Comment Form - Reliability Guideline: Area Control Error

Official Comment Form Reliability Guideline: Area Control Error Diversity Interchange Process

Please use this form to submit comments on the proposed Reliability Guideline: Area Control Error Diversity Interchange Process. Comments must be submitted by 5:00 p.m. ET on August 31, 2017. You may submit the completed Microsoft Word form by e-mail to ([email protected]) with the words “Reliability Guideline: Area Control Error Diversity Interchange Process” in the subject line. Only comments submitted in Microsoft Word format using this comment form will be accepted. Red-line document changes, PDF versions of this document, or email comments will NOT be accepted. Comments may be submitted by individuals or groups. If the comments are from an individual, please provide the contact information for the submitter in Information Table 1, and provide the requested affiliation information in Information Table 2. If the comments are from a group, please provide the contact information for the leader of the group in Information Table 1, the requested affiliation information in Information Table 2, and a list of all group participants in Information Table 3. Note: If you need to add a row to the table below please select Table from the above toolbar then Insert “Row Above” or “Row Below.” If you have any questions on the subject information, please contact [email protected].

mailto:[email protected]?subject=Reliability%20Guideline:%20Generator%20Loss%20of%20Communication

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Official Comment Form – Reliability Guideline: Area Control Error Diversity Interchange Process 2

Information Table 1

Individual Commenter or Group Leader Contact Information Name: Ruida Shu Entity Name: NPCC Telephone: 917-232-5140 E-mail: [email protected]

Information Table 2 Select each NERC Region that you

represent: Select each Industry Segment that you represent:

ERCOT FRCC MRO NPCC RFC SERC SPP WECC NA – Not Applicable

1 — Transmission Owners 2 — RTOs, ISOs 3 — Load-serving Entities 4 — Transmission-dependent Utilities 5 — Electric Generators 6 — Electricity Brokers, Aggregators, and Marketers 7 — Large Electricity End Users 8 — Small Electricity End Users 9 — Federal, State, and Provincial Regulatory or other Government Entities 10 — Regional Reliability Organizations and Regional Entities NA – Not Applicable


Information Table 3

Group Comments (Complete this page if comments are from a group.) Group Name: NPCC Regional Standards Committee

Additional Member Name Additional Member Entity Name

Region(s) Segment(s)

Paul Malozewski Hydro One NPCC 1 Michael Forte Con-Edison Company of New

York NPCC 1

Michael Schiavone National Grid NPCC 1 Laura Mcleod New Brunswick Power

Corporation NPCC 1

Michele Tondalo The United Illuminating Company

NPCC 1

Sylvain Clermont Hydro-Quebec TransEnergie NPCC 1 Ori Shmul Orange and Rockland Utilities NPCC 1 Quintin Lee Eversource Energy NPCC 1 Gregory Campoli NY-ISO NPCC 2 Kathleen Goodman ISO-NE NPCC 2 Helen Lainis IESO NPCC 2 Chantal Mazza Hydro-Quebec TransEnergie NPCC 2 Randy MacDonald New Brunswick Power

Corporation NPCC 2

Daniel Grinkevich Con-Edison Company of New York

NPCC 3, 4

Michael Jones National Grid NPCC 3, 4 David Burke Orange and Rockland Utilities NPCC 3, 4 Peter Yost Con-Edison Company of New

York NPCC 5


Salvatore Spagnolo New York Power Authority NPCC 5 Sean Bodkin Dominion Energy Services NPCC 5 David Ramkalawan Ontario Power Generation NPCC 5 Glen Smith Entergy Services NPCC 5 Brian O'Boyle Con-Edison Company of New

York NPCC 6

Brian Robinson Utility Services NPCC 6 Shivaz Chopra New York Power Authority NPCC 9 Vijay Puran NYS Department of Public

Service NPCC 9

Alan Adamson NYS Reliability Council NPCC 10


Enter all comments in the tables below . Red-line changes w ill not be accepted. Submit this form in M icrosoft Word format only. There are two forms provided for your use to submit comments on this guideline. The first form is used to provide general comments on the guideline. These general comments should not reference a specific section or page in the guideline, but rather, should be overall comments on the guideline or concepts in the guideline, and may include repeating comments that are applicable to a number of sections. The second form is used to provide comments to specific sections of the guideline, such as spelling, punctuation or word usage comments, as well as to provide specific comments to concepts on the indicated page and line of the guideline. When performing the review, please use the “clean version (not any “redline” versions) of the document in order to ensure consistently in provided comments from multiple commenters. Please provide sufficient information in your comments to allow the working group to understand the issue being commented upon, and provide suggested changes to the guideline that the working group may use to update the guideline.


Instructions for general comments:

• Provide a description (or explanation) of your comments in the Comment column.

• Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the working group to update the document.

The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert “Row Above” or “Row Below.”

Comment Proposed Change Comment resolution adopted by the

working/task group on each comment submitted


Instructions for specific comments on the text of the document:

• Provide a page number and line number reference for each comment (page and line numbers are provided in the review version of the document). When referencing page and line numbers, refer to the “clean” version of the posted document. Please DO NOT refer to page and line numbers in “redline” versions of documents.

• Identify each comment as either E (editorial), i.e., spelling, punctuation, formatting; or, T (technical) i.e., content changes.

• Provide a description (or explanation) of your comments in the Comment column.

• Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the NERC Operating Committee to update the document.

The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert “Row Above” or “Row Below.”

Page Number

Line Number

Type of Comment

(Editorial / Technical)

Comment Proposed Change Comment resolution

adopted by the working/task group on

each comment submitted

4 136-138 Technical RSC Members have a minor concern with the guidance in the Potential ACE Diversity Guideline

The statement at issue is (on page 4 of the Guideline): "To clarify, the ADI adjustment should not modify the real-time NIA value for any other purpose other than end of hour inadvertent Interchange accounting."

NPCC participating BAs model ADI as a pseudo-tie and include it in the ACE

Please clarify that treating ADI as a pseudo-tie and factoring the ADI into ACE equation calculations by summing ADI with the Actual Net Interchange NIA) is an acceptable practice under this Guideline. If that is not the case, RSC requests revising the Guideline to specifically, allow for this scenario.


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each comment submitted equation as an adder to NIA and the above statement appears to be contradicting the first statement in the same paragraph. ("The ADI process as defined above is a process that directly modifies ACE in order to achieve a final value of lesser magnitudes for each participating BA to use in the calculation of CPS1 or BAAL.") We are requesting clarification of the statement at issue.

3 109-110 Editorial Please consider removing the following sentence: “It does not affect the tie line meters as an actual amount of energy transfer”.

The current sentence is not accurate and explaining it further will not provide additional value.


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Documents

Comment Form - Reliability Guideline: Area Control Error