Regional Standard Authorization Request (RSAR)
The tables below identify information to be submitted in a Regional Standard
Authorization Request to the NPCC Regional Standards Manager,
NPCC-CBREstandard@npcc.org . The NPCC Cross-Border Regional Entity (CBRE)
Regional Standards Process Manager shall be responsible for implementing and
maintaining this form as needed to support the information requirements of the standards
process.
Regional Standard Authorization Request Form
Title of Proposed Standard:
NPCC Registration Criteria for Materially
Impactive Entities
Request Date:
April 20, 2008
RSAR Requester Information
Name:
Ron Falsetti, Chair, CC Registration Sub-Committee
RSAR Type (Check box for one of these
selections.)
Company:
CC Registration Sub-Committee
New Standard
Telephone:
905.855.6187
Revision to Existing Standard
Fax:
905.855.6372
Withdrawal of Existing Standard
Email:
ron.falsetti@ieso.ca
Urgent Action
Purpose (Describe the purpose of the proposed standard – what the standard will achieve in
support of reliability.)
Establish an NPCC Inc. (NPCC) Regional registration criterion that will define:
i)
The „materialality criteria‟ to be used in determining the specific reliability standards
that will apply to all generators irrespective of their connection to “NPCC A-10 defined” Bulk
Power System (BPS) facilities; and
ii)
Threshold criteria for determining which Generator Owners and/or Generator Operators
that are currently excluded from registering under the NERC registration criterion would need to
comply with the above NPCC sub-set of reliability standards and only these standards.
Industry Need (Provide a detailed statement justifying the need for the proposed standard,
along with any supporting documentation.)
There is a general consensus within the NPCC Compliance Committee (Committee) that certain
reliability standards need be applied to generators irrespective of their connection to BPS
facilities and be enforceable through the NPCC Compliance Monitoring and Enforcement
Program (CMEP). However, the NPCC lacks a suitable means of achieving this objective
without using the existing NERC registration process that places mandatory obligations on the
registered entity to comply with all standards applicable to that functional entity registration
without considering the appropriateness implications of a standard and/or requirement.
This NPCC registration criterion being proposed will limit the applicable set of reliability
standards and/or requirements such that only those elements deemed „material‟ for system
reliability will be applied to the impacted facilities.
This is of particular important to NPCC as there is some 39,000 MW (Quebec not included) of
generation capacity within the NPCC jurisdiction that is excluded under the existing registration
criteria. In aggregate, this has specific relevance with the implications on system reliability,
when these facilities do not need to certify the maintenance of their generator U/F relays.
Similar concerns have been expressed with respect to a number of other NERC standards that the
Committee believes need to be adhered to by all generators.
Brief Description (Describe the proposed standard in sufficient detail to clearly define the scope
in a manner that can be easily understood by others.)
The focus of this regional registration criteria standard is the functional model entities of
Generator Owners and/or Generator Operators (GO/GOP). However, it is recognized that
this regional standard could evolve and be applied to other functional model entities as
well.
The applicability of a standard, to an entity, is presently based upon of the NERC
registration criteria and the “applicable to” section of each standard. The interpretation
then is that once you are registered as a functional model entity, then every standard that
refers to that functional model entity is enforceable.
This NPCC regional standard will establish a “materiality criteria” for determining the
specific reliability standards that need be applied to all generators, irrespective of their
connection to “NPCC A-10 defined” Bulk Power System facilities. And the “threshold
criteria” to define the Generator Owners and/or Generator Operators, which were
excluded under the existing NERC registration criterion, that would need to comply with
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the above sub-set of reliability standards.
Reliability Functions
The Standard will Apply to the Following Functions (Check all applicable boxes.)
Reliability
The entity that is the highest level of authority who is responsible for the
Coordinator
reliable operation of the Bulk Electric System, has the Wide Area view of the
Bulk Electric System, and has the operating tools, processes and procedures,
including the authority to prevent or mitigate emergency operating situations in
both next-day analysis and real-time operations. The Reliability Coordinator
has the purview that is broad enough to enable the calculation of
Interconnection Reliability Operating Limits, which may be based on the
operating parameters of transmission systems beyond any Transmission
Operator‟s vision.
Balancing
Authority
The responsible entity that integrates resource plans ahead of time, maintains
load-interchange-generation balance within a Balancing Authority Area, and
supports Interconnection frequency in real time.
Interchange
Authority
Authorizes valid and balanced Interchange Schedules.
Planning
Authority
The responsible entity that coordinates and integrates transmission facility and
service plans, resource plans, and protection systems.
Transmission
Service
Provider
The entity that administers the transmission tariff and provides Transmission
Service to Transmission Customers under applicable transmission service
agreements.
Transmission
Owner
The entity that owns and maintains transmission facilities.
Transmission
Operator
The entity responsible for the reliability of its “local” transmission system, and
that operates or directs the operations of the transmission facilities.
Transmission
Planner
The entity that develops a long-term (generally one year and beyond) plan for
the reliability (adequacy) of the interconnected bulk electric transmission
systems within its portion of the Planning Authority Area.
Resource
Planner
The entity that develops a long-term (generally one year and beyond) plan for
the resource adequacy of specific loads (customer demand and energy
requirements) within a Planning Authority Area.
Generator
Operator
The entity that operates generating unit(s) and performs the functions of
supplying energy and Interconnected Operations Services.
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Generator
Owner
Entity that owns and maintains generating units.
PurchasingSelling Entity
The entity that purchases or sells, and takes title to, energy, capacity, and
Interconnected Operations Services. Purchasing-Selling Entities may be
affiliated or unaffiliated merchants and may or may not own generating
facilities.
Distribution
Provider
Provides and operates the “wires” between the transmission system and the
customer.
Load-Serving
Entity
Secures energy and transmission service (and related Interconnected Operations
Services) to serve the electrical demand and energy requirements of its end-use
customers.
Reliability and Market Interface Principles
Applicable Reliability Principles (Check all boxes that apply.)
1. Interconnected bulk power systems shall be planned and operated in a coordinated
manner to perform reliably under normal and abnormal conditions as defined in
the NERC Standards.
2. The frequency and voltage of interconnected bulk power systems shall be
controlled within defined limits through the balancing of real and reactive power
supply and demand.
3. Information necessary for the planning and operation of interconnected bulk
power systems shall be made available to those entities responsible for planning
and operating the systems reliably.
4. Plans for emergency operation and system restoration of interconnected bulk
power systems shall be developed, coordinated, maintained, and implemented.
5. Facilities for communication, monitoring, and control shall be provided, used, and
maintained for the reliability of interconnected bulk power systems.
6. Personnel responsible for planning and operating interconnected bulk power
systems shall be trained, qualified, and have the responsibility and authority to
implement actions.
7. The security of the interconnected bulk power systems shall be assessed,
monitored, and maintained on a wide-area basis.
Does the proposed Standard comply with all of the following Market Interface
Principles? (Select ‘yes’ or ‘no’ from the drop-down box.)
Recognizing that reliability is an Common Attribute of a robust North American economy:
1. A reliability standard shall not give any market participant an unfair competitive
advantage.Yes
2. A reliability standard shall neither mandate nor prohibit any specific market structure.
Yes
3. A reliability standard shall not preclude market solutions to achieving compliance with
that standard. Yes
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4. A reliability standard shall not require the public disclosure of commercially sensitive
information. All market participants shall have equal opportunity to access
commercially non-sensitive information that is required for compliance with reliability
standards. Yes
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Detailed Description (Provide enough detail so that an independent entity familiar with the
industry could draft a standard based on this description.)
As indicated, the applicability of a standard to an entity is presently based upon of the NERC
registration criteria and the “applicable to” section of each standard. The interpretation is that
once you are registered as a functional model entity, then every standard that refers to that
functional model entity is enforceable
There are several issues with this approach.
1.
The NERC registration criteria define a base line for registration that may not capture all
the entities that are “material” to the reliability of the bulk power system.
2.
The development process of a standard can, in some cases, list functional entities such as
GO/GOP or LSE/DP because of the possibility that they may be impactive. This “catch all”
approach coupled with the NERC registration criteria will force entities to allocate limited
resources to achieve compliance with a standard that may not be truly “material” for system
reliability. Examples include standards such as Sabotage Reporting (CIP-001), Cyber Security
(CIP-002-CIP-009) or Protection System Miss-operations (PRC-004). This issue would be more
relevant if we explicitly add generators to the registration list because of a very specific impact,
but then, inappropriately, continue to enforce all standards to that generator.
3.
From the Statement of Compliance Registry Criteria for GO/GOP: “Any generator,
regardless of size, that is material to the reliability of the bulk power system” remains undefined.
NPCC needs to define what is meant by „is material to the reliability of the bulk power system‟.
An entity needs to understand how it might impact reliability in order to properly address those
Reliability Standard requirements that apply to its operations.
4.
Generator Owners and Operators typically are not aware of the impact to transmission,
but are asked to register with NPCC directly. NPCC is also not aware of their impact and is
relying on the generator‟s assessment. The registration information may not even provide
sufficient information to identify individual generators when registered as a group.
Our proposed solution is to develop a NPCC regional standard that will define when a GO/GOP
is “material to the reliability of the bulk power system” on a standard-by-standard basis and
possibly on a requirement basis as warranted. This “material” basis will be used to develop the
criteria around the material impact of each requirement. This proposal is a shift from the original
thinking in that when a generator meets the criteria for a Reliability Standard based on a broad
criterion, such as being directly connected to the bulk power system, then all Requirements of
the Reliability Standard are applicable and thus enforceable.
Example (s)
Standard PRC-008-0 – Underfrequency Load Shedding Equipment Maintenance Programs.
Register all GO/GOP that require verification of Underfrequency trip relays. Make applicable
those UFLS standards only.
Related Standards
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Standard No.
Explanation
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Related SARs or RSARs
SAR ID
Explanation
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