MOD Final Voting Record

Transcription

1 Final Voting Record Ballot Name: Verification of Models and Data for Generator Excitation Control or Plant Volt/VAR Control Function Ballot Pool Opened: 07/05/ /29/2016 Ballot Period: 08/09/ /25/2016 Total Ballot Pool: 108 Total Number of Votes: 90 Quorum: 83.3% Weighted Vote: 24.2% Ballot Results: The Document has Not Passed Voting Sectors Total In Ballot Pool Votes Non- Abstain Sector Weight Yes Votes Weighted Segment Vote No Votes Abstain Total Votes for Quorum Didn't Vote Distribution % End User Representative % Generation % Marketers and Brokers % Other Non-Registered WECC Members and Participating Stakeholders % State and Provincial Representatives % % Transmission % Totals % WESTERN ELECTRICITY COORDINATING COUNCIL 155 North 400 West, Suite 200 Salt Lake City, Utah

2 Final Voting Record 2 AES Corporation Generation 0 Leo Bernier Arizona Public Service Company No AZPS does not support the approval of these WECC Regional Standards and reiterates its previously submitted comments. AZPS respectfully submits that the current national NERC-approved standards are appropriate and sufficient for the Western Interconnection and, therefore, suggests that a regional variation is not necessary or appropriate. As such, AZPS recommends that WECC not impose any additional requirements. Stephanie Little Arizona Public Service Company Arizona Public Service Company Arizona Public Service Company Arizona Public Service Company Balancing Authority of Northern California Marketers and Brokers No See AZPS Comments Above Todd Komaromy Transmission No See AZPS Comments Above Gary Nolan Generation No See AZPS Comments Above Jeri Freimuth Distribution No See AZPS Comments Above Michelle Amarantos Yes Joe Tarantino Basin Electric Power Cooperative Basin Electric Power Cooperative Transmission No Basin Electric prefers NO additional Regional variation for this NERC Standard. The NERC Standard is sufficient to ensure reliability. David Rudolph Distribution No See Basin Electric Comments Above David Rudolph

3 Final Voting Record 3 Basin Electric Power Cooperative Basin Electric Power Cooperative Generation No See Basin Electric Comments Above David Rudolph No See Basin Electric Comments Above David Rudolph Black Hills Corporation Generation Yes Sheila Suurmeier Black Hills Corporation Transmission 0 Wes Wingen Bonneville Power Administration Bonneville Power Administration Bonneville Power Administration Bonneville Power Administration Transmission Yes Donald Watkins Yes Francis Halpin Distribution Yes Rebecca Berdahl Marketers and Brokers Yes Alex Spain

4 Final Voting Record 4 British Columbia Hydro & Power Authority (aka BC Hydro) Distribution No 1. BC Hydro does not believe that the WECC 026 and -027 regional variance standards to the approved NERC 026 and 027 standards are necessary. From Posting 4, it was stated that the models have improved under the WECC Policy. However the Posting also goes on to state that WECC Policies are voluntary and unenforceable. If WECC members have been following the Policy voluntarily to date, why does the drafting team and working group feel that the NERC 026 and standards would mean entities would stop following the Policy? Faramarz Amjadi British Columbia Hydro & Power Authority (aka BC Hydro) 2. Revalidation every 5 years. Now that the models are improved, and a significant amount of entities have digital relays versus analog, there is no reasonable justification why the shorter time frame is proposed. BC Hydro has been performing WECC testing (ie model validation) since the late 1990's and re-validation test results have not identified any significant reliability risks. As such, there does not appear to be any measurable technical benefit to perform the testing more frequently than the 10 year interval established in the NERC standards. Generation No See BC Hydro Comments Above Helen Hamilton Harding British Columbia Hydro & Power Authority (aka BC Hydro) No See Basin Electric Comments Above Patricia Robertson

5 Final Voting Record 5 British Columbia Hydro & Power Authority (aka BC Hydro) Transmission No See Basin Electric Comments Above Patricia Robertson California Independent Operator California Independent Operator Abstain The CAISO is not a GO or TO and this standard is therefore not applicable to our registration. We are abstaining at this time. Transmission Abstain The CAISO is not a GO or TO and this standard is therefore not applicable to our registration. We are abstaining at this time. Calpine Corporation Generation No We believe this variance to be unnecessary. Colorado Springs Utilities Colorado Springs Utilities Colorado Springs Utilities Colorado Springs Utilities No CSU does not believe a WECC variance is necessary. Generation No CSU does not believe a WECC variance is necessary. Distribution No CSU does not believe a WECC variance is necessary. Transmission No CSU does not believe a WECC variance is necessary. Richard Vine Richard Vine Phil Porter Shawna Speer Shawna Speer Shawna Speer Shawna Speer

6 Final Voting Record 6 El Paso Electric Company Generation No El Paso Electric Company provides the following response to the proposed WECC variances: EPE acknowledges the effort that went into the development of the variances drafted for purposes of and Modeling, Data, and Analysis WECC Variances, but recent communications with respect to registered entity MOD compliance has revealed that there would be risk of a non-compliant finding if the WECC variances are approved in their current state. By way of background, on Thursday July 28, 2016, EPE posed a question to the DT: would an entity be compliant with the proposed variances if such entity recently tested its generators as per the NERC Reliability Standards 025, 026, and 027?. The DT member reactions were not unanimous, and EPE has not yet received a final response to this important question. In contrast, on Thursday August 18, 2016 EPE asked the WECC MOD audit team whether an entity that performed the WECC testing for 2015 as per the 025, 026, and 027 standards (and received the WECC certificates and performed the required coordination/communication) would be considered compliant with new proposed WECC variances for 026 and 027. The response from the WECC s audit team was yes - that such entity would be compliant. The presence of such conflicting answers between the WECC DT members and the WECC MOD audit team members creates uncertainty, Pablo Onate

7 Final Voting Record 7 and it is this uncertainty that compels EPE to vote against the variances. We had hoped that this matter would have come to a final unanimous conclusion within the DT in a manner that echoed the response received from the WECC MOD audit staff, and had it, EPE would be casting an affirmative vote. El Paso Electric Company Exelon Generation Company, LLC - Constellation Marketers and Brokers No See EPE Comments Above Pablo Onate No Considering R4 and R4 currently require entities to re-validate their models every time the response characteristic of generator and turbine controls systems changes,. Exelon Generation believes the combination of the current 10-year validation interval and the revalidation required by R4 are more than sufficient to maintain valid models. Exelon Generation does not see a reliability benefit to increasing the model validation frequency from 10 years to 5 years. Mary Lynch

8 Final Voting Record 8 Farmington Electric Utility Generation No a. The WECC regional variances have changed the Applicability section and there does not appear to be adequate justification to lower the facilities threshold from 75MVA to the BES definition. b. The revalidation cycle of 5 years instead of NERC's 10 is not reasonable nor technically justified. BC Hydro has been performing WECC testing since the late 1990's and re-validation test results have not identified any significant reliability risks. As such, there does not appear to be any measurable technical benefit to perform the testing more frequently. Linda Jacobson- Quinn Farmington Electric Utility Gridforce Energy Management, LLC c. Changing a Policy to a Regional Variance Standard that is more onerous than the NERC MOD standards without adequate justification would mean WECC entities would be subject to MRS obligations and potential penalties that other regions wouldn't experience. Transmission No See Farmington Electric Comments Above Linda Jacobson- Quinn 0 David Blackshear

9 Final Voting Record 9 Idaho Power Company Generation No (1) IPC's experience reviewing revalidation data for units that have not experienced an equipment change is that the 5-year revalidation data does not significantly differ from the last data set. IPC recognizes the value provided with 5-year interval in the WECC Policy during the infancy of dynamic model verification within WECC, and the benefits such an interval has provided toward the development and understanding of dynamic models and model validation testing techniques in addition to the improvements provided to the quality of the WECC Master Dynamics Dataset. However, IPC believes that model verification for our units has reached a level of maturity where data accuracy can be maintained with the NERC 10-year validation requirement. (2) The NERC 026 and 027 standards provide the processes needed to correct poor model performance and provide a mechanism to require retesting due to an identified modeling deficiency. This process, coupled with the availability of PMU data at generating units, provides a sufficient mechanism for maintaining data quality; therefore, reducing the NERC interval to 5 years is unnecessary. (3) IPC supports the language that identifies the need to establish baseline modeling requirements and criteria for the sample resolution of disturbance recordings used to perform model verification. (4) IPC has concerns regarding the modeling accuracy of renewable generation within WECC models Laura Nelson

10 Final Voting Record 10 (steady state and dynamic representation; registered NERC renewables and non-registered renewables). Reducing the testing interval to 5 years for registered generating units does not address the potential reliability gap within WECC regarding the penetration of non-registered renewables not required to be tested. (5) The WECC Policy provides a provision for exemption to better coordinate equipment upgrades with model validation efforts; the proposed WECC variance to NERC 026 and 027 does not capture this exemption provision. Idaho Power Company Distribution No See Idaho Power Comments Above Laura Nelson Idaho Power Company Transmission No See Idaho Power Comments Above Laura Nelson Idaho Power Company No See Idaho Power Comments Above Laura Nelson

11 Final Voting Record 11 Nevada Power Company No NV Energy still has concerns with requirement E.B.7. No-load tests such as the open-circuit saturation test mentioned in the requirement necessitates an operating configuration of the turbine controls where combustion dynamics are secondary to the output control, and as such, the units cannot maintain emission compliance. Under the current air permit for our units, we are prohibited from operating out of emission compliance. There is no exception of any duration allowed in the permit. Performing the tests in this requirement on existing generators that haven't been previously validated will cause us to violate the current air permits for these units. Eric Schwarzrock It should also be noted that this problem is likely not unique to NV Energy. Modern combustion turbines are being permitted by environmental agencies at lower and lower emission levels. These levels are being met because the turbine manufacturers are realizing great advancements in emission control through improved combustion controls. However, all of these improvements require a level of flame stability that is inherently incompatible with noload/low-load operation, which means that reliability testing at no/low load operation is unlikely to be compliant with permitted emission levels. This has the potential for putting reliability standards at odds with air permits. NV Energy is also uncertain about which alternative methods could be

12 Final Voting Record 12 used in place of open-circuit testing to obtain test results as mentioned in Footnote 4. We would like to see additional guidance on the type of alternative tests that could be performed or would like to see an exception clause to the requirement when open-circuit testing could cause violations with other local requirements. Nevada Power Company Nevada Power Company Nevada Power Company Generation No See NV Energy Comments Above Eric Schwarzrock Distribution No See NV Energy Comments Above Eric Schwarzrock Transmission No See NV Energy Comments Above Eric Schwarzrock

13 Final Voting Record 13 Northern California Power Agency Marketers and Brokers No 1. WECC should concentrate it's efforts on modifying the NERC standards 026 and 027 to benefit the whole continent instead of one region if the benefits are truly significant.2. The 10 year model revalidation requirement should remain until the cost/benefit analysis shows that shortening the time to 5 years becomes economical.3. WECC should have conducted a cost/benefit analysis on the effect of this new proposed regional standard instead of leaving it up to the entities. WECC should have worked with the entities to come up with a report. If the cost/benefit results do not show that the proposed regional variance provides a net benefit to the reliability of the BES, then a reprioritization of work should have occurred. Dennis Sismaet Northern California Power Agency Pacific Gas and Electric Company PacifiCorp Generation No It is not necessary to change the existing NERC standard. Marty Hostler Generation Yes Alex Chua No PacifiCorp does not support a WECC regional variance that introduces obligations that are more onerous than the NERC 026-1/ requirements. PacifiCorp believes that the WECC region should adhere to the 026-1/027-1 reliability standards as currently written and enforceable nationwide. Sandra Shaffer PacifiCorp Generation No See PacifiCorp comments Above Sandra Shaffer

14 Final Voting Record 14 PacifiCorp Distribution No See PacifiCorp comments Above Sandra Shaffer PacifiCorp Transmission No See PacifiCorp comments Above Sandra Shaffer PacifiCorp Platte River Power Authority Marketers and Brokers No See PacifiCorp comments Above Sandra Shaffer Transmission No 026/027 WECC Regional Variance Platte River Power Authority (PRPA) would like to thank the drafting team for their work on this proposed standard and allowing us to submit comments and feedback. Platte River believes that the proposed WECC variances do not improve upon or add important requirements to the already approved NERC generator validation standards (026, 027, 032, and 033). The proposed regional variances also include additional technical requirements including increased sampling rates and data specifications than the currently approved WECC Model Validation Policy and aforementioned NERC Standards. This could potentially require each generating unit that has recently been tested to meet the WECC Policy and/or NERC approved 026/027 requirements to re-test in order to meet the stricter technical requirements of this proposed variance. Thus, generators will incur a significant financial burden without an equal amount of reliability gain. The already approved NERC standards require Jeff Landis

15 Final Voting Record 15 re-testing and verification if any changes are made to plant systems that may affect the model. With this requirement in place, there is no need for a stricter 5-year testing interval per the regional variance. We believe there will be minimal reliability improvements due to the standard as proposed. Platte River would like to see the already approved NERC standards become fully implemented before a need is determined for a regional variance. Platte River Power Authority Platte River Power Authority Platte River Power Authority Marketers and Brokers No See PRPA Comments Above Matthew Thompson No See PRPA Comments Above Sabrina Martz Generation No See PRPA Comments Above Tyson Archie

16 Final Voting Record 16 Powerex, Inc. Marketers and Brokers No 1. Powerex does not believe that the WECC 026 and -027 regional variance standards to the approved NERC 026 and 027 standards are necessary. From Posting 4, it was stated that the models have improved under the WECC Policy. However the Posting also goes on to state that WECC Policies are voluntary and unenforceable. If WECC members have been following the Policy voluntarily to date, why does the drafting team and working group feel that the NERC 026 and standards would mean entities would stop following the Policy?2. Revalidation every 5 years. Now that the models are improved, and a significant amount of entities have digital relays versus analog, there is no reasonable justification why the shorter time frame is proposed. BC Hydro has been performing WECC testing (ie model validation) since the late 1990's and re-validation test results have not identified any significant reliability risks. As such, there does not appear to be any measurable technical benefit to perform the testing more frequently than the 10 year interval established in the NERC standards. Gordon Dobson- Mack Public Service Company of Colorado (Xcel Energy) No Public Service Company of Colorado has participated in the drafting process for the regional variances for 026 and 027. While the drafting team has attempted to address concerns to some extent, the proposed standards essentially come down to a desire by the drafting team to increase the data requirements to a gold standard modeling effort. From Public Service Company of Colorado s perspective, these proposed Robert Staton

17 Final Voting Record 17 Public Service Company of Colorado (Xcel Energy) standards will only result in increased costs to our customers, and increase the administrative burden. Unfortunately there is no improvement to the reliability of the Bulk Electric. Additionally, it is Public Service Company of Colorado s position that there is no significant electrical difference between the WECC and the other regions that justify these proposed standards. For these reasons, Public Service Company of Colorado votes no. Transmission No See Public Service Company of Colorado comments above. Robert Staton Public Service Company of Colorado (Xcel Energy) Generation No See Public Service Company of Colorado comments above. David Lemmons Public Service Company of Colorado (Xcel Energy) Public Service Company of New Mexico Public Service Company of New Mexico Public Service Company of New Mexico Public Service Company of New Mexico Distribution 0 Chad Nickell Marketers and Brokers 0 Laurie Williams Transmission 0 Laurie Williams Distribution 0 Laurie Williams Generation 0 Laurie Williams

18 Final Voting Record 18 Public Service Company of New Mexico Public Utility District No. 1 of Chelan County Public Utility District No. 1 of Chelan County Public Utility District No. 1 of Chelan County Public Utility District No. 1 of Chelan County 0 Laurie Williams Generation No The variance reduces the NERC 10 year requirement to 5 years, which is in line with the existing policy and not, of itself, unduly burdensome. However, the existing policy provides for an exemption for when a planned governor or AVR/PSS replacement is to occur. Under the exemption, the GO provides a timeline for when equipment will be replaced and validated. The variance does not include this exemption provision. How this could work in practicality for Chelan PUD is that we would have to validate a unit, and then under existing schedules, have to revalidate it a year or so later when a governor or exciter is replaced. This equates to as many as three validations in a ten year period where at most, the NERC standard would require one. This seems an undue burden that does not improve BES reliability. An exemption provision should be included, not to exceed the 10 year NERC requirement. John Yale Transmission No See Chelan PUD comments above. Chad Bowman Distribution No See Chelan PUD comments above. Steven Wickel No See Chelan PUD comments above. John Appel

19 Final Voting Record 19 Public Utility District No. 1 of Chelan County Public Utility District No. 1 of Clark County Puget Sound Energy, Inc. Puget Sound Energy, Inc. Puget Sound Energy, Inc. Puget Sound Energy, Inc. Marketers and Brokers Yes See Chelan PUD comments above. Janis Weddle Transmission No See comments on ballot for No Although PSE understands the potential benefits of WECC: 1) identifying the values to be verified and the proper sampling rates to be used; 2) including E.B.7 in 026 for TPs and 3) using the BES definition for the size of units to be tested, PSE believes the reasons to vote no are greater. For example, as Entities have to verify the models anytime major equipment changes are made, it doesn t seem beneficial, but rather burdensome to test every 5 years. PSE doesn t believe that parameters would change significantly due to wear and tear and aging of the machine over a 10-year period as compared to a 5-year period. Additionally, the ability to request a WECC extension is limited to one year, in that the WECC variance would limit testing to a maximum of every 6 years, instead of every 10 years. For these reasons, as well as those addressed by other Entities, PSE votes no for project Distribution No See Puget Sound Energy Comments Above. Transmission No See Puget Sound Energy Comments Above. Generation No See Puget Sound Energy Comments Above. Jack Stamper Theresa Rakowsky Theresa Rakowsky Theresa Rakowsky Lynda Kupfer

20 Final Voting Record 20 Puget Sound Energy, Inc. Sacramento Municipal Utility District Sacramento Municipal Utility District Sacramento Municipal Utility District Sacramento Municipal Utility District Sacramento Municipal Utility District Marketers and Brokers No Yes See Puget Sound Energy Comments Above. Andrea Basinski Joe Tarantino Generation Yes Joe Tarantino Distribution Yes Joe Tarantino Transmission Yes Joe Tarantino Marketers and Brokers Salt River Project Distribution No Changes proposed do not add reliability above the existing standard. Salt River Project Generation No Change does not add reliability above existing standard Salt River Project Salt River Project Marketers and Brokers Yes Joe Tarantino Rudy Navarro Kevin Nielsen No Salt River Project William Abraham 0 Steven Cobb Salt River Project Transmission 0 Steven Cobb

21 Final Voting Record 21 San Diego Gas & Electric Distribution No From the perspective of a GO, SDG&E is voting No on the WECC variance. SDG&E thanks the SDT for its efforts. Respectfully, SDG&E is casting this No vote based upon its objective observation that a more frequent validation (every 5 years) of a generator s excitation control system, volt/var control functions and turbine governor and load control or power/frequency control functions has NOT created a marked increase in reliability that other regions have consistently obtained from a less frequent verification of the same data (every 10 years). Through SDG&E s research, neither public nor independent metrics have been found which support the identification that reliability of the BES has increased within the WECC region using the WECC Generating Unit Model Validation Policy (GUMVP) of a 5 year verification period for the same generator data in its models that other regions have historically obtained using a 10 year verification period. The proposed NERC Standard variance increases the cost of maintaining generation resources in the WECC region, while not providing an objectively assessed, increase to reliability to WECC s regional reliability. SDG&E s near term suggestion is to align the WECC GUMVP to the NERC Standards, and and require the generation data to be re-verified every 10 years, not every 5 years. This near term suggestion in place of the approval of the proposed Standard variance is ANNIE RUIZ

22 Final Voting Record 22 expected to help reduce the ambiguity of when the model data is required to be submitted by WECC Registered Entities. A second alternative suggestion is to establish a Standard requiring an online model validation for all Registered Entities to be used when submitting modeling data. The intent for an online model validation protocol is expected to enhance the ability of model administrators to identify model discrepancies or model data deficiencies in a shorter period than 10 years and further ensures higher accuracy for the modeling data being used. San Diego Gas & Electric San Diego Gas & Electric San Diego Gas & Electric No See SDG&E Comments Above. Bridget Silvia Generation No See SDG&E Comments Above. Jerome Gobby Transmission No See SDG&E Comments Above. Jennifer Wright Seattle City Light Distribution Yes Dana Wheelock Seattle City Light Transmission Yes Hao Li

23 Final Voting Record 23 Seattle City Light Southern California Edison Company Southern California Edison Company Southern California Edison Company Southern Power Company 0 Pawel Krupa Distribution Yes Steven Mavis Transmission Yes Steven Mavis Generation 0 Romel Aquino Generation 0 William D (Bill) Shultz Tacoma Power Distribution 0 Chad Edinger Tacoma Power 0 Twila Hofer

24 Final Voting Record 24 Talen Montana, LLC Generation No Talen Montana, LLC (TALN) appreciates the opportunity to comment. Please accept the following as suggestions for improvement: 1. Recommended Changes to : a. Accept OEM-calculated rotational inertia data (H values), due to being better than trip testderived results (i.e. based on manufacturing drawings, and not subject to frictional effects or measurement uncertainty). This is a more restrictive criterion than the NERC standard, taking "restrictive" in the present context to mean "more accurate." Trip testing also subjects equipment to meaningful wear and tear, thereby degrading its reliability, which would be an inappropriate outcome for a reliability standard. b. Rephrase footnote 2 for clarity. It appears from the text of the variance that it should present a list of typical < 180-day changes, but it commingles permanent items (e.g. new AVR) as well as short-term ones (shifting between voltage and PF control). c. State that any approved model type is acceptableanother clarification) d. Change the revalidation interval to 10 years. TALN does not agree that requiring model validation every 5 years, rather than the 10 years required by the NERC standard, will lead to significant reliability benefits. Tri-State Generation & Transmission (Reliability) Generation No See Tri-State G&T Comments below. Leland McMillan Mark Stein

25 Final Voting Record 25 Tri-State Generation & Transmission (Reliability) No Tri-State continues to believe that the proposed WECC variances do not improve the reliability of the BES but rather add undue burden. Tri-State feels that the requirements and associated intervals (R2 & R4) in the NERC standards are adequate for future preservation and maintenance of the system model. In Tri-State's opinion, the 2nd Technical Paper did not contain sufficient evidence to support the stricter 5 year requirements, as the source of the generator model changes between intervals is not known (i.e. Were the changes related to equipment modifications, drift, previous model errors, or some other cause.). We continue to believe that proposing a regional variance based solely on the continuation of a legacy policy is not a valid reason. Tracy Sliman Tri-State Generation & Transmission (Reliability) and will help improve the models and overall reliability of the BES. Tri- State would like to allow for some time following the effective dates to determine if a variance is needed to improve reliability of the BES and Models. Transmission No See Tri-State G&T Comments above. Tracy Sliman Tucson Electric Power Transmission No We don't support a more onerous requirement. US Bureau of Reclamation carmelina spina Transmission 0 Erika Doot

26 Final Voting Record 26 US Bureau of Reclamation Generation 0 Erika Doot Utility Efficiencies, Inc. Other Non- Registered WECC Members and Participating Stakeholders Yes Catrina Martin Western Area Power Administration - Rocky Mountain Region Transmission Yes James Hirning Western Area Power Administration - Rocky Mountain Region Yes Orlando Reyes