System Review Working Group Position Paper on Implementation of MOD-032-1 Effective R1 July 1, 2015, R2-R4 July 1, 2016 The System Review Working Group (SRWG) is tasked with implementing and monitoring guidelines and policies pertaining to steady state and dynamic data to support analysis of the reliability of the Western Interconnection transmission system. Introduction MOD-032-1 – Data for Power System Modeling and Analysis was approved by FERC May 1, 2014. Requirement R1 will become effective July 1, 2015. The remainder of the requirements, R2-R4, will become effective July 1, 2016. The requirements of the new standard are directly related to the primary task of SRWG as stated above. After review of MOD-032-1 and related SRWG documentation, SRWG has collectively determined the following actions should be taken: Action Responsible entities Data Preparation Manual modified to align with new Requirements SRWG Develop data requirement and reporting procedures Each Planning Coordinator MOD-11 & 13-WECC-CRT-1 needs to be modified or retired WECC Establish methodology to account for Planning Coordinator responsibility in base cases SRWG The following sections outline each of the above actions and present SRWG’s position. Successfully following SRWG’s position for each action will help ensure the development of high quality interconnection-wide cases and support compliance of Planning Coordinators with MOD-032-1. Data Preparation Manual The Data Preparation Manual has recently been focused on specifying what data “Member Systems” need to provide to WECC and a data submittal process in order to develop interconnection-wide cases. With implementation of MOD-032-1, The Data Preparation Manual could transition to specifying the data requirements and data submittal process for Planning Coordinators submitting data to WECC. The data requirements and reporting procedures jointly developed by each individual Planning Coordinator and each of the individual Planning Coordinator’s Transmission Planners can address and incorporate desires, concerns, and issues of the entities within its Planning Coordinator Area. Modifying the Data Preparation Manual to only apply to Planning Coordinators will align the WECC processes with NERC standards, specifically MOD-032-1, R4. Incorporating The Data Preparation Manual into the Planning WESTERN ELECTRICITY COORDINATING COUNCIL 155 North 400 West, Suite 200 Salt Lake City, Utah 84103-1114 WECC Position Paper 2 Coordinator’s jointly developed data requirements and reporting procedures will also align their processes with the interconnection-wide case building process as required in MOD-032-1, R1.2. Proposed modifications to the Data Preparation Manual follow: 1. Restate purpose of the document to align with MOD-032-1, R1.2 and R4 and applicability to Planning Coordinator 2. State “other information” required to create interconnection-wide cases not included in MOD032-1, Attachment 1 and the need for Planning Coordinators to incorporate the “other information” in their jointly developed data requirements and reporting procedures 3. Remove/replace references to MOD-010 through MOD-015 4. Incorporate intent of language in MOD-011 and 013-WECC-CRT-1 as stated below A proposed revision of the Data Preparation Manual will be included as an appendix. Data Requirement and Reporting Procedures Planning Coordinators should include the Data Preparation Manual as part of their jointly developed modeling data requirements and reporting procedure as required in MOD-032-1, R1. The Data Preparation Manual will be applicable to Planning Coordinators. Planning Coordinators may choose to use the Data Preparation Manual in-part or as a subset of the data requirements they develop. The reporting procedures between Balancing Authorities, Generator Owners, Load Serving Entities, Resource Planners, Transmission Owners, Transmission Planners, Transmission Service Providers, and their Planning Coordinators is not addressed by any WECC documentation at this time. SRWG is taking the position that an interconnection wide data requirements and reporting procedures should not be developed with the intent of Planning Coordinators adopting them for complete compliance with MOD-032-1, R1. Any documentation developed at the WECC level will need to be supplemented by each Planning Coordinator. A single process cannot reasonably accommodate the needs and wants of all Planning Coordinators and their Transmission Planners due to differences in software being utilized and individual business practices. MOD-11 & 13-WECC-CRT-1 The implementation of MOD-032-1 includes the replacement of existing MOD-010-0, MOD-011-0, MOD-012-0, MOD-013-1, MOD-014-0, and MOD-015.0.1. WECC developed MOD-11 & 13-WECC-CRT-1 to satisfy the fill-in-the-blanks requirements of MOD-011-0 and MOD-013-1. Upon retirement of MOD011-0 and MOD-013-1, MOD-11 & 13-WECC-CRT-1 will no longer be required but the intent of the requirements needs to be captured in other documentation. The following is proposed for each requirement: W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L WECC Position Paper 3 WR1 Existing Language The Reliability Assurer (WECC) shall verify the System Review Work Group (SRWG), or its successor, develops and documents both comprehensive steady-state and comprehensive dynamic data requirements, and reporting procedures for the Western Interconnection to meet the steady-state data requirements listed in Attachment A (Steady State Data Requirements) and dynamic data requirements list in Attached B (Dynamic Data Requirements) of this criterion. Proposal Incorporate the existing requirement intent into the SRWG charter. Without a specific NERC standard identifying the need, a WECC criterion requirement is not necessary to ensure SRWG will perform its assigned tasks. WR2 Existing Language The Reliability Assurer (WECC) shall designate the SRWG, or its successor, as the entity responsible to develop for the Western Interconnection any additional steady-state and dynamic data requirements not otherwise specified by NERC Proposal Incorporate the existing requirement intent into the SRWG charter. The intent of WR2 was to have SRWG develop and maintain the Data Preparation Manual. SRWG will continue to perform this task. WR3 Existing Language The Reliability Assurer (WECC) shall designate the Planning Coordination Committee, or its successor, as the entity responsible to approve the development of both comprehensive steady-state and comprehensive dynamic data requirements, and reporting procedures, within the Western Interconnection, as developed by the SRWG, or its successor. Proposal Requirement WR3 can be retired in its entirety. The requirement intended PCC to approve the Data Preparation Manual to improve the perception of due process in modifying data requirements which would potentially impact the ability for applicable functional entities of MOD-010-1 and MOD-012-1 to be compliant with the standards. It is proposed that the level of approval for the Data Preparation W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L WECC Position Paper 4 Manual be lowered to the Technical Studies Subcommittee. The Data Preparation Manual should no longer be considered a necessary means to be compliant with NERC standards but rather a procedure for developing interconnection-wide cases. The TSS represents a sufficient level of expertise to ensure interconnection-wide cases are developed as necessary to meet the needs of its members. WR4 Existing Language The Reliability Assurer (WECC) shall review this criterion, no less than each five years, by causing to be filed a WECC Standards/Regional Criterion Request Form (or its successor), for the purpose of reviewing the data requirements and reporting procedures addressed herein. Proposal Requirement WR4 can be retired in its entirety as there will be no criterion to review. WR5 Existing Language The Reliability Assurer (WECC) shall post on the WECC Web site each steady-state and dynamic data request required by this criterion, to include, at a minimum, each of the following elements: 1) 2) 3) 4) 5) A statement of the purpose for which the case will be developed The case year The case season The case load, generation and interchange requirements Required due dates for data submittal to the Reliability Assurer (WECC). Proposal The intent of WR5 is proposed to be incorporated into the SRWG Annual Study Program Scope of Work document. Data requests from WECC for the development of a specific interconnection-wide case will continue to require the minimum set of descriptions provided in the requirement. The process should continue to include the use of the WECC web site. WR6 Existing Language The Reliability Assurer (WECC) shall post on the WECC Web site each steady-state and dynamic data request, as referred to in WR5 above, at least eight weeks prior to the required due dates for data submittal back to the Reliability Assurer (WECC). W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L WECC Position Paper 5 Proposal The intent of WR6 is proposed to be incorporated into the SRWG Annual Study Program Scope of Work document in conjunction with WR5. WR7 Existing Language Each Transmission Owner, Transmission Planner, Generator Owner and Resource Planner as specified in the “Functional Entity” column of Attachment A of this criterion, shall submit to the Reliability Assurer (WECC) the data specified in the “Data Required” column of Attachment A of this criterion, in accordance with the due dates for data submittal to the Reliability Assurer (WECC) specified in WR5 above. Proposal MOD-032-1 requires Balancing Authorities, Generator Owners, Load Serving Entities, Resource Planners, Transmission Owners, and Transmission Service Providers to provide modeling data to their Transmission Planners and Planning Coordinators. MOD-032-1 also requires Planning Coordinators to make the collected data available to WECC for development of interconnection-wide cases. Requirement WR7 can be retired in its entirety. WR8 Existing Language Each Transmission Owner, Transmission Planner, Generator Owner, and Resource Planner as specified in the “Functional Entity” column of Attachment B of this criterion, shall submit to the Reliability Assurer (WECC) the data specified in the “Data Required” column of Attachment B of this criterion, in accordance with the due dates for data submittal to the Reliability Assurer (WECC) specified in WR5 above. Proposal Requirement WR8 can be retired in its entirety. See WR7 above. WR9 Existing Language Each Generator Owner shall submit to the Reliability Assurer (WECC), the generator data required on Attachments A and B in accordance with the following size-threshold criteria: W If the individual generator unit capacity is 10 MVA or larger, and is connected to the WECC transmission system at 60 kV or higher, then steady-state data shall be submitted for each E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L WECC Position Paper 6 generator in accordance with the requirement stated at Attachment A, “NERC Requirement, MOD-11-0, R1.2”, and dynamics data shall be submitted for each generator in accordance with all of Attachment B (excluding Attachment B, “NERC Requirement, MOD-13-1, R1.4.”). If the aggregated generator unit capacity is 20 MVA or larger, and is connected to the WECC transmission system at 60 kV or higher, and is not a collector–based generation facility, then steady-state data shall be submitted for each individual generator in accordance with Attachment A, “NERC Requirement, MOD-11-0, R1.2”, and dynamics data shall be submitted for each generator in accordance with all of Attachment B, excluding Attachment B, “NERC Requirement, MOD-13-1, R1.4.”. (Wind and solar farms are an example of a collector-based generation facility.) If the aggregated generation capacity is 20 MVA or larger, and is connected to the WECC transmission system at 60 kV or higher, and is a collector–based generation facility, then steady-state data shall be submitted in accordance with Attachment A, “NERC Requirement, MOD-11-0, R1.2”, and dynamics data shall be submitted in accordance with all of Attachment B (excluding Attachment B, “NERC Requirement, MOD-13-1, R1.4.”) for the aggregated generation capacity as a single-unit generator model. (Wind and solar farms are an example of a collector-based generation facility.) All other generating facilities shall either be netted with bus load and steady-state data shall be submitted in accordance with Attachment A, “NERC Requirement, MOD-11-0, R1.1b; or, steadystate data shall be submitted in accordance with Attachment A, “NERC Requirement R1.2”. Proposal The intent of WR9 is proposed to be moved to the Data Preparation Manual. The modeling requirements for generators based on their capacity are still necessary. WR10 Existing Language Each Transmission Owner, Transmission Planner, Generator Owner and Resource Planner shall submit steady-state data in accordance with Attachment A, and dynamic data in accordance with Attachment B that is consistent with submitted steady-state data. Proposal The intent of WR10 is proposed to be moved to the Data Preparation Manual. The present modeling practices at WECC utilize different datasets for steady state and dynamic data to represent the same transmission system elements therefore presenting the potential for inconsistent data. W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L WECC Position Paper 7 WR11 Existing Language The Reliability Assurer (WECC) shall post on the WECC Web site the approved solved and solvable base-case data and supporting documentation. Proposal The intent of WR11 is proposed to be moved to the SRWG Study Program Procedure document. The practice of making the interconnection-wide cases available through the WECC web site will continue to be desired. W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L WECC Position Paper 8 Planning Coordinator Accounting Presently, WECC interconnection-wide cases are modeled with the ability to aggregate data into Areas, Zones, and Owners. Areas have historically represented a geographical aggregation of entities transmission system models. Zones are used to further sub-divide Areas but a consistent application of their use and purpose has not been established across WECC. Owners are intended to capture the owner of the facility being represented. The use of bus number ranges has also historically been used to aggregate data. The use of these data aggregation methods have been developed based on the limitations of the modeling software used widely throughout WECC; PSLF and PSSE. The ability to aggregate data to Planning Authority Area will help support applicable functional entities complying with MOD-032-1. The use of each of the above aggregation fields is considered in the following table: Field General consideration of using each Field to represent PC Areas Worth further consideration Area Area is used within the modeling software as the bases for balancing interchanges. Interchange values are necessary to accurately represent desired scenarios and may only be associated with Planning Coordinator Areas by coincidence. Areas should either continue to represent geographic regions or be modified to more accurately capture scheduled and actual interchanges. NO Zone The use of Zones may be used for specific processes within individual entities planning processes but they do not represent useful information from an interconnection-wide case perspective. Planning Coordinators could be allocated Zone number ranges allowing for Planning Coordinator accounting and still provide sufficient flexibility for entities to use Zones as desired. YES Owner Using the Owner field to represent Planning Coordinator Area will eliminate the ability to account for owner of the facilities represented in the cases. NO Bus Number The use of Bus Numbers for any type of aggregation is historical and represents poor modeling practices when attempting to consolidate multiple transmission system models, i.e. Westwide System Model and “Planning Cases.” NO New Field A new data field would accommodate the desire to account for Planning Coordinator Areas without modifying the existing model. Adding fields has historically been very difficult due to lag time of software vendors and lack of specificity from SRWG to the requirements of the field. YES W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L WECC Position Paper 9 Zone representation of Planning Coordinator Area Appendix 2 of the Data Preparation Manual presently assigns Area, Zone and Bus Numbers to “Member Systems.” Irrespective of the term Member System 1lacking specificity, Zone ranges and Areas do not need to be related. After assigning Planning Coordinator Zone number ranges, each Planning Coordinator will be capable of allocating its assigned Zone numbers to the entities within its Area through its jointly developed modeling data requirements and reporting procedures developed to comply with MOD-032-1, R1. An excerpt of the existing Appendix 2 is shown below: Area Number Range Zone Number Range Bus Number Range Area No. 10 10 – 18 100 – 199, 1500-1599 10,000 – 19,999 100,000 – 199,999 Zone Range Area Name 100-109 New Mexico Member System PNM 120-139 TSGT New Mexico LAC, NAPI, TNP 11 110 – 119 El Paso EPE 14 140-149 Arizona APS Member System Bus Range 10,000 – 10,999 100,000 – 109,999 12,000 – 12,999 120,000 – 129,999 13,000 – 13,999 130,000 – 139,999 11,000 – 11,999 110,000 – 119,999 14,000 – 14,999 84,000 – 85,999 140,000 – 149,999 An example of Appendix 2 with the use of Zones to represent Planning Coordinators follows: Planning Coordinator Arizona Public Service Company Zone Range 1400-1499 Avista Corporation 4400-4499 Bonneville Power Administration 4000-4109 4569-4579 1 Bus Range 14,000 – 14,999 84,000 – 85,999 140,000 – 149,999 48,000 – 49,999 480,000 – 499,999 40,000 – 41,999 44,000 – 44,499 400,000 – 419,999 Member Systems missing from new table: Tri-State LAC, NAPI, TNP AEPC, Others WALC CDWR, MWD, Others BURB, GLEN So Cal Others NW Others – Public, and Private or IOU WPE W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L WECC Position Paper 10 Planning Coordinator California Independent System Operator City of Tacoma, Department of Public Utilities, Light Division Zone Range 4860-4869 4910-4919 1899 2200-2599 3000-3999 4660-4670 Colorado Springs Utilities El Paso Electric Company 1100-1199 Idaho Power Company 6000-6199 Imperial Irrigation District 2100-2199 Los Angeles Department of Water and Power Nevada Power Company 2600-2999 NorthWestern Corporation 6200-6299 PacifiCorp 4110-4199 4700-4799 4810-4819 4830-4859 4880-4899 6500-6999 440,000 – 444,999 18,900 - 18,999 189,000 - 189,999 22,000 – 22,999 220,000 – 229,999 24,000 – 24,999 240,000 – 249,999 30,000 – 36,999 300,000 – 369,999 37,900 – 38,399 379,000 – 383,999 38,600 – 39,999 386,000 – 399,999 46,600 – 46,799 46,900 – 46,999 466,000 – 467,999 469,000 – 469,999 11,000 – 11,999 110,000 – 119,999 60,000 – 61,999 600,000 – 619,999 21,000 – 21,999 210,000 – 219,999 26,000 – 26,999 260,000 – 269,999 18,000 – 18,899 180,000 – 188,999 62,000 – 62,999 620,000 – 629,999 44,500 – 45,599 445,000 – 455,999 65,000 – 69,999 650,000 – 699,999 1800-1889 75,000 – 75,999 750,000 – 759,999 43,000 – 43,999 430,000 – 439,999 70,000 – 70,999 700,000 – 709,999 10,000 – 10,999 100,000 – 109,999 46,800 – 46,899 468,000 – 468,999 Platte River Power Authority Portland General Electric Company Bus Range 4500-4559 Public Service Company of Colorado Public Service Company of New Mexico 1000-1099 Public Utility District No. 1 of Chelan County Public Utility District No. 2 of Grant County, Washington Puget Sound Energy, Inc. 4820-4829 46,000 – 46,199 460,000 – 461,999 4200-4399 42,000 – 42,999 W E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L WECC Position Paper 11 Planning Coordinator Zone Range Bus Range 420,000 – 429,999 37,000 – 37,499 370,000 – 374,999 15,000 – 15,999 150,000 – 159,999 Sacramento Municipal Utility District Salt River Project Agricultural Improvement and Power District Seattle City Light 1500-1599 Sierra Pacific Power Company 6400-6499 Tucson Electric Power 1600-1699 46,400 – 46,599 464,000 – 465,999 64,000 – 64,999 640,000 – 649,999 16,000 – 16,999 160,000 – 169,999 38,400 – 38,599 384,000 – 385,999 4640-4649 Turlock Irrigation District Western Area Power Administration Desert Southwest Region Western Area Power Administration Sierra Nevada Region Western Area Power Administration Upper Great Plains Region Western Area Power AdministrationRocky Mountain Region 37,500 – 37,899 375,000 – 378,999 6300-6399 63,000 – 63,999 630,000 – 639,999 7300-7999 73,000 – 73999 740,000 – 749,999 76,000 – 76,999 790,000 – 799,999 CFE 2000-2099 BC Hydro 5000-5199 Fortis BC 5200-5399 Alberta ISO 5400-5999 20,000 – 20,999 200,000 – 209,999 50,000 – 51,999 500,000 – 519,999 80,000 – 81,999 52,000 – 53,999 520,000 – 539,999 54,000 – 59,999 540,000 – 599,999 A separate table is warranted to assign responsibility for the Area field. The responsible entity would be primarily responsible for coordinating interchanges. Additional functions historically assumed by the Area Coordinator role could be phased out with implementation of the Base Case Coordination System and Planning Coordinators aggregating data. The responsible entity for each geographical modeling Area would not be tied to a specific NERC standard requirement (NERC does not have a functional entity matching the footprints of the geographical modeling Areas), but rather would provide interchange data as members of the SRWG and a desire to contribute towards the development of interconnection-wide cases. An example of what the area allocation table could look like follows: Modeling Area W E S T E R N E Responsible Entity L E C T R I C I T Y Area Number C O O R D I N A T I N G C O U N C I L WECC Position Paper 12 NEW MEXICO Public Service Company of New Mexico 10 EL PASO El Paso Electric Company 11 ARIZONA Power Engineers 14 NEVADA Nevada Power Company 18 MEXICO-CFE Comision Federal de Electricidad 20 IMPERIALCA Imperial Irrigation District 21 SANDIEGO San Diego Gas & Electric 22 SOCALIF 24 PG AND E Southern California Edison Transmission & Distribution Los Angeles Department of Water and Power Pacific Gas and Electric Company NORTHWEST ColumbiaGrid 40 B.C.HYDRO BC Hydro 50 FORTISBC FortisBC 52 ALBERTA Alberta Electric System Operator 54 IDAHO Idaho Power Company 60 MONTANA NorthWestern Corporation 62 WAPA U.M. 63 SIERRA Western Area Power Administration Upper Great Plains Region Sierra Pacific Power Company PACE PacifiCorp 65 PSCOLORADO Public Service Company of Colorado 70 WAPA R.M. Western Area Power AdministrationRocky Mountain Region 73 LADWP 26 30 64 New Field – “Planning Coordinator” SRWG will request modeling software vendors to provide a new data field to account for Planning Coordinator through the Joint Users Group Subcommittee of TSS. The following specifications are required: W Mimic the functionality of the Zones field Field should be added to all element type tables; bus, branch, generator, etc. Capability to apply global filtering similar to Area, Zone and Owner E S T E R N E L E C T R I C I T Y C O O R D I N A T I N G C O U N C I L