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

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4<strong>Comments</strong>:4. The VSL for Requirement R5 was modified to increase the number of days late for a LowerVSL from 10 to 30 days. Do you agree with Requirement R5, its measures, and its VSLs?YesNo<strong>Comments</strong>:5. Requirement R7 has been modified for additional clarity. Do you agree with RequirementR7, its measures, and its VSLs?YesNo<strong>Comments</strong>: R7 does not mirror the NERC standard which does not apply togenerator owners. R7 belongs in a PRC-024 SERC supplement.6. A number of ballot comments stated objection to the SERC UFLS standard (PRC-006-SERC-01) expanding applicability to entities with load under the 25MW registration criteria.The UFLS SDT responded that the same wording is used in the SERC UFLS standard as inthe new NERC Standard PRC-006-1 regarding the applicability to loads. The NERCstandard applies to all load in a Planning Coordinator’s (PC) area, and requires the PC toidentify UFLS entities included in their scheme. The SERC standard cannot reduce thisapplicability. However, the SERC standard does contain a requirement (R4, part 4.2) for aUFLS entity identified by a PC that has a total load less than 100 MW shall not be requiredby the PC to have more than one UFLS step. Is Draft 7 clear that it does not broaden theapplicability beyond what is contained in the NERC UFLS standard?YesNoIf your answer is “No” please provide comments on any proposed revisions to address thisconcern.<strong>Comments</strong>: The NERC standard does not apply to generator owners. The SERCstandard R7 broadens the NERC standard by introducing generator ownerapplicability. See comment on #5.7. Do you have additional comments on any item(s) not addressed in Questions 1 through 6?Yes
5No<strong>Comments</strong>: R4 should be clarified that the 100 MW limit applies to UFLS entitiesper Planning Coordinator. For example, a UFLS entity with 1000 MW in one PCand 95 MW in another PC should be allowed to use the less stringent criteria inthe PC that it only has 95 MW in.
Page 1 and 2: 1Comment Form for: Draft 7 of the S
Page 3: 3individual subregions, let them id
Page 7 and 8: 22008. Draft 2 incorporated revisio
Page 9 and 10: 4to NERC and the applicable regiona
Page 13 and 14: 33. Requirement R3 has been modifie
Page 25 and 26: 3Comments: Require
Page 27: From:To:Cc:Subject:Date:Shah, Kirit

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