Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance; Protection and Control; and Voltage and Reactive, 80397-80409 [2010-32157]
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Federal Register / Vol. 75, No. 245 / Wednesday, December 22, 2010 / Proposed Rules
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
18 CFR Part 40
[Docket No. RM09–9–000]
Version One Regional Reliability
Standards for Facilities Design,
Connections, and Maintenance;
Protection and Control; and Voltage
and Reactive
December 17, 2010.
Federal Energy Regulatory
Commission, DOE.
ACTION: Notice of proposed rulemaking.
AGENCY:
Under section 215 of the
Federal Power Act, the Commission
proposes to approve four revised
regional Reliability Standards
developed by the Western Electricity
Coordinating Council and approved by
the North American Electric Reliability
Corporation, which the Commission has
certified as the Electric Reliability
Organization responsible for developing
and enforcing mandatory Reliability
Standards. These regional Reliability
Standards have been designated by
WECC as FAC–501–WECC–1—
Transmission Maintenance, PRC–004–
WECC–1—Protection System and
Remedial Action Scheme Misoperation,
VAR–002–WECC–1—Automatic Voltage
Regulators, and VAR–501–WECC–1—
Power System Stabilizer. Proposed
FAC–501–WECC–1 addresses
transmission maintenance for specified
SUMMARY:
transmission paths in the Western
Interconnection. Proposed PRC–004–
WECC–1 addresses the analysis of
misoperations that occur on
transmission and generation protection
systems and remedial action schemes in
the Western Interconnection. Proposed
VAR–002–WECC–1 is meant to ensure
that automatic voltage regulators remain
in service on synchronous generators
and condensers in the Western
Interconnection. Proposed VAR–501–
WECC–1 is meant to ensure that power
system stabilizers remain in service on
synchronous generators in the Western
Interconnection. In addition, under
section 215(d)(5) of the Federal Power
Act, the Commission proposes to direct
the Western Electricity Coordinating
Council, working through its standards
development process, to develop
modifications to these to regional
Reliability Standards to address specific
issues, as discussed below.
DATES: Comments are due February 22,
2011.
ADDRESSES: You may submit comments,
identified by docket number and in
accordance with the requirements
posted on the Commission’s Web site,
https://www.ferc.gov. Comments may be
submitted by any of the following
methods:
• Agency Web Site: Documents
created electronically using word
processing software should be filed in
native applications or print-to-PDF
format, and not in a scanned format, at
https://www.ferc.gov/docs-filing/efiling.
asp.
80397
• Mail/Hand Delivery: Commenters
unable to file comments electronically
must mail or hand-deliver an original
copy of their comments to: Federal
Energy Regulatory Commission,
Secretary of the Commission, 888 First
Street, NE., Washington, DC 20426.
These requirements can be found on the
Commission’s Web site, see, e.g., the
‘‘Quick Reference Guide for Paper
Submissions,’’ available at https://www.
ferc.gov/docs-filing/efiling.asp or via
phone from FERC Online support at
(202) 502–6652 or toll-free at 1–866–
208–3676.
FOR FURTHER INFORMATION CONTACT:
A. Cory Lankford (Legal Information)
Office of the General Counsel, Federal
Energy Regulatory Commission, 888
First Street, NE., Washington, DC
20426, (202) 502–6711.
Nick Henery (Technical Information),
Office of Electric Reliability, Federal
Energy Regulatory Commission, 888
First Street, NE., Washington, DC
20426, (202) 502–8636.
Danny Johnson (Technical Information),
Office of Electric Reliability, Federal
Energy Regulatory Commission, 888
First Street, NE., Washington, DC
20426, (202) 502–8892.
Scott Sells (Technical Information),
Office of Electric Reliability, Federal
Energy Regulatory Commission, 888
First Street, NE., Washington, DC
20426, (202) 502–6664.
SUPPLEMENTARY INFORMATION:
Table of Contents
Paragraph
Nos.
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I. Background ..........................................................................................................................................................................................
A. Mandatory Reliability Standards ...............................................................................................................................................
B. Western Electricity Coordinating Council .................................................................................................................................
II. Proposed Regional Reliability Standards .........................................................................................................................................
III. Discussion .........................................................................................................................................................................................
A. FAC–501–WECC–1—Transmission Maintenance ....................................................................................................................
B. PRC–004–WECC–1—Protection System and Remedial Action Scheme Misoperation ..........................................................
C. VAR–002–WECC–1—Automatic Voltage Regulators ................................................................................................................
D. VAR–501–WECC–1—Power System Stabilizer .........................................................................................................................
IV. Information Collection Statement ...................................................................................................................................................
V. Environmental Analysis ....................................................................................................................................................................
VI. Regulatory Flexibility Act Certification ..........................................................................................................................................
VII. Comment Procedures ......................................................................................................................................................................
VIII. Document Availability ...................................................................................................................................................................
1. Under section 215 of the Federal
Power Act (FPA),1 the Commission
proposes to approve four revised
regional Reliability Standards
developed by the Western Electricity
Coordinating Council (WECC) and
approved by the North American
Electric Reliability Corporation (NERC),
1 16
U.S.C. 824o (2006).
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which the Commission has certified as
the Electric Reliability Organization
(ERO) responsible for developing and
enforcing mandatory Reliability
Standards.2 These regional Reliability
Standards have been designated by
2 North American Electric Reliability Corp., 116
FERC ¶ 61,062, order on reh’g & compliance, 117
FERC ¶ 61,126 (2006), aff’d sub nom. Alcoa, Inc.
v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).
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3
6
8
10
11
25
42
65
88
92
93
94
98
WECC as FAC–501–WECC–1—
Transmission Maintenance, PRC–004–
WECC–1—Protection System and
Remedial Action Scheme Misoperation,
VAR–002–WECC–1—Automatic Voltage
Regulators, and VAR–501–WECC–1—
Power System Stabilizer. Proposed
FAC–501–WECC–1 addresses
transmission maintenance for specified
transmission paths in the Western
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Interconnection. Proposed PRC–004–
WECC–1 addresses the analysis of
misoperations that occur on
transmission and generation protection
systems and remedial action schemes in
the Western Interconnection. Proposed
VAR–002–WECC–1 is meant to ensure
that automatic voltage regulators remain
in service on synchronous generators
and condensers in the Western
Interconnection. Proposed VAR–501–
WECC–1 is meant to ensure that power
system stabilizers remain in service on
synchronous generators in the Western
Interconnection. Under section
215(d)(5) of the Federal Power Act, the
Commission proposes to direct WECC,
through its standard development
process, to develop modifications to
these regional Reliability Standards to
address specific issues, as discussed
below.
2. Related, the Commission also seeks
comment on whether it should direct
the ERO to develop modifications to the
NERC Reliability Standards addressing
the use of automatic voltage regulators
and power system stabilizers. The
Commission’s concerns regarding the
NERC Reliability Standard are
introduced here as they correspond with
certain elements of the WECC standards
that are the subject of the immediate
proceeding. However, any proposal to
direct the development of modifications
to the NERC Reliability Standards
would be addressed in a separate
proceeding.
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I. Background
A. Mandatory Reliability Standards
3. Section 215 of the FPA requires a
Commission-certified ERO to develop
mandatory and enforceable Reliability
Standards, which are subject to
Commission review and approval. Once
approved, the Reliability Standards may
be enforced by the ERO, subject to
Commission oversight, or by the
Commission independently.3
4. Reliability Standards that the ERO
proposes to the Commission may
include Reliability Standards that are
proposed to the ERO by a Regional
Entity to be effective in that region.4 A
Regional Entity is an entity that has
been approved by the Commission to
enforce Reliability Standards under
delegated authority from the ERO.5
When the ERO reviews a regional
Reliability Standard that would be
applicable on an interconnection-wide
basis and that has been proposed by a
Regional Entity organized on an
interconnection-wide basis, the ERO
3 16
U.S.C. 824o(e)(3).
U.S.C. 824o(e)(4).
5 16 U.S.C. 824o(a)(7) and (e)(4).
4 16
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must rebuttably presume that the
regional Reliability Standard is just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest.6 In turn, the Commission must
give ‘‘due weight’’ to the technical
expertise of the ERO and of a Regional
Entity organized on an interconnectionwide basis.7
5. In Order No. 672, the Commission
urged uniformity of Reliability
Standards, but recognized a potential
need for regional differences.8
Accordingly, the Commission stated
that:
As a general matter, we will accept the
following two types of regional differences,
provided they are otherwise just, reasonable,
not unduly discriminatory or preferential and
in the public interest, as required under the
statute: (1) A regional difference that is more
stringent than the continent-wide Reliability
Standard, including a regional difference that
addresses matters that the continent-wide
Reliability Standard does not; and (2) a
regional Reliability Standard that is
necessitated by a physical difference in the
Bulk-Power System.9
B. Western Electricity Coordinating
Council
6. On April 19, 2007, the Commission
accepted delegation agreements between
NERC and each of eight Regional
Entities.10 In its order, the Commission
accepted WECC as a Regional Entity
organized on an Interconnection-wide
basis. As a Regional Entity, WECC
oversees transmission system reliability
in the Western Interconnection. The
WECC region encompasses nearly
1.8 million square miles, including 14
western U.S. states, the Canadian
provinces of Alberta and British
Columbia, and the northern portion of
Baja California in Mexico.
7. In June 2007, the Commission
approved eight regional Reliability
Standards for WECC including the
currently-effective WECC PRC–STD–
001–1, PRC–STD–003–1, PRC–STD–
005–1, VAR–STD–002a–1, and VAR–
STD–002b–1.11 The Commission
directed WECC to develop certain
modifications to WECC PRC–STD–001–
1, PRC–STD–003–1, PRC–STD–005–1,
6 18
CFR 39.5 (2010).
U.S.C. 824o(d)(2).
8 Rules Concerning Certification of the Electric
Reliability Organization; Procedures for the
Establishment, Approval, and Enforcement of
Electric Reliability Standards, Order No. 672, 71 FR
8662 (Feb. 17, 2006), FERC Stats. & Regs. ¶ 31,204,
at P 290, order on reh’g, Order No. 672–A, 71 FR
19814 (Apr. 18, 2006), FERC Stats. & Regs. ¶ 31,212
(2006).
9 Id. P 291.
10 North American Electric Reliability Corp., 119
FERC ¶ 61,060, at P 432 (2007).
11 North American Electric Reliability Corp., 119
FERC ¶ 61,260 (2007).
7 16
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VAR–STD–002a–1, and VAR–STD–
002b–1, as identified by NERC in its
filing letter for the current standards.12
For example, the Commission
determined that: (1) Regional definitions
should conform to definitions set forth
in the NERC Glossary of Terms Used in
Reliability Standards (NERC Glossary),
unless a specific deviation has been
justified; and (2) documents that are
referenced in the Reliability Standard
should be attached to the Reliability
Standard. The Commission also found
that it is important that regional
Reliability Standards and NERC
Reliability Standards achieve a
reasonable level of consistency in their
structure so that there is a common
understanding of the elements.
II. Proposed Regional Reliability
Standards
8. On March 25, 2009, NERC
submitted a petition (NERC Petition) to
the Commission seeking approval of
four WECC regional Reliability
Standards.13 The four proposed WECC
regional Reliability Standards are
designated as FAC–501–WECC–1, PRC–
004–WECC–1, VAR–002–WECC–1, and
VAR–501–WECC–1.14 In its petition,
NERC explains that the four proposed
regional Reliability Standards are meant
to replace certain currently approved
regional Reliability Standards:
• FAC–501–WECC–1 is intended to
replace the current approved PRC–STD–
005–1;
• PRC–004–WECC–1 is intended to
replace WECC PRC–STD–001–1 and
PRC–STD–003–1;
• VAR–002–WECC–1 is intended to
replace WECC VAR–STD–002a–1; and
• VAR–501–WECC–1 is intended to
replace WECC VAR–STD–002b–1.
NERC states that the NERC board of
trustees approved the proposed regional
Reliability Standards on October 29,
2008, on the condition that WECC
address certain shortcomings raised
during the comment periods in the next
revision of the Reliability Standards.
9. NERC requests an effective date for
FAC–501–WECC–1, VAR–002–WECC–
1, and VAR–501–WECC–1 of the first
day of the first quarter after Commission
approval. For PRC–004–WECC–1, NERC
requests an effective date of the first day
of the second quarter after approval by
the Commission.
12 Id.
13 See 18 CFR 39.5(a) (requiring the ERO to
submit regional Reliability Standards on behalf of
a Regional Entity).
14 The proposed regional Reliability Standards are
not attached to the NOPR. They are, however,
available on the Commission’s eLibrary document
retrieval system in Docket No. RM09–9–000 and are
posted on the ERO’s Web site, available at https://
www.nerc.com.
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III. Discussion
WECC and NERC Proposal
10. As discussed below, the
Commission proposes to approve FAC–
501–WECC–1, PRC–004–WECC–1,
VAR–002–WECC–1, and VAR–501–
WECC–1 as just, reasonable, not unduly
discriminatory or preferential, and in
the public interest. In addition, under
section 215(d)(5) of the FPA and section
39.5(f) of our regulations, the
Commission proposes to direct WECC to
develop certain modifications to further
clarify the requirements of the proposed
WECC regional Reliability Standards.
13. NERC states that proposed FAC–
501–WECC–1 is intended to replace
approved WECC PRC–STD–005–1. The
proposed regional Reliability Standard
would apply to transmission owners
that maintain transmission paths listed
in the WECC Transfer Path Table, which
is no longer an attachment to the
Reliability Standard but is maintained
on the WECC Web site. Proposed FAC–
501–WECC–1 contains three main
provisions. Requirement R1 provides
that each transmission owner must have
a transmission, maintenance, and
inspection plan, and each transmission
owner must annually review and update
as required their transmission
maintenance and inspection plan.
Requirement R2 states that each
transmission owner must include
specified maintenance categories 16
when developing their transmission
maintenance and inspection plan.
Requirement 3 states that each
transmission owner must implement
and follow their transmission
maintenance and inspection plan.
14. NERC recommends approval of
FAC–501–WECC–1, stating that the
proposed regional Reliability Standard
addresses matters that the NERC
Reliability Standard does not.
Specifically, according to NERC, FAC–
501–WECC–1 requires, for specified
transmission paths, a highly detailed
maintenance and inspection plan for all
transmission and substation equipment
components, beyond the relay and
communication system maintenance
and testing required by the
corresponding NERC Reliability
Standard.17
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A. FAC–501–WECC–1—Transmission
Maintenance
11. NERC PRC–005–1 applies to all
transmission and generator owners as
well as distribution providers that own
a transmission protection system. The
Reliability Standard is meant to ensure
that all transmission and generation
protection systems affecting the
reliability of the Bulk-Power System are
maintained and tested.
12. On June 8, 2007, the Commission
approved a WECC regional Reliability
Standard that corresponds to the NERC
Reliability Standard PRC–005–1.15
WECC PRC–STD–005–1 applies to
transmission owners and operators
identified in an attached table titled
‘‘Major WECC Transfer Paths in the Bulk
Electric System’’ (WECC Transfer Path
Table) and to owners of remedial action
schemes identified in the ‘‘Major WECC
Remedial Action Schemes’’ table (WECC
Remedial Action Schemes Table).
WECC PRC–STD–005–1 requires each
transmission owner and operator of the
specified transmission paths to perform
maintenance and inspection on those
paths as described by its transmission
maintenance and inspection plan. The
regional Reliability Standard identifies
specific contents that each applicable
transmission owner and transmission
operator must include in its
transmission maintenance and
inspection plan. For example, a plan
must include the scheduled interval for
time-based maintenance, describe
maintenance and inspection methods,
provide relevant checklists or forms,
and provide criteria for assessing the
condition of a facility. Each applicable
entity must retain all pertinent
maintenance and inspection records for
at least five years. Further each
applicable entity must annually certify
to WECC staff that it has developed,
documented, and implemented a
transmission maintenance and
inspection plan.
15 North American Electric Reliability Corp., 119
FERC ¶ 61,260 at P 95.
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NOPR Proposal
15. The Commission proposes to
approve FAC–501–WECC–1 as just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest. As explained by NERC,
proposed FAC–501–WECC–1 appears to
be more stringent, by virtue of its
requirement for a highly detailed
maintenance and inspection plan,
compared to the corresponding NERC
Reliability Standard.
16. Further, in approving the
currently-effective WECC PRC–STD–
005–1, the Commission directed WECC
to make certain modifications to the
regional Reliability Standard. To
address these directives, the proposed
16 The maintenance categories to be included in
the transmission maintenance and inspection plan
are included in Attachment 1 of FAC–501–WECC–
1—‘‘Transmission Line and Station Maintenance
Details.’’
17 NERC Petition at 11, 14.
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80399
regional Reliability Standard no longer
references any WECC Forms, and text
regarding the Compliance Monitoring
Period has been removed. The proposed
regional Reliability Standard no longer
refers to a regional definition of
Disturbance, which conflicted with the
definition of Disturbance in the NERC
Glossary. Since the term is not included
in any of the proposed regional
Reliability Standards, the Commission
proposes to direct the ERO to remove
this regional definition from the NERC
Glossary of terms upon Commission
approval of FAC–501–WECC–1. The
proposed regional Reliability Standard
also removes the Sanctions Table and
includes Violation Risk Factors,
Violation Severity Levels, Measures,
and Time Horizons, as directed by the
Commission. These revisions appear
generally consistent with the
Commission’s directives, and signify
meaningful improvement. Accordingly,
we propose to approve FAC–501–
WECC–1. We also propose to approve
NERC’s petition to retire currentlyeffective WECC PRC–STD–005–1.
17. While we propose to approve
FAC–501–WECC–1, we have several
concerns regarding the requirements of
the proposed regional Reliability
Standard that were not adequately
addressed in the NERC petition. Below,
we discuss our concerns and, in the
absence of a satisfactory explanation
from WECC, NERC and other
commenters, under section 215(d)(5) of
the FPA and section 39.5(f) of our
regulations, we propose to direct that
the Regional Entity develop
modifications to the regional Reliability
Standard, as discussed below.
WECC Transfer Path Table
18. First, we have a concern regarding
the applicability of the proposed
regional Reliability Standard. As
mentioned above, WECC PRC–STD–
005–1 is applicable to transmission
owners or operators that maintain
transmission paths listed in the WECC
Transfer Path Table, which is attached
to the regional Reliability Standard. The
attachment identifies 40 major
transmission paths in the Western
Interconnection. By contrast, FAC–501–
WECC–1 removes the attachment and,
instead, directs transmission owners to
the most current WECC Transfer Path
Table, which is available on the WECC
Web site. The table currently posted on
the WECC Web site identifies the same
40 major paths as the attachment to the
approved regional Reliability
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Standard.18 However, the Commission
is concerned that, by referencing the
WECC Transfer Path Table posted on
the WECC Web site, the applicability of
FAC–501–WECC–1 could change
without review and approval by the
ERO and the Commission, as required to
make effective a modification to a
Reliability Standard.
19. The possibility for the
applicability of the Reliability Standard
to change at any time could create
confusion for entities that need to
comply as well as any compliance
enforcement staff trying to determine
which entities are responsible for
complying with the Reliability
Standard. Under section 215(d)(5) of the
FPA, we propose to direct that WECC
develop a modification to the Reliability
Standard to address our concern. For
example, WECC could include its
criterion for identifying and modifying
major transmission paths listed in the
WECC Transfer Path Table and make an
informational filing each time it makes
a modification to the table. Another
option would be for WECC to file its
criterion with the Commission and post
revised transfer path tables and
referenced catalogs on its Web site
before they become effective with
concurrent notification to NERC and the
Commission. Alternatively, the Regional
Entity could include the WECC Transfer
Path Table as an attachment to the
modified Reliability Standard. In this
way, the Commission would be able to
verify that the Regional Entity is
applying the requirements of the
regional Reliability Standard in a just
and reasonable manner.
srobinson on DSKHWCL6B1PROD with PROPOSALS
System Operating Limits (SOL)
20. Second, the Commission is
concerned about WECC’s use of the term
System Operating limit, as it is defined
in the NERC Glossary.19 Currently,
WECC determines transfer capability
based on a ‘‘rated system path’’
methodology and the table of Major
WECC Transfer Paths and associated
catalog identify the facilities that make
up each rated system path. For at least
ten years, WECC has used the defined
term Operating Transfer Capability
18 See Major WECC Transfer Paths table available
at https://www.wecc.biz/Standards/Approved%20
Standards/Supporting%20Tables/Table%20
Major%20Paths%204-28-08.pdf. It appears that the
list of major transfer paths is relatively stable as the
list has not changed for at least the past three years.
19 A System Operating Limit is defined in the
NERC Glossary as ‘‘the value (such as MW, MVar,
Amperes, Frequency or Volts) that satisfies the most
limiting of the prescribed operating criteria for a
specified system configuration to ensure operation
within acceptable reliability criteria.’’ See NERC
Glossary, available at https://www.nerc.com/docs/
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limits, and not System Operating Limit,
to describe transmission limitations.
WECC TOP–STD–007–0 defines
Operating Transfer Capability limits as:
* * * the maximum amount of actual
power that can be transferred over direct or
parallel transmission elements comprising:
• An interconnection from one
Transmission Operator area to another
Transmission Operator area; or
• A transfer path within a Transmission
Operator area.
The net schedule over an interconnection
or transfer path within a Transmission
Operator area shall not exceed the [operating
transfer capability], regardless of the
prevailing actual power flow on the
interconnection or transfer path.
Unlike a System Operating Limit, the
definition of Operating Transfer
Capability limits is limited to direct or
parallel transmission elements between
or within specific transmission
operators. Moreover, the rating of a
System Operating Limit, which is based
on an operating criteria that is either
thermally (based on facility ratings) or
stability-based (based on transient
stability, voltage stability, or system
voltage limits) is the first element to
calculate in order to determine the
Operating Transfer Capability limit
rating.
21. Based on the above, it appears that
a System Operating Limit is not the
same as an Operating Transfer
Capability limit. Yet, WECC and NERC
believe that the terms can be used
interchangeably and that WECC revised
the regional Reliability Standard to refer
to System Operating Limits to conform
its terminology to the NERC Glossary.
While we believe using NERC Glossary
terminology is generally preferable,20
we are concerned that, in this instance,
the use of a regional definition might be
most appropriate.
22. Specifically, the Commission is
concerned that the introduction of the
NERC Glossary definition of System
Operating Limit in Requirement R1 of
the proposed regional Reliability
Standard could create confusion
regarding which transmission owners
are required to maintain a transmission
maintenance and inspection plan.
Requirement R1 of the approved WECC
Reliability Standard requires
transmission owners to inspect and
maintain ‘‘all bulk power transmission
elements (i.e., lines, stations and rights
of way) included as part of the
transmission facilities (or required to
maintain transfer capability) impacting
each of the transmission paths listed
20 See W. Elec. Coordinating Council Reg’l
Reliability Standard Regarding Automatic Time
Error Corr., Order No. 723, 74 FR 25442 (May 28,
2009), 127 FERC ¶ 61,176, at P 38–40 (2009).
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* * *.’’ 21 By contrast, Requirement R1
of WECC’s proposed regional Reliability
Standard would require transmission
owners to maintain a transmission
maintenance and inspection plan
detailing their inspection and
maintenance requirements that ‘‘apply
to all transmission facilities necessary
for System Operating Limits associated
with each of the transmission paths
identified in the WECC Transfer Path
Table.’’ 22 Facilities that are System
Operating Limits associated with
transmission paths identified in the
WECC Transfer Path Table are not
necessarily on paths identified in the
WECC Transfer Path Table.
23. Thus, under the proposed
language, Requirement R1 could apply
to more transmission facilities than
identified in the WECC Transfer Path
Table. For example, a System Operating
Limit for a rated path in the WECC
Transfer Path Table could be defined by
a facility on a path that is not identified
in the WECC Transfer Path Table but
which is associated with an identified
path. Under these circumstances, it is
unclear whether Requirement R1 would
require maintenance on these facilities
that are not identified in the WECC
Transfer Path Table. If so, the
requirement might need to apply to
transmission owners that do not own
any paths identified in the WECC
Transfer Path Table. Accordingly, the
Commission seeks comment as to
whether, under Requirement R1, a
transmission owner that owns a major
path would be responsible for
maintaining and inspecting
transmission facilities owned by another
entity if such facilities are ‘‘necessary for
[System Operating Limits] associated
with’’ the major path.
Summary
24. In summary, the Commission
proposes to approve FAC–501–WECC–
1. The Commission also proposes to
approve NERC’s petition to retire
currently-effective WECC PRC–STD–
005–1. In addition, the Commission
requests comment on two issues
discussed above regarding the (1) Major
WECC Transfer Path table, and (2) use
of the term System Operating Limits.
21 WECC Reliability Standard PRC–STD–005–1,
Requirement R1.
22 Proposed WECC Reliability Standard, FAC–
501–WECC–1, Requirement R1, emphasis added.
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B. PRC–004–WECC–1—Protection
System and Remedial Action Scheme
Misoperation
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Background—Currently-Effective PRC–
STD–001–1 and PRC–STD–003–1
25. Currently-effective WECC PRC–
STD–001–1 applies to transmission
operators or transmission owners of 40
specified transmission paths. The
regional Reliability Standard requires
these entities to certify to WECC that all
(1) protective relay applications and (2)
protective relay settings and logic are
appropriate for the specified
transmission paths. It also requires that
these entities, once every three years,
certify that information is updated and
accurate.
26. WECC PRC–STD–001–1
corresponds with NERC PRC–001–1,
which addresses protection systems,
requires transmission operators and
generator operators to notify appropriate
entities of relay or equipment failures
and to coordinate when installing new
or modified protection systems.
27. Currently-effective WECC PRC–
STD–003–1 applies to transmission
operators and owners of the same 40
specified transmission paths as
Reliability Standard PRC–STD–001–1.
WECC PRC–STD–003–1 requires
applicable transmission operators and
owners to ensure all transmission and
generation protection system
misoperations affecting the reliability of
the bulk electric system are analyzed
and mitigated.
28. WECC PRC–STD–003–1
corresponds to NERC PRC–003–1,
which also relates to protection system
misoperations.
WECC and NERC Proposal
29. NERC states that proposed PRC–
004–WECC–1 is intended to replace two
currently-effective WECC Reliability
Standards, PRC–STD–001–1 and PRC–
STD–003–1. NERC recommends
approval of PRC–004–WECC–1,
explaining that it is more stringent than
the corresponding NERC PRC–004–1.
Specifically, NERC explains that PRC–
004–WECC–1 requires that all
transmission and generation protection
system and remedial action scheme
misoperations on major WECC transfer
paths be analyzed and mitigated within
a specific timeframe. In contrast, NERC
PRC–003–1 requires Regional Entities to
establish procedures for review,
analysis, reporting, and mitigation of
transmission and generation Protection
System Misoperations, but it does not
specifically address the owners of the
transmission and generation facilities.
NERC also explains that NERC PRC–
004–1 has requirements for protection
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system misoperations, but does not
provide for the additional requirements
included in PRC–004–WECC–1.23
30. Proposed PRC–004–WECC–1
contains three main provisions.
Requirement R1 provides that ‘‘System
Operators and System Protection
Personnel’’ of transmission owners and
generator owners must analyze all
protection system and remedial action
scheme operations. Requirements R1.1
and R1.2 identify time limits for the
review and analysis of transmission
element tripping, remedial action
scheme operations and protection
systems. Requirement R2 and the
associated sub-requirements identify
actions expected to be performed by
transmission owners and generator
owners for each protection system or
remedial action scheme misoperation,
including identifying timelines for
removing the equipment that failed from
service. Requirement R3 states that
transmission owners and generator
owners are to submit incident reports
for any misoperation or repair of
equipment that misoperated.
31. Like the approved regional
Reliability Standard, the proposed
regional Reliability Standard is
applicable to transmission owners and
transmission operators, but it also is
applicable to the generator owners that
own facilities listed in the WECC
Transfer Path Table and the WECC
Remedial Action Schemes Table, which
are available on WECC’s Web site.24 In
addition, WECC proposes four new
regional definitions for Functionally
Equivalent Protection System,
Functionally Equivalent Remedial
Action Scheme, Security-Based
Misoperation and Dependability Based
Misoperation.
NOPR Proposal
32. The Commission proposes to
approve PRC–004–WECC–1 as just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest. The Commission also proposes
to approve NERC’s petition to withdraw
currently-effective WECC PRC–STD–
001–1 and WECC PRC–STD–003–1. As
NERC explains above, it appears that the
proposed PRC–004–WECC–1 is more
stringent than the corresponding NERC
PRC–004–1. Moreover, the proposed
PRC–004–WECC–1 addresses
Commission directives to develop
modifications to the currently-effective
regional Reliability Standards.
33. Specifically, in approving the
currently-effective WECC PRC–STD–
23 See
NERC Petition at 11, 19–20.
proposed regional Reliability Standard
PRC–004–WECC–1, Section 4 (Applicability).
24 See
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001–1 and WECC PRC–STD–003–1, the
Commission directed WECC to make
certain modifications in developing
replacement Reliability Standards. To
address these directives, in the
proposed Standard, WECC no longer
references any WECC forms, and the
text regarding the compliance
monitoring period has been removed
from the proposed Standard. In
addition, the proposed regional
Reliability Standard no longer
references the regional definition of
Disturbance, which did not match the
NERC definition of Disturbance in the
NERC Glossary. The proposed regional
Reliability Standard also would remove
the definition for Business Day. Since
these terms are not included in any of
the existing or proposed regional
Reliability Standards, the Commission
proposes to direct the ERO to remove
these regional definitions from the
NERC Glossary, upon approval of the
PRC–004–WECC–1. The proposed
regional Reliability Standard also
removes the sanctions table and
includes violation risk factors, violation
severity levels, measures and time
horizons. The Commission commends
WECC for addressing these directives.
34. Nevertheless, the Commission has
concerns regarding several provisions of
the proposed regional Reliability
Standard, and seeks additional
comments, as discussed below.
WECC Transfer Path Table
35. Similar to the discussion above
regarding proposed FAC–501–WECC–1,
we are concerned regarding the removal
of the list of major transmission paths
from proposed PRC–004–WECC–1 and
the replacement with a link to the
WECC Web site. Currently-effective
WECC PRC–STD–003–1 is applicable to
transmission owners or operators that
maintain transmission paths listed in an
attachment to the Reliability Standard.
The attachment identifies 40 major
transmission paths in the Western
Interconnection. By contrast, the
proposed PRC–004–WECC–1 removes
attachment A and, instead, directs
transmission owners to the most current
WECC Transfer Path Table, which is
available on the WECC Web site.
Although the table posted on the WECC
Web site lists the same 40 major paths
as the attachment to the approved
regional Reliability Standard, the
Commission is concerned that by
referencing the WECC Transfer Path
Table posted on the WECC Web site,
WECC could modify the document
without Commission and industry
notice and opportunity to respond.
36. The possibility for the
applicability of the Reliability Standard
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to change at any time could create
confusion for entities that need to
comply as well as any compliance
enforcement staff trying to determine
which entities are responsible for
complying with the Reliability
Standard. Accordingly, the Commission
seeks comment on how NERC and
WECC intend to develop and provide
notice of proposed changes to the WECC
Transfer Path Table. We also seek
comment on how NERC and WECC will
ensure that changes to the applicability
of the Reliability Standard will not
undermine its effectiveness. We propose
to direct WECC to develop a
modification to the Reliability Standard
to address our concern. For example,
WECC could include its criterion for
identifying and modifying major
transmission paths listed in the WECC
Transfer Path Table and make an
informational filing each time it makes
a modification to the table. Another
option would be for WECC to file its
criterion with the Commission and post
revised transfer path tables and
referenced catalogs on its Web site
before they become effective with
concurrent notification to NERC and the
Commission. Alternatively, the Regional
Entity could include the WECC Transfer
Path Table as an attachment to the
modified Reliability Standard. In this
way, the Commission would be able to
verify that the Regional Entity is
applying the requirements of the
regional Reliability Standard in a just
and reasonable manner.
Proposed Regional Definitions
37. The proposed regional Reliability
Standard includes four new regional
definitions meant to apply only in
WECC. Two of the proposed definitions
(Functionally Equivalent Protection
System and Functionally Equivalent
Remedial Action Scheme) have added
‘‘functionally equivalent’’ to terms that
already exist in the NERC Glossary.25
The NERC Glossary definition of
Protection System lists the types of
equipment that can be used as
protection systems (i.e. protective
relays, associated communication
systems, voltage and current sensing
devices, station batteries and DC control
circuitry). By contrast, the proposed
WECC definition of Functionally
Equivalent Protection System is not
limited to any specific components or
operating characteristics but, instead,
defines Functionally Equivalent
Protection Systems based on what they
can do: ‘‘[e]ach Protection System can
detect the same faults within the zone
25 See NERC Glossary definitions for Protection
System and Remedial Action Scheme.
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of protection and provide the clearing
times and coordination needed to
comply with all Reliability Standards.’’
In addition, the NERC Glossary defines
Remedial Action Scheme, or Special
Protection System, as ‘‘[a]n automatic
protection system designed to detect
abnormal or predetermined system
conditions, and take corrective actions
other than and/or in addition to the
isolation of faulted components to
maintain system reliability.’’ 26 By
contrast, WECC proposes to define
Functionally Equivalent RAS as ‘‘[a]
Remedial Action Scheme that provides
the same performance as follows: Each
[Remedial Action Scheme] can detect
the same conditions and provide
mitigation to comply with all Reliability
Standards. Each [Remedial Action
Scheme] may have different
components and operating
characteristics.’’
38. The Commission has expressed
concern about the unnecessary
proliferation of glossary terms and has
directed the ERO to be vigilant in
assuring that a regional definition is
consistent with both NERC Glossary
terms and other approved Regional
Entity glossary terms.27 In the instant
proceeding, we are concerned that the
proposed definitions of Functionally
Equivalent Protection System and
Functionally Equivalent RAS do not add
any further clarity to the NERC Glossary
terms. Accordingly, we seek an
explanation from WECC and other
interested commenters regarding
whether these new terms are more
inclusive than the corresponding NERC
Glossary definitions and, if so, how.
39. WECC proposes to define
Functionally Equivalent Protection
System as ‘‘[a] Protection System that
provides performance as follows: Each
Protection System can detect the same
faults within the zone of protection
* * *.’’ 28 It is unclear what the phrase
‘‘detect the same faults’’ means within
this definition. For example, this phrase
could refer to the ability of one
protection system to act as a back-up for
another protection system.
Alternatively, this phrase could imply
that a protection system should be able
to detect a fault within in a different
sub-area of the same zone of protection.
Accordingly, we seek comment on the
26 NERC Glossary definition of Special Protection
System (Remedial Action Scheme), available at
https://www.nerc.com/docs/standards/rs/
Glossary_of_Terms_2010April20.pdf.
27 Order No. 723, 74 FR 25,442 at P 37–40.
28 See Proposed Reliability Standard PRC–004–
WECC–1, proposed definition of Functionally
Equivalent Protection System.
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meaning of the phrase ‘‘the same faults’’
within the definition.
40. In addition, the current NERC
Glossary definition of Misoperation
includes: (1) Failure of a protection
system to operate; (2) protection system
operation for a fault outside of the
planned zone of protection; and (3)
unintentional operation of a protection
system. Instead of using this NERC
Glossary definition, WECC has
developed two new terms: SecurityBased Misoperations and DependabilityBased Misoperations. The proposed
WECC definitions address: (1) Incorrect
operation of a protection system
(Security-Based Misoperation); and (2)
absence of a protection system to
operate (Dependability-Based
Misoperation). The bifurcation of the
term Misoperation may be confusing
because at least some of the
requirements for each type of
misoperation appear to overlap. We seek
an explanation from WECC and other
interested commenters regarding why
these two new regional terms are
necessary or desirable within the
context of the proposed regional
Reliability Standard, and how they will
enhance reliability.
Summary
41. The Commission proposes to
approve PRC–004–WECC–1 as just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest. The Commission also proposes
to approve NERC’s petition to withdraw
currently-effective WECC PRC–STD–
001–1 and WECC PRC–STD–003–1. In
addition, the Commission requests
comment on three issues discussed
above regarding (1) the Major WECC
Transfer Path table; (2) whether the
proposed regional terms, Functionally
Equivalent Protection System and
Functionally Equivalent RAS, are more
inclusive than the corresponding NERC
Glossary definitions; and, (3) the
necessity of the proposed regional
terms, Security-Based Misoperations
and Dependability-Based Misoperations.
C. VAR–002–WECC–1—Automatic
Voltage Regulators
Background
42. Applicable to all generator
operators and generator owners, NERC
VAR–002–1.1b is meant to ensure that
generators provide reactive and voltage
control necessary to ensure voltage
levels, reactive flows, and reactive
resources are maintained within
applicable facility ratings to protect
equipment and the reliable operation of
the Interconnection. Unless exempted
by the transmission operator, each
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generator operator must maintain the
generator voltage or reactive power
output (within applicable facility
ratings) 29 as directed by the
transmission operator. Thus, the NERC
Reliability Standard does not require
generator operators to operate in
automatic voltage control mode when
they are operating outside of their
facility rating, e.g., generators that are
starting-up or generators used to serve
peak load that typically run at low
megawatt levels.
43. On June 8, 2007, the Commission
approved WECC VAR–STD–002a-1,
which applies to generator operators of
synchronous generating units equipped
with automatic voltage regulators in the
Western Interconnection. The stated
purpose of the regional Reliability
Standard is to ensure that automatic
voltage control equipment on
synchronous generators shall be kept in
service at all times, except in specified
circumstances, and that outages of such
equipment must be coordinated. It
requires that generator operators must
normally operate automatic voltage
control equipment in voltage control
mode and set to respond effectively to
voltage deviations. Nevertheless, the
levels of non-compliance associated
with the approved regional Reliability
Standard permit generator operators to
operate without automatic voltage
control equipment for two percent of the
operating hours in a calendar year
without penalty. The Commission
approved the current regional
Reliability Standard as more stringent
than the NERC Reliability Standard
because the WECC regional Reliability
Standard requires synchronous
generators to have their automatic
voltage regulators in service at all times
with exceptions limited to specific
circumstances. In contrast, the NERC
Reliability Standard does not specify a
list of exceptions, which could mean
that transmission operators may, upon
request of the generator operators,
permit outages of automatic voltage
regulators for a broader range of
reasons.30
WECC and NERC Proposal
44. NERC requests approval of VAR–
002–WECC–1 (Automatic Voltage
Regulators) and requests the concurrent
retirement of WECC VAR–STD–002a–1.
Proposed VAR–002–WECC–1 would be
applicable to all generator operators and
29 NERC defines ‘‘facility rating’’ as the maximum
or minimum voltage, current, frequency, or real or
reactive power flow through a facility that does not
violate the applicable equipment rating of any
equipment comprising the facility.
30 North American Electric Reliability Corp., 119
FERC ¶ 61,260 at P 116.
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transmission operators that operate
synchronous condensers. It would only
apply to synchronous generators and
synchronous condensers that are
connected to the bulk electric system.
45. Proposed VAR–002–WECC–1
contains two requirements. Requirement
R1 provides that each generator operator
and transmission operator shall have
automatic voltage regulators in service
and in automatic voltage control mode
for synchronous generators and
synchronous condensers during 98
percent of all operating hours unless
exempted by the transmission operator.
Sub-requirements R1.1 through R1.10
detail the type of exemptions that the
transmission operator may grant to the
generator operator to excuse the
generator from operating the automatic
voltage regulator in automatic voltage
control mode. Requirement R2 states
that each generator operator and
transmission operator must have
documentation identifying the number
of hours excluded for each subrequirement R1.1 through R1.10.
46. WECC also proposes to replace the
sanctions table with violation risk
factors, violation severity levels,
measures and time horizons. Finally,
WECC proposes a new glossary term,
Commercial Operation, to be applicable
only in the Western Interconnection.
47. During the standards development
process, NERC expressed concern that
proposed Requirement R1 was less
stringent than the current NERC
Reliability Standard.31 WECC
responded that, although Requirement
R1 appears to decrease the number of
operating hours that a generator
operator and transmission operator must
keep automatic voltage regulators in
service and in automatic voltage control
mode from 100 percent to 98 percent,
the 98 percent requirement is a
translation of the limits set in the levels
of non-compliance associated with the
current regional Reliability Standard.32
In addition, WECC explained that the
two percent allowance provides more
time to start up generating facilities
when the automatic voltage regulators
are not yet in voltage control mode and
allows for evaluation when a generator
operator responds to an unforeseen
event.33 WECC also pointed out that
31 NERC
Petition at 34.
levels of non-compliance assigned to the
currently-effective regional Reliability Standard
specify that there shall be a level 1 non-compliance
if automatic voltage regulators are in service less
than 98 percent but at least 96 percent or more of
all hours during which the synchronous generating
unit is on line for each calendar quarter.
33 Specifically, WECC explains ‘‘[t]he two percent
allowance provides for time to start up generating
facilities when the [automatic voltage regulators]
are not yet in voltage control mode. It also allows
32 The
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NERC VAR–002–1a does not place any
restrictions on the length of time or
range of acceptable reasons for operating
in modes other than automatic voltage
control mode. By contrast, WECC
pointed out that the proposed VAR–
002–WECC–1 limits the range of
acceptable reasons and time for
operating a generator without the
automatic voltage regulator in service
and controlling voltage.34
48. NERC also notes that, during the
Reliability Standards development
process, it expressed concern regarding
sub-requirement R1.1, which includes
an exemption for units operating less
than five percent of all hours during a
calendar quarter. NERC explains that it
raised a concern that the proposed subrequirement ‘‘excludes the hours
attributed to the synchronous generator
or condenser that operates for less than
five percent of all hours during any
calendar quarter.’’ 35 WECC responded
by explaining that there is no change in
the basic five percent threshold between
the existing regional Reliability
Standard and the proposed regional
Reliability Standard. WECC further
explained that peaking units often
operate, for short periods, at low
megawatt levels (below where
manufacturers recommend placing the
automatic voltage regulators in-service).
WECC states that the exclusion below
the five percent threshold during a
calendar quarter permits the continued
practice of allowing the operation of
peaking units without penalty for
having an out-of-service automatic
voltage regulator per the manufacturer’s
recommendations.36
49. NERC states that, whereas NERC
VAR–002–1a requires only that a
generator operator notify its
transmission operator when it either
removes or operates the automatic
voltage regulator in a condition other
than automatic voltage control mode
and does not limit the amount of time
for such operations, the proposed WECC
regional Reliability Standard sets only
very limited circumstances for when a
generator’s automatic voltage regulator
should be operated in a mode other than
for evaluation when the Generator Operators
respond to unforeseen events.’’ WECC further
explains ‘‘[p]eaking units often operate, for short
periods, at low megawatt levels (below where
manufactures recommend placing the [automatic
voltage regulators] in-service). The exclusion below
the five percent threshold during a calendar quarter
permits the continued practice of allowing the
operation of peaking units without penalty for
having an out-of-service [automatic voltage control
regulators] per the manufacturer recommendations.’’
NERC Petition at 34–35.
34 Id.
35 Id. at 34–35.
36 Id. at 35.
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the automatic voltage control mode and
further limits the cumulative timeframe
for doing so. Thus, NERC represents that
the proposed regional Reliability
Standard is more stringent than the
NERC Reliability Standard.37
NOPR Proposal
50. The Commission proposes to
approve VAR–002–WECC–1 as just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest. Further, the Commission
proposes the concurrent retirement of
currently-effective WECC VAR–STD–
002a–1. As represented by NERC, it
appears that proposed VAR–002–
WECC–1 is more stringent than the
corresponding NERC Reliability
Standard.
51. Moreover, in approving the
currently-effective WECC VAR–STD–
002a–1, the Commission directed WECC
to make certain modifications in
developing a replacement Reliability
Standard. To address these directives,
WECC has added violation risk factors,
violation severity levels, measures and
time horizons, and has removed the
sanctions table. WECC also has rewritten Requirement WR1 so that it does
not include more than one main topic,
removed language suggested to move to
the Additional Compliance Information
section, and removed the reference to
Form A.5 to address recommendations
made by NERC to modify WECC VAR–
STD–002a–1.38 Thus, it appears that
proposed VAR–002–WECC–1 maintains
stringencies above the corresponding
NERC Reliability Standard while
providing additional clarity and
conformity. Thus, the Commission
proposes to approve the regional
Reliability Standard.
52. In addition, the Commission seeks
comments on several issues posed by
the WECC proposal, as discussed below.
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Automatic Voltage Regulators
53. Requirement R1 of proposed
VAR–002–WECC–1 provides that
‘‘Generator Operators and Transmission
Operators shall have [automatic voltage
regulators] in service and in automatic
voltage control mode 98% of all
operating hours for synchronous
generators or synchronous
condensers.’’ 39 Requirement R1 then
identifies ten circumstances in which a
generator operator or transmission
operator is excused from this
requirement. By specifying the
circumstances in which a generator
37 Id.
at 29.
id. at 31.
39 Proposed regional Reliability Standard VAR–
002–WECC–1, Requirement R1.
operator or transmission operator is
excused from operating in automatic
voltage regulator mode, the proposed
requirement appears to be more
stringent than the requirement in NERC
VAR–002–1.1b.
54. The Commission believes that,
where installed, automatic voltage
regulators should be in-service at all
times except in circumstances when the
generator is operating at an output level
that is not within the design parameters
of the automatic voltage regulator or
operations of the automatic voltage
regulator would result in instability.
Automatic voltage regulators are
intended to assist in maintaining the
reliability of the Bulk-Power System by
controlling system voltages. In addition,
System Operating Limits for
transmission paths in the bulk electric
system in the Western Interconnection
assume that automatic voltage regulators
are in service to control voltage to
support the transfer capability.40 When
automatic voltage regulators are out of
service, the time required to
appropriately respond to disturbances
that cause voltage deviations would
increase due to the time required to take
manual action. If not corrected in
sufficient time, these voltage deviations
could lead to instability, uncontrolled
separation and cascading outages.
55. Although the proposed regional
Reliability Standard would limit the
circumstances in which a transmission
operator or generator operator is
excused from keeping automatic voltage
regulators in automatic voltage control
mode, it also provides a blanket
exemption for two percent of all
operating hours. In its petition, NERC
explains that this exemption would
accommodate generating facilities when
they are starting up and when the
automatic voltage regulators are not yet
in voltage control mode. NERC also
explains that this exemption allows for
evaluation when the generator operators
respond to unforeseen events.41 These
limitations identified by NERC in its
petition are not explicit in the
requirements of the proposed regional
Reliability Standard.
56. We are concerned that the
proposed provision is written more
broadly than necessary. We believe it is
appropriate to exempt automatic voltage
regulators from being in-service during
times when the generator is operating
outside of applicable facility ratings.
However, as proposed, Requirement R1
would provide generators with a blanket
exemption—equal to two percent of all
operating hours—from the requirement
38 See
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40 See
NERC Petition at 29.
41 NERC Petition at 34–35.
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to maintain automatic voltage regulators
in-service. We seek comment on
whether the Commission should direct
WECC to develop a modification to the
proposed regional Reliability Standard
to address our concern. For example,
consistent with NERC’s explanation,
NERC could develop a modification
replacing the blanket two percent
exemption with a list of specific
exemptions that would accommodate
generating units that are starting up or
responding to unforeseen events and are
operating outside of applicable facility
ratings.
57. The purpose of NERC VAR–002–
1.1b is to ensure appropriate reactive
and voltage control are provided to
maintain voltage levels, reactive flows,
and reactive resources are within
applicable facility ratings for Reliable
Operation. Requirement R1 of VAR–
002–1.1b states that the ‘‘Generator
Operator shall operate each generator
connected to the interconnected
transmission system in the automatic
voltage control mode (automatic voltage
regulator in service and controlling
voltage) unless the Generator Operator
has notified the Transmission Operator.’’
Requirement R2 continues that ‘‘[u]nless
exempted by the Transmission
Operator, each Generator Operator shall
maintain the generator voltage or
Reactive Power output (within
applicable Facility Ratings) as directed
by the Transmission Operator.’’ Based
on the same rationale articulated
regarding the two percent exemption in
the regional Reliability Standard, we
have a concern regarding the
corresponding NERC Reliability
Standard. In particular, we seek
comment on whether it would provide
additional support for Bulk-Power
System reliability to propose to direct
the ERO to develop a modification to
NERC VAR–002–1.1b. Specifically to
clarify that, if a generator has an
automatic voltage regulator installed, it
must be in-service and controlling
voltage at all times, equipment and
facility ratings permitting, unless
exempted by the transmission operator.
We believe that such a modification
could be consistent with Commission
precedent.42 The Commission’s
concerns regarding the NERC Reliability
Standard are introduced here as they
correspond with certain elements of the
WECC standards that are the subject of
the immediate proceeding. However,
any proposal to direct the development
of modifications to the NERC Reliability
42 Order on Reliability Standard Interpretation,
132 FERC ¶ 61,220, at P 27 (2010) (VAR
Interpretation Order).
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Automatic Voltage Regulator
Replacement
60. Proposed sub-requirement R1.6
Exclusion of Synchronous Generators
lengthens the automatic voltage
that Operate for Less Than Five Percent
regulator replacement timeline due to
of All Hours During a Calendar Quarter
component failure from 15 months to 24
58. Requirement R1.1 of proposed
months ‘‘to accommodate design and
VAR–002–WECC–1 would allow
procurement especially for nuclear
exclusion of any synchronous generator units.’’ 45 The ERO supported the
or synchronous condenser that ‘‘operates extension of the outage time frame for
for less than five percent of all hours
the automatic voltage regulators. The
during any calendar quarter’’ from
Commission, giving due weight to
operating with automatic voltage
WECC and the ERO, proposes to accept
regulator in service and in automatic
the Reliability Standard with the
voltage control mode. During the
modification to this provision.
Reliability Standard development
61. We are concerned that allowing an
process of the proposed regional
additional nine months of nonReliability Standard, NERC expressed
operation of automatic voltage regulator
concern regarding the exclusion of these is not necessary for many, if not most,
hours.43 WECC responded by explaining units. The additional replacement time
that the ‘‘exclusion below the five
could lead to a decrease in generation
percent threshold during a calendar
that can react in automatic voltage
quarter permits the continued practice
regulator mode. In the event of a
of allowing the operation of peaking
contingency, this could have an impact
units without penalty for having an out- on bulk electric system reliability. We
of-service [automatic voltage regulator]
believe that it may be appropriate to
per the manufacturer recommendations’’ direct WECC to develop a modification
since ‘‘[p]eaking units often operate, for
to this provision to address our concern.
short periods, at low megawatt levels
For example, WECC could allow fifteen
(below where manufacture[r]s
months for replacement with an
recommend placing the [automatic
opportunity to seek an extension up to
voltage regulators] in-service).’’ 44 Thus,
nine months where justified.
it appears that WECC developed the five Alternatively, WECC could retain a
fifteen month replacement period for
percent threshold provision to account
non-nuclear generator units, and a
for out-of-service automatic voltage
twenty-four month replacement period
regulators per the manufacturer
for nuclear generator units. The
recommendations regarding automatic
Commission seeks comment from
voltage regulator design limitations.
WECC, NERC and other interested
59. We are concerned, however, that
commenters regarding the historical
the provision is written more broadly
replacement period for nuclear and nonthan necessary. It appears inefficient to
nuclear units, and the appropriateness
allow an exemption for any
of the Commission proposal. For
synchronous generator or synchronous
example, comments could include
condenser that ‘‘operates for less than
documentation and timeline summary
five percent of all hours during any
of previous ‘‘design and procurement’’
calendar quarter’’ in order to address
for automatic voltage regulator
concerns about operation limits based
component failures demonstrating that
on manufacture recommendations, and
automatic voltage regulator outages
could potentially exempt other
frequently last more than 15 months in
generator operators and transmission
order to support extending the
operators. The Commission seeks
replacement period.
comment on whether it is necessary or
desirable to direct WECC to develop a
Responding to Voltage Deviations
modification through its Reliability
62. The current regional Reliability
Standards development process that
Standard provides that ‘‘[a]ll
addresses this concern. For example,
synchronous generators with automatic
one reasonable solution would be to
develop a replacement requirement that voltage control equipment shall
normally be operated in voltage control
directly addresses the need for an
mode and set to respond effectively to
exemption for peaking units operating
voltage deviations.’’ The proposed
automatic voltage regulators when
regional Reliability Standard removes
necessary to satisfy manufacturer
this requirement but the NERC Petition
recommendations regarding the
does not provide any explanation why,
operation of an automatic voltage
regulator.
45
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Standards would be addressed in a
separate proceeding.
NERC Petition at Exhibit C, ‘‘Consideration of
Comments for VAR–002–WECC–1—Automatic
Voltage Regulator Comments were due January 2,
2008.’’
43 NERC
44 Id.
Petition at 34–35.
at 35.
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80405
or potential impact of, removing the
provision.
63. We seek further explanation from
WECC, NERC, and public comment, on
the impact of removing this provision
from the currently-effective WECC
regional Reliability Standard. We are
concerned that, by removing the
requirement for automatic voltage
regulators to respond effectively to
voltage deviations, the proposed
regional Reliability Standard would not
require entities to assess the
performance of the automatic voltage
regulators to ensure they are
appropriately responding to voltage
deviations to support reliability of the
Bulk-Power System.
Summary
64. The Commission proposes to
approve VAR–002–WECC–1 as just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest. Further, the Commission
proposes the concurrent retirement of
currently-effective WECC VAR–STD–
002a–1. In addition, the Commission
requests comment on issues discussed
above regarding whether the
Commission should direct WECC to
develop modifications to the proposed
regional Reliability Standard that
would: (1) Replace the blanket two
percent exemption with a list of specific
exemptions; and (2) more narrowly
tailor the exemption for any
synchronous generator or synchronous
conductor that operates less than five
percent of all operating hours during
any calendar quarter. The Commission
also seeks comment on the historical
replacement period for nuclear and nonnuclear units and whether the
Commission should direct WECC to
modify the regional Reliability Standard
to limit the acceptable duration of
automatic voltage regulator outages.
Finally, the Commission seeks comment
on the impact of removing the
requirement that all generators with
automatic voltage control equipment be
operated in automatic voltage control
mode and set to respond to voltage
deviations.
D. VAR–501–WECC–1—Power System
Stabilizer
Background
65. Currently-effective WECC VAR–
STD–002b–1 applies to generator
operators with generators equipped with
power system stabilizers. The current
regional Reliability Standard requires
that generator operators keep power
system stabilizers in service at all times,
except in specified circumstances.
Further, currently-effective WECC VAR–
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STD–002b–1 requires that power system
stabilizers are properly tuned in
accordance with WECC Criterion,
referenced in the standard. This regional
Reliability Standard does not have a
corresponding NERC Reliability
Standard. The Commission approved
the current regional Reliability Standard
because it addresses matters that are not
addressed by a NERC Reliability
Standard.46
srobinson on DSKHWCL6B1PROD with PROPOSALS
WECC and NERC Proposal
66. NERC requests approval of VAR–
501–WECC–1 and asks for the
concurrent retirement of the current
WECC VAR–STD–002b–1. Proposed
VAR–501–WECC–1 would apply to
generator operators. Its purpose is to
ensure that power system stabilizer on
synchronous generators are kept in
service.
67. Proposed VAR–501–WECC–1
contains two requirements. Requirement
R1 provides that each generator operator
with a synchronous generator equipped
with a power system stabilizer must
have the power system stabilizer in
service during 98 percent of all
operating hours. NERC explains that a
power system stabilizer is part of the
excitation control system of a generator
used to increase power transfer levels by
improving power system dynamic
performance. Sub-requirements R1.1
through R1.12 set forth exceptions to the
operating requirement in Requirement
R1. Requirement R2 states that each
generator operator must have
documentation identifying the number
of hours excluded for each subrequirement R1.1 through R1.12.
68. In the Petition, NERC and WECC
explain that the purpose of VAR–501–
WECC–1 is to ensure that power system
stabilizers on synchronous generators
are kept in service. NERC and WECC
state that the corresponding NERC
VAR–002–1.1b requires only that a
generator operator notify its
transmission operator when it removes
the power system stabilizer from service
and does not limit the amount of time
for operating generators without power
system stabilizers in service.47 NERC
and WECC explain that, in contrast,
proposed VAR–501–WECC–1 requires
power system stabilizers to be in service
except for specific conditions and for a
cumulative time limit per quarter. Thus,
according to NERC and WECC, the
proposed regional Reliability Standard
is more stringent than the corresponding
NERC Reliability Standard.
46 See North American Electric Reliability Corp.,
119 FERC ¶ 61,260 at P 122.
47 NERC Petition at 36.
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69. In addition, the Petition explains
that the proposed regional Reliability
Standard includes modifications to
address the Commission’s directives in
the June 2007 order that accepted
WECC’s currently-effective standards.48
In particular, WECC proposes to replace
the current sanctions table with
violation risk factors, violation severity
levels, measures and time horizons.
Proposed VAR–501–WECC–1 removes
the definition of ‘‘disturbance’’ and
makes certain directed formatting
revisions. WECC also proposes a new
glossary term, Commercial Operation, to
be applicable only in the Western
Interconnection.49
70. In the Petition, NERC notes that,
during the Reliability Standards
development process, NERC expressed
concern that the proposed regional
Reliability Standard appears less
stringent than the current regional
Reliability Standard because it would
reduce the number of hours that
generator operators must keep power
system stabilizers in service from 100
percent to 98 percent of all operating
hours.50 WECC responded to NERC’s
concerns by explaining that the
requirement had not been modified but
rather was a translation of the existing
levels of non-compliance into the
requirements of the proposed regional
Reliability Standard.51 WECC further
explained that the levels of noncompliance for the current regional
Reliability Standard allow generator
operators to operate without power
system stabilizers in service for two
percent of all operating hours without
penalty.52
71. NERC also notes that, during the
regional Reliability Standards
development process, NERC expressed
concern that sub-requirement R1.1 of
the proposed regional Reliability
Standard excludes the hours for power
system stabilizer operation attributed to
the synchronous generator that operates
for less than five percent of all hours
during any calendar quarter. WECC
responded that there is no change in the
48 North American Electric Reliability Corp., 119
FERC ¶ 61,260 at P 123.
49 Pursuant to WECC’s proposal, ‘‘Commercial
Operation’’ is defined as ‘‘* * * receiving all
approvals necessary for operation after completion
of initial start-up testing.’’ Requirement R1.1 of
VAR–501–WECC–1 excludes a unit from
compliance when ‘‘the synchronous generator has
not achieved Commercial Operation.’’
50 NERC Petition at 40.
51 Id.
52 The levels of non-compliance assigned to the
currently-effective regional Reliability Standard
specify that there shall be a level 1 non-compliance
if power system stabilizers are in service less than
98 percent but at least 96 percent or more of all
hours during which the synchronous generating
unit is on line for each calendar quarter.
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basic five percent threshold between the
current and the proposed regional
Reliability Standards. WECC further
explained that peaking units often
operate, for short periods, at low
megawatt levels where manufacturers
do not recommend using a power
system stabilizer. WECC stated that the
exclusion below the five percent
threshold during a calendar quarter
permits the continued practice of
allowing the operation of peaking units
without penalty for having an out-ofservice power system stabilizer per the
manufacturer recommendations.
NOPR Proposal
72. The Commission proposes to
approve VAR–501–WECC–1 as just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest. The Commission also proposes
to approve NERC’s proposed retirement
of currently-effective WECC VAR–STD–
002b–1.
73. As explained by NERC and WECC,
proposed VAR–501–WECC–1 is more
stringent than the corresponding NERC
VAR–002–1.1b. Unlike the NERC
Reliability Standard, proposed VAR–
501–WECC–1 requires power system
stabilizers to be in service except for
specific conditions and for a cumulative
time limit per quarter. Further, the
proposed regional Reliability Standard
reflects modifications to address the
Commission’s concerns in the June 2007
order.53 As discussed above, WECC has
added violation risk factors, violation
severity levels, measures and time
horizons and has removed the reliability
management system sanctions table.
WECC also made formatting changes,
removed the definition for
‘‘Disturbance,’’ and included a definition
of ‘‘Commercial Operation.’’
Accordingly, the Commission proposes
to approve proposed VAR–501–WECC–
1 because it appears to be more stringent
than the requirements of the applicable
NERC Reliability Standards while
providing additional clarity and
conformity over the current regional
Reliability Standard.
74. In addition to the modifications
that address the Commission’s earlier
directives, WECC’s proposal includes
further modifications about which the
Commission seeks comment.
75. The language of proposed VAR–
501–WECC–1 is similar to the proposed
VAR–002–WECC–1, addressed above.
As a result, the Commission discusses
below several similar issues as
discussed above regarding VAR–002–
WECC–1. In particular, the same items
53 See North American Electric Reliability Corp.,
119 FERC ¶ 61,260 at P 123.
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discussed above regarding the
requirement that generator operators
meet the requirements of the proposed
regional Reliability Standard only 98
percent of the time, and the exclusion
of hours for generators that operate less
than five percent of all hours during a
calendar quarter, apply to this proposed
regional Reliability Standard as well.
In-Service Requirement
76. As proposed, Requirement R1 of
VAR–501–WECC–1 provides that
‘‘Generator Operators shall have [power
system stabilizers] in service 98
[percent] of all operating hours for
synchronous generators equipped with
[power system stabilizers].’’ 54
Requirement R1 also sets forth twelve
circumstances in which a generator
operator is excused from this
requirement. By specifying the
circumstances in which a generator
operator is excused from keeping its
power system stabilizer in service, the
proposed requirement appears to be
more stringent than the currentlyeffective requirement in NERC VAR–
002–1.1b, which requires only that a
generator operator notify its
transmission operator when there is a
change in status of its power system
stabilizer.
77. The Commission believes that,
where installed, power system
stabilizers should be in-service at all
times, equipment and facility ratings
permitting, unless exempted by the
transmission operator. Power system
stabilizers are designed to ensure that
the generator provides the proper
damping to maintain system stability
when generation and transmission
outages occur.55 As NERC explains, in
the Western Interconnection System,
Operating Limits for transmission paths
in the bulk electric system assume that
power system stabilizers are in service
to enhance system damping. When
power system stabilizers are out of
service, generators may not be able to
dampen oscillations occurring on the
system, which could lead to instability,
uncontrolled separation and cascading
outages.
78. Although the proposed regional
Reliability Standard would limit the
circumstances in which a generator
operator is excused from keeping power
system stabilizers in-service, it also
provides a blanket exemption for two
percent of all operating hours. Similar to
our discussion above on VAR–002–
WECC–1, we believe that an exemption
might be appropriate to accommodate
54 Proposed regional Reliability Standard VAR–
501–WECC–1, Requirement R1.
55 Id. at 35.
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generating facilities when they are
starting up or operating outside of their
facility ratings. However, proposed
regional Reliability Standard provides
no limitation as to when generating
units may use the two percent
exemption.
79. We are concerned that the
proposed provision is written more
broadly than necessary. We believe it is
appropriate to exempt power system
stabilizers from being in-service during
times when the generator is operating
outside of applicable facility ratings.
However, as proposed, Requirement R1
would provide a blanket exemption for
generators to maintain power system
stabilizers in-service for two percent of
all operating hours without
qualification. We seek comment on
whether the Commission should direct
WECC to develop a modification to the
proposed regional Reliability Standard
that would address our concern. For
example, WECC could develop a
modification to replace the blanket two
percent exemption with a more specific
exemption that would accommodate
generating units that are starting up or
are operating outside of applicable
facility ratings.
80. Requirement R3 and R3.1 of VAR–
002–1.1b require a generator operator to
inform the transmission operator as
soon as possible, but within 30 minutes,
whenever there is a change in status or
capability, and the expected duration of
this change, of any reactive power
resource including power system
stabilizers. Based on similar concerns
articulated above regarding the regional
Reliability Standard, we have concerns
about the NERC Reliability Standard
and whether it adequately addresses
power system stabilizer in-service
obligations. In particular, we seek
comment on whether it would be
appropriate to propose to direct the ERO
to develop a modification to NERC
VAR–002–1.1b to clarify that, if a
generator has a power system stabilizer
installed, it must be in-service at all
times, equipment and facility ratings
permitting, unless exempted by the
transmission operator. The
Commission’s concerns regarding the
NERC Reliability Standard are
introduced here as they correspond with
certain elements of the WECC standards
that are the subject of the immediate
proceeding. However, any proposal to
direct the development of modifications
to the NERC Reliability Standards
would be addressed in a separate
proceeding.
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80407
Exclusion of Synchronous Generators
That Operate for Less Than Five Percent
of All Hours During a Calendar Quarter
81. Requirement R1.1 of proposed
VAR–501–WECC–1 would allow
exclusion of any synchronous generator
that operates for less than five percent
of all hours during any calendar quarter
from operating with power system
stabilizer in service. During the
Reliability Standard development
process of the proposed regional
Reliability Standard, NERC expressed
concern regarding the exclusion of these
hours.56 WECC responded by explaining
that the ‘‘exclusion below the five
percent threshold during a calendar
quarter permits the continued practice
of allowing the operation of peaking
units without penalty for having an outof-service power system stabilizer per
the manufacturer recommendations’’
since ‘‘[p]eaking units often operate, for
short periods, at low megawatt levels
(below where manufacture[r]s
recommend placing the [power system
stabilizer] in-service).’’ 57 Thus, it
appears that WECC developed the five
percent threshold provision to account
for out-of-service power system
stabilizer per the manufacturer
recommendations.
82. We seek comment on whether the
proposed provision is written more
broadly than necessary. Comments
should address why it is appropriate to
allow an exemption for any
synchronous generator that ‘‘operates for
less than five percent of all hours during
any calendar quarter’’ to address
concerns about limitations based on
manufacturer recommendations, and
could potentially exempt other
generator operators. Based on the
comments received, the Commission
may propose to direct WECC to develop
a modification through its Reliability
Standards development process that
addresses this concern. It appears that
one reasonable solution would be to
develop a replacement requirement that
directly addresses the need for an
exemption for peaking units that may
not operate with power system
stabilizers to satisfy manufacturer
recommendations.
Power System Stabilizer Replacement
83. Proposed sub-requirement R1.10
lengthens the power system stabilizer
replacement timeline due to component
failure from 15 months to 24 months ‘‘to
accommodate design and procurement
56 Id.
at 40.
57 Id.
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especially for nuclear units.’’ 58 The
Commission notes that no other
evidence was provided in the record to
support the extension of the outage time
frame for the power system stabilizers
from 15 months to 24 months. The
Commission proposes to accept the
Reliability Standard with this
modification.
84. However, since the rationale
provided for the increased replacement
period is based on the needs of nuclear
power generators, we are concerned
whether the additional nine months is
necessary for many, if not most, units.
The additional replacement time could
lead to a decrease in generation units
operating with the power system
stabilizers. In the event of a
contingency, this could have an impact
on bulk electric system reliability.
Accordingly, the Commission seeks
comment from WECC, NERC and other
interested commenters regarding the
historical replacement period for
nuclear and non-nuclear units, and the
appropriateness of the Commission
proposal. For example, comments could
include documentation and timeline
summary of previous ‘‘design and
procurement’’ for power system
stabilizer component failures
demonstrating that power system
stabilizer outages frequently last more
than 15 months in order to support
extending the replacement period.
srobinson on DSKHWCL6B1PROD with PROPOSALS
Power System Stabilizer Tuning
85. The current regional Reliability
Standard requires all generators with
power system stabilizers to be properly
tuned in accordance with the WECC
requirements.59 The proposed regional
Reliability Standard removes the tuning
requirement without explanation or
analysis of the potential impact of
removing the provision. The
Commission believes that, if the power
system stabilizer is in service, it must be
properly tuned to enhance system
damping and maintain system stability.
The Commission, therefore, seeks
further explanation from WECC and
NERC, and public comment on, the
impact of removing the tuning
requirement.
86. This highlights another concern.
Currently, no NERC Reliability Standard
addresses power system stabilizer
tuning. As explained above, a properly
58 NERC Petition at Exhibit C, ‘‘Consideration of
Comments for VAR–501–WECC–1—Power System
Stabilizer Comments were due January 2, 2008.’’
59 Id. Requirement WR1 of the currently-effective
regional Reliability Standard provides: ‘‘Power
System Stabilizers on generators shall be kept in
service at all times, unless one of the exemptions
listed in Section C (Measures) applies, and shall be
properly tuned in accordance with WECC
requirements.’’
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tuned power system stabilizer is
necessary to enhance system damping.
If a power system stabilizer is installed,
periodic review of the power system
stabilizer tuning is a significant
component of maintaining system
stability to ensure that system changes
have not impacted the performance of
the power system stabilizer in
supporting system stability.
Accordingly, the Commission seeks
comment on whether it should propose
to direct the ERO to develop a
continent-wide Reliability Standard to
address this concern. In particular, we
seek comment on directing the ERO to
develop a Reliability Standard with the
purpose of ensuring that, if a power
system stabilizer is installed, the power
system stabilizer must be properly
tuned for operation. Such a Reliability
Standard would not require installation
of a power system stabilizer, but would
ensure that power system stabilizer that
are in service would need to be tuned
prior to service and the settings must be
reviewed periodically to ensure the
power system stabilizer operates
properly to support the reliability of the
Bulk-Power System. The Commission’s
concerns regarding the NERC Reliability
Standard are introduced here as they
correspond with certain elements of the
WECC standards that are the subject of
the immediate proceeding. However,
any proposal to direct the development
of modifications to the NERC Reliability
Standards would be addressed in a
separate proceeding.
Summary
87. The Commission proposes to
approve VAR–501–WECC–1 as just,
reasonable, not unduly discriminatory
or preferential, and in the public
interest. Further, the Commission
proposes the concurrent retirement of
currently-effective WECC VAR–STD–
002b–1. In addition, the Commission
requests comment on issues discussed
above regarding whether the
Commission should direct WECC to
develop modifications to the proposed
regional Reliability Standard that
would: (1) Replace the blanket two
percent exemption with a list of specific
exemptions; and (2) more narrowly
tailor the exemption for any
synchronous generator or synchronous
conductor that operates less than five
percent of all operating hours during
any calendar quarter. The Commission
also seeks comment on the historical
replacement period for nuclear and nonnuclear units and whether the
Commission should direct WECC to
modify the regional Reliability Standard
to limit the acceptable duration of
power system stabilizer outages. Finally,
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the Commission seeks comment on
whether it should propose to direct the
ERO to develop a continent-wide
Reliability Standard that ensures that, if
a power system stabilizer is installed,
the power system stabilizer must be
properly tuned for operation.
IV. Information Collection Statement
88. The Office of Management and
Budget (OMB) regulations require that
OMB approve certain reporting and
recordkeeping (collections of
information) imposed by an agency. The
information contained here is also
subject to review under section 3507(d)
of the Paperwork Reduction Act of 1995.
As stated above, the Commission
previously approved the current
regional Reliability Standards that are
proposed for replacement in this
rulemaking. In the event that the
Commission, after receiving comments,
determines to adopt the four proposed
Reliability Standards, they would not
substantially change the entities’ current
reporting burdens under the five
currently effective, approved Reliability
Standards.
89. The four proposed WECC regional
Reliability Standards (and the five
currently approved regional Reliability
Standards they are intended to replace)
are designated as: FAC–501–WECC–1
(Transmission Maintenance; to replace
approved PRC–STD–005–1); PRC–004–
WECC–1 (Protection System and
Remedial Action Scheme Misoperation;
to replace approved WECC PRC–STD–
001–1 and PRC–STD–003–1); VAR–
002–WECC–1 (Automatic Voltage
Regulators; to replace approved WECC
VAR–STD–002a–1); and VAR–501–
WECC–1 (Power System Stabilizer; to
replace approved WECC VAR–STD–
002b–1). The proposed standards do not
modify or otherwise affect the burdens
related to the collection of information
already in place. Thus, the proposed
replacement Reliability Standards will
neither increase the reporting burden
nor impose any additional information
collection requirements.
Burden Estimate: The Commission
does not foresee any additional impact
on the reporting burden for small
businesses, because the proposed
modifications do not increase the
existing burdens. However, we will
submit this proposed rule to OMB for
review.
Title: Version One Regional
Reliability Standard for Facilities
Design, Connections, and Maintenance;
Protection and Control; and Voltage and
Reactive.
Action: Proposed Collection FERC–
725E.
OMB Control No.: 1902–0246.
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Respondents: Businesses or other forprofit institutions; not-for-profit
institutions.
Frequency of Responses: On occasion.
Necessity of the Information: This
proposed rule proposes to approve four
requested replacements (to five existing
approved regional Reliability
Standards). The proposed regional
Reliability Standards help ensure the
reliable operation of the Western
Interconnection.
Internal Review: The Commission
proposes to approve FAC–501–WECC–
1, PRC–004–WECC–1, VAR–002–
WECC–1, and VAR–501–WECC–1 as
just, reasonable, not unduly
discriminatory or preferential, and in
the public interest. In addition, under
section 215(d)(5) of the FPA and section
39.5(f) of our regulations, the
Commission proposes to direct the ERO
to develop certain modifications to
further clarify the requirements of the
proposed WECC regional Reliability
Standards.
90. Interested persons may obtain
information on the reporting
requirements by contacting the
following: Federal Energy Regulatory
Commission, 888 First Street, NE.,
Washington, DC 20426 [Attention: Ellen
Brown, Office of the Executive Director,
e-mail: DataClearance@ferc.gov, Phone:
(202) 502–8663, fax: (202) 273–0873].
91. For submitting comments
concerning the collection(s) of
information and the associated burden
estimate(s), please send your comments
to the Commission and to the Office of
Management and Budget, Office of
Information and Regulatory Affairs,
Washington, DC 20503 [Attention: Desk
Officer for the Federal Energy
Regulatory Commission, phone (202)
395–4638, fax: (202) 395–7285]. For
security reasons, comments to OMB
should be submitted by e-mail to:
oira_submission@omb.eop.gov.
Comments submitted to OMB should
include Docket Number RM09–14 and
OMB Control Number 1902–0246.
srobinson on DSKHWCL6B1PROD with PROPOSALS
V. Environmental Analysis
92. The Commission is required to
prepare an Environmental Assessment
or an Environmental Impact Statement
for any action that may have a
significant adverse effect on the human
environment.60 The Commission has
categorically excluded certain actions
from this requirement as not having a
significant effect on the human
environment. Included in the exclusion
are rules that are clarifying, corrective,
or procedural or that do not
substantially change the effect of the
regulations being amended.61 The
actions proposed herein fall within this
categorical exclusion in the
Commission’s regulations.
VI. Regulatory Flexibility Act
Certification
93. The Regulatory Flexibility Act of
1980 (RFA) 62 generally requires a
description and analysis of final rules
that will have significant economic
impact on a substantial number of small
entities. The RFA mandates
consideration of regulatory alternatives
that accomplish the stated objectives of
a proposed rule and that minimize any
significant economic impact on a
substantial number of small entities.
The Small Business Administration’s
(SBA) Office of Size Standards develops
the numerical definition of a small
business.63 The SBA has established a
size standard for electric utilities,
stating that a firm is small if, including
its affiliates, it is primarily engaged in
the transmission, generation and/or
distribution of electric energy for sale
and its total electric output for the
preceding twelve months did not exceed
four million megawatt hours.64 The RFA
is not implicated by this proposed rule
because the modification discussed
herein will not have a significant
economic impact on a substantial
number of small entities. Moreover, the
proposed Reliability Standards reflect a
continuation of existing requirements
for these reliability entities.
Accordingly, no regulatory flexibility
analysis is required.
VII. Comment Procedures
94. The Commission invites interested
persons to submit comments on the
matters and issues proposed in this
notice to be adopted, including any
related matters or alternative proposals
that commenters may wish to discuss.
Comments are due February 22, 2011.
Comments must refer to Docket No.
RM09–9–000, and must include the
commenter’s name, the organization
they represent, if applicable, and their
address in their comments.
95. The Commission encourages
comments to be filed electronically via
the eFiling link on the Commission’s
Web site at https://www.ferc.gov. The
Commission accepts most standard
word processing formats. Documents
created electronically using word
processing software should be filed in
61 18
60 Regulations
Implementing the National
Environmental Policy Act of 1969, Order No. 486,
FERC Stats. & Regs. ¶ 30,783 (1987).
VerDate Mar<15>2010
17:40 Dec 21, 2010
Jkt 223001
CFR 380.4(a)(2)(ii).
U.S.C. 601–612.
63 13 CFR 121.101.
64 13 CFR 121.201, Sector 22, Utilities & n. 1.
62 5
PO 00000
Frm 00046
Fmt 4702
Sfmt 9990
80409
native applications or print-to-PDF
format and not in a scanned format.
Commenters filing electronically do not
need to make a paper filing.
96. Commenters unable to file
comments electronically must mail or
hand-deliver an original copy of their
comments to: Federal Energy Regulatory
Commission, Secretary of the
Commission, 888 First Street, NE.,
Washington, DC 20426. These
requirements can be found on the
Commission’s Web site, see, e.g., the
‘‘Quick Reference Guide for Paper
Submissions,’’ available at https://
www.ferc.gov/docs-filing/efiling.asp or
via phone from FERC Online Support at
(202) 502–6652 or toll-free at 1–866–
208–3676.
97. All comments will be placed in
the Commission’s public files and may
be viewed, printed, or downloaded
remotely as described in the Document
Availability section below. Commenters
on this proposal are not required to
serve copies of their comments on other
commenters.
VIII. Document Availability
98. In addition to publishing the full
text of this document in the Federal
Register, the Commission provides all
interested persons an opportunity to
view and/or print the contents of this
document via the Internet through
FERC’s Home Page (https://www.ferc.gov)
and in FERC’s Public Reference Room
during normal business hours (8:30 a.m.
to 5 p.m. Eastern time) at 888 First
Street, NE., Room 2A, Washington, DC
20426.
99. From FERC’s Home Page on the
Internet, this information is available on
eLibrary. The full text of this document
is available on eLibrary in PDF and
Microsoft Word format for viewing,
printing, and/or downloading. To access
this document in eLibrary, type the
docket number excluding the last three
digits of this document in the docket
number field.
100. User assistance is available for
eLibrary and the FERC’s Web site during
normal business hours from FERC
Online Support at (202) 502–6652 (toll
free at 1–866–208–3676) or e-mail at
ferconlinesupport@ferc.gov, or the
Public Reference Room at (202) 502–
8371, TTY (202) 502–8659. E-mail the
Public Reference Room at
public.referenceroom@ferc.gov.
By direction of the Commission.
Kimberly D. Bose,
Secretary.
[FR Doc. 2010–32157 Filed 12–21–10; 8:45 am]
BILLING CODE 6717–01–P
E:\FR\FM\22DEP1.SGM
22DEP1
Agencies
[Federal Register Volume 75, Number 245 (Wednesday, December 22, 2010)]
[Proposed Rules]
[Pages 80397-80409]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-32157]
[[Page 80397]]
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
18 CFR Part 40
[Docket No. RM09-9-000]
Version One Regional Reliability Standards for Facilities Design,
Connections, and Maintenance; Protection and Control; and Voltage and
Reactive
December 17, 2010.
AGENCY: Federal Energy Regulatory Commission, DOE.
ACTION: Notice of proposed rulemaking.
-----------------------------------------------------------------------
SUMMARY: Under section 215 of the Federal Power Act, the Commission
proposes to approve four revised regional Reliability Standards
developed by the Western Electricity Coordinating Council and approved
by the North American Electric Reliability Corporation, which the
Commission has certified as the Electric Reliability Organization
responsible for developing and enforcing mandatory Reliability
Standards. These regional Reliability Standards have been designated by
WECC as FAC-501-WECC-1--Transmission Maintenance, PRC-004-WECC-1--
Protection System and Remedial Action Scheme Misoperation, VAR-002-
WECC-1--Automatic Voltage Regulators, and VAR-501-WECC-1--Power System
Stabilizer. Proposed FAC-501-WECC-1 addresses transmission maintenance
for specified transmission paths in the Western Interconnection.
Proposed PRC-004-WECC-1 addresses the analysis of misoperations that
occur on transmission and generation protection systems and remedial
action schemes in the Western Interconnection. Proposed VAR-002-WECC-1
is meant to ensure that automatic voltage regulators remain in service
on synchronous generators and condensers in the Western
Interconnection. Proposed VAR-501-WECC-1 is meant to ensure that power
system stabilizers remain in service on synchronous generators in the
Western Interconnection. In addition, under section 215(d)(5) of the
Federal Power Act, the Commission proposes to direct the Western
Electricity Coordinating Council, working through its standards
development process, to develop modifications to these to regional
Reliability Standards to address specific issues, as discussed below.
DATES: Comments are due February 22, 2011.
ADDRESSES: You may submit comments, identified by docket number and in
accordance with the requirements posted on the Commission's Web site,
https://www.ferc.gov. Comments may be submitted by any of the following
methods:
Agency Web Site: Documents created electronically using
word processing software should be filed in native applications or
print-to-PDF format, and not in a scanned format, at https://www.ferc.gov/docs-filing/efiling.asp.
Mail/Hand Delivery: Commenters unable to file comments
electronically must mail or hand-deliver an original copy of their
comments to: Federal Energy Regulatory Commission, Secretary of the
Commission, 888 First Street, NE., Washington, DC 20426. These
requirements can be found on the Commission's Web site, see, e.g., the
``Quick Reference Guide for Paper Submissions,'' available at https://www.ferc.gov/docs-filing/efiling.asp or via phone from FERC Online
support at (202) 502-6652 or toll-free at 1-866-208-3676.
FOR FURTHER INFORMATION CONTACT:
A. Cory Lankford (Legal Information) Office of the General Counsel,
Federal Energy Regulatory Commission, 888 First Street, NE.,
Washington, DC 20426, (202) 502-6711.
Nick Henery (Technical Information), Office of Electric Reliability,
Federal Energy Regulatory Commission, 888 First Street, NE.,
Washington, DC 20426, (202) 502-8636.
Danny Johnson (Technical Information), Office of Electric Reliability,
Federal Energy Regulatory Commission, 888 First Street, NE.,
Washington, DC 20426, (202) 502-8892.
Scott Sells (Technical Information), Office of Electric Reliability,
Federal Energy Regulatory Commission, 888 First Street, NE.,
Washington, DC 20426, (202) 502-6664.
SUPPLEMENTARY INFORMATION:
Table of Contents
Paragraph
Nos.
I. Background.............................................. 3
A. Mandatory Reliability Standards..................... 3
B. Western Electricity Coordinating Council............ 6
II. Proposed Regional Reliability Standards................ 8
III. Discussion............................................ 10
A. FAC-501-WECC-1--Transmission Maintenance............ 11
B. PRC-004-WECC-1--Protection System and Remedial 25
Action Scheme Misoperation............................
C. VAR-002-WECC-1--Automatic Voltage Regulators........ 42
D. VAR-501-WECC-1--Power System Stabilizer............. 65
IV. Information Collection Statement....................... 88
V. Environmental Analysis.................................. 92
VI. Regulatory Flexibility Act Certification............... 93
VII. Comment Procedures.................................... 94
VIII. Document Availability................................ 98
1. Under section 215 of the Federal Power Act (FPA),\1\ the
Commission proposes to approve four revised regional Reliability
Standards developed by the Western Electricity Coordinating Council
(WECC) and approved by the North American Electric Reliability
Corporation (NERC), which the Commission has certified as the Electric
Reliability Organization (ERO) responsible for developing and enforcing
mandatory Reliability Standards.\2\ These regional Reliability
Standards have been designated by WECC as FAC-501-WECC-1--Transmission
Maintenance, PRC-004-WECC-1--Protection System and Remedial Action
Scheme Misoperation, VAR-002-WECC-1--Automatic Voltage Regulators, and
VAR-501-WECC-1--Power System Stabilizer. Proposed FAC-501-WECC-1
addresses transmission maintenance for specified transmission paths in
the Western
[[Page 80398]]
Interconnection. Proposed PRC-004-WECC-1 addresses the analysis of
misoperations that occur on transmission and generation protection
systems and remedial action schemes in the Western Interconnection.
Proposed VAR-002-WECC-1 is meant to ensure that automatic voltage
regulators remain in service on synchronous generators and condensers
in the Western Interconnection. Proposed VAR-501-WECC-1 is meant to
ensure that power system stabilizers remain in service on synchronous
generators in the Western Interconnection. Under section 215(d)(5) of
the Federal Power Act, the Commission proposes to direct WECC, through
its standard development process, to develop modifications to these
regional Reliability Standards to address specific issues, as discussed
below.
---------------------------------------------------------------------------
\1\ 16 U.S.C. 824o (2006).
\2\ North American Electric Reliability Corp., 116 FERC ]
61,062, order on reh'g & compliance, 117 FERC ] 61,126 (2006), aff'd
sub nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).
---------------------------------------------------------------------------
2. Related, the Commission also seeks comment on whether it should
direct the ERO to develop modifications to the NERC Reliability
Standards addressing the use of automatic voltage regulators and power
system stabilizers. The Commission's concerns regarding the NERC
Reliability Standard are introduced here as they correspond with
certain elements of the WECC standards that are the subject of the
immediate proceeding. However, any proposal to direct the development
of modifications to the NERC Reliability Standards would be addressed
in a separate proceeding.
I. Background
A. Mandatory Reliability Standards
3. Section 215 of the FPA requires a Commission-certified ERO to
develop mandatory and enforceable Reliability Standards, which are
subject to Commission review and approval. Once approved, the
Reliability Standards may be enforced by the ERO, subject to Commission
oversight, or by the Commission independently.\3\
---------------------------------------------------------------------------
\3\ 16 U.S.C. 824o(e)(3).
---------------------------------------------------------------------------
4. Reliability Standards that the ERO proposes to the Commission
may include Reliability Standards that are proposed to the ERO by a
Regional Entity to be effective in that region.\4\ A Regional Entity is
an entity that has been approved by the Commission to enforce
Reliability Standards under delegated authority from the ERO.\5\ When
the ERO reviews a regional Reliability Standard that would be
applicable on an interconnection-wide basis and that has been proposed
by a Regional Entity organized on an interconnection-wide basis, the
ERO must rebuttably presume that the regional Reliability Standard is
just, reasonable, not unduly discriminatory or preferential, and in the
public interest.\6\ In turn, the Commission must give ``due weight'' to
the technical expertise of the ERO and of a Regional Entity organized
on an interconnection-wide basis.\7\
---------------------------------------------------------------------------
\4\ 16 U.S.C. 824o(e)(4).
\5\ 16 U.S.C. 824o(a)(7) and (e)(4).
\6\ 18 CFR 39.5 (2010).
\7\ 16 U.S.C. 824o(d)(2).
---------------------------------------------------------------------------
5. In Order No. 672, the Commission urged uniformity of Reliability
Standards, but recognized a potential need for regional differences.\8\
Accordingly, the Commission stated that:
---------------------------------------------------------------------------
\8\ Rules Concerning Certification of the Electric Reliability
Organization; Procedures for the Establishment, Approval, and
Enforcement of Electric Reliability Standards, Order No. 672, 71 FR
8662 (Feb. 17, 2006), FERC Stats. & Regs. ] 31,204, at P 290, order
on reh'g, Order No. 672-A, 71 FR 19814 (Apr. 18, 2006), FERC Stats.
& Regs. ] 31,212 (2006).
As a general matter, we will accept the following two types of
regional differences, provided they are otherwise just, reasonable,
not unduly discriminatory or preferential and in the public
interest, as required under the statute: (1) A regional difference
that is more stringent than the continent-wide Reliability Standard,
including a regional difference that addresses matters that the
continent-wide Reliability Standard does not; and (2) a regional
Reliability Standard that is necessitated by a physical difference
in the Bulk-Power System.\9\
---------------------------------------------------------------------------
\9\ Id. P 291.
---------------------------------------------------------------------------
B. Western Electricity Coordinating Council
6. On April 19, 2007, the Commission accepted delegation agreements
between NERC and each of eight Regional Entities.\10\ In its order, the
Commission accepted WECC as a Regional Entity organized on an
Interconnection-wide basis. As a Regional Entity, WECC oversees
transmission system reliability in the Western Interconnection. The
WECC region encompasses nearly 1.8 million square miles, including 14
western U.S. states, the Canadian provinces of Alberta and British
Columbia, and the northern portion of Baja California in Mexico.
---------------------------------------------------------------------------
\10\ North American Electric Reliability Corp., 119 FERC ]
61,060, at P 432 (2007).
---------------------------------------------------------------------------
7. In June 2007, the Commission approved eight regional Reliability
Standards for WECC including the currently-effective WECC PRC-STD-001-
1, PRC-STD-003-1, PRC-STD-005-1, VAR-STD-002a-1, and VAR-STD-002b-
1.\11\ The Commission directed WECC to develop certain modifications to
WECC PRC-STD-001-1, PRC-STD-003-1, PRC-STD-005-1, VAR-STD-002a-1, and
VAR-STD-002b-1, as identified by NERC in its filing letter for the
current standards.\12\ For example, the Commission determined that: (1)
Regional definitions should conform to definitions set forth in the
NERC Glossary of Terms Used in Reliability Standards (NERC Glossary),
unless a specific deviation has been justified; and (2) documents that
are referenced in the Reliability Standard should be attached to the
Reliability Standard. The Commission also found that it is important
that regional Reliability Standards and NERC Reliability Standards
achieve a reasonable level of consistency in their structure so that
there is a common understanding of the elements.
---------------------------------------------------------------------------
\11\ North American Electric Reliability Corp., 119 FERC ]
61,260 (2007).
\12\ Id.
---------------------------------------------------------------------------
II. Proposed Regional Reliability Standards
8. On March 25, 2009, NERC submitted a petition (NERC Petition) to
the Commission seeking approval of four WECC regional Reliability
Standards.\13\ The four proposed WECC regional Reliability Standards
are designated as FAC-501-WECC-1, PRC-004-WECC-1, VAR-002-WECC-1, and
VAR-501-WECC-1.\14\ In its petition, NERC explains that the four
proposed regional Reliability Standards are meant to replace certain
currently approved regional Reliability Standards:
---------------------------------------------------------------------------
\13\ See 18 CFR 39.5(a) (requiring the ERO to submit regional
Reliability Standards on behalf of a Regional Entity).
\14\ The proposed regional Reliability Standards are not
attached to the NOPR. They are, however, available on the
Commission's eLibrary document retrieval system in Docket No. RM09-
9-000 and are posted on the ERO's Web site, available at https://www.nerc.com.
---------------------------------------------------------------------------
FAC-501-WECC-1 is intended to replace the current approved
PRC-STD-005-1;
PRC-004-WECC-1 is intended to replace WECC PRC-STD-001-1
and PRC-STD-003-1;
VAR-002-WECC-1 is intended to replace WECC VAR-STD-002a-1;
and
VAR-501-WECC-1 is intended to replace WECC VAR-STD-002b-1.
NERC states that the NERC board of trustees approved the proposed
regional Reliability Standards on October 29, 2008, on the condition
that WECC address certain shortcomings raised during the comment
periods in the next revision of the Reliability Standards.
9. NERC requests an effective date for FAC-501-WECC-1, VAR-002-
WECC-1, and VAR-501-WECC-1 of the first day of the first quarter after
Commission approval. For PRC-004-WECC-1, NERC requests an effective
date of the first day of the second quarter after approval by the
Commission.
[[Page 80399]]
III. Discussion
10. As discussed below, the Commission proposes to approve FAC-501-
WECC-1, PRC-004-WECC-1, VAR-002-WECC-1, and VAR-501-WECC-1 as just,
reasonable, not unduly discriminatory or preferential, and in the
public interest. In addition, under section 215(d)(5) of the FPA and
section 39.5(f) of our regulations, the Commission proposes to direct
WECC to develop certain modifications to further clarify the
requirements of the proposed WECC regional Reliability Standards.
A. FAC-501-WECC-1--Transmission Maintenance
11. NERC PRC-005-1 applies to all transmission and generator owners
as well as distribution providers that own a transmission protection
system. The Reliability Standard is meant to ensure that all
transmission and generation protection systems affecting the
reliability of the Bulk-Power System are maintained and tested.
12. On June 8, 2007, the Commission approved a WECC regional
Reliability Standard that corresponds to the NERC Reliability Standard
PRC-005-1.\15\ WECC PRC-STD-005-1 applies to transmission owners and
operators identified in an attached table titled ``Major WECC Transfer
Paths in the Bulk Electric System'' (WECC Transfer Path Table) and to
owners of remedial action schemes identified in the ``Major WECC
Remedial Action Schemes'' table (WECC Remedial Action Schemes Table).
WECC PRC-STD-005-1 requires each transmission owner and operator of the
specified transmission paths to perform maintenance and inspection on
those paths as described by its transmission maintenance and inspection
plan. The regional Reliability Standard identifies specific contents
that each applicable transmission owner and transmission operator must
include in its transmission maintenance and inspection plan. For
example, a plan must include the scheduled interval for time-based
maintenance, describe maintenance and inspection methods, provide
relevant checklists or forms, and provide criteria for assessing the
condition of a facility. Each applicable entity must retain all
pertinent maintenance and inspection records for at least five years.
Further each applicable entity must annually certify to WECC staff that
it has developed, documented, and implemented a transmission
maintenance and inspection plan.
---------------------------------------------------------------------------
\15\ North American Electric Reliability Corp., 119 FERC ]
61,260 at P 95.
---------------------------------------------------------------------------
WECC and NERC Proposal
13. NERC states that proposed FAC-501-WECC-1 is intended to replace
approved WECC PRC-STD-005-1. The proposed regional Reliability Standard
would apply to transmission owners that maintain transmission paths
listed in the WECC Transfer Path Table, which is no longer an
attachment to the Reliability Standard but is maintained on the WECC
Web site. Proposed FAC-501-WECC-1 contains three main provisions.
Requirement R1 provides that each transmission owner must have a
transmission, maintenance, and inspection plan, and each transmission
owner must annually review and update as required their transmission
maintenance and inspection plan. Requirement R2 states that each
transmission owner must include specified maintenance categories \16\
when developing their transmission maintenance and inspection plan.
Requirement 3 states that each transmission owner must implement and
follow their transmission maintenance and inspection plan.
---------------------------------------------------------------------------
\16\ The maintenance categories to be included in the
transmission maintenance and inspection plan are included in
Attachment 1 of FAC-501-WECC-1--``Transmission Line and Station
Maintenance Details.''
---------------------------------------------------------------------------
14. NERC recommends approval of FAC-501-WECC-1, stating that the
proposed regional Reliability Standard addresses matters that the NERC
Reliability Standard does not. Specifically, according to NERC, FAC-
501-WECC-1 requires, for specified transmission paths, a highly
detailed maintenance and inspection plan for all transmission and
substation equipment components, beyond the relay and communication
system maintenance and testing required by the corresponding NERC
Reliability Standard.\17\
---------------------------------------------------------------------------
\17\ NERC Petition at 11, 14.
---------------------------------------------------------------------------
NOPR Proposal
15. The Commission proposes to approve FAC-501-WECC-1 as just,
reasonable, not unduly discriminatory or preferential, and in the
public interest. As explained by NERC, proposed FAC-501-WECC-1 appears
to be more stringent, by virtue of its requirement for a highly
detailed maintenance and inspection plan, compared to the corresponding
NERC Reliability Standard.
16. Further, in approving the currently-effective WECC PRC-STD-005-
1, the Commission directed WECC to make certain modifications to the
regional Reliability Standard. To address these directives, the
proposed regional Reliability Standard no longer references any WECC
Forms, and text regarding the Compliance Monitoring Period has been
removed. The proposed regional Reliability Standard no longer refers to
a regional definition of Disturbance, which conflicted with the
definition of Disturbance in the NERC Glossary. Since the term is not
included in any of the proposed regional Reliability Standards, the
Commission proposes to direct the ERO to remove this regional
definition from the NERC Glossary of terms upon Commission approval of
FAC-501-WECC-1. The proposed regional Reliability Standard also removes
the Sanctions Table and includes Violation Risk Factors, Violation
Severity Levels, Measures, and Time Horizons, as directed by the
Commission. These revisions appear generally consistent with the
Commission's directives, and signify meaningful improvement.
Accordingly, we propose to approve FAC-501-WECC-1. We also propose to
approve NERC's petition to retire currently-effective WECC PRC-STD-005-
1.
17. While we propose to approve FAC-501-WECC-1, we have several
concerns regarding the requirements of the proposed regional
Reliability Standard that were not adequately addressed in the NERC
petition. Below, we discuss our concerns and, in the absence of a
satisfactory explanation from WECC, NERC and other commenters, under
section 215(d)(5) of the FPA and section 39.5(f) of our regulations, we
propose to direct that the Regional Entity develop modifications to the
regional Reliability Standard, as discussed below.
WECC Transfer Path Table
18. First, we have a concern regarding the applicability of the
proposed regional Reliability Standard. As mentioned above, WECC PRC-
STD-005-1 is applicable to transmission owners or operators that
maintain transmission paths listed in the WECC Transfer Path Table,
which is attached to the regional Reliability Standard. The attachment
identifies 40 major transmission paths in the Western Interconnection.
By contrast, FAC-501-WECC-1 removes the attachment and, instead,
directs transmission owners to the most current WECC Transfer Path
Table, which is available on the WECC Web site. The table currently
posted on the WECC Web site identifies the same 40 major paths as the
attachment to the approved regional Reliability
[[Page 80400]]
Standard.\18\ However, the Commission is concerned that, by referencing
the WECC Transfer Path Table posted on the WECC Web site, the
applicability of FAC-501-WECC-1 could change without review and
approval by the ERO and the Commission, as required to make effective a
modification to a Reliability Standard.
---------------------------------------------------------------------------
\18\ See Major WECC Transfer Paths table available at https://www.wecc.biz/Standards/Approved%20Standards/Supporting%20Tables/Table%20Major%20Paths%204-28-08.pdf. It appears that the list of
major transfer paths is relatively stable as the list has not
changed for at least the past three years.
---------------------------------------------------------------------------
19. The possibility for the applicability of the Reliability
Standard to change at any time could create confusion for entities that
need to comply as well as any compliance enforcement staff trying to
determine which entities are responsible for complying with the
Reliability Standard. Under section 215(d)(5) of the FPA, we propose to
direct that WECC develop a modification to the Reliability Standard to
address our concern. For example, WECC could include its criterion for
identifying and modifying major transmission paths listed in the WECC
Transfer Path Table and make an informational filing each time it makes
a modification to the table. Another option would be for WECC to file
its criterion with the Commission and post revised transfer path tables
and referenced catalogs on its Web site before they become effective
with concurrent notification to NERC and the Commission. Alternatively,
the Regional Entity could include the WECC Transfer Path Table as an
attachment to the modified Reliability Standard. In this way, the
Commission would be able to verify that the Regional Entity is applying
the requirements of the regional Reliability Standard in a just and
reasonable manner.
System Operating Limits (SOL)
20. Second, the Commission is concerned about WECC's use of the
term System Operating limit, as it is defined in the NERC Glossary.\19\
Currently, WECC determines transfer capability based on a ``rated
system path'' methodology and the table of Major WECC Transfer Paths
and associated catalog identify the facilities that make up each rated
system path. For at least ten years, WECC has used the defined term
Operating Transfer Capability limits, and not System Operating Limit,
to describe transmission limitations. WECC TOP-STD-007-0 defines
Operating Transfer Capability limits as:
---------------------------------------------------------------------------
\19\ A System Operating Limit is defined in the NERC Glossary as
``the value (such as MW, MVar, Amperes, Frequency or Volts) that
satisfies the most limiting of the prescribed operating criteria for
a specified system configuration to ensure operation within
acceptable reliability criteria.'' See NERC Glossary, available at
https://www.nerc.com/docs/standards/rs/Glossary_of_Terms_2010April20.pdf.
* * * the maximum amount of actual power that can be transferred
over direct or parallel transmission elements comprising:
An interconnection from one Transmission Operator area
to another Transmission Operator area; or
A transfer path within a Transmission Operator area.
The net schedule over an interconnection or transfer path within
a Transmission Operator area shall not exceed the [operating
transfer capability], regardless of the prevailing actual power flow
on the interconnection or transfer path.
Unlike a System Operating Limit, the definition of Operating
Transfer Capability limits is limited to direct or parallel
transmission elements between or within specific transmission
operators. Moreover, the rating of a System Operating Limit, which is
based on an operating criteria that is either thermally (based on
facility ratings) or stability-based (based on transient stability,
voltage stability, or system voltage limits) is the first element to
calculate in order to determine the Operating Transfer Capability limit
rating.
21. Based on the above, it appears that a System Operating Limit is
not the same as an Operating Transfer Capability limit. Yet, WECC and
NERC believe that the terms can be used interchangeably and that WECC
revised the regional Reliability Standard to refer to System Operating
Limits to conform its terminology to the NERC Glossary. While we
believe using NERC Glossary terminology is generally preferable,\20\ we
are concerned that, in this instance, the use of a regional definition
might be most appropriate.
---------------------------------------------------------------------------
\20\ See W. Elec. Coordinating Council Reg'l Reliability
Standard Regarding Automatic Time Error Corr., Order No. 723, 74 FR
25442 (May 28, 2009), 127 FERC ] 61,176, at P 38-40 (2009).
---------------------------------------------------------------------------
22. Specifically, the Commission is concerned that the introduction
of the NERC Glossary definition of System Operating Limit in
Requirement R1 of the proposed regional Reliability Standard could
create confusion regarding which transmission owners are required to
maintain a transmission maintenance and inspection plan. Requirement R1
of the approved WECC Reliability Standard requires transmission owners
to inspect and maintain ``all bulk power transmission elements (i.e.,
lines, stations and rights of way) included as part of the transmission
facilities (or required to maintain transfer capability) impacting each
of the transmission paths listed * * *.'' \21\ By contrast, Requirement
R1 of WECC's proposed regional Reliability Standard would require
transmission owners to maintain a transmission maintenance and
inspection plan detailing their inspection and maintenance requirements
that ``apply to all transmission facilities necessary for System
Operating Limits associated with each of the transmission paths
identified in the WECC Transfer Path Table.'' \22\ Facilities that are
System Operating Limits associated with transmission paths identified
in the WECC Transfer Path Table are not necessarily on paths identified
in the WECC Transfer Path Table.
---------------------------------------------------------------------------
\21\ WECC Reliability Standard PRC-STD-005-1, Requirement R1.
\22\ Proposed WECC Reliability Standard, FAC-501-WECC-1,
Requirement R1, emphasis added.
---------------------------------------------------------------------------
23. Thus, under the proposed language, Requirement R1 could apply
to more transmission facilities than identified in the WECC Transfer
Path Table. For example, a System Operating Limit for a rated path in
the WECC Transfer Path Table could be defined by a facility on a path
that is not identified in the WECC Transfer Path Table but which is
associated with an identified path. Under these circumstances, it is
unclear whether Requirement R1 would require maintenance on these
facilities that are not identified in the WECC Transfer Path Table. If
so, the requirement might need to apply to transmission owners that do
not own any paths identified in the WECC Transfer Path Table.
Accordingly, the Commission seeks comment as to whether, under
Requirement R1, a transmission owner that owns a major path would be
responsible for maintaining and inspecting transmission facilities
owned by another entity if such facilities are ``necessary for [System
Operating Limits] associated with'' the major path.
Summary
24. In summary, the Commission proposes to approve FAC-501-WECC-1.
The Commission also proposes to approve NERC's petition to retire
currently-effective WECC PRC-STD-005-1. In addition, the Commission
requests comment on two issues discussed above regarding the (1) Major
WECC Transfer Path table, and (2) use of the term System Operating
Limits.
[[Page 80401]]
B. PRC-004-WECC-1--Protection System and Remedial Action Scheme
Misoperation
Background--Currently-Effective PRC-STD-001-1 and PRC-STD-003-1
25. Currently-effective WECC PRC-STD-001-1 applies to transmission
operators or transmission owners of 40 specified transmission paths.
The regional Reliability Standard requires these entities to certify to
WECC that all (1) protective relay applications and (2) protective
relay settings and logic are appropriate for the specified transmission
paths. It also requires that these entities, once every three years,
certify that information is updated and accurate.
26. WECC PRC-STD-001-1 corresponds with NERC PRC-001-1, which
addresses protection systems, requires transmission operators and
generator operators to notify appropriate entities of relay or
equipment failures and to coordinate when installing new or modified
protection systems.
27. Currently-effective WECC PRC-STD-003-1 applies to transmission
operators and owners of the same 40 specified transmission paths as
Reliability Standard PRC-STD-001-1. WECC PRC-STD-003-1 requires
applicable transmission operators and owners to ensure all transmission
and generation protection system misoperations affecting the
reliability of the bulk electric system are analyzed and mitigated.
28. WECC PRC-STD-003-1 corresponds to NERC PRC-003-1, which also
relates to protection system misoperations.
WECC and NERC Proposal
29. NERC states that proposed PRC-004-WECC-1 is intended to replace
two currently-effective WECC Reliability Standards, PRC-STD-001-1 and
PRC-STD-003-1. NERC recommends approval of PRC-004-WECC-1, explaining
that it is more stringent than the corresponding NERC PRC-004-1.
Specifically, NERC explains that PRC-004-WECC-1 requires that all
transmission and generation protection system and remedial action
scheme misoperations on major WECC transfer paths be analyzed and
mitigated within a specific timeframe. In contrast, NERC PRC-003-1
requires Regional Entities to establish procedures for review,
analysis, reporting, and mitigation of transmission and generation
Protection System Misoperations, but it does not specifically address
the owners of the transmission and generation facilities. NERC also
explains that NERC PRC-004-1 has requirements for protection system
misoperations, but does not provide for the additional requirements
included in PRC-004-WECC-1.\23\
---------------------------------------------------------------------------
\23\ See NERC Petition at 11, 19-20.
---------------------------------------------------------------------------
30. Proposed PRC-004-WECC-1 contains three main provisions.
Requirement R1 provides that ``System Operators and System Protection
Personnel'' of transmission owners and generator owners must analyze
all protection system and remedial action scheme operations.
Requirements R1.1 and R1.2 identify time limits for the review and
analysis of transmission element tripping, remedial action scheme
operations and protection systems. Requirement R2 and the associated
sub-requirements identify actions expected to be performed by
transmission owners and generator owners for each protection system or
remedial action scheme misoperation, including identifying timelines
for removing the equipment that failed from service. Requirement R3
states that transmission owners and generator owners are to submit
incident reports for any misoperation or repair of equipment that
misoperated.
31. Like the approved regional Reliability Standard, the proposed
regional Reliability Standard is applicable to transmission owners and
transmission operators, but it also is applicable to the generator
owners that own facilities listed in the WECC Transfer Path Table and
the WECC Remedial Action Schemes Table, which are available on WECC's
Web site.\24\ In addition, WECC proposes four new regional definitions
for Functionally Equivalent Protection System, Functionally Equivalent
Remedial Action Scheme, Security-Based Misoperation and Dependability
Based Misoperation.
---------------------------------------------------------------------------
\24\ See proposed regional Reliability Standard PRC-004-WECC-1,
Section 4 (Applicability).
---------------------------------------------------------------------------
NOPR Proposal
32. The Commission proposes to approve PRC-004-WECC-1 as just,
reasonable, not unduly discriminatory or preferential, and in the
public interest. The Commission also proposes to approve NERC's
petition to withdraw currently-effective WECC PRC-STD-001-1 and WECC
PRC-STD-003-1. As NERC explains above, it appears that the proposed
PRC-004-WECC-1 is more stringent than the corresponding NERC PRC-004-1.
Moreover, the proposed PRC-004-WECC-1 addresses Commission directives
to develop modifications to the currently-effective regional
Reliability Standards.
33. Specifically, in approving the currently-effective WECC PRC-
STD-001-1 and WECC PRC-STD-003-1, the Commission directed WECC to make
certain modifications in developing replacement Reliability Standards.
To address these directives, in the proposed Standard, WECC no longer
references any WECC forms, and the text regarding the compliance
monitoring period has been removed from the proposed Standard. In
addition, the proposed regional Reliability Standard no longer
references the regional definition of Disturbance, which did not match
the NERC definition of Disturbance in the NERC Glossary. The proposed
regional Reliability Standard also would remove the definition for
Business Day. Since these terms are not included in any of the existing
or proposed regional Reliability Standards, the Commission proposes to
direct the ERO to remove these regional definitions from the NERC
Glossary, upon approval of the PRC-004-WECC-1. The proposed regional
Reliability Standard also removes the sanctions table and includes
violation risk factors, violation severity levels, measures and time
horizons. The Commission commends WECC for addressing these directives.
34. Nevertheless, the Commission has concerns regarding several
provisions of the proposed regional Reliability Standard, and seeks
additional comments, as discussed below.
WECC Transfer Path Table
35. Similar to the discussion above regarding proposed FAC-501-
WECC-1, we are concerned regarding the removal of the list of major
transmission paths from proposed PRC-004-WECC-1 and the replacement
with a link to the WECC Web site. Currently-effective WECC PRC-STD-003-
1 is applicable to transmission owners or operators that maintain
transmission paths listed in an attachment to the Reliability Standard.
The attachment identifies 40 major transmission paths in the Western
Interconnection. By contrast, the proposed PRC-004-WECC-1 removes
attachment A and, instead, directs transmission owners to the most
current WECC Transfer Path Table, which is available on the WECC Web
site. Although the table posted on the WECC Web site lists the same 40
major paths as the attachment to the approved regional Reliability
Standard, the Commission is concerned that by referencing the WECC
Transfer Path Table posted on the WECC Web site, WECC could modify the
document without Commission and industry notice and opportunity to
respond.
36. The possibility for the applicability of the Reliability
Standard
[[Page 80402]]
to change at any time could create confusion for entities that need to
comply as well as any compliance enforcement staff trying to determine
which entities are responsible for complying with the Reliability
Standard. Accordingly, the Commission seeks comment on how NERC and
WECC intend to develop and provide notice of proposed changes to the
WECC Transfer Path Table. We also seek comment on how NERC and WECC
will ensure that changes to the applicability of the Reliability
Standard will not undermine its effectiveness. We propose to direct
WECC to develop a modification to the Reliability Standard to address
our concern. For example, WECC could include its criterion for
identifying and modifying major transmission paths listed in the WECC
Transfer Path Table and make an informational filing each time it makes
a modification to the table. Another option would be for WECC to file
its criterion with the Commission and post revised transfer path tables
and referenced catalogs on its Web site before they become effective
with concurrent notification to NERC and the Commission. Alternatively,
the Regional Entity could include the WECC Transfer Path Table as an
attachment to the modified Reliability Standard. In this way, the
Commission would be able to verify that the Regional Entity is applying
the requirements of the regional Reliability Standard in a just and
reasonable manner.
Proposed Regional Definitions
37. The proposed regional Reliability Standard includes four new
regional definitions meant to apply only in WECC. Two of the proposed
definitions (Functionally Equivalent Protection System and Functionally
Equivalent Remedial Action Scheme) have added ``functionally
equivalent'' to terms that already exist in the NERC Glossary.\25\ The
NERC Glossary definition of Protection System lists the types of
equipment that can be used as protection systems (i.e. protective
relays, associated communication systems, voltage and current sensing
devices, station batteries and DC control circuitry). By contrast, the
proposed WECC definition of Functionally Equivalent Protection System
is not limited to any specific components or operating characteristics
but, instead, defines Functionally Equivalent Protection Systems based
on what they can do: ``[e]ach Protection System can detect the same
faults within the zone of protection and provide the clearing times and
coordination needed to comply with all Reliability Standards.'' In
addition, the NERC Glossary defines Remedial Action Scheme, or Special
Protection System, as ``[a]n automatic protection system designed to
detect abnormal or predetermined system conditions, and take corrective
actions other than and/or in addition to the isolation of faulted
components to maintain system reliability.'' \26\ By contrast, WECC
proposes to define Functionally Equivalent RAS as ``[a] Remedial Action
Scheme that provides the same performance as follows: Each [Remedial
Action Scheme] can detect the same conditions and provide mitigation to
comply with all Reliability Standards. Each [Remedial Action Scheme]
may have different components and operating characteristics.''
---------------------------------------------------------------------------
\25\ See NERC Glossary definitions for Protection System and
Remedial Action Scheme.
\26\ NERC Glossary definition of Special Protection System
(Remedial Action Scheme), available at https://www.nerc.com/docs/standards/rs/Glossary_of_Terms_2010April20.pdf.
---------------------------------------------------------------------------
38. The Commission has expressed concern about the unnecessary
proliferation of glossary terms and has directed the ERO to be vigilant
in assuring that a regional definition is consistent with both NERC
Glossary terms and other approved Regional Entity glossary terms.\27\
In the instant proceeding, we are concerned that the proposed
definitions of Functionally Equivalent Protection System and
Functionally Equivalent RAS do not add any further clarity to the NERC
Glossary terms. Accordingly, we seek an explanation from WECC and other
interested commenters regarding whether these new terms are more
inclusive than the corresponding NERC Glossary definitions and, if so,
how.
---------------------------------------------------------------------------
\27\ Order No. 723, 74 FR 25,442 at P 37-40.
---------------------------------------------------------------------------
39. WECC proposes to define Functionally Equivalent Protection
System as ``[a] Protection System that provides performance as follows:
Each Protection System can detect the same faults within the zone of
protection * * *.'' \28\ It is unclear what the phrase ``detect the
same faults'' means within this definition. For example, this phrase
could refer to the ability of one protection system to act as a back-up
for another protection system. Alternatively, this phrase could imply
that a protection system should be able to detect a fault within in a
different sub-area of the same zone of protection. Accordingly, we seek
comment on the meaning of the phrase ``the same faults'' within the
definition.
---------------------------------------------------------------------------
\28\ See Proposed Reliability Standard PRC-004-WECC-1, proposed
definition of Functionally Equivalent Protection System.
---------------------------------------------------------------------------
40. In addition, the current NERC Glossary definition of
Misoperation includes: (1) Failure of a protection system to operate;
(2) protection system operation for a fault outside of the planned zone
of protection; and (3) unintentional operation of a protection system.
Instead of using this NERC Glossary definition, WECC has developed two
new terms: Security-Based Misoperations and Dependability-Based
Misoperations. The proposed WECC definitions address: (1) Incorrect
operation of a protection system (Security-Based Misoperation); and (2)
absence of a protection system to operate (Dependability-Based
Misoperation). The bifurcation of the term Misoperation may be
confusing because at least some of the requirements for each type of
misoperation appear to overlap. We seek an explanation from WECC and
other interested commenters regarding why these two new regional terms
are necessary or desirable within the context of the proposed regional
Reliability Standard, and how they will enhance reliability.
Summary
41. The Commission proposes to approve PRC-004-WECC-1 as just,
reasonable, not unduly discriminatory or preferential, and in the
public interest. The Commission also proposes to approve NERC's
petition to withdraw currently-effective WECC PRC-STD-001-1 and WECC
PRC-STD-003-1. In addition, the Commission requests comment on three
issues discussed above regarding (1) the Major WECC Transfer Path
table; (2) whether the proposed regional terms, Functionally Equivalent
Protection System and Functionally Equivalent RAS, are more inclusive
than the corresponding NERC Glossary definitions; and, (3) the
necessity of the proposed regional terms, Security-Based Misoperations
and Dependability-Based Misoperations.
C. VAR-002-WECC-1--Automatic Voltage Regulators
Background
42. Applicable to all generator operators and generator owners,
NERC VAR-002-1.1b is meant to ensure that generators provide reactive
and voltage control necessary to ensure voltage levels, reactive flows,
and reactive resources are maintained within applicable facility
ratings to protect equipment and the reliable operation of the
Interconnection. Unless exempted by the transmission operator, each
[[Page 80403]]
generator operator must maintain the generator voltage or reactive
power output (within applicable facility ratings) \29\ as directed by
the transmission operator. Thus, the NERC Reliability Standard does not
require generator operators to operate in automatic voltage control
mode when they are operating outside of their facility rating, e.g.,
generators that are starting-up or generators used to serve peak load
that typically run at low megawatt levels.
---------------------------------------------------------------------------
\29\ NERC defines ``facility rating'' as the maximum or minimum
voltage, current, frequency, or real or reactive power flow through
a facility that does not violate the applicable equipment rating of
any equipment comprising the facility.
---------------------------------------------------------------------------
43. On June 8, 2007, the Commission approved WECC VAR-STD-002a-1,
which applies to generator operators of synchronous generating units
equipped with automatic voltage regulators in the Western
Interconnection. The stated purpose of the regional Reliability
Standard is to ensure that automatic voltage control equipment on
synchronous generators shall be kept in service at all times, except in
specified circumstances, and that outages of such equipment must be
coordinated. It requires that generator operators must normally operate
automatic voltage control equipment in voltage control mode and set to
respond effectively to voltage deviations. Nevertheless, the levels of
non-compliance associated with the approved regional Reliability
Standard permit generator operators to operate without automatic
voltage control equipment for two percent of the operating hours in a
calendar year without penalty. The Commission approved the current
regional Reliability Standard as more stringent than the NERC
Reliability Standard because the WECC regional Reliability Standard
requires synchronous generators to have their automatic voltage
regulators in service at all times with exceptions limited to specific
circumstances. In contrast, the NERC Reliability Standard does not
specify a list of exceptions, which could mean that transmission
operators may, upon request of the generator operators, permit outages
of automatic voltage regulators for a broader range of reasons.\30\
---------------------------------------------------------------------------
\30\ North American Electric Reliability Corp., 119 FERC ]
61,260 at P 116.
---------------------------------------------------------------------------
WECC and NERC Proposal
44. NERC requests approval of VAR-002-WECC-1 (Automatic Voltage
Regulators) and requests the concurrent retirement of WECC VAR-STD-
002a-1. Proposed VAR-002-WECC-1 would be applicable to all generator
operators and transmission operators that operate synchronous
condensers. It would only apply to synchronous generators and
synchronous condensers that are connected to the bulk electric system.
45. Proposed VAR-002-WECC-1 contains two requirements. Requirement
R1 provides that each generator operator and transmission operator
shall have automatic voltage regulators in service and in automatic
voltage control mode for synchronous generators and synchronous
condensers during 98 percent of all operating hours unless exempted by
the transmission operator. Sub-requirements R1.1 through R1.10 detail
the type of exemptions that the transmission operator may grant to the
generator operator to excuse the generator from operating the automatic
voltage regulator in automatic voltage control mode. Requirement R2
states that each generator operator and transmission operator must have
documentation identifying the number of hours excluded for each sub-
requirement R1.1 through R1.10.
46. WECC also proposes to replace the sanctions table with
violation risk factors, violation severity levels, measures and time
horizons. Finally, WECC proposes a new glossary term, Commercial
Operation, to be applicable only in the Western Interconnection.
47. During the standards development process, NERC expressed
concern that proposed Requirement R1 was less stringent than the
current NERC Reliability Standard.\31\ WECC responded that, although
Requirement R1 appears to decrease the number of operating hours that a
generator operator and transmission operator must keep automatic
voltage regulators in service and in automatic voltage control mode
from 100 percent to 98 percent, the 98 percent requirement is a
translation of the limits set in the levels of non-compliance
associated with the current regional Reliability Standard.\32\ In
addition, WECC explained that the two percent allowance provides more
time to start up generating facilities when the automatic voltage
regulators are not yet in voltage control mode and allows for
evaluation when a generator operator responds to an unforeseen
event.\33\ WECC also pointed out that NERC VAR-002-1a does not place
any restrictions on the length of time or range of acceptable reasons
for operating in modes other than automatic voltage control mode. By
contrast, WECC pointed out that the proposed VAR-002-WECC-1 limits the
range of acceptable reasons and time for operating a generator without
the automatic voltage regulator in service and controlling voltage.\34\
---------------------------------------------------------------------------
\31\ NERC Petition at 34.
\32\ The levels of non-compliance assigned to the currently-
effective regional Reliability Standard specify that there shall be
a level 1 non-compliance if automatic voltage regulators are in
service less than 98 percent but at least 96 percent or more of all
hours during which the synchronous generating unit is on line for
each calendar quarter.
\33\ Specifically, WECC explains ``[t]he two percent allowance
provides for time to start up generating facilities when the
[automatic voltage regulators] are not yet in voltage control mode.
It also allows for evaluation when the Generator Operators respond
to unforeseen events.'' WECC further explains ``[p]eaking units
often operate, for short periods, at low megawatt levels (below
where manufactures recommend placing the [automatic voltage
regulators] in-service). The exclusion below the five percent
threshold during a calendar quarter permits the continued practice
of allowing the operation of peaking units without penalty for
having an out-of-service [automatic voltage control regulators] per
the manufacturer recommendations.'' NERC Petition at 34-35.
\34\ Id.
---------------------------------------------------------------------------
48. NERC also notes that, during the Reliability Standards
development process, it expressed concern regarding sub-requirement
R1.1, which includes an exemption for units operating less than five
percent of all hours during a calendar quarter. NERC explains that it
raised a concern that the proposed sub-requirement ``excludes the hours
attributed to the synchronous generator or condenser that operates for
less than five percent of all hours during any calendar quarter.'' \35\
WECC responded by explaining that there is no change in the basic five
percent threshold between the existing regional Reliability Standard
and the proposed regional Reliability Standard. WECC further explained
that peaking units often operate, for short periods, at low megawatt
levels (below where manufacturers recommend placing the automatic
voltage regulators in-service). WECC states that the exclusion below
the five percent threshold during a calendar quarter permits the
continued practice of allowing the operation of peaking units without
penalty for having an out-of-service automatic voltage regulator per
the manufacturer's recommendations.\36\
---------------------------------------------------------------------------
\35\ Id. at 34-35.
\36\ Id. at 35.
---------------------------------------------------------------------------
49. NERC states that, whereas NERC VAR-002-1a requires only that a
generator operator notify its transmission operator when it either
removes or operates the automatic voltage regulator in a condition
other than automatic voltage control mode and does not limit the amount
of time for such operations, the proposed WECC regional Reliability
Standard sets only very limited circumstances for when a generator's
automatic voltage regulator should be operated in a mode other than
[[Page 80404]]
the automatic voltage control mode and further limits the cumulative
timeframe for doing so. Thus, NERC represents that the proposed
regional Reliability Standard is more stringent than the NERC
Reliability Standard.\37\
---------------------------------------------------------------------------
\37\ Id. at 29.
---------------------------------------------------------------------------
NOPR Proposal
50. The Commission proposes to approve VAR-002-WECC-1 as just,
reasonable, not unduly discriminatory or preferential, and in the
public interest. Further, the Commission proposes the concurrent
retirement of currently-effective WECC VAR-STD-002a-1. As represented
by NERC, it appears that proposed VAR-002-WECC-1 is more stringent than
the corresponding NERC Reliability Standard.
51. Moreover, in approving the currently-effective WECC VAR-STD-
002a-1, the Commission directed WECC to make certain modifications in
developing a replacement Reliability Standard. To address these
directives, WECC has added violation risk factors, violation severity
levels, measures and time horizons, and has removed the sanctions
table. WECC also has re-written Requirement WR1 so that it does not
include more than one main topic, removed language suggested to move to
the Additional Compliance Information section, and removed the
reference to Form A.5 to address recommendations made by NERC to modify
WECC VAR-STD-002a-1.\38\ Thus, it appears that proposed VAR-002-WECC-1
maintains stringencies above the corresponding NERC Reliability
Standard while providing additional clarity and conformity. Thus, the
Commission proposes to approve the regional Reliability Standard.
---------------------------------------------------------------------------
\38\ See id. at 31.
---------------------------------------------------------------------------
52. In addition, the Commission seeks comments on several issues
posed by the WECC proposal, as discussed below.
Automatic Voltage Regulators
53. Requirement R1 of proposed VAR-002-WECC-1 provides that
``Generator Operators and Transmission Operators shall have [automatic
voltage regulators] in service and in automatic voltage control mode
98% of all operating hours for synchronous generators or synchronous
condensers.'' \39\ Requirement R1 then identifies ten circumstances in
which a generator operator or transmission operator is excused from
this requirement. By specifying the circumstances in which a generator
operator or transmission operator is excused from operating in
automatic voltage regulator mode, the proposed requirement appears to
be more stringent than the requirement in NERC VAR-002-1.1b.
---------------------------------------------------------------------------
\39\ Proposed regional Reliability Standard VAR-002-WECC-1,
Requirement R1.
---------------------------------------------------------------------------
54. The Commission believes that, where installed, automatic
voltage regulators should be in-service at all times except in
circumstances when the generator is operating at an output level that
is not within the design parameters of the automatic voltage regulator
or operations of the automatic voltage regulator would result in
instability. Automatic voltage regulators are intended to assist in
maintaining the reliability of the Bulk-Power System by controlling
system voltages. In addition, System Operating Limits for transmission
paths in the bulk electric system in the Western Interconnection assume
that automatic voltage regulators are in service to control voltage to
support the transfer capability.\40\ When automatic voltage regulators
are out of service, the time required to appropriately respond to
disturbances that cause voltage deviations would increase due to the
time required to take manual action. If not corrected in sufficient
time, these voltage deviations could lead to instability, uncontrolled
separation and cascading outages.
---------------------------------------------------------------------------
\40\ See NERC Petition at 29.
---------------------------------------------------------------------------
55. Although the proposed regional Reliability Standard would limit
the circumstances in which a transmission operator or generator
operator is excused from keeping automatic voltage regulators in
automatic voltage control mode, it also provides a blanket exemption
for two percent of all operating hours. In its petition, NERC explains
that this exemption would accommodate generating facilities when they
are starting up and when the automatic voltage regulators are not yet
in voltage control mode. NERC also explains that this exemption allows
for evaluation when the generator operators respond to unforeseen
events.\41\ These limitations identified by NERC in its petition are
not explicit in the requirements of the proposed regional Reliability
Standard.
---------------------------------------------------------------------------
\41\ NERC Petition at 34-35.
---------------------------------------------------------------------------
56. We are concerned that the proposed provision is written more
broadly than necessary. We believe it is appropriate to exempt
automatic voltage regulators from being in-service during times when
the generator is operating outside of applicable facility ratings.
However, as proposed, Requirement R1 would provide generators with a
blanket exemption--equal to two percent of all operating hours--from
the requirement to maintain automatic voltage regulators in-service. We
seek comment on whether the Commission should direct WECC to develop a
modification to the proposed regional Reliability Standard to address
our concern. For example, consistent with NERC's explanation, NERC
could develop a modification replacing the blanket two percent
exemption with a list of specific exemptions that would accommodate
generating units that are starting up or responding to unforeseen
events and are operating outside of applicable facility ratings.
57. The purpose of NERC VAR-002-1.1b is to ensure appropriate
reactive and voltage control are provided to maintain voltage levels,
reactive flows, and reactive resources are within applicable facility
ratings for Reliable Operation. Requirement R1 of VAR-002-1.1b states
that the ``Generator Operator shall operate each generator connected to
the interconnected transmission system in the automatic voltage control
mode (automatic voltage regulator in service and controlling voltage)
unless the Generator Operator has notified the Transmission Operator.''
Requirement R2 continues that ``[u]nless exempted by the Transmission
Operator, each Generator Operator shall maintain the generator voltage
or Reactive Power output (within applicable Facility Ratings) as
directed by the Transmission Operator.'' Based on the same rationale
articulated regarding the two percent exemption in the regional
Reliability Standard, we have a concern regarding the corresponding
NERC Reliability Standard. In particular, we seek comment on whether it
would provide additional support for Bulk-Power System reliability to
propose to direct the ERO to develop a modification to NERC VAR-002-
1.1b. Specifically to clarify that, if a generator has an automatic
voltage regulator installed, it must be in-service and controlling
voltage at all times, equipment and facility ratings permitting, unless
exempted by the transmission operator. We believe that such a
modification could be consistent with Commission precedent.\42\ The
Commission's concerns regarding the NERC Reliability Standard are
introduced here as they correspond with certain elements of the WECC
standards that are the subject of the immediate proceeding. However,
any proposal to direct the development of modifications to the NERC
Reliability
[[Page 80405]]
Standards would be addressed in a separate proceeding.
---------------------------------------------------------------------------
\42\ Order on Reliability Standard Interpretation, 132 FERC ]
61,220, at P 27 (2010) (VAR Interpretation Order).
---------------------------------------------------------------------------
Exclusion of Synchronous Generators that Operate for Less Than Five
Percent of All Hours During a Calendar Quarter
58. Requirement R1.1 of proposed VAR-002-WECC-1 would allow
exclusion of any synchronous generator or synchronous condenser that
``operates for less than five percent of all hours during any calendar
quarter'' from operating with automatic voltage regulator in service
and in automatic voltage control mode. During the Reliability Standard
development process of the proposed regional Reliability Standard, NERC
expressed concern regarding the exclusion of these hours.\43\ WECC
responded by explaining that the ``exclusion below the five percent
threshold during a calendar quarter permits the continued practice of
allowing the operation of peaking units without penalty for having an
out-of-service [automatic voltage regulator] per the manufacturer
recommendations'' since ``[p]eaking units often operate, for short
periods, at low megawatt levels (below where manufacture[r]s recommend
placing the [automatic voltage regulators] in-service).'' \44\ Thus, it
appears that WECC developed the five percent threshold provision to
account for out-of-service automatic voltage regulators per the
manufacturer recommendations regarding automatic voltage regulator
design limitations.
---------------------------------------------------------------------------
\43\ NERC Petition at 34-35.
\44\ Id. at 35.
---------------------------------------------------------------------------
59. We are concerned, however, that the provision is written more
broadly than necessary. It appears inefficient to allow an exemption
for any synchronous generator or synchronous condenser that ``operates
for less than five percent of all hours during any calendar quarter''
in order to address concerns about operation limits based on
manufacture recommendations, and could potentially exempt other
generator operators and transmission operators. The Commission seeks
co