Revisions to TOP-001-3

Report
Project 2014-03
Revisions to TOP-001-3
Third Posting Webinar
October 2014
Agenda
• Objectives
• Background
 Standard Drafting Team (SDT) Roster
 Project History and Schedule
 Project Inputs
• Second Posting Ballot Results
• Third Posting Details – TOP-001-3
• Questions and Answers
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NERC Antitrust Compliance
Guidelines
It is NERC’s policy and practice to obey the antitrust laws and to
avoid all conduct that unreasonably restrains competition. This
policy requires the avoidance of any conduct that violates, or
that might appear to violate, the antitrust laws. Among other
things, the antitrust laws forbid any agreement between or
among competitors regarding prices, availability of service,
product design, terms of sale, division of markets, allocation of
customers or any other activity that unreasonably restrains
competition. It is the responsibility of every NERC participant
and employee who may in any way affect NERC’s compliance
with the antitrust laws to carry out this commitment.
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Public Announcement
Participants are reminded that this meeting is public. Notice of
the meeting was posted on the NERC website and widely
distributed. The notice included the number for dial-in
participation. Participants should keep in mind that the
audience may include members of the press and
representatives of various governmental authorities, in addition
to the expected participation by industry stakeholders.
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Objectives
• Present the changes in the third posting with emphasis on TOP001-3
• Explain the SDT’s reasons for the changes
• Or, explain why the SDT didn’t make certain changes
• Continue outreach and education
 If you have a group that you would like to make certain receives a
presentation, let one of the SDT members know
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SDT Roster
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Dave Souder, PJM, Chair
Andy Pankratz, FPL, Vice Chair
David Bueche, Center Point
Jim Case, Entergy
Allen Klassen, Westar
Bruce Larsen, WE Energies
Jason Marshall, ACES
Bert Peters, Arizona Public Service
Robert Rhodes, SPP
Kyle Russell, IESO
Eric Senkowicz, FRCC
Kevin Sherd, MISO
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Project History and Schedule
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April 16, 2013: Projects 2006-06 and 2007-03 submitted
November 21, 2013: Both projects proposed for remand
December 20, 2013: NERC asked FERC to postpone remand
January 14, 2014: FERC agreed to postpone until January 31, 2015
February 12, 2014: Project 2014-03 started
May 19, 2014 – July 2, 2014: First posting
August 6, 2014 – September 19, 2014: Second Posting
October x, 2014 – October y, 2014: Final ballot
October x, 2014 – October y, 2014: Third posting of TOP-001-3
November 12, 2014: Present to NERC Board of Trustees (Board) for
approval
• January 31, 2015: submittal to FERC deadline
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Project Inputs
• Projects 2006-06 and 2007-03
 Standard Authorization Requests (SARs)
 Directives and Issues
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FERC Notice of Proposed Rulemaking (NOPR)
Independent Experts Report
SW Outage Report
Operating Committee Executive Committee Memo
IRO Five-Year Review
Technical Conferences
 St. Louis, MO
 Washington, DC
 Sacramento, CA
• First and Second Posting Comments
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Second Posting Ballot Results
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Standard
1st Ballot
2nd Ballot
Final Ballot
IRO-001-4
68.57%
76.05%
October
IRO-002-4
36.94%
74.05%
October
IRO-008-2
47.87%
75.54%
October
IRO-010-2
60.26%
84.21%
October
IRO-014-3
61.67%
75.60%
October
IRO-017-1
57.94%
78.40%
October
TOP-001-3
30.99%
48.04%
November
TOP-002-4
62.18%
78.77%
October
TOP-003-3
63.07%
85.72%
October
Definitions
62.64%
93.04%
October
* Dr
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Third Posting Details
TOP-001-3
• Requirements R1 and R2:
• Deleted ‘Operations Planning’ from all time horizons dealing with
Operating Instructions
• Operating Instructions are Real-time oriented
• Replaced ‘ensure’ with ‘address’
• Entity can only address reliability issues, can’t guarantee reliability
• Restructured requirement wording for clarity
• Did not bring back Reliability Directive
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Definition was rejected in FERC NOPR
Operating Instruction is approved terminology and capture’s SDT intent
RSAW modified to address industry concern regarding increased compliance risk.
Data Retention modified to address industry concern regarding administrative
burden.
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Third Posting Details
TOP-001-3
• Requirement R7:
• Capitalized ‘E’ in Emergency
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Uses defined term from Glossary
Requirement R8:
• Deleted ‘other’ from ‘known other Transmission Operators’
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Consistency with other requirements
Wouldn’t be notifying itself so term is redundant
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Third Posting Details
TOP-001-3
• Requirement R9:
• Deleted ‘NERC registered’ in front of ‘entities’
• Consistent with other such deletions in second posting
• Added ‘sustained’ in front of ‘outages’
• Not interested in momentary loss
• Combined ‘telemetering’ and ‘control’ equipment
• Consistent with Version 0 requirement language
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Third Posting Details
TOP-001-3
• Requirement R10:
• Restructured to make clear what needs to be done internal versus
neighboring TOP Areas
• Emphasized why this was being done – to determine SOL exceedances
• Changed ‘sub-100 kV’ to ‘non-BES’ for clarity of SDT’s intent
• Did not delete requirement for non-BES as this is required from FERC NOPR, IERP
Report recommendations, and SW Outage Report recommendations
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Third Posting Details
TOP-001-3
• Requirement R11:
 Replaced ‘ensure’ with ‘in order for it to be able to’ perform its reliability
functions
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 Can’t ensure reliability
Requirement R13:
• Did not replace ‘ensure’ as term is correct here – entity must ensure Realtime Assessment is performed
• Did not change 30 minute timeframe as this is a FERC approved
timeframe for Real-time Assessments
• Emphasized that an entity may have others perform the assessment
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Third Posting Details
TOP-001-3
• Requirement R16:
• Replaced ‘Real-time Assessment’ with ‘analysis’
• Need to consider all analyses such as Operational Planning Analysis
• Requirement R18:
• Deleted ‘Balancing Authority’
• Balancing Authority not involved with SOLs
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Third Posting Details
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SDT made a good faith effort to address comments within
constraints of project inputs
Although 8 of 9 standards passed in second posting, all is
dependent on TOP-001-3 as standards are tightly intertwined
and can’t be filed in pieces
If TOP-001-3 doesn’t pass, then all fail
FERC remand kicks in if Project 2014-03 isn’t filed by January
31, 2015
• Result would be specific directives from FERC on how to revise TOP and
IRO standards
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