC Glossary essentially replicates all existing
terms listed in A-07.
Presently, defined terms are bolded in all NPCC documents including Directories, A, B
and C documents and capitalizing the terms listed in the NPCC Glossary of Terms
used in Directories while leaving terms used in NPCC documents bolded may create
confusion. Therefore, this suggestion has not been adopted at this time.
Nonetheless, NPCC will consider changing all defined terms from bolded to capitalize
to be consistent with the approach adopted for NERC standards. This issue will be
presented to the lead Task Forces for the Directories and A, B and C documents for
their consideration.
2. Definition principles. Here are some suggested NPCC Glossary principles:
a. Improve unclear definitions. For example, “applicable emergency
limits” should have each term capitalized per the comment above
regarding capitalization. Also capitalize “stability” and “bulk power
system,” which are NPCC proposed Glossary terms. Finally, this
definition would benefit from some redrafting to make it more coherent,
including looking at the definition of “Operating Limit” which
incorporates similar concepts.
NPCC Response to Comments on NPCC Glossary of Terms
8
NPCC Response:
Thank you for the comment. NPCC will present this to the lead Task Forces for
consideration along with your other suggestion to capitalize defined terms, as
indicated above.
b. Adopt a NERC Glossary definition where possible. Per the e-mail sent
by Gerry Dunbar, we note that this will be done in Phase II, and we
agree it’s needed. It would help if NPCC adopted the same definition for
the same term used by NERC.
NPCC Response:
Thank you for the comment.
Comments from Ted Dahill – National Grid
As requested, below are my comments on the 'NPCC Glossary of Terms Used or Not
Used by Directories'. I was not able to provide a red-line version since you sent a 'PDF'
file.
My format is the 'Term' being defined then my comment on the 'Definition'.
•
General comment - suggest when use 'See NERC definition' we provide generic
reference to the NERC website to help people start looking for the definition.
NPCC Response:
Comment accepted. Another commenter suggested that the NERC definitions be
provided in the definition box. NPCC agrees with that commenter to adopt this
more user-friendly approach and have made the corresponding changes. This
should address your concern.
•
Area - 'control areas' is not defined but is in the second file of 'terms not used in
the directories' so should be moved in to the 'used in the directories' file.
NPCC Response to Comments on NPCC Glossary of Terms
NPCC Response:
Thank you for the comment.
The term “control area” is not used in any Directories, but is defined in the A-07
document and referenced in the defined term “area”. The intent of developing the
proposed initial NPCC Glossary, among others, is to identify terms that have been
defined and the documents that they are used (or not used) without revising them or
determining whether or not terms not used need to be removed. As we begin
developing Phase II Directories, we will review the terms “area” and “control area”
(and any other terms used or otherwise) to determine if they are still applicable in
today’s environment where control area is no longer an appropriate term to use when
it has been essentially replaced with Balancing Area, Transmission Operator Area,
Reliability Coordination Area, etc.
•
Energize - suggest changing the word ' alive' to 'capable of conducting electric
power
NPCC Response:
Thank you for the comment. Change to the definition must be posted for members’
commenting and balloting so we are unable to make any changes at this time. Your
suggestion will be forwarded to the attention of and appropriate action by the lead
Task Force of the Directory that first uses this term.
•
Interconnection - 'Control Areas' is not defined but is in the second file of 'terms
not used in the directories' so should be moved in to the 'used in the directories'
file.
NPCC Response:
Thank you for the comment. The term “control area” is not used in any Directories,
but is defined in the A-07 document and referenced in the defined term “area”. The
intent of developing the proposed initial NPCC Glossary, among others, is to
identify terms that have been defined and the documents that they are used (or not
used) without revising them or determining whether or not terms not used need to
be removed. As we begin developing Phase II Directories, we will review the terms
NPCC Response to Comments on NPCC Glossary of Terms
10
“area” and “control area” (and any other terms used or otherwise) to determine if
they are still applicable in today’s environment where control area is no longer an
appropriate term to use when it has been essentially replaced with Balancing Area,
Transmission Operator Area, Reliability Coordination Area, etc.
•
Maintenance Outage - 'availability' is not defined but is in the second file of
'terms not used in the directories' so should be moved in to the 'used in the
directories' file.
NPCC Response:
Thank you for the comment. The term “availability” is not used in any Directories,
but is defined in the A-07 document and referenced in the defined term
“Maintenance Outage”, which is used in Directory 1. As we begin developing
Phase II Directories, we will review the need to keep the term “availability”. Your
suggestion will be brought to the attention of and appropriate action by the lead
Task Force of Directory 1.
•
Normal (Pre-contingency Operating Procedure - 'system operator' referenced
but provide definition as 'Operator, System' with NERC reference. NERC's
Glossary of Terms has it as 'System Operator'. Suggest changing the 'Operator,
System' to 'System Operator and relocate in file as appropriate.
NPCC Response:
Comment accepted. “Operator, System” changed to “System Operator” and
relocated the term.
•
Planned Outage - 'availability' not defined - see 'Maintenance Outage' above.
NPCC Response:
Thank you for the comment. Please see our response to your comment on
Maintenance Outage, above.
•
Reactive Power Capability (of a generator or generating facility), Net - 'Gross
Reactive Power Capability' is not defined in either file. Should add definition
after the 'Gross Real Power Capability' definition.
NPCC Response to Comments on NPCC Glossary of Terms
NPCC Response:
Comment accepted. Other commenters also pointed this out. NPCC has made
changes to arrive at a consistent treatment of the Gross and Net Real and Reactive
Power Capability terms.
•
Reclosing - reference 'synchronism-check' that is then defined within the
'Reclosing' definition. Suggest making 'synchronism-check- a separate defined
term as it is referenced other places - such as in the 'Supervision' definition.
NPCC Response:
Thank you for the comment. The term “synchronism-check” is not used in any
Directories, but is defined in the A-07 document and referenced in the defined term
“Reclosing”, which is used in Directory 1. As we begin developing Phase II
Directories, we will review the need to keep the term “synchronism-check”. Your
suggestion will be brought to the attention of and appropriate action by the lead
Task Force of Directory 1.
•
Reportable Events - 'Control Areas' is not defined - see 'Area' above.
NPCC Response:
Thank you for the comment. The term “control area” is not used in any Directories,
but is defined in the A-07 document and referenced in the defined term “area”. The
intent of developing the proposed initial NPCC Glossary, among others, is to
identify terms that have been defined and the documents that they are used (or not
used) without revising them or determining whether or not terms not used need to
be removed. As we begin developing Phase II Directories, we will review the terms
“area” and “control area” (and any other terms used or otherwise) to determine if
they are still applicable in today’s environment where control area is no longer an
appropriate term to use when it has been essentially replaced with Balancing Area,
Transmission Operator Area, Reliability Coordination Area, etc.
•
Reserve on Automatic Generation Control (AGC) - 'load demand' is bold and
not define. Suggest use either 'load' or 'demand' both of which are defined
using NERC reference.
NPCC Response:
NPCC Response to Comments on NPCC Glossary of Terms
12
Comment accepted: We have removed the word “demand”.
•
Ten-minute Reserve - refer to 'non-synchronized' which is not a defined term.
Suggest removing the bolding from the 'non' so will refer back to the
''synchronized' definition.
NPCC Response:
Comment accepted. Suggested change has been made.
•
Thirty-minute Reserve - see 'Ten-minute Reserve' issue.
NPCC Response:
Comment accepted. Suggested change has been made.
•
Total Transfer Capability - in point 1, suggest changing 'normal (precontingency ) operating procedures' to all bold and drop the hyphen to agree
with the defined term.
NPCC Response:
Comment accepted. Suggested change has been made.
•
Total Transfer Capability - in point 3, the term 'emergency ratings' is not defined
but is in the second file of 'terms not used in the directories' so
suggest moving the definition into the 'used in the directories'. An alternative
would be to add the term into the glossary with a reference to the NERC
definitions.
NPCC Response:
Thank you for the comment. The term “emergency rating” is not used in any
Directories, but is defined in the A-07 document and referenced in the defined term
“Total Transfer Capability”, which is used in Directory D5. Further, “emergency
rating” by itself is not defined but the “Short Term Emergency Rating” is defined
and used in Directory 1. As we begin developing Phase II Directories, we will
request the lead Task Forces for Directories 1 and 5 to assess the need to define
emergency rating as a separate term.
•
Total Transfer Capability - in point 5, the term 'power pool' is not defined but is
in the second file of 'terms not used in the directories' so should be moved in to
the 'used in the directories' file’.
NPCC Response to Comments on NPCC Glossary of Terms
NPCC Response:
Thank you for the comment. The term “power pool” is not used in any Directories,
but is defined in the A-07 document and referenced in the defined term “Total
Transfer Capability”, which is used in Directory 5. As we begin developing Phase II
Directories, we will review the need to keep the terms “power pool. Your
suggestion will be brought to the attention of and appropriate action by the lead
Task Force of Directory 5.
As for the file of 'Not Used by any Directories', beside the referenced changes above
(moving definitions back into the 'used' file:
•
Available Transfer Capability - would use of the NERC definition satisfy
NPCC's needs or are TRM and CBM specific terms that need referencing?
NPCC Response:
Comment accepted. The NPCC term Available Transfer Capability is defined
differently than the NERC terms. We will highlight this in the NPCC Glossary
table. Further, the terms TRM and CBM are defined differently from the NERC
terms. We have highlighted them to indicate the difference.
•
Average Demand - delete the '-' from the 'Term' column
NPCC Response:
Comment accepted. “-“ has been deleted from the Term column.
•
Peaking Capacity - refers to 'peak demand' which is not a defined term in either
file. Suggest adding into the 'used in directories' file with a reference to the
NERC definition.
NPCC Response:
Thank you for the comment. Peak Demand is defined in the A-07 document but is
not used in any Directories. Consistent with the approach we presented in the cover
NPCC Response to Comments on NPCC Glossary of Terms
14
letter when we posted the NPCC Glossary, we would keep these terms as defined
but not used in any Directories for now. As we begin developing Phase II
Directories and start reviewing terms used in the A, B and C document, we will
review these terms and determine where to list them under the NPCC Glossary.
NPCC Response to Comments on NPCC Glossary of Terms