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

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22008. Draft 2 incorporated revisions to address industry comments and to include themeasures and compliance elements. Draft 2 of the standard and a draft implementation planwere posted for comments from November 21, 2008 through December 22, 2008. Draft 3 ofthe standard was developed to address industry comments. It was posted for information onFebruary 9, 2009. Draft 3a SERC UFLS Standard was designed to meet the applicabilityand performance characteristics specified in the then latest NERC draft UFLS Standard. Itwas posted for comments from September 15, 2009 through October 15, 2009. Draft 4 ofthe standard was developed to address industry comments and was posted for ballot fromNovember 13-23, 2009. Draft 4 was not approved.Draft 5 of the standard was developed to address industry comments listed on the Draft 4ballots. The requirement for generators that do not coordinate with the underfrequencyperformance curves to provide compensatory load shedding was removed. To address theindustry comments on timing, additional work on the SERC standard was delayed until theinitial ballot on the NERC continent-wide UFLS standard was scheduled. Draft 5 was alsore-formatted to be consistent with the Results-based Reliability Standards template. Draft 5was posted for comment. Draft 6 was developed in response to comments received andwas posted for ballot from December 9-20, 2011. Draft 6 was not approved. Draft 7 hasbeen developed in response to comments received on the ballot.The SERC UFLS Standard Drafting Team (SDT) is requesting your comments on Draft 7 ofthe SERC UFLS standard.Please enter all comments in simple text format.Insert a “check’ mark in the appropriate boxes by clicking the gray areas.1. Requirement R1 has been modified to allow the PC to adjust island boundaries to differ fromsubregional boundaries where necessary for the sole purpose of producing a contiguoussubregional island more suitable for simulation. Do you agree with Requirement R1, itsmeasures, and its VSLs?YesNo<strong>Comments</strong>: AECI would like to thank the SDT for the modifications to R1. While R1is now workable, it does not make sense. The idea that some subregional islandswould have to include members of other subregions just for that subregionalisland to work seems to defeat the purpose of studying subregional islands. It isa waste of time and money to study something that provides no benefit.The whole purpose of studying a regional island per the NERC standard is notbecause you expect the regional island to happen, but so that everybody wouldstudy at least one island, and FERC confirmed this at the last SDT meeting. Thesubregional islands would never happen in reality either, and this additionalrequirement does not add to the reliability of the system because at least oneisland is already being studied. If some members of SERC want to study
3individual subregions, let them identify it in their island criteria, don't forceeverybody to do something that would not be realistic simulation for everybody.Furthermore, the grey box suggests that because SERC has so many differentschemes, it needs to be studied in smaller islands. However, it was SERC's ownregional standard that allowed all of these different schemes, and the samelanguage is even included in this latest draft. If it members can comply with R2,there is no reason to test at a stricter level than R2.2. Requirement R2 has been modified for additional clarity. Do you agree with RequirementR2, its measures, and its VSLs?YesNo<strong>Comments</strong>: We fundamentally disagree with R2.1. The language that says "servedfrom the PC's transmission system" represents a drastic change from howbusiness is currently conducted. This probably is not that big of a deal to thoseon the inside of the SERC region, but for those of us on the edge it is huge.Currently the method for those of us PC's who are intermingled is "you handleyour load, I'll handle mine." This means all loads are divided by which PC theybelong to (which matches the NERC standard requiring division by PC area), notnecessarily which transmission system they are connected to. All loads areaccounted for and coordinated with the PC of the transmission system they areconnected to.To depart from this method would result in expensive solutions that provide nobenefit to reliability. We would have to redo all of our agreements withneighboring PCs. No PC is going to let another PC have a free ride on its system,and small loads would be required to be shed in small steps - the smaller the loadthe more incredibly expensive this becomes. The only way around it would be tobuild duplicate transmission facilities, also expensive and unecessary.R2.1 would result in extremely high costs with no benefit to reliability. Suggestedrewording "Have the capability of shedding at least 30 percent of the PeakDemand (MW) of the Planning Coordinator."3. Requirement R3 has been modified for additional clarity. Do you agree with RequirementR3, its measures, and its VSLs?YesNo
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