Comments on Draft 7 SERC UFLS Standard_PRC-006-SERC-01_ ...

4response to draft 5. In that response, ODEC commented "Yes, but…I think thatutilities that would otherwise not be subject to registering should be exemptaltogether from this requirement. My understanding is that the threshold forregistration without UFLS is a peak load of 25MW or greater. I know of at least onesmall utility (~15 MW) that only has to register because it has UFLS. This seemstoo punitive in terms of cost of compliance.Therefore, I would suggest anexemption at 25 MW or less. "The SDT responded "The SDT disagrees that entities smaller than 25 MW shouldbe automatically exempted from this requirement. However, the PlanningCoordinator may exclude smaller entities from their UFLS scheme on a case-bycasebasis. "We see nothing in PRC-006-1 that explicity states that NERC intended PCs toapply UFLS programs to any entity that is not included on the NERC ComplianceRegistry. We agree that the explicit langauge doesn't preclude such action, butcontend that the taken together, the Rules of Procedure, and the Statement ofCompliance Registry Criteria, accompanied by these published statements on theNERC compliance webpage (http://www.nerc.com/page.php?cid=3|249), it isinferred that an entity will be identified by NERC or the Regional Entity andincluded on the Compliance Registry if it is to adhere to the NERC reliabilitystandards. To infer that entities under the thresholds indicated should have todetermine for themselves whether or not they "have a material impact on the bulkpower system" does not seem to be the correct way to insure an adequate level ofreliability.7. Do you have additional comments on any item(s) not addressed in Questions 1 through 6?YesNo<strong>Comments</strong>: Dominion thanks the SDT for its efforts in developing this regionalreliability standard.