project 2006-02: tpl-001-1 1 assess transmission future … · brian keel, srp ron mazur

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Project 2006 Project 2006 - - 02: TPL 02: TPL - - 001 001 - - 1 1 Assess Transmission Future Needs Assess Transmission Future Needs John Odom John Odom Drafting Team Chair Drafting Team Chair June 30, 2009 June 30, 2009

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Page 1: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Project 2006Project 2006--02: TPL02: TPL--001001--11 Assess Transmission Future NeedsAssess Transmission Future Needs

John OdomJohn OdomDrafting Team ChairDrafting Team ChairJune 30, 2009June 30, 2009

Page 2: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

AgendaAgenda

1. NERC Antitrust Compliance Guidelines

2. Opening Remarks and Introductions

3. Webinar Objectives

4. High Level Overview of Comments Received

5. Overview of Changes from Previous Draft

6. Comment Form

7. Q & A

8. Wrap - up

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Page 3: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

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Anti-trust 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.

Presenter
Presentation Notes
We should all be aware of these guidelines, but to ensure that we are aware of them – (read above) 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.
Page 4: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

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Introduction

Presenter
Presentation Notes
Thank team for efforts to date This team has been meeting regularly for since January 2007 (2 ½ years or 30 months). Many face-to-face meetings and many more sub-team meetings and countless e-mail discussions Importance of this standard – elaborate on impact to Transmission Owners and Bulk System Reliability. This standard is the cornerstone of transmission planning This call is not to debate the requirements in the standard or provide comments to the drafting team. Written comments should be provided for the team. This call is to help you, the industry participants, understand the revision that we have made to the draft standard and why the team made the changes. Thank the callers for participating
Page 5: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

ATFNSDT Roster

John Odom, FRCC (Chair)

Bob Millard, RFC (Vice Chair)

Darrin Church, TVA

Bill Harm, PJM

Doug Hohlbaugh, FirstEnergy

Julius Horvath, LCRA

Bob Jones, Southern

Brian Keel, SRP

Ron Mazur, Manitoba Hydro

Tom Mielnik, MidAmerican

Bernie Pasternack, AEP

Bob Pierce, Duke

Chifong Thomas, PG&E

Jim Useldinger, KCPL

Dana Walters, National Grid

Active observers

NERC Staff Coordinator – Ed Dobrowolski

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Presenter
Presentation Notes
Bob Williams – FMPA (deceased) There are many “official” observers and many of them have been and are very active. Many have been given assignments and they have provided valuable insight and input. The only difference is that when we take a vote, they cannot vote. We try to limit the number of times that we have to vote. We encourage active participation by everyone, including observers, and our meetings are always open.
Page 6: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

ObjectivesObjectives

1. Update industry on Standard Drafting Team (SDT) efforts.

2. Highlight areas where SDT made:a. Changes from 2nd posting

b. Additions since 2nd posting

3. Q & A to clarify the intent of SDT

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Page 7: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Background Background –– Drafting Team ObjectivesDrafting Team Objectives

Create a new standard that:

1. Has clear, enforceable requirements

2. Is not a Least Common Denominator standard

3. Addresses the issues raised in the SAR and issues raised by FERC and others

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Presenter
Presentation Notes
Want to remind you of the Drafting Team’s Objectives, they are to: The team always come back to these items. We often get into long, drawn out debates about a specific issue, but we always come back to these guiding principles.
Page 8: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Update on Standard Drafting Team Update on Standard Drafting Team ActivitiesActivities

The response to the first 2 postings has been very good. Between the two postings, the SDT has carefully considered:

More than 180 sets of comments

From over 250 different people

Representing over 100 companies & 9 of the 10 Industry Segments

20 face-to-face meetings & 28 full team conference calls & many more sub-team conference calls

3rd draft posted on May 26 – Comments due July 09

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Presenter
Presentation Notes
Thank you for comments on the 1st 2 postings. I believe that they have helped the Drafting Team refine the Standard. I believe that we were able to add clarity to the standard and make it a better standard because of your comments. Thank you again With this 3rd draft, we also posted over 500 pages of comments and drafting team responses. The team spent about 9 months reviewing comments, debating & formulating positions, writing requirements and writing responses. It has not been easy but the team took their job very seriously. I plan is to turn around this next set of comments more quickly. However we need your help. We need your comments to concise with suggested language. Please don’t just say something is ambiguous. At a minimum, tell us specifics about each way that it can be interpreted. Then, it would be appreciated very much if you would provide language with your suggested interpretation and why you believe that your interpretation is correct.
Page 9: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

High Level Overview of CommentsHigh Level Overview of Comments

Draft standard still not as it clear as it could be

Many commenter's agreed with general approach

Most significant disagreements were based on:

1. Lack of clarity in the draft standard

2. Disagreed with a specific requirement, often based on cost to implement

3. Thought that standard caused too much study work 9

Page 10: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Made Areas Where Drafting Team Made ChangesChanges

Definitions

Requirement Text

Performance Table

Violation Risk Factors and Time Horizon

Measures and Data Retention

Violation Severity Levels

Implementation Plan

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Presenter
Presentation Notes
Review the changes made to Definitions, Requirement Text and the Performance Table at a high level with rationale for the more significant changes. These changes were made in response to one or more commenters. Also, we added Violation Risk Factors, Time Horizons, Measures, Data Retention, VSLs and the implementation plan. Today’s presentation will focus on changes made by the team to the Requirement Text and the Performance Table and will also address the implementation plan.
Page 11: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Made Areas Where Drafting Team Made ChangesChanges

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Presenter
Presentation Notes
Start today with Definitions – we eliminated, added new definitions and made changes to other definitions: Start with the deletions and additions – Generating Unit Stability Study and System Stability Study – eliminated the entire section based on comments Bus-tie Breaker – simplified and eliminated examples Consequential Load Loss – simplified and closer to the definition contained in FERC Order 693 Year One – clarified definition by making it where it ties to the current calendar year instead of the completion of the previous years assessment.
Page 12: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Definitions (continued)

Non-Consequential Load Loss

Load Reduction - Load that is still connected to the System, but is reduced due to lower voltage conditions following a Planning or Extreme Event.

Supplemental Load Loss - Load that is disconnected from the network by end-user equipment responding to post-Contingency System conditions.

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Presenter
Presentation Notes
Non-Consequential Load Loss – Major change – Created new definitions for Load Reduction and Supplemental Load Loss. To make it clear that Supplemental Load Loss and Load Reduction are not non-consequential load loss
Page 13: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R1 - Modeling

Includes all modeling/data issues to reduce overlap with requirements in the MOD standards

Eliminates the need for requirements R9 – R14

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Presenter
Presentation Notes
Requirement R1 is Modeling Many commenters stated that R9 – R14 did not belong in the TPL standard. The SDT review and discussed the issue in depth. We have expanded R1 to reduce the overlap with MOD standards and to make sure that the planner has the responsibility to utilize the data provided, consistent with existing TPL standards. The SDT has asked NERC to add an issue to the NERC Standards Action database to update the MOD standards to eliminate the potential holes in the data requirements that could arise with the deletion of these requirements. The SDT believes that with the expansion of R1 and the current MOD standards that the planners and Planning Coordinators will continue to get the accurate data to enable them to complete their planning assessments.
Page 14: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R2 – Prepare Planning Assessment

• Minor changes in main requirement

• R2.1 – Revised explanation of sensitivities, removed requirement to explain rationale for those not run and added language to address spare equipment strategy

• R2.3 – Added detail to short circuit analysis section

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Presenter
Presentation Notes
Requirement R2 concerns the Planning Assessment Main requirement was modified to clarify the SDT’s intent R2.1 – Many commenters stated that the language in the sensitivity section was confusing. The SDT revised them to make them clearer, clarified that the sensitivity must be something that is in addition to the planner’s existing process. The SDT also removed the requirement to explain the rationale for why certain sensitivities were not studied. Also, the team added a requirement to address the utilization of the spare equipment strategy when completing the planning assessment R2.3 is the short circuit analysis section. Added specifics to clarify the SDT’s intent for the analysis
Page 15: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R2 – Planning Assessment (continued)

• R2.4 – Clarified that aggregate dynamic models are permitted and made conforming changes from R2.1 concerning the sensitivities

• R2.5 (old) – Removed Generator Stability sub-requirement

• R2.5 – Clarified requirement and added examples of material changes

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Presenter
Presentation Notes
R2.4 addresses Stability requirements. R2.5 (old) in the previous draft was removed. This sub-requirement required generator stability analysis. The majority of the commentors stated that the generator portion of the stability analysis system should not be separated. They felt that the system stability analysis section covered this requirement and as such, this sub-requirement was not necessary. Therefore, the SDT removed this requirement. R2.5 addresses past studies. The SDT clarified the requirement and added examples of material changes.
Page 16: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R2 – Planning Assessment (continued)

• R2.6 – Corrective Action Plan

Created bulleted list of examples

Eliminated the requirement to explain why changes were made (or not made) based on sensitivities

Added a new requirement that requires documentation when Non-Consequential Load is dropped under circumstances beyond the control of the TP or PC 16

Presenter
Presentation Notes
R2.6
Page 17: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R2 – Planning Assessment (continued)

• R2.7 – New requirement to develop corrective action plans for deficiencies from short circuit analysis

• R2.8 – Requirement to document the largest Consequential Load for single contingencies – moved from R2.3.2

• R2.9 – New requirement to document the largest Non-Consequential Load

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Presenter
Presentation Notes
R2.7 – need corrective action plans for short circuit analysis R2.8 – Requirement to state maximum load from any one single contingency – moved from R2.3.2 in previous draft. R2.9 – New requirement to state the maximum non-consequential load dropped for planning events where non-consequential load loss is permitted.
Page 18: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R3 – Steady State Analysis

• Main requirement changed to require utilization of models from R1

• R3.1 and R3.2 spells out requirements for Planning and Extreme Events

• R3.3 was reformatted for clarity and added requirement to simulate the expected operation of steady state control devices

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Presenter
Presentation Notes
Requirement R3 concerns the steady state analysis section Created an explicit link to R1 R3.1 spells out the requirements for Planning Events from list required to be created in R3.4 R3.2 spells out the requirements for Extreme Events R3.3 reformatted to create a list of things that the contingencies must do and added a requirement about steady state control devices, such as tap changing transformers and steps on capacitor banks – This requirement mirrors R1.3.11 from current in force TPL standards.
Page 19: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R3 – Steady State Analysis (continued)

• R3.4 changed to require the creation of a list of Planning Event contingencies and an explanation of why the remaining contingencies will be less severe

• R3.5 changed to require the creation of a list of Extreme Event contingencies and an explanation of why the remaining contingencies will be less severe

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Presenter
Presentation Notes
Removed notes from table that pointed back to this requirement.
Page 20: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R3 – Steady State Analysis (continued)

• Eliminate R3.5 (old) since it was not a requirement

R4 (old) – Short Circuit

• Deleted requirement and moved details to R2.3.4

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Presenter
Presentation Notes
Page 21: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R4 – Stability Analysis

• Parallel changes from R3 (Steady State)

• Deleted generator unit stability requirement

R5 – Proxies

• Minor changes for clarity

R6 – Define responsibilities (unchanged)

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Presenter
Presentation Notes
Requirement R4 concerns the stability analysis section
Page 22: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

R7 – Distribution of Assessments

• Deleted “neighboring systems” and replaced with “adjacent Planning Coordinators and any functional entity who has indicated a reliability need”.

R9, R10, R11, R12, R13 & R14

• Deleted

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Presenter
Presentation Notes
Page 23: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 – Performance Requirements

• Combined into a single table

• Top Note b

Added supplemental load loss and load reduction

Clarified that load loss is not allowed for P0

Added restriction that supplemental load loss cannot be utilized to meet steady state performance requirements

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Presenter
Presentation Notes
Page 24: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 (continued)

• Top Note e – re-wording of note f to clarify that operator actions must be able to be completed within the time duration allowed for the specific rating being utilized

• Top Note g – added to state that P0 is only applicable to steady state conditions

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Presenter
Presentation Notes
Page 25: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 (continued)

• Top note i – changed language to Transient Voltage Response instead of Dynamic Voltage

• Top note i (old) – Moved “Simulate Normal Clearing” to Footnote 3

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Presenter
Presentation Notes
Page 26: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 (continued)

• P0 – changed to “No Contingency”

• P1, P3 & P6 – Changed Single Pole of DC line to SLG fault type

• P1 & P3 – Changed requirements to treat AC lines and DC lines the same

• P3 & P6 – Eliminated SLG fault from fault type column

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Presenter
Presentation Notes
P0 – changed to NO Contingency from Normal System Conditions – Commentors pointed out that Normal System Conditions may mean several different states. P1 – Single Pole of a DC line was previously shown as a 3 phase fault P1 and P3 in the previous draft allowed for the curtailment of Firm Transfers if the line providing those transfers was lost. This when combined with footnote changes should eliminate the concerns raised by many commentors that the table in the previous posting was discriminatory. P3 & P6 – Changed them so that the planner is required to evaluate the 3 phase fault – This is consistent with the existing standards as it requires the study of the worst case event
Page 27: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 (continued)

• P2 – Clarified language to include “Opening of breaker without a fault”

• P5 – Changed language to clarify that the event is a single Protection System failure

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Presenter
Presentation Notes
P2 – Added “opening of” and removed “Loss of one of the following” P5 – Much debate about how to handle Protection System failures. The SDT worked closely with the System Protection and Control Subcommittee to develop an approach for this standard that was consistent with their developing work without creating gaps or holes. We, the SDT, believe that we have done that by limiting planning events portion of this standard to the loss of a single Protection System. We stayed away from components in this Planning Standard because we believe that gets down into the design requirements of the Protection System, and we thought that that work should be left for a different group of Protection System experts to finalize. The redline on P6 language showing that text was removed “followed by system adjustments” was redlined in error. This language was not in 2nd Posting. Please ignore it.
Page 28: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 (continued)

• Extreme Events portion of table

Added shunt devices to the contingency

Changed “single component failure” to “failure of a single protection system”

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Presenter
Presentation Notes
Page 29: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 (continued)

• Footnote 1 – Added Reserve Sharing Group to definition of Angular Stability

• Footnote 3 – Simulate Normal Clearing, except where noted and added a note that if 3Ø performance is acceptable, then 1Ø performance is acceptable

• Footnote 4 – Added to simplify the table by defining EHV and HV

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Presenter
Presentation Notes
Page 30: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 (continued)

• Footnote 5 – Added to clarify that Conditional Firm Transmission Service can be curtailed under the basis granted

• Footnote 6 – Changed to clarify that step-up transformers are covered under the requirements of this standard

• Footnote 7 – Added “that are connected to ground”

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Presenter
Presentation Notes
Page 31: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 (continued)

• Footnote 8 – Added to clarify the intent of description of event P2.1

• Footnote 10 – Added to allow for curtailment of firm transfers (to be consistent with Footnote b in existing TPL standards) and describe allowed circumstances

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Presenter
Presentation Notes
Page 32: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Areas Where Drafting Team Areas Where Drafting Team Made ChangesMade Changes

Table 1 (continued)

• Footnote 11 – Removed definitions for Normal Clearing and Delayed Clearing

• Footnote 12 – Added to be consistent with Footnote e in existing TPL standard and define short distances as 1 mile or less

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Presenter
Presentation Notes
Page 33: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Additions since 2Additions since 2ndnd PostingPosting

Violation Risk Factors (VRFs)

Time Horizons

Measures

Data Retention

Violation Severity Levels (VSLs)

Implementation Plan

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Presenter
Presentation Notes
These are the new items that were added with this draft. Violations Risk Factors – R1 – R4 were rated by the SDT as Medium and R5 – R7 were rated Low Time Horizons are all LONG TERM PLANNING Measures describes the evidence required for each requirement Data Retention describes how long you need to keep each item Violation Severity Levels – The SDT added a new table. The SDT attempted to make them as straightforward as possible, but in order to capture all of the elements it is more complex than I would like. Please look at all of these items in detail and provide feedback to the team. I will address the Implementation Plan in more detail on the next few slides.
Page 34: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Implementation PlanImplementation Plan

Effective Dates

• R1 (Modeling) – 12 months

• R7 (Define Responsibilities) – 12 months

• Remaining requirements – 24 months(Excludes “raise the bar” issues)

• “Raise the bar” requirements – 60 months

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Presenter
Presentation Notes
(xx after 1st day of 1st quarter after approval)
Page 35: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Implementation PlanImplementation Plan

“Raise the bar” requirements

• P2-1• P2-2 (above 300 kV)• P2-3 (above 300 kV)• P3-1 through P3-5• P4-1 through P4-5 (above 300 kV)• P5 (above 300 kV)

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Page 36: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Implementation PlanImplementation Plan

“Raise the bar” requirements

• For the 60 month time period, Non- Consequential Load Loss and curtailment of Firm Transmission Service is permitted, as long as all other requirements are met

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Page 37: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Implementation PlanImplementation Plan

“Raise the bar” requirements

• If entity cannot meet the performance requirements without Non-Consequential Load Loss and/or curtailing Firm Transmission Service by the end of the 60 months, a mitigation plan is required

• The plan will be submitted to the Regional Entity and NERC for approval.

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Page 38: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Comment FormComment Form

One question for each requirement

• Asks about the requirement text, VRF, Time Horizon, measure, data retention and VSL

Definitions

Performance Table

Footnotes 5 & 10

Implementation Plan

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Presenter
Presentation Notes
Team has devoted a tremendous amount of effort to get the performance requirements to where they had the correct balance between the differing interpretations of the existing standards, not developing lowest common denominator standards and “raising the bar”, that is, make specific tighter criteria in areas where positive reliability improvements could be made with prudent investments. The SDT believes that we have obtained that balance and we know that if we haven’t you will tell us. On the call today and on the comment form. However, the SDT is hopeful that you will accept the major requirements as laid out in this draft and will use this comment period to help us further clarify and refine the standard language. We have 7 questions – 1 for each requirement where we are asking you to respond to all aspects of that requirement; the requirement text, the Violation Risk Factor, the Time Horizon, measure, data retention and Violation Severity Level. If you will follow this format, it will really help the Team to compile the comments and make the necessary adjustments. In addition we have 4 more questions – Definitions, Performance Table, Footnotes 5 & 10 (since it is a significant change) and the implementation plan.
Page 39: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

Question & Answer

Page 40: Project 2006-02: TPL-001-1 1 Assess Transmission Future … · Brian Keel, SRP Ron Mazur

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Team plans to continue monthly meetings with conference calls every two weeks

Please provide written comments by July 9, 2009

Plan to post 4th draft later this year

Conclusion