consistent with its System Operating Limit Methodology (“SOL Methodology”) as established in FAC-011-4. proposed revisions do not change the intent of the standard the RC develop the SOL Methodology for establishing SOLs in its RC Area, and the TOP following the RC SOL Methodology in establishing those SOLs. Accordingly, the proposed Requirement R2 requires that the TOP establish SOLs as required by the RC SOL Methodology. The SDT believes this clarifies the appropriate responsibilities of the respective functional entities, while not creating ambiguity in the requirements in requiring the RC to do something that the TOP is, in all actuality, required to do. Additionally, this requirement carries forward the obligation of the RC to establish IROLs for its RC Area. The RC maintains primary responsibility for establishment of IROLs because these limits have the potential to impact a IROLs are establishing for its RC Area, consistent with its SOL Methodology. FAC-014-2 Requirement R2 – Requires the TOP to establish SOLs consistent with the RC SOL Methodology. Question 1: Do you agree with that the Reliability Coordinator (RC) should have primary responsibility for establishing IROLs for its RC Area? If not, please provide your comments on the appropriate break down of responsibilities (between RC and TOP) in establishing IROLs. Yes No Comments: Proposed Reliability Standard: FAC-014-3, Requirement R2 Proposed New/Revised Requirement Explanation of Proposed Revision Relevant Requirements in Existing Reliability Standard(s)
Question 10: Do you believe a specific timeframe should be included that sets the minimum acceptable time for when the RC must provide the information to the Transmission Owner and Generator Owner? Yes No Comments: Proposed Reliability Standard: FAC-014-3, Requirement R7 Proposed New/Revised Requirement Explanation of Proposed Revision Relevant Requirements in Existing Reliability Standard(s) Transmission Operator shall provide any SOLs and updates to those limits to its Reliability Coordinator and to the Transmission Service Providers that share its portion of the Reliability Coordinator Area. The SDT did not make substantive changes to this requirement; however, the requirement previously existed as a “part” of a requirement and it is now a stand-alone requirement. Mapping to existing FAC standards under revision: FAC-014-2 Part 5.2 – Requires the TOP to provide its SOLs to the RC and Transmission Service Providers in its portion of the RC Area. Question: None. Proposed Reliability Standard: FAC-014-3, Requirement R8 Proposed New/Revised Requirement Explanation of Proposed Revision Relevant Requirements in Existing Reliability Standard(s) Planning Coordinator and Transmission Planner shall communicate the results of the stability analysis identified in its Planning Assessment and Transfer Capability assessment to each Under proposed FAC-011-4 Part 4.4, the RC SOL Methodology must consider the stability limitations provided by the Planning Coordinator. Also, proposed FAC-014-3 Requirements R2 and R3, the applicable entities are required to establish stability limitations (if any) in accordance with Background regarding existing standards not under revision by SDT: TPL-001-4 FAC-013-2