COMMENTS OF THE INTERVENOR NEWFOUNDLAND AND LABRADOR
HYDRO REGARDING FOLLOW-UP OF DECISIONS D-2011-068 AND
D-2012-091 WITH RESPECT TO THE REQUEST BY HYDRO-QUÉBEC
CONTRÔLE DU MOUVEMENT DES ÉNERGIES TO ADOPT RELIABILITY
STANDARDS
FILE R-3699-2009 - PHASE 1
Presented to the Régie de l’énergie du Québec
Montréal, Québec
January 14, 2013
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TABLE OF CONTENTS
1.
INTRODUCTION ................................................................................................. 3
2.
GENERAL COMMENTS ..................................................................................... 3
3.
SPECIFIC COMMENTS ON NOVEMBER 2, 2012 FILING BY HQRC .......... 4
4.
5.
(a)
Québec’s Appendix to BAL-003-0.1b ............................................................. 4
(b)
Québec’s Appendices to Standards TPL-001 to TPL-004 ............................. 7
(c)
Québec’s Appendix to Standard VAR-002 .................................................. 10
SPECIFIC COMMENTS ON NOVEMBER 30, 2012 FILING BY HQRC ...... 11
(a)
PRC-001: ....................................................................................................... 11
(b)
EOP-004: ....................................................................................................... 12
SPECIFIC COMMENTS ON DECEMBER 7, 2012 FILING BY HQRC: ....... 14
(a)
Glossary ......................................................................................................... 14
(b)
FAC-010-2.1, and FAC-014-2 ....................................................................... 14
6.
SPECIFIC COMMENTS ON DECEMBER 14, 2012 FILING BY HQRC ...... 15
7.
CONCLUSION .................................................................................................... 15
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1.
INTRODUCTION
Newfoundland and Labrador Hydro (“NLH”) as the purchaser of Transmission Service
from Hydro-Québec (“HQT”) and its parent company Nalcor (“Nalcor”) wishes to pass
comment on the Reliability Standards recently filed by the HQ Reliability Coordinator
(“HQRC”) and submitted to the Régie de l’énergie (“Régie”) on November 2, 2012,
November 30, 2012, December 7, 2012 and on December 14, 2012.
NLH’s comments are in some cases general and apply to numerous Standards, while in
other instances they are directed at a given Standard.
2.
GENERAL COMMENTS
NLH submits these comments following the Régie’s decision which invokes the
necessity of clarity in the codification of the Appendices. In the most recent decisions,
the Régie specifically mentions that the Québec specificities need to be clearly codified
into the normative documents. As it appears from decision D-2012-091 of July 25, 2012:
[56] La Régie est d’avis que, considérant les spécificités introduites par le
Coordonnateur en matière d’application des normes au Québec, le champ
d’application spécifique au Québec doit, le cas échéant, être clairement codifié
dans les documents normatifs. Par ailleurs, elle est d’avis que cette codification
ne peut être systématisée par une règle générique unique, mais doit tenir compte
de la teneur des exigences des normes.
The Régie clearly mentioned the guidelines for HQRC to follow when developing the
Appendices to the Reliability Standards, as it appears from decision D-2011-068. of
May 13, 2011:
[129] La Régie demande au Coordonnateur de suivre les lignes directrices suivantes lors
de l’élaboration des normes de fiabilité.
[130] L’annexe de chaque norme de fiabilité doit préciser :
la norme NERC à laquelle l’annexe est associée;
la date d’adoption, par la Régie, de la norme NERC associée;
la date d’adoption, par la Régie, de l’annexe;
la date de mise en vigueur de la norme NERC et de son annexe, conformément
aux décisions de la Régie;
que la Régie est responsable, au Québec, de la vérification de la conformité aux
normes de fiabilité et à leur annexe qu’elle adopte;
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le cas échéant, l’historique des versions d’origine et révisions subséquentes de
l’annexe ainsi que leur date d’adoption par la Régie.
As a result, when filing any standards, appendices or associated requests, HQRC must
clearly meet the Régie’s requirements in order to have its filing approved by the Régie.
3.
SPECIFIC COMMENTS ON NOVEMBER 2, 2012 FILING BY HQRC
(a)
Québec’s Appendix to BAL-003-0.1b
HQRC’s submission of its Québec specific Appendix for Standard BAL-003
recommends that neither Requirement R4 nor R6 of the Standard be applicable in
Québec. In each case, NLH believes that the Régie should consider the following when
assessing the Appendix;
It appears as though HQRC is attempting to justify the removal of a
Requirement in a Standard by stating that the condition to be approved
does not presently exist. NLH believes the applicability of a Requirement
within a Standard is best assessed when the Standard is being applied.
HQRC’s rationale inappropriately applies assessment decisions that
should be made during the application of a Standard to the process of
Standard adoption1.
Neither of the explanations provided is satisfactory in that neither
addresses all the Requirements contained in the specified sections.
NLH believes it is not ‘necessary’ to remove Requirements R4 and R6 from the Standard
simply because the HQRC claims that the activity mentioned in the Standard has not yet
been undertaken, particularly when this claim is being made by a division of a company
whose related entities will be subject to the Standard. The ‘Agreement on the
Development of Electric Power Transmission Reliability Standards and of Procedures
and a Program for the Monitoring of the Application of the Standards for Québec’, at 4.2
states:
‘NERC and NPCC undertake to ascertain that any electric power transmission
reliability standards specific to Québec, and/or any variant of such standards
specific to Québec, which the reliability coordinator deems necessary to ensure
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the reliability of electric power transmission in Québec, is as stringent as the
NERC reliability standards applicable in the rest of North America’2.
It is NLH’s view that the existing approval process is not intended to examine the present
activities of the entities to determine if a Requirement of the Standard is applicable.
Instead the process is intended to approve, and modify where and when required, the
NERC Standards submitted, taking into consideration the ‘uniqueness of the Québec
electrical system and it is not intended to produce variants to the Standards based on
practices which can be performed optionally, and not ruled out specifically as a result of
the system’s uniqueness.
The ‘Agreement on the Development of Electric Power Transmission Reliability
Standards and of Procedures and of a Program for the Monitoring of the Application of
the Standards for Québec’ states:
‘Whereas the Québec electric power transmission system is an asynchronous
interconnection and NERC and NPCC have recognized it as an Interconnection,
it may, therefore, require reliability standards or variants of such standards
specific to this Interconnection’3.
The Standard, as written by NERC, permits the suitability and usefulness of
Requirements R4 and R6 to be assessed at the time the Standard is applied (the time of
application is prescribed in the Standard), or at the time of audit. The present need, or
lack thereof, for a Requirement is not indicative of the future need for such a
Requirement. As a result, if the Appendix is approved as presently submitted by HQRC,
the Standard may not contain all the checks needed to support the purpose of the
Standard if practices change.
NLH believes that the suggested removal of Requirements R4 and R6 will make the
Standard less stringent, particularly given that NLH is unaware of the presence of a
procedure that would require the reinsertion of R4 and R6 into Québec’s Appendix
before the Balancing Authority is permitted to accept energy from jointly owned units or
to perform Supplemental Regulation Services, both of which activities can affect the
purpose of the Standard. Removing the Requirement from the Standard at the time of its
adoption removes the opportunity for auditing the activity in the event such a situation
arises.
2
3
Agreement on the Development of Electric Power Transmission Reliability Standards and of
Procedures and a Program for the Monitoring of the Application of the Standards for Québec, signed
May 8, 2009.
Id.
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The processing of these sections of the Standard on January 1st of each year, as written by
NERC, does not appear burdensome.
Requirement R4
In the Appendices to BAL-003, HQRC states: ‘No jointly owned units in Québec’ as
justification for the non-applicability of both sub-Requirements R4.1 and R4.2 of the
Standard. NLH believes the explanation is unsatisfactory in that it does not address all
Requirements contained in the subsections of R4.
Requirement R4, in addition to recognising fixed schedule deliveries from jointly owned
units ‘within’ Balancing Area of Québec, as per R4.1, also requires the Balancing
Authority to reflect, in its Frequency Bias Setting, deliveries from Jointly Owned Units
‘Outside’ its Balancing Authority Area, as per sub-Requirement R4.2.
HQRC’s justification fails to address R4.2. NLH believes that this omission should be
rectified so as to eliminate ambiguity.
Finally, in order for HQRC’s justification to adequately address the requirements of
R4.1, and to do so in a clear manner, NLH proposes that HQRC use language consistent
with the terminology of the Standard. Thus, HQRC could express its reasoning for the
exemption of R4.1 by stating: ‘No jointly owned units ‘within’ Quebec Balancing
Authority Area’.
Requirement R6
NLH has similar comments with respect to R6.
NLH would like to see a more thorough explanation as to why HQRC believes
Requirement R6 is not applicable in Québec.
HQRC has reasoned that Requirement R6 is not applicable to Balancing Authorities in
Québec because, ‘Overlap Regulation Service is not used in Québec’, however this
explanation addresses only one of the regulation services mentioned in the Requirement
and does not address the requirement associated with supplemental regulation.
Requirement R6 speaks to both Overlap Regulation Service and to Supplemental
Regulation Service and does so with the Requirement for the Balancing Authority to
adjust its Frequency Bias Setting if the Balancing Authority is involved in either form of
regulation service.
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HQRC’s justification, which states ‘Overlap Regulation Service is not used in Québec’
does not address the Supplemental Regulation Services Requirement of section R6 of the
Standard. NLH believes that this omission should be rectified so as to eliminate
ambiguity and that such an justification should use terminology consistent with the
requirements, i.e. it should incorporate the term ‘Balancing Authority’.
That being said, and as stated initially, the applicability of either Requirement R4 or R6
should be determined on January 1st of each year, as required by the Standard, or during
an audit, and should not be ruled out during the Standard adoption process.
(b)
Québec’s Appendices to Standards TPL-001 to TPL-004
The HQRC Appendices to NERC Standards TPL-001 to TPL-004 identify the scope of
the Standards to be the BPS. NLH, as a purchaser of transmission services, is concerned
that the scope of these Standards may produce a list of contingencies and critical
elements different than those applied to other related groups of Standards such as FAC010, FAC-011 and the MOD group of Standards (which have not yet been submitted)
thus establishing different lists of contingencies for planning purposes (TPL), system
operating limits (FAC) and ATC calculations (MOD).
This concern is manifested from a joint assessment of the TPL and FAC standards
submitted. The following wording illustrates the ambiguity that can develop when
interpreting the standards jointly and also the ambiguity that exists within the FAC
standards. The assessment is based on the interpretation of the following 3 references
from the standards presented.
1) Standards TPL-001 to TPL-004, in accordance with section 6 of the related QC
specific appendix identifies the scope of the standards to be the BPS. From the
scope statement it appears that Table 1 of the Standards which lists contingencies
(ie single line to ground fault), is speaking of contingencies on BPS elements.
2) Standard FAC-010, in accordance with section 6 of its QC specific appendix
identifies the scope of the standard as the MTS.
3) Requirement R2.2.1 of FAC-010 speaks to a single line to ground fault without
specifically identifying the classification of the fault (BES, BPS,MTS).
The text reference made to a single line to ground fault in R2.2.1 of FAC-010 has the
potential to be interpreted 3 ways:
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1) The line to ground fault reference in R2.2.1 could be a reference to a BES
element given that section B of the QC specific appendix for FAC-010 uses the
phrase 'No Specific Provision' thus indicating that the standard should be
interpreted as written by NERC, thus applicable to NERC's BES definition.
2) The line to ground fault could be a reference to an MTS element given that the
scope of the FAC standard is identified as MTS in the QC specific appendix
(the two example above identify ambiguity within the standard).
3) The line to ground fault in question could be related to a BPS element given
that the TPL Standards, which in Table 1 identifies system contingencies,
contains in section 6 of the QC appendix a statement identifying the BPS as the
proper scope for the TPL standards. This third example illustrates ambiguity
between the TPL standards and both of the FAC interpretations above.
NLH is concerned with what it perceives as inconsistency and ambiguity within the FAC
standards and additional ambiguity and inconsistency between the FAC and TPL
standards.
The illustration above is one example of the difficulty associated with identifying the
proper list of contingent elements and ensuring that the list is consistent throughout and
between standards.
NLH’s concern with respect to the use of different contingency lists between these two
groups of Standards is consistent with the concerns expressed by FERC. In Order 705
FERC has said:
47. Further, the Commission is persuaded by NERC’s comments that it will
coordinate the assumptions and conditions considered in system planning under
the TPL Reliability Standards, SOL determination under the FAC Reliability
Standards and TTC calculation under the MOD Reliability Standards.
At the time the above order, 705 was issued, the MOD Standards related to TTC and ATC had
not yet been submitted to FERC, a situation not unlike that before the Régie given that Standards
MOD-028 to MOD-030 have not been submitted for approval in Québec. However FERC was
cognisant of intent and content of these MOD Standards and in that same ruling made the
following determinations
48. At this time, the Commission disagrees with the commenters that argue that
there is a potential for undue discrimination in the FAC Reliability Standards.
The Commission raised the question regarding the application of the SOL
methodology in the FAC Reliability Standards compared with the calculation of
ATC. However, NERC has not at this time filed the Reliability Standards
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concerning TTC and ATC calculation. The Commission notes that it has
previously provided directives concerning the need for coordination and
consistency among short- and long-term ATC calculations, operations planning
and system expansion determinations. The Commission agrees with commenters
that the directives concerning consistency in Order Nos. 693 and 890 should
alleviate concerns about the potential for undue discrimination. These directives
are currently being addressed by NERC in Reliability Standards under
development. We will not change those directives in this proceeding. When
NERC files revised MOD Reliability Standards for calculating ATC or TTC, the
Commission will review the resulting Reliability Standards for compliance with
our directives in Order Nos. 890 and 693 concerning consistency for SOLs,
transfer capability and TTC.
49. Because the TPL series of Reliability Standards sets the foundation for the
types of contingencies to be considered to meet Requirements in the FAC
Reliability Standards, and the FAC Reliability Standards are intended to be
consistent with the set of contingencies identified in the TPL Reliability
Standards, the Commission would be concerned if the TPL Reliability Standards
use one set of contingencies to plan the system, while the FAC Reliability
Standards generate another set to calculate SOLs in the planning horizon. As
NERC acknowledges, as the TPL series of Reliability Standards is modified,
conforming changes to the corresponding lists of contingencies in the FAC or
MOD series of Reliability Standards are expected to be necessary to ensure
consistency in the list of contingencies. Similarly, the Commission believes that
as FAC or MOD Reliability Standards are updated, the TPL series of Reliability
Standards must be updated to remain consistent. Therefore, we direct that any
revised TPL Reliability Standards must reflect consistency in the lists of
contingencies between the two Reliability Standards. Should NERC file such
revised TPL Reliability Standards, the Commission will review the resulting
Reliability Standards for compliance with our directives in Order Nos. 890 and
693 concerning consistency for SOLs, transfer capability and TTC4.
FERC's intentions related to the application of contingencies amongst the related TPL,
FAC and MOD Standards were manifested in Requirements R6 and R7 of Standard
MOD-001 that was yet to be presented to the Régie.
R6. When calculating Total Transfer Capability (TTC) or Total Flowgate
Capability (TFC) the Transmission Operator shall use assumptions no more
limiting than those used in the planning of operations for the corresponding time
period studied, providing such planning of operations has been performed for that
4
Order 705 FERC, 121 FERC ¶ 61,296, Facilities Design, Connections and Maintenance Reliability
Standards, Issued December 27, 2007.
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time period. [Violation Risk Factor: Lower] [Time Horizon: Operations
Planning]
R7. When calculating ATC or AFC the Transmission Service Provider shall use
assumptions no more limiting than those used in the planning of operations for
the corresponding time period studied, providing such planning of operations has
been performed for that time period. [Violation Risk Factor: Lower] [Time
Horizon: Operations Planning]
In a similar vein, Requirement R3 of the yet to be submitted MOD-029 links that
Standard to the FAC Standards when it says;
R3. Each Transmission Operator shall establish the TTC at the lesser of the
value calculated in R2 or any System Operating Limit (SOL) for that ATC Path.
[Violation Risk Factor: Lower] [Time Horizon: Operations Planning]
NLH believes that it is appropriate for HQRC to justify the need for establishing
differences in scope between the TPL and FAC Standards (and potentially the related
MOD Standards). This justification can be accomplished through either a technical
session or in a hearing. In addition the potential for ambiguity within the Standard, as
evidenced between the Québec specific Scope and Requirement R2.1 of FAC-010,
should be eliminated.
(c)
Québec’s Appendix to Standard VAR-002
HQRC's Appendix to Standard VAR-002 states that Requirements R4 and R5 are not
applicable in Québec. NLH Requests an explanation for that position.
R4 requires the generator to provide to the transmission operator and planner,
information related to the transformers which connect the generator to the
system. This data permits the operator to model, and subsequently to study, the
system, particularly in relation to voltage stability.
R5 requires the generator owner to modify its transformer tap settings at the
request of the transmission operator, based on the studies and simulations
performed by the transmission operator.
Given that properly conducted system voltage studies require the data mentioned in the
Requirement and that the transmission operator cannot ensure proper system performance
unless he has the authority to modify transformer tap settings, NLH believes an
explanation which justifies the omission of these Requirements in Québec should
accompany HQRC’s submission.
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That explanation, while it may be as simple as a statement which indicates that the
transformers in question are all owned by HQT and not the generator owner, should be
submitted by HQRC for review by the stakeholders and the approval of the Régie.
The Régie’s approval of the Appendix to Standard VAR-002 should be withheld until
justifications for the omission of Requirements R4 and R5 are provided.
4.
SPECIFIC COMMENTS ON NOVEMBER 30, 2012 FILING BY HQRC
(a)
PRC-001:
In our comments filed October 31, 2012, we specifically mentioned, regarding
this particular Standard, that:
‘The HQRC Appendix to standard PRC-001, in subsection A.6,
titled “Scope”, indicates that the scope of the standard is the Main
Transmission System (MTS) or any element of a regional system
whose protection trips an element of the MTS. The Glossary of
Terms accompanying the HQRC standards does not contain a
definition for the term “regional system”.
In an effort to provide clarity with respect to interpretation of the
standard and the identification of to whom the standards apply, NLH
believes that the term “regional system” should be defined, prior to
approval of the standard, for inclusion in the Glossary of Terms used in
the standards. NLH requests that the definition be sufficiently clear for
the reader to differentiate a “regional system” from;
“local system” or “local area”,
the MTS
the entirety of a “Balancing Area” or
the collective systems of a Regional Entity.
As was the case with the use of the phrase BPS, NLH is concerned with
the possible ambiguity or the subjective use of an undefined term’.
We note, in HQRC’s November 30, 2012 filing, that it has modified the Québec
Appendix on the Scope (A.6.) deleting the following reference ‘or any element of
a regional system whose protection trips an element of the MTS’.
This section now reads as follows:
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6. Scope: Main Transmission System (MTS)
Concerning these modifications, for the record, NLH wishes to mention that it has
taken note of the changes and we will ask HQRC to explain it at the technical
session.
(b)
EOP-004:
In our comments on Standard EOP-004 filed October 31, 2012, we specifically
cited FERC’s Order No. 693, paragraph 604, which adjudicates the approval of
most of NERC’s Standards, including EOP-004.
We specifically mentioned, regarding this particular Standard, that:
The HQRC Appendix submitted to clarify the application of this
Standard in Québec recommend, through modifications to Requirements
R1 and Applicability A4.6, that the RRO not be responsible for
establishing and maintaining a reporting procedure for Disturbances.
General concerns linked to HQRC’s removal of the RRO’s role were expressed in
those comments, as it appears from Section 1 a) of the document submitted on
October 31, 2012.
That document also mentions that:
The HQRC Appendix to this Standard, through the abolishment of the
above and Measure M1, recommends that a procedure not be available to
appropriate stakeholders.
Similarly, the abolishment of Requirement R5, recommends that the
RRO will not be required to track the status of any recommendations
which may result from these reports, nor be required to notify various
NERC committees on the progress associated with the implementation of
the recommendations.
NLH, as a holder of a Transmission Service Agreement with HQ, is
subject to delivery Curtailment and interruptions during those periods
when Disturbances require that load relief be applied to the Transmission
System.
As a consequence NLH believes that a written procedure to guide the
analysis and to establish content requirements, developed in accordance
with industry practices, be made available to HQRC customers so that
transmission customers can verify the reason for the curtailments. As
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mentioned earlier, NPCC is recognised by the Régie, HQRC and NERC
as the RRO for Québec.
In May 2009 the Régie, NERC and NPCC entered into an agreement
titled “Agreement on the development of electric power transmission
reliability standards and of procedures and a program for the monitoring
of the application of these standards for Québec”. Section 4.2 of that
agreement states: […]
In brief, NLH concluded that:
NLH believes that the change proposed to the standard should be
demonstrated as a change needed to ensure reliable operation of the
electric power system in Québec and that such changes ensure the
standard is as stringent as that applicable in the rest of North America.
We note, in HQRC’s November 30, 2012 filing, that it has modified the Québec
Appendix, deleting the following reference ‘or any element of a regional system
whose protection trips an element of the MTS’ from the Scope section that now
reads as follow:
1.3. Data Retention
The first paragraph is not applicable in Québec.
Concerning these modifications, NLH is requesting that the Régie identify the
entity that will carry out NPCC’s role for that requirement in Québec? NLH asks
the Régie to review the comments that was made on October 31, 2012 on the role
of RRO and NPCC.
For the record, NLH wishes to mention that it has noticed the changes and may
revert to this question in the future.
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5.
SPECIFIC COMMENTS ON DECEMBER 7, 2012 FILING BY HQRC:
(a)
Glossary
In its letter dated December 7, 2012, HQRC mentioned that the final version of the
Glossary is the version filed on June 8, 2012. In this regard, NLH specifically mentioned
in its comments of October 31, 2012 that it requested that the Glossary be revised and
updated to incorporate the new terms for which approval is requested, such as : ‘Local
Area’, ‘Québec Interconnection’ and ‘Regional System’.
NLH took note that the expression ‘regional system’ has been deleted from Scope (EOP004 Appendix). Unless that expression is not used elsewhere in the Standards
collectively, NLH reiterates its request for a definition for the expression.
(b)
FAC-010-2.1, and FAC-014-2
In its December 7, 2012 filing, HQRC submitted new versions of the following Standards
CIP-001-2a, FAC-002-1, FAC-010-2.1, and FAC-014-2 that had been filed on June 11,
2012.
In NLH’s January 27, 2012 comments relating to the HQRC’s proposed modifications
for filing in June 2012, NLH made specific comments on Standards FAC-010-2.1, and
FAC-014-2.
NLH has since taken note that the majority of those comments were not integrated into
the June 2012, as filed.
On December 7, 2012, HQRC made certain modifications to the aforementioned
Standards, which modifications do not, however, address NLH’s initial recommendations
of January 27, 2012:
NLH recognize that the Scope was added but that the other concerns were not addressed.
We ask the Régie to review NLH’s comments made in previous submissions.
NLH will want to have receive exact explanations in this regard at the technical session.
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6.
SPECIFIC COMMENTS ON DECEMBER 14, 2012 FILING BY HQRC
NLH requests that HQRC justify the changes requested to those Standards (part of the 95
Standards already filed).
7.
CONCLUSION
As mentioned in the general comments, NLH submits these comments in the interest of
consistency and clarity, with respect to individual Standards and to related groups of
Standards for which the application of one cannot be divorced from the application of
another.
NLH looks forward to participating in public sessions related to the Standards and hopes
to be able to pass comment on the comprehensive collection once all the Standards have
been presented.
NLH believes it is incumbent upon HQRC to provide, for the consideration of the Régie
and other stakeholders, the rationale for the to the Quebec specific changes proposed to
the NERC Standards. NLH expects this rationale to include a description of HQ's
planning and operating procedures and practices. The explanation should identify how
these planning and operating procedures and practices are born from the uniqueness of
the HQ’s system and how it is that the NERC standards as written by NERC cannot
apply to the HQ system without the modifications proposed by in the HQRC specific
Appendices.
Moreover, NLH wishes to draw the Régie’s attention to the importance that should be
attributed to the comments that have been formulated throughout the consultation
process, since its commencement in 2009. In fact, NLH is of the opinion that it is
necessary to perform a global assessment of the 95 Standards, rather than assigning an
individual interpretation to each, many of the Standards being co-dependent or
interactive. As a result of this inability to divorce Standards one from one the other, NLH
believes that it is possible that some of the 95 Standards presently under consideration
may require adjustments after the next group of Standards is presented. This
reassessment may be required to ensure that all of the Standards presented are not only
consistent with one another but are as well consistent with the manner by which the HQ
system is planned and operated.
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