status of bulk electric system definition project

BES Definition
Proposed new BES Definition and Exception Process approved by NERC
BOT and filed with the FERC in January, 2012
FERC NOPR issued proposing to approve the new definition and exception
process but soliciting comments on some parts of the definition
FERC Order issued on December 20—approved definition with some
directed changes /clarifications
FERC Order Major features/directed changes:
 Entities seeking exclusion of “local distribution facilities “
otherwise included in the BES would appeal directly to
FERC (Seven Factor test used as starting point along with
“other factors”)
 Lines >100 KV that are looped by a <100 KV line are not
radial in nature and are not excluded under Exclusion E1
(although the < 100 KV loop(s) would be excluded unless
brought in by the exception process). However, the entire
system could qualify for Exclusion E3 (Local Network).
BES Definition
• FERC Order
 Interconnection lines (>100 KV) for Generators included
by I2 are directed to be included in the BES as part of
E1 implementation. If owned by GO, NERC can
register GO as TO/TOP with select set of applicable
standards or consider tie-line as part of generator
(applies to E3 also)
 Directs NERC to modify Exclusion E3 to include
networks looped at voltages < 100 KV for consideration
(proposed definition limited LNs to 100 KV to 300KV)
 Exception Process
 Confirms that burden of proof lies with submitting entity
 Expects Registered Entities and Regional Entities to identify
sub-100 KV elements that should be included in the BES, but
affirms FERC’s ability to order such elements (and any other
elements) to be included in the BES
BES Definition
• FERC Order
 Exception Process
 NERC can request the Regional Entities to include
elements in the BES (aimed at sub-100 KV systems)
 Basic tenet is that Registered Entities will determine
which of their facilities are part of the BES by the
application of the BES Definition in its entirety.
Registered Entities are required to notify the Regional
Entities when an element is no longer part of the BES
• FERC suggested that other issues brought by
commenters be pursued in Phase 2 by those
• The FERC Order is subject to FERC’s due process for
requests for rehearing, etc. and the BES SDT will
respond to the final order.
BES Definition
• Standard Drafting Team (SDT) posted for
comments a detailed guidance document
containing the BES Definition application
methodology as envisioned by the SDT with
detailed examples for various configurations
• Examples illustrated the hierarchy of applying the
BES “core” definition and the Inclusions and
Exclusions that make up the total BES Definition
• The comments and the FERC Order are currently
being considered. Changes will be made to the
guidance document when the FERC Order is
finalized and again with the completion of Phase 2.
BES Definition
 Phase 2—Standard Authorization Request
• The SAR was posted for comments in early 2012,
comments incorporated and SAR was approved by
the NERC Standards Committee
• SAR proposed four areas for further consideration
1. Technical justification of appropriate thresholds for
including Real and Reactive Resources in the BES
2. Determine if there is a need to change the Phase 1
basis of a non-contiguous BES
BES Definition
Phase 2--SAR
3. Determine if there is technical justification to revise
the 100 KV bright-line voltage level
4. Determine if there is technical justification to allow
power flow out of a local network (Exclusion E3)
under certain conditions and, if so, what magnitude
and duration should be allowed.
In addition, the SAR proposed to clarify certain
items based on industry comments and to
determine if any other improvements in the
definition could be made
In addition, the SAR is broad enough to respond
to changes due to the FERC Order on Phase 1
BES Definition
 Phase 2
• The SDT formulated a problem statement
containing details of the four Phase 2 issues--sent
to the NERC Planning Committee (PC) for analysis
by their appropriate technical subcommittees
• The PC recommended no changes in the definition
with the exception of Exclusion E3 (Local
• PC recommended changes in E3 involve extension
of “no outflow” to any of the interconnections of the
LN with the BES and limiting the LN to 300 MW of
BES Definition
 Phase 2
• The BES SDT is considering changes in Inclusion
I4 (Phase 1 dispersed power producing resources)
to clarify I4 and more closely correlate with
Inclusion I2 (traditional power producing resources)
based on industry comments on the guidance
• The BES SDT is considering a change in Exclusion
E1 (radial line exclusion) also based on industry
comments requesting clarification of the term “nonretail generation”
BES Definition
 Phase 2
• In future meetings the BES SDT will be
o Sequence of Exclusions in the definition based on
the hierarchical application of the definition
o The NERC PC recommendations
o Possible changes to the ERO Statement of
Compliance Registry Criteria based on revised BES
o Additional Guidance Document revisions
o Response to directives in the FERC Order on Phase
1 Definition
BES Definition
 Phase 2 Schedule
First Posting in April
Successive Ballot in Q3 2013
Recirculation Ballot in Q3 2013
BOT Approval Q4 2013

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