+-----------------------------------------------------------------------+
| #### *SAR Commenter Information (For Individual Commenters)*          |
+-----------------------------------------------------------------------+
| Name Chifong Thomas                                                   |
|                                                                       |
| Organization WECC-Technical Studies Subcommittee                      |
|                                                                       |
| Industry Segment \# 2                                                 |
|                                                                       |
| Telephone (415) 973-7646                                              |
|                                                                       |
| E-mail clt7@pge.com                                                   |
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+------------------------------+----------------------+---------------+
| #### *SAR Comme              |                      |               |
| nter Information (For Groups |                      |               |
|  Submitting Group Comments)* |                      |               |
+------------------------------+----------------------+---------------+
| #                            | #                    |               |
| ### *Name of Group:* WECC Te | ### *Group Represent |               |
| chnical Studies Subcommittee | ative:* Peter Mackin |               |
|                              |                      |               |
|                              | **Representative     |               |
|                              | Phone:**             |               |
|                              | 916-631-3200         |               |
|                              |                      |               |
|                              | **Representative     |               |
|                              | Email:**             |               |
|                              | pmackin@na           |               |
|                              | vigantconsulting.com |               |
+------------------------------+----------------------+---------------+
| #### *                       |                      |               |
| List of Group Participants t |                      |               |
| hat Support These Comments:* |                      |               |
+------------------------------+----------------------+---------------+
| #### *Name*                  | #### *Company*       | #### *Industr |
|                              |                      | y Segment \#* |
+------------------------------+----------------------+---------------+
| #### Peter Mackin            | #### Tr              | #### 1        |
|                              | ansmission Agency of |               |
|                              |  Northern California |               |
+------------------------------+----------------------+---------------+
| #### John Collins            | #### Platte R        | #### 4        |
|                              | iver Power Authority |               |
+------------------------------+----------------------+---------------+
| #### Jay Seitz               | #### US Depa         | #### 4        |
|                              | rtment of Interior B |               |
|                              | ureau of Reclamation |               |
+------------------------------+----------------------+---------------+
| #### Chuck Russell           | ###                  | #### 1        |
|                              | # Salt River Project |               |
+------------------------------+----------------------+---------------+
| #### Craig Quist             | #### PacifiCorp      | #### 1        |
+------------------------------+----------------------+---------------+
| #### Peter Krzykos           | #### Arizona Pu      | #### 1        |
|                              | blic Service Company |               |
+------------------------------+----------------------+---------------+
| #### C.V. Chung              | ###                  | #### 4        |
|                              | # Seattle City Light |               |
+------------------------------+----------------------+---------------+
| #### David Barajas           | #### Imperial        | #### 1        |
|                              |  Irrigation District |               |
+------------------------------+----------------------+---------------+
| #### Vance Crocker           | ##                   | #### 1        |
|                              | ## Black Hills Power |               |
+------------------------------+----------------------+---------------+
| #### Mathew Stoltz           | #### Basin Electr    | #### 1        |
|                              | ic Power Cooperative |               |
+------------------------------+----------------------+---------------+
| #### Kenneth Dillon          | #### Portland Gene   | #### 1        |
|                              | ral Electric Company |               |
+------------------------------+----------------------+---------------+
| #### Mark Hanson             | ####                 | #### 1        |
|                              |  Idaho Power Company |               |
+------------------------------+----------------------+---------------+
| #### Chuck Stigers           | ####                 | #### 1        |
|                              |  NorthWestern Energy |               |
+------------------------------+----------------------+---------------+
| #### Abbas Abed              | #### San Diego Gas   | #### 1        |
|                              | and Electric Company |               |
+------------------------------+----------------------+---------------+
| #### Joe Seabrook            | ###                  | #### 1, 3     |
|                              | # Puget Sound Energy |               |
+------------------------------+----------------------+---------------+
| #### Milt Percival           | ####                 | #### 1        |
|                              |  Western Area Power  |               |
|                              | Administration - DSW |               |
+------------------------------+----------------------+---------------+
| #### Tom Green               | #### Public Service  | #### 1        |
|                              |  Company of Colorado |               |
+------------------------------+----------------------+---------------+
| #### Dana Cabbell            | #### Southern Calif  | #### 1        |
|                              | ornia Edison Company |               |
+------------------------------+----------------------+---------------+
| #### Joe Tarantino           | #### Sierra P        | #### 1        |
|                              | acific Power Company |               |
+------------------------------+----------------------+---------------+
| #### Chifong Thomas          | #### Pacific Gas     | #### 1        |
|                              | and Electric Company |               |
+------------------------------+----------------------+---------------+

### Background Information:

##### Notes to Industry Commenters:

####### 

####### The standard drafting team (SDT) considered the SAR for this proposed standard as well as the SAR comments and comments in response to version 1 of this standard while developing version 2 of the standard. The SDT believes that it is helpful for the industry to understand the perspective of the SDT while reviewing this draft standard. The SDT also believes that it would be helpful to explain the linkages with other standards currently under development. The explanations below are offered to provide context and facilitate industry comments.

##### What has changed from Version 1 to Version 2?

The drafting team is most appreciative of all those who submitted
comments in response to the first posted version of this standard. These
comments were used as the basis for revisions to the standard that is
now posted for a second round of industry review. Highlights of the
changes made in response to industry comments:

-   The table of expected performance used when determining System
    Operating Limits (Section 603) has been replaced with text in order
    to add greater clarity (Subsections 603(a)(3)(i) - (iv).

-   In some cases, the levels of non-compliance have been re-ordered or
    clarified, as suggested by industry commenters.

-   In some cases, the compliance monitoring process has been modified
    or clarified, as suggested by industry commenters.

-   Additional definitions have been added in response to industry
    comments, such as: cascading outage, normal clearing, delayed
    clearing and performance-reset period.

-   The numbering system used in the standard has been revised. Comments
    received in response to other standards indicated confusion with the
    previous numbering system.

-   Minor clarifications have been made in various locations in response
    to industry comments, including capitalization of defined terms.

Changes were also made in the standard to conform to the recently
approved version 2 of NERC's Functional Model. Version 2 identified a
few new functions, such as Transmission Planner, Generator Owner, and
Planning Authority, which are associated with this standard. The
drafting team is generally supportive of Version 2 of the Functional
Model, but did notice some inappropriate or incomplete task descriptions
in it. These deficiencies will be pointed out to the group responsible
for the model so that the Model can be corrected. Notably:

-   The Model incorrectly assumes that Reliability Authorities will only
    determine Interconnected Reliability Operating Limits (IROL). In the
    draft standard, Reliability Authorities are responsible for
    determining all System Operating Limits (SOL) in their area, not
    just the subset that are considered IROLs.

-   The Model misunderstands the relationship between SOLs and IROLs.
    IROLs are a subset of SOLs.

-   The Model does not recognize the role played by the Planning
    Authority and Transmission Planner in the determination of SOLs.

##### General Philosophy:

The SDT addressed the three components of this draft standard in three
sets of pairs: Facility Ratings (601, 602), System Operating Limits
(603, 604), and Transfer Capabilities (605,606). In each of these pairs,
the draft standard requires the development and availability of a
"methodology" to determine the required quantities and secondly the
application of this methodology in the establishment and communication
of these values to the users of the values. These standards were
developed assuming that the Facility Ratings, System Operating Limits
and Transfer Capability values are to be provided to the user (e.g.
those entities performing the reliability authority, planning authority,
and transmission operator functions) on a schedule established by the
*user*. The SDT endeavored to ensure that this draft standard would not
require the determination of various values that had no identified user.
For this reason, the user of the various values must request the
specific values from the value provider (e.g. those entities performing
the facility owner and planning authority functions) through the
establishment of a schedule to supply the data.

##### Levels of Noncompliance:

In the three 'methodologies' sections (601, 603, 605), the levels of
noncompliance are based upon the availability and completeness of the
documented procedures. In the three 'communication' sections (602,
603,605), the levels of noncompliance are based on the availability of
the values *[requested by the users]{.underline}* of the information and
the consistency of these values with the documented methodologies.

##### Sanctions:

The SDT believes that failure to comply with the three 'methodologies'
sections (601, 603, 605) does not warrant monetary sanctions, since the
methodologies themselves would not *[directly]{.underline}* impact the
ability to operate the transmission system. However the SDT feels that
the issuance of Letters of Non-compliance to various officer level
persons and oversight bodies will provide sufficient encouragement to
promote compliance.

The unavailability of Facility Rating *values*, System Operating Limit
*values* and to a lesser extent, Transfer Capability *values* will have
a real and detrimental impact on the real time reliability of the
transmission system as well as the validity of transmission plans for
future transmission system additions. Therefore, the three
'communication' sections (602, 604, 606) include monetary sanctions for
repeated and/or significant noncompliance as per the sanction table. The
SDT believes that nominal, fixed dollar sanctions are appropriate in
these cases. The application of 'per MW' variable sanctions would be
inappropriate for these infractions compared to the consequences of
violating the requirements of the standard. While the SDT realizes that
a minor omission of a requested value could result in sanction, the SDT
also believes that graduated sanctions based upon the level of
'completeness' of the data received by the users are impractical. The
SDT is of the opinion that not all values have equal importance to the
reliability of the transmission system, and therefore, sanctions based
upon 'percentage of requested data received' (perhaps omitting values of
specific critical limitations) would be arbitrary. Additionally,
formulating levels to include completeness and importance would result
in a cumbersome and complex matrix in itself.

##### Relationship with "Operate Within Interconnected Reliability Operating Limits" Standard:

The SDT suggests that this draft standard be reviewed in concert with
the "Operate Within IROL" draft standard. The Facility Ratings, System
Operating Limits, and Transfer Capabilities draft standard requires the
availability and usability of these data. The Operate Within Limits
standard addresses the use of a subset of these values in real time
operation. The SDT believes that the definitions developed in
conjunction with this standard do not prohibit the stratification, or
sub-classification, of the requested data (Facility Ratings, System
Operating Limits, Transfer Capabilities) for specific uses or users. The
intent and purpose of this standard, however, is to identify *all*
system operating limits and not to differentiate them based upon the
impacts of violating them.

The "Operate Within IROL" standard will be balloted in December.

+-----------------------------------------------------------------------+
| 1.  **Requirement 603 has been rewritten to clarify and amplify the   |
|     material contained in the table present in the earlier version of |
|     this draft standard. The underlying requirements in that table    |
|     were not modified.**                                              |
|                                                                       |
| > **Is it clear that system limits may have to be adjusted during     |
| > long term outages to reflect the requirement that load shedding     |
| > and/or system reconfiguration will not be permitted for a first     |
| > contingency on any generator, transmission circuit or transformer   |
| > except when such an element is part of a single circuit radial      |
| > connection?**                                                       |
| >                                                                     |
| > Yes                                                                 |
| >                                                                     |
| > No                                                                  |
| >                                                                     |
| > Comments                                                            |
|                                                                       |
| 2.  **Do you see a need for contingencies known in the current NERC   |
|     Planning Standards as \"Level C contingencies", such as breaker   |
|     failure, double circuit loss and bipole block, to be examined to  |
|     ensure that system cascading, instability and uncontrolled        |
|     separation do not result at system transfers consistent with the  |
|     limits developed using this methodology?**                        |
|                                                                       |
| > Yes                                                                 |
| >                                                                     |
| > No                                                                  |
| >                                                                     |
| > Comments The WECC TSS feels that these contingencies should be      |
| > examined as is the current practice in WECC. However, this          |
| > additional level of analysis can be implemented as a Regional       |
| > Standard specific to WECC.                                          |
|                                                                       |
| 3.  **NPCC has requested a Regional Difference in this section. Are   |
|     there any other Regions who require a Difference, in light of the |
|     revisions to this section?**                                      |
|                                                                       |
| > Yes                                                                 |
| >                                                                     |
| > No                                                                  |
| >                                                                     |
| > Comments * WECC is requesting a \"Regional Difference\" as shown in |
| > the attached file.    *                                             |
+-----------------------------------------------------------------------+

+-----------------------------------------------------------------------+
| 4.  **The drafting team made every effort to respond to industry      |
|     comments received during the first posting of this proposed       |
|     standard. The standard was modified in response to these comments |
|     in many cases. If the team's response did not properly respond to |
|     your comment, please let us know in the space below.**            |
|                                                                       |
| > Comments The WECC TSS believes that all of its previous comments    |
| > were adequately addressed.                                          |
|                                                                       |
| 5.  **Do you agree with that Planning Authorities and Transmission    |
|     Planners play a role in the development of System Operating       |
|     Limits?**                                                         |
|                                                                       |
| > Yes                                                                 |
| >                                                                     |
| > No                                                                  |
| >                                                                     |
| > Comments                                                            |
+-----------------------------------------------------------------------+

+-----------------------------------------------------------------------+
| 6.  **Please enter any other comments you have regarding this         |
|     standard in the space below.**                                    |
|                                                                       |
| > Comments The WECC TSS would like to complement the SDT on this      |
| > revised draft standard. It is obvious that a great deal of effort   |
| > has been expended in developing the draft and in responding to      |
| > industry comments.                                                  |
| >                                                                     |
| > We have some additional minor comments on Draft 2:                  |
| >                                                                     |
| > \(1\) Some of our reviewers are not sure why the definition for     |
| > "Cascading Outages" was changed to exclude the second sentence,     |
| > "Cascading results in widespread electric service interruption,     |
| > which cannot be restrained from sequentially spreading beyond an    |
| > area predetermined by appropriate studies". This second sentence    |
| > would clarifies the extent of the outages and should be included.   |
| >                                                                     |
| > \(2\) Some of our reviewers were confused by the definition of      |
| > Facility. It might be helpful to also define Equipment. This        |
| > additional definition would help clarify the Facility definition. A |
| > draft definition for Equipment is provided below:                   |
| >                                                                     |
| > **Equipment:** A single piece of electrical apparatus that can      |
| > comprise a portion of a Facility and that has ratings that may      |
| > limit the capability of the Facility of which the electrical        |
| > apparatus is a part. Examples of Equipment include: disconnect      |
| > switches, circuit breakers, generator excitation systems, line      |
| > voltage regulators, and line conductors.                            |
| >                                                                     |
| > \(3\) We are confused about the use of the "minimum" values in the  |
| > definition of SOL, since, depending on the specific value           |
| > referenced, these terms may not be applicable. (For example, what   |
| > would a minimum current limit apply to?) We understand that the     |
| > definition must be broad enough to cover limits that are set based  |
| > on parameters other than MW or MVAR flows. Perhaps rewording the    |
| > definition by separating it into two parts and some examples may    |
| > help.                                                               |
| >                                                                     |
| > \(4\) Standard 200 refers to the [Interconnection Reliability       |
| > Operating Limit]{.underline} (IROL) as a subset of SOLs and only    |
| > would enforce that subset of limits. Standard 600 does not refer to |
| > IROLs or explain/identify the requirement for documenting the       |
| > methodology and developing these specific limits, unless it is      |
| > implied in 603 and 604. 600 and 200 need to be linked.              |
| >                                                                     |
| > \(5\) 601(a)(3) is a long sentence. We suggest rewording for        |
| > readability, as follows:                                            |
| >                                                                     |
| > "The methodology required in 601(a)(1) shall identify the           |
| > assumptions used to determine Facility Ratings, including:          |
|                                                                       |
| -   the method by which ratings of major bulk electric system         |
|     equipment types that comprise the Facilities\* are determined and |
|                                                                       |
| -   references to industry rating practices or other standards (e.g., |
|     IEEE, ANSI, CSA), when applied.                                   |
|                                                                       |
| > \*Facilities for which rating methodologies are required include,   |
| > but are not limited to,                                             |
|                                                                       |
| -   generators,                                                       |
|                                                                       |
| -   transmission lines,                                               |
|                                                                       |
| -   transformers,                                                     |
|                                                                       |
| -   terminal equipment, and                                           |
|                                                                       |
| -   series and shunt compensation devices"                            |
|                                                                       |
| > \(6\) Section 601(d)(2) allows entities one year to get in          |
| > compliance after adoption of the Standard. This is a very tight     |
| > time frame and significant reporting burden; after all it generally |
| > takes longer than a year to just write a standard. We suggest a     |
| > longer time frame for entities to initially comply. Similar comment |
| > for 603(d)(2) and 605(d)(2).                                        |
| >                                                                     |
| > \(7\) 601(e) Levels of noncompliance. Suggest adding words on all   |
| > levels to the effect that the non-compliance levels do not address  |
| > non-*applicable* items. We have seen confusion on noncompliance     |
| > levels where missing items would determine noncompliance when some  |
| > of the items listed may not be applicable to all entities           |
| >                                                                     |
| > \(8\) Section 602(b)(1) states: "Responsible entities shall         |
| > establish their Facility Ratings consistent with their ratings      |
| > methodology, described in 601(a)." Section 601(a) does not describe |
| > any ratings methodology, it cites the requirement for a             |
| > methodology. We suggest a little wordsmithing, rewriting the        |
| > sentence to read: "Responsible entities shall establish their       |
| > Facility Ratings consistent with their ratings methodology required |
| > by 601(a)."                                                         |
| >                                                                     |
| > \(9\) Section 602(d): Once this standard is approved, it does not   |
| > seem reasonable to expect entities to have ratings for all          |
| > facilities completed immediately. There should be a reasonable      |
| > period of time to allow organizations to complete facility ratings. |
| > We suggest a three-year period.                                     |
| >                                                                     |
| > \(10\) Levels of noncompliance in section 602(e) are cumbersome.    |
| > Identify whether "some" ratings were not provided would also        |
| > require considerable tracking of rating information.                |
| >                                                                     |
| > \(11\) The references to 603.1.4.4-603.1.4.4 in 603(a)(4)(iv) on    |
| > page 8 should probably be changed to 603(a)(4)(i)-603(a)(4)(iv).    |
| >                                                                     |
| > \(12\) Please move the last sentence in section 603(a)(3)(i)(A),    |
| > "Curtailment of load or transfers is not required to maintain the   |
| > system within the System Operating Limits", to section              |
| > 603(a)(3)(i)(B). This change would remove the potential conflict    |
| > between 603(a)(3)(i)(A) and 603(a)(3)(i)(C) and allow the operators |
| > the flexibility to curtail transmission service if deemed necessary |
| > to accommodate planned maintenance.                                 |
| >                                                                     |
| > \(13\) In section 603(a)(3)(ii) requires the evaluation of "(a)     |
| > Single line to ground or 3-phase fault, with Normal Clearing, on    |
| > *any* faulted Facility". The previous draft showed a Table I, which |
| > specifies "single line to ground or 3-phase fault, with normal      |
| > clearing on, Generator, Transmission Circuit, or Transformer".      |
| > Since "any Facility" includes more than those specified in Table I, |
| > for example, faults on bus sections, this draft appears to be more  |
| > stringent than the previous version. Please replace "any faulted    |
| > Facility" with "any faulted Generator, Transmission Circuit, or     |
| > Transformer".                                                       |
|                                                                       |
| (14) Please replace [603(a)(iv)(e) with footnote d]{.mark} from       |
|      Table I. Footnote d states:                                      |
|                                                                       |
| > "Depending on system design and expected system impacts, the        |
| > controlled interruption of electric supply to Customers (load       |
| > shedding), the planned removal from service of certain generators,  |
| > and/or the curtailment of contracted firm (non-recallable reserved) |
| > electric power transfers may be necessary to maintain the overall   |
| > security of the interconnected transmission systems."               |
| >                                                                     |
| > Footnote (d) applies to Category C contingencies (N-1-1), which is  |
| > more in line with operating studies.                                |
| >                                                                     |
| > \(15\) In section 603(a)(iv)(f) and (g), we allow interruption of   |
| > firm load for operating studies, but make no mention of             |
| > interruption of contracted firm transfer.  This would put           |
| > contracted firm transfer ahead of firm load.  Please change these   |
| > sections to allow for interrupting \"contracted transfer\" if       |
| > needed.                                                             |
| >                                                                     |
| > \(16\) In section 603(c)(1)(i) there is no mention of single        |
| > line-to-ground faults with normal clearing on a bus section or a    |
| > circuit breaker (failure or internal fault) as in the previous      |
| > version of the draft. Was this intentional or was it an oversight?  |
| >                                                                     |
| > \(17\) Section 603(e)(1) might be clearer if a parenthetical        |
| > reference was made to section 603(a)(2) since that section          |
| > \[603(a)(2)\] is also referenced in non-compliance level 3 just     |
| > below in section 603(e)(3).                                         |
| >                                                                     |
| > \(18\) Sections 602, 604 and 606 have no requirements for periodic  |
| > review and update of the ratings established in 602 -- Establish    |
| > and Communicate Facility Ratings, 604 -- Establish and Communicate  |
| > System Operating Limits, and 606 -- Establish and Communicate       |
| > Transfer Capabilities. To assure the ratings are still current and  |
| > accurate we believe this issue should be addressed by the standard. |
| >                                                                     |
| > \(19\) In section 605(a)(2) "The methodology required in 605(a)(1)  |
| > shall state that Transfer Capabilities shall adhere to all          |
| > applicable System Operating Limits". Please change "adhere to" to   |
| > "remain within" because as written, this section could be           |
| > interpreted as the Transfer Capabilities shall be the same as all   |
| > applicable System Operating Limits.                                 |
+-----------------------------------------------------------------------+