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 Individual or group.NameOrganizationGroup NameLead ContactContact OrganizationQuestion 1Question 1 CommentsQuestion 2Question 2 CommentsQuestion 3Question 3 CommentsQuestion 4Question 4 CommentsQuestion 5Question 5 CommentsQuestion 6 Comments
Group  NPCCGuy ZitoNPCCYes Yes Yes Yes Yes  
IndividualJack Cashin/Barry GreenEPSA   No preference No preference No. Some of the detail that has been eliminated was valuable and what is left resembles a fill-in-the-blank standard in some important aspects. For example, the previous draft required that CBM requirements be updated every 30 days. While the requirement for updates every 30 days may be excessive, it is important that the quantity withheld for CBM be reviewed regularly, as this transmission capability is not available for use by the market. We suggest a minimum of quarterly be required. The previous draft also specified the requirement for a TSP to make all CBM available to eligible parties requesting it (when in an EEA 2) even if some of those parties had needs that exceeded amounts requested in advance. While EPSA agreed that this was appropriate at the time of the emergency, there needed to be a reconciliation after the fact, and a possible finding of a violation, if the appropriate amounts of CBM were not being requested and paid for and therefore inappropriate amounts of transmission capability were being withheld from the market. In the current draft standard, it is not clear that any requirement would be violated under these circumstances. No preference No preference In the following areas, EPSA believes that additional specificity in the standard would be beneficial. • The update frequency for specifying the quantities of CBM to be withheld (see question 3 above) • R3.1 specifies certain types of studies that are appropriate for the determination of CBM to be requested, for example LOLP studies. However, no guidance is provided on the appropriate target reliability. For example is 1 day in 10 years appropriate or 1 day in 100 years. • R3.2 requires the purchaser of CBM to specify the import paths or source region for the CBM. Is there any ability for the TSP to alter this request? If so, on what basis? On what frequency should this information be updated? • In R12 there is no indication of a priority level when CBM is requested by multiple LSEs in an EEA 2 and less than the full requested amount is available. Is the CBM granted to the LSE that had requested that it be set aside (R3)? Is it merely first come first served? Under this scenario, where a single contingency prompts a request for CBM from multiple LSEs, this suggests that it would be granted to the LSE that completes the paper work most quickly.
IndividualGreg RowlandDuke Energy Corporation   Yes Yes Yes Yes NoSection 1.3 Data Retention, first bullet should identify a maximum retention period, such as the most recent three calendar years plus the current year.In Requirements R7 and R8, and Measures M7 and M8 the phrase "to meet their need" should be struck. This phrase implies that the CBM set-aside would be assigned/allocated to specific LSEs and Resource Planners, which is not the case.
IndividualDennis KimmMidAmerican Energy   Yes No preference NoThe standard is a fill-in-blank standard, and although probably won't be approved by the industry unless it is a fill-in-the blank standard, I will be in the minority and not vote for this standard.No preference No preference NERC needs to develop clear standards for how the CBM value shall be determined, allocated across transmission paths, and used. The current standard does not require that to happen.
IndividualDanny DeesMEAG Power   No preference No preference No preference No preference No preference I wish to thank the SDT for its consideration of comments I submitted previously. Others at MEAG Power may choose to comment on other aspects of this standard; however, I comment solely to request that the SDT reconsider the wording of R12.3 in light of the fact that no Balancing Authority IS LOCATED WITHIN MEAG Power's service area. More specifically, MEAG Power's transmission system provides network service from network resources in Georgia to the loads of 48 cities and one county in Georgia. MEAG Power owns no transmission facilities outside of Georgia even though its system operates within the (multi-state) Southern Company Balancing Authority pursuant to a FERC-approved contract. Thus, MEAG Power is incapable of providing CBM to substantial amounts of load located within our host balancing authority (e.g., load located in Mississippi, Alabama and Florida). While it may not be typical for a TSP's service area to be a subset of its host balancing authority's footprint, I believe there are some others in this situation. Therefore, please consider if the following alternative wording would be suitable: R12.3 The energy deficient entity in the Balancing Authority with the EEA 2 has load located within the Transmission Service Provider’s area.
IndividualChuck FallsSRP   Yes Yes Yes NoVSL for R2 - The VSL ties the number of days for notification to others using the phrase "after a change was made" in the CBMID. The requirement R2 refers instead to "the effective date of the change" which may be different from the date a change is made in the CBMID. We suggest the wording at all levels of VSL for this requirement be modified to refer to the effective date of the change. VSL for R5 - None of the VSL levels are identified if the TSP never re-establishes the CBM once first established. Suggest adding the following words to the Severe VSL description " OR The TSP never re-establishes the CBM after first established." Also, in both the Moderate & Severe VSL description the words "if available" should be added following reference to R5.1 since none of the items in this section may be available which is acceptable per the first sentence in R5.1. VSL for R6 - Same comments apply as for R5 VSL. VSL for R7 - Change the "all" to "of" in the last sentence of the severe VSL. Yes No other comments to offer.
IndividualJohn HarmonMidwest ISO   Yes Yes Yes Yes Yes R6: Can the SDT clarify the intent of "planning purposes during the subsequent years two through ten." Does this refer to transmission expansion planning or long term TSR planning? The Midwest ISO believes the intent is for transmission expansion planning. If this is true, then we believe that establishing/using a predetermined CBM value per path or flowgate should not be the only way to account for LOLE in the planning process. The Midwest ISO, through Module E of its Tariff, conducts Resource Adequacy studies to determine the total amount of generation available in its footprint and then derive the total amount of power remaining to satisfy its LOLE requirements. This remaining power can be accounted for by building additional transmission in order to import or new generation can be built to meet the remaining power requirement. The Midwest ISO calculates CBM values for flowgates based on the remaining power requirement for short term (less than a year) ATC calculations. The Midwest ISO processes for Resource Adequacy and CBM Methodology have been through a Stakeholder process. We ask the SDT to consider the following language change: R6: The Transmission Planner shall establish a predetermined CBM value for each ATC Path or Flowgate or GCIR for each designated area to be used for future transmission planning during the subsequent years two through ten. R6.1 CBM and GCIR values shall reflect consideration of each of the following if available: •Any studies (as described in R3.1) performed by Load-Serving Entities for loads within the Transmission Planner’s area •Any studies (as described in R4.1) performed by Resource Planners for loads within the Transmission Planner’s area •Any reserve margin or resource adequacy requirements for loads within the Transmission Planner’s area established by other entities, such as municipalities, state commissions, regional transmission organizations, independent system operations, Regional Reliability Organizations, or regional entities R6.2 Predetermined CBM values shall be allocated as follows: •For ATC Paths, based on the expected import paths or source regions provided by Load-Serving Entities or Resource Planners •For Flowgates, based on the expected import paths or source regions provided by Load-Serving Entities or Resource Planners and the distribution factors associated with those paths or regions, as determined by the Transmission Planner R6.3 Entities that do not utilize a predetermined CBM value in their respective planning process shall describe in their CBMID how the GCIR is calculated for each area and how the GCIR is used to calculate CBM values for ATC paths or Flowgates for selling transmission service. R8: The Midwest ISO believes this requirement will also need modification based on our comments and proposed revision to R6. Please consider the language below: R8. Less than 31 calendar days after the establishment of CBM or GCIR, the Transmission Planner shall notify all the Load-Serving Entities and Resource Planners that determined they had a need for CBM on the system being planned by the Transmission Planner of the amount of CBM set aside or the GCIR required to meet their resource adequacy requirements.
Group  FirstEnergySam CicconeFirstEnergy Corp.Yes NoPer our comments from Item 1 in Question 6 regarding the TSP electing to maintain CBM, we suggest changing "Transmission Planner, when their associated Transmission Service Provider has elected to maintain CBM" to simply "Transmission Planners".YesWe agree that the standard should be much less prescriptive as to how CBM is determined and utilized.  NoM6 - The phrase "(Note that CBM values may legitimately be zero)" should be removed from the measures and be integrated into the requirements. M10 - The end of the statement in the measure should say "EEA 2 or higher". 1. We question how the TSP can "elect" to maintain CBM per R1. What if, per R3, the LSE determined they had a need to set aside transmission capacity as CBM but their TSP does not maintain CBM? Per FERC Orders 890 and 693, the LSE has the right to request CBM be set aside if it can prove that it is a critical need based on LOLE, deterministic studies, historical data, etc. as described in R3. We suggest revising the first part of the first sentence of R1 to state "The Transmission Service Provider that has been asked by its LSE or RP to maintain CBM…". 2. Per R3 and R4, it is not clear how GCIR is used in the CBM process. Is it merely equal to the CBM value or is it somehow used by the TSP to determine how much CBM is needed for each ATC Path or Flowgate? Either way, the standard should explain what is done with the GCIR once it has been established. 3. In R3.1 and R4.1, can the LSE and RP use different studies for different ATC Paths or Flowgates? If so, then R3.1 and R4.1 should be revised to state "Using one of the following for each ATC Path or Flowgate to determine the GCIR:". 4. With regard to R3 and the responsibilities of the LSE, currently many LSEs work with their TSP to determine the need for CBM because most LSEs do not have the capability to undertake these studies on their own. In addition, several LSEs participate within a Planned Resource Sharing Group that works with that sharing group's TSP to determine the need for CBM. We assume that these activities would be permitted to continue and that this standard will not preclude LSEs from working with their TSP to determine CBM needs. We ask the SDT to confirm our assumptions.
IndividualH. Steven MyersERCOT   No preferenceAt present, ERCOT does not use the concept of CBM in its operating activities. Therefore, I do not feel it would be appropriate for me to comment upon the VRFs. I believe that ATC, TTC, AFC, CBM, and TRM are concepts that apply to the operation of a Transmission Service Market and do not have an associated reliability function if such a market is not in use.NoI believe language should be added to make it very clear that only those entities that have ATC paths are applicable. I believe that the Requirements have been modified to indicate that only such entities that use the concept of CBM have a performance expected, but further clarifying the applicable entities language would help to make it even clearer.Yes No preferenceAt present, ERCOT does not use the concept of CBM in its operating activities. Therefore, I do not feel it would be appropriate for me to comment upon the VSLs. I believe that ATC, TTC, AFC, CBM, and TRM are concepts that apply to the operation of a Transmission Service Market and do not have an associated reliability function if such a market is not in use. No preferenceAt present, ERCOT does not use the concept of CBM in its operating activities. Therefore, I do not feel it would be appropriate for me to comment upon the measures and compliance elements. I believe that ATC, TTC, AFC, CBM, and TRM are concepts that apply to the operation of a Transmission Service Market and do not have an associated reliability function if such a market is not in use. 
IndividualAlessia DawesHydro One Networks   Yes NoThe Applicability section of the standard reads as if maintaining a CBM is optional. We have concern with the following: Section 4.5 "Transmission Planners, when their associated Transmission Service Provider has elected to maintain CBM." This reads as though the TSP has the option of not maintaining a CBM and hence a TP has no responsibility as well. We suggest removing the "… when their associated TSP has elected to maintain CBM…" as it is manditory that CBM is established and maintained (even if it is zero).Yes NoVSL for R2: The VSL should be based on whether the TSP gave prior notice to changes in the CBMID before the changes took effect. Hence the requirement needs to be modified to specify how much "prior" is acceptable. We propose 30 days as appropriate. Hence the VSLs could be: Low = "…notification of less than 30 days but greater than 20 days of effective date." Medium = "… notification of 20 days or less but greater than 10 days of effective…" High = "…notification of 10 days or less but greater than 1 day of effective date…" Severe = "… gave 1 day or no notice of change prior to the effective date …" As well, the VSLs for the second condition of R2 (the entities requiring CBMID) use the word "some" which is a loose term. We suggest rewording the "AND" part of the VSLs as follows: High = " …made available the CBMID to less than 100% but greater than 50% of all entities listed in R2 who require it." Severe = "…made available the CBMIS to 50% or less of all entities listed in R2 who require it." VSLs for R7, R8 and R9 using this "some" loosely as well. We recommend the same wording recommended for R2 VSLs above. VSL for R6: The VSL ranges need to be modified to match the requirement range OR change the requirement to state the frequency at which they must maintain the subsequent 2 to 10 year CBM values. Also, requirement R6 induces the question "subsequent to what?" Do we assume subsequent to R5's 13 months? We may be interpreting the requirement wrong. If so, please rephrase the requirement. Yes Effective Date: We believe there is a fundamental issue related with effective dates, that is, the dates in which Reliability Standards become effective and enforceable. In principle, the effective date of standards must be the same for all jurisdictions in North America. It does not make sense that there is a period of time when a standard is effective only in some jurisdictions while not in others. This is particularly important in standards that have a clear reliability impact. In addition, it does not seem appropriate to have entities exposed to sanctions for non-compliance in some jurisdictions while not in others. The words inserted in the Effective Date of the Standards as well as in the Implementation Plan posted documents permit that these Standards are effective in some jurisdictions and not others. The Standard and the Implementation Plan should be modified to ensure that they become effective in all jurisdictions at the same time, including those where such regulatory approval in not required, that is, only when all regulatory approvals have been obtained. We suggest the same words used in MOD-001, 28, 29 and 30 be used: “All requirements in the standard should become effective on the first day of the first calendar quarter that is twelve months beyond the date the standard is approved by all applicable regulatory authorities.” R11 and R12: We think these requirements belong in the INT standards which deals with reliability assessment of Arranged Interchange.
IndividualCatherine WesleyPJM   Yes Yes Yes Yes Yes PJM submits the following comments for consideration. PJM proposes revising Requirement 6 as follows: R6 - At least every 13 months, the Transmission Planner shall establish a CBM value for each ATC Path or Flowgate to be used during the subsequent years 2 through 10. This value shall: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] PJM proposes the addition of a new Requirement 7 as follows: New R7 - At least every 13 months, the Transmission Planner shall establish a CBM value to be used for planning purposes during the subsequent years 2 through 10. This value shall: [Violation Risk Factor: Lower] [Time Horizon: Operations Planning] PJM agrees that Requirements 10, 11 and 12 are essential. PJM identifies these requirements as addressing emergency scenarios. PJM proposes that it is more appropriate to include these requirements in EOP-002, Attachment 1 which governs emergency operations.
Group  ISO RTO Council/Standards Review CommitteeCharles YeungSouthwest Power PoolYes Yes Yes NoWe agree with all VSLs except the following: R2: The structure of R2 is fine, but the identification of "late" notification of changes to CBMID needs to be based upon some specific time frame requirement in R2, which is absent in this draft standard. Please see our related comments under Q6. Further, the second condition for the HIGH VSL is loose. It assigns a HIGH to the TSP if it made available the CBMID to "some", but not all, of the entities specified in R2. "Some" needs to be more specific as otherwise, it will be a basis for argument in an audit process. Suggest to expand and grade the second condition VSLs by 1, 2, 3 and 4 or more for Low, Medium, High and Severe. R7: Same comment and suggestion for R2 on the assignment of HIGH based on "some" also applies here. R8: Same comment and suggestion for R2 on the assignment of HIGH based on "some" also applies here. R9: Same comment and suggestion for R2 on the assignment of HIGH based on "some" also applies here. In this case, the graded VSLs can be based on the percentage of total data requested. Yes R2: It requires the TSP to notify those entities of any changes to the CBMID prior to the effective date of the change. There should be a time frame specified for the notification to tighten up the requirement and facilitate proper development of measures and VSLs. Given that the changes affect the CBMID, we'd think that a period of 7 to 30 days would be approriate. R9: It requires the TSP and TP to provide copies of the supporting data, including any models, used for determining CBM to a number of entities. It should be noted that some of these requesting entities may have commercial interests or affiliations. Further, in some established markets or jurisdictions, the TSPs and/or the TPs may not be able to provide such data, especially the model, to a third party. We suggest this requirement be qualified by adding "subject to confidentiality and security requirements" as in MOD-001, R8. R11 and R12: We think these 2 requirements should be moved to INT-006 which deals with reliability assessment of Arranged Interchange. The draft INT-006 being posted for comments deals specifically with emergency requests (and reliability adjustment requests).
IndividualRon FalsettiOntario IESO   Yes Yes Yes NoWe agree with all VSLs except the following: R2: The structure of R2 is fine, but the identification of "late" notification of changes to CBMID needs to be based upon some specific time frame requirement in R2, which is absent in this draft standard. Please see our related comments under Q6. Further, the second condition for the HIGH VSL is loose. It assigns a HIGH to the TSP if it made available the CBMID to "some", but not all, of the entities specified in R2. "Some" needs to be more specific as otherwise, it will be a basis for argument in an audit process. Suggest to expand and grade the second condition VSLs by 1, 2, 3 and 4 or more for Low, Medium, High and Severe. R7: Same comment and suggestion for R2 on the assignment of HIGH based on "some" also applies here. R8: Same comment and suggestion for R2 on the assignment of HIGH based on "some" also applies here. R9: Same comment and suggestion for R2 on the assignment of HIGH based on "some" also applies here. In this case, the graded VSLs can be based on the percentage of total data requested. Yes R2: It requires the TSP to notify those entities of any changes to the CBMID prior to the effective date of the change. There should be a time frame specified for the notification to tighten up the requirement and facilitate proper development of measures and VSLs. Given that the changes affect the CBMID, we'd think that a period of 7 to 30 days would be approriate. R9: It requires the TSP and TP to provide copies of the supporting data, including any models, used for determining CBM to a number of entities. It should be noted that some of these requesting entities may have commercial interests or affiliations. Further, in some established markets or jurisdictions, the TSPs and/or the TPs may not be able to provide such data, especially the model, to a third party. We suggest this requirement be qualified by adding "subject to confidentiality and security requirements" as in MOD-001, R8. R11 and R12: We think these 2 requirements should be moved to INT-006 which deals with reliability assessment of Arranged Interchange. The draft INT-006 being posted for comments deals specifically with emergency requests (and reliability adjustment requests).
IndividualJason ShaverAmerican Transmission Company   NoATC supports the change to raise R11 and R12 from lower to medium. This is an example where clearly there is the potential for violations to "directly affect the electrical state or the capability of the Bulk-Power System" as described in the definition for the Medium Risk Requirement. In addition, ATC suggests that R10 be assigned as a "Medium" VRF as well. There is the potential for violations to "directly affect the electrical state or the capability of the Bulk-Power System" as described in the definition for the Medium Risk Requirement. No preference YesATC supports the proposed elimination of excess detail. In addition, ATC suggests that R9 be changed to "The Transmission Service Provider or Transmission Planner that maintains CBM shall provide copies of the applicable supporting data".Yes Yes 1. Due to the Midwest ISO methodology of calculating CBM in the short-term (1 year) and GCIR in the long-term, we believe that R6 should be changed to include: "GCIR for each designated area to be used for future transmission planning." and add the words "that maintains CBM" after "the Transmission Planner" 2. R6.1 should include "CBM and GCIR values shall reflect consideration of each of the following if available". 3. R6.3 should include "Entities that do not utilize a predetermined CBM value in their respective planning process shall describe in their CBMID how the GCIR is calculated for each area and how the GCIR is used to calculate CBM values for ATC paths or Flowgates for selling transmission service." 4. R8 should include "Less than 31 calendar days after the establishment of CBM or GCIR, the Transmission Planner shall notify all the Load-Serving Entities and Resource Planners that determined they had a need for GCIR on the system being planned by the Transmission Planner of the amount of CBM set aside or the GCIR required to meet their need." 5. Change the wording in 1.3 Data Retention to: "The Compliance Enforcement Authority shall keep the last audit records and all subsequent requested and submitted audit records."
Group  Bonneville Power AdministrationDenise KoehnTransmission Reliability ProgramNo preference No preference NoWhy isn’t the LSE among the entities listed in sec B.R.2, to which the TSP must make the current copy of the CBMID available to?No preference No preference How would a generator in a neighboring Balancing Authority (or control area) provide the CBM due to a sudden generation outage in the host control area (or BA area) where the outage occurred? The CBM would be provided after the TRM and has been established as a reliability requirement by an LSE. The ATC DT should explain how this standard ensures that an LSE can replace the lost generation from a neighboring BA. New Section A.5. Effective date : On the third line, "become" should be "becomes" that is unless they intend to pluralize standard to be standards. CBM is a scheduled transmission reservation that is implemented following the expiration of the TRM. (TRM is unscheduled transmission capacity that can be used to implement emergency operations up to 59 minutes.) Would like to suggest that that the scope of Project 2009-09, a Resource Adequacy Assessments Standard, which is slated for development in 2009, be enlarged to include aspects of MOD-004 that relate to defining the four analyses upon which the GCIR determination is based in greater detail. Although we agree that any one of these analyses is appropriate in calculating GCIR, we believe that these analyses need to be defined in greater detail in order to achieve the stated purpose of the standard. The stated purpose of this standard is: "To promote the consistent and reliable calculation, verification, preservation, and use of Capacity Benefit Margin (CBM) to support analysis and system operations." The standard also states that the determination of Generation Capability Import Requirement (GCIR), which is the basis for the CBM request, can be calculated using any of the following analyses: (1) Loss of Load Expectation (LOLE) studies, (2) Loss of Load Probability (LOLP) studies, (3) Deterministic risk-analysis studies and (4) Reserve margin or resource adequacy requirements established by other entities, such as municipalities, state commissions, regional transmission organizations, independent system operators, Regional Reliability.